In the Official Gazette of the Republic of Serbia, No. 120 of December 30th, 2025, the Rulebook on Amendments to the Rulebook on Electronic Delivery Notes was published, introducing significant normative amendments which further specify the obligations of users of the electronic delivery note system (hereinafter: “e-delivery notes”), the technical modalities for using the e-delivery note system, the mandatory content of e-delivery notes, and the procedures applicable in specific cases of movement of goods.
Key Amendments:
- Registration of Public Sector Entities
It is prescribed that, by way of exception, the registration of a public sector entity in the system shall be carried out by the Central Information Intermediary.
- Expansion of Technical Solutions for System Use
In addition to the existing solutions, a third technical solution has been introduced, namely a mobile application for system users (MAKS), which enables the performance of the same actions as the primary technical solution.
- New Rules on Internal e-Delivery Notes
An obligation has been introduced to issue an internal e-delivery note in cases which do not constitute a supply for VAT purposes, including the free distribution of business samples and the distribution of promotional materials and low-value gifts. At the same time, the Rulebook expressly prescribes cases in which an e-delivery note is not required to be issued.
- Expanded Mandatory Content of e-Delivery Notes
New mandatory data elements have been introduced, including the place of loading and the place of delivery or unloading. Additional rules have been prescribed for cases involving multiple deliveries using a single vehicle, import and export of goods, and the involvement of multiple means of transport or multiple carriers.
- Special Rules for Excise Goods
The content of e-delivery notes relating to the movement of excise goods has been further specified, including the expansion of excise categories (e.g. nicotine products), additional required data (type of packaging, density, volume), and special rules applicable to certain categories of nicotine products.
- Monitoring of the Transport Process After Issuance of the e-Delivery Note
An obligation has been introduced to subsequently add data relevant to the transport process, including the commencement of transport, changes of vehicle or driver, unplanned transhipment, and the date and time of physical receipt of goods.
- Detailed Regulation of Procedures in the Event of System Unavailability
The rules governing paper-form e-delivery notes have been amended, including the mandatory preparation of three copies, mandatory use of holographic labels, recording through the MAKS application, and subsequent data entry once the connection with the system has been re-established.
- New Rules on Electronic Receipt Notes
The Rulebook further specifies mandatory content, technical statuses, the possibility of cancellation, automatic rejection upon expiry of a 30-day period, and the automatic issuance of an electronic receipt note by the system in cases where the recipient fails to fulfil its statutory obligation.
- Entry into Force and Application Deadlines
Most amendments shall apply as of January 1st, 2026, while provisions relating to procedures in cases of system unavailability (Article 11) shall apply as of April 1st, 2026.
For additional information or consultations, the Tasić & Partners team is at your disposal.