Serbia Prepares for Mandatory Electronic Delivery Notes

Serbia is making strides towards digitizing its goods movement documentation with the recent release of a draft law by the Ministry of Finance. The proposed legislation introduces mandatory electronic goods delivery notes for both public and private sector entities, applicable to B2B and B2G exchanges. The draft law outlines the main obligations and timelines for businesses and transporters to comply with.

Key Details of the Draft Law

Implementation Timeline:

• Q2 2025: Expected adoption of the law.
• January 1, 2026: Law enters into force.
• October 1, 2027: Specific rules for private sector organizations and transporters begin.

Scope and Applicability:

• Applies to public and private sector.
• Excludes private individuals exempt from self-employment income tax.
• Exceptions include:
  • Movements via networks like water or electricity
  • Retail supply
  • Military goods
  • International agreements
  • Internal relocations within the same public sector organization.

Obligations:

• Electronic goods delivery notes must be issued prior to the transport of goods.
• Carriers will be obligated to display these electronic notes during inspections.

Upcoming Regulations and Penalties

Once the law is passed, additional by-laws will be introduced within 90 days to provide more detailed guidelines on how to send, receive, and present electronic goods delivery notes.

Depending on the nature of the violation, fines for non-compliance range from RSD 50,000 (approximately EUR 430) to RSD 2 million (approximately EUR 17,100).

Public Consultation

To ensure broad stakeholder input, the draft law was open for public consultation until September 30, 2024. This period allowed businesses and other relevant parties to offer input and suggestions before the legislation is finalized.

As Serbia moves forward with this new initiative, businesses should prepare for the upcoming changes in electronic goods delivery note requirements to ensure timely compliance.

There’s more you should know about e-invoicing in Serbia – learn more about the new and upcoming regulations.