Amendments to legislation on electronic delivery notes and electronic invoicing – applicable as of 1 January 2026.
- Expansion of exemptions from the obligation to issue an e-delivery note
New exemptions where an e-delivery note is not required include:
- Refuelling and lubrication of aircraft where the place of dispatch and the place of receipt are the same airport;
- Return of goods by the same means of transport immediately after delivery, with a mandatory e-receipt note;
- Movement of goods within approved clinical trials of medicinal products and medical devices.
- Expansion of entities required to use the system
The system must also be used by public sector entities that are contracting parties to framework agreements in public procurement procedures, for the purpose of receiving, storing and monitoring e-delivery notes and e-receipt notes.
It is further specified that a postal operator is exempt from the obligation to take over an e-delivery note only if the consignment consists of correspondence, documents, books, catalogues, newspapers and/or magazines.
- Amendments to the handling of paper delivery notes in case of system disruption – applicable as of 1 April 2026
- The consignor is required to: print three copies of the paper delivery note with a hologram security label; submit two copies to the carrier and retain one; and enter all missing data into the system no later than the first following business day after the connection is restored.
- The consignee must submit the e-receipt note no later than the first following business day after the connection has been restored.
The e-delivery note system is now aligned with the Law on excise duties (“Official Gazette of RS”, No. 109/2025).
Errors in e-delivery notes and e-receipt notes will not be sanctioned during supervisory procedures in the period 1 January – 30 June 2026.
Amendments to the Law on electronic invoicing – applicable to tax periods starting after 31 March 2026.
- Extension of the scope of the law – the scope now includes the storage of all documents processed within the e-invoicing system.
- Clarification of rules for retail transactions – notwithstanding the general exemption from issuing an e-invoice in retail transactions, an e-invoice must still be issued:
- to holders of corporate cards;
- to public sector entities that request an e-invoice within 7 days from the retail transaction.
An e-invoice may not be issued before the fiscal receipt is issued.
- Amendments to electronic VAT recording – a taxpayer is not required to electronically record VAT for retail supply and received advances for which there is no obligation to issue an e-invoice.
- Expansion of functionalities of the e-invoicing system – the system may be used for other transaction-related documents, with mandatory storage of all documents processed in the system.
- Direct receipt of European-standard e-invoices in the private sector – private sector entities will be able to directly receive foreign e-invoices compliant with the European standard once the technical conditions are in place.
- Extension of document-retention rules – all rules on the retention of e-invoices now apply to other documents generated within the e-invoicing system.
For additional information or consultations, the Tasić & Partners team is at your disposal.