Serbia e-Invoicing Guide

Serbia runs its e-invoicing mandate through Sistem e-Faktura (SEF), a central platform operated by the Central Information Intermediary, a unit inside the Ministry of Finance. The framework comes from the Law on Electronic Invoicing , published in Official Gazette 44/2021 and amended five times since, most recently by 109/2025. Public sector transactions came into scope on 1 May 2022 and transactions between private sector entities on 1 January 2023, so the mandate has been fully live for over three years.

SEF does more than move invoices. Articles 4 and 4a of the law also make it the place where VAT is recorded electronically: the supplier records calculated VAT and the buyer records input tax, aggregated for the tax period and filed by the 12th day of the following month. That second obligation is where most compliance effort actually goes, and it is the part that has changed most often. Serbia is not an EU member, so ViDA does not apply, but the invoice format is built on the European standard all the same.

The rollout ran in three steps. From 1 May 2022 public bodies had to receive and store e-invoices and invoice each other, and private suppliers had to invoice public bodies. From 1 July 2022 public bodies had to issue e-invoices to private suppliers, and private sector entities had to receive and store what they were sent. From 1 January 2023 the obligation to issue and store e-invoices applied between private sector entities, along with electronic VAT recording for transactions with no public sector party. Every date in that sequence comes from Article 24 of the Law on Electronic Invoicing.

Since then the changes have been refinements rather than new phases. Amendments in Official Gazette 94/2024 added the subject status declaration and the customs declaration list from 1 January 2025. The amendments in 109/2025 entered into force on 12 December 2025 but apply for tax periods beginning after 31 March 2026, which is why the retail and internal invoice rules landed with the April 2026 tax period. A separate track opened on 1 January 2026 when electronic delivery notes went live. Two dates remain ahead: the preliminary VAT return from January 2027, and the second phase of electronic delivery notes on 1 October 2027.

The mandate is keyed to VAT registration, not company size or turnover. Article 2 defines a private sector entity as a VAT payer other than a public sector entity, so businesses below the VAT threshold sit outside the duty. They can enrol as voluntary users instead, which commits them to SEF for the current and the following calendar year. The tax representative of a foreign person in Serbia carries the same issuing duty as a domestic supplier. Every subject must also declare a subject status within five days of being added to the SEF user list, recording whether it is a VAT payer and whether its tax period is monthly or quarterly, and must keep that status current.

Article 3(2) carves out seven categories. Retail sales under the fiscalisation law are the broadest, covered by fiscal receipts instead. Also outside scope: contractual obligations towards beneficiaries of international framework agreements, defence and security procurement, delivery of electricity and its take-up into the energy system other than for final consumption, supplies made without consideration, transactions whose consideration is a public revenue unless VAT is chargeable, and claims for costs and fees in court proceedings paid from the court's own funds.

The retail exemption narrowed for tax periods beginning after 31 March 2026. Two cases are now back in scope: sales to the holder of a corporate card, including advances for them, and sales to a public sector entity that requests an e-invoice within seven days. In both, the e-invoice may only be issued once the fiscal receipt has been issued. On storage, Article 15 holds public sector e-invoices permanently in SEF and sets 10 years from the end of the year of issue for private sector entities, kept either in SEF or with an information intermediary engaged for the purpose.

Serbia operates a centralised platform with no pre-clearance. Article 5 makes SEF compulsory for public and private sector entities, which register for access and then send, receive, record and store through it, either directly or through an information intermediary approved by the Ministry of Finance. Nothing is authorised before issue: an invoice is not held for tax authority approval, and the compliance step comes afterwards, when calculated VAT and input tax are recorded for the closed tax period. The Ministry of Finance supervises the law under Article 16.

Invoices are issued in the Serbian e-invoicing standard, which Article 6 defines as the standard adopted by the national standardisation body. In practice that is a CIUS of EN 16931-1, published by the Ministry of Finance and implemented in UBL 2.1 XML, with the Institute for Standardization of Serbia having adopted SRPS EN 16931-1:2017 into the national system. Cross-border reception is narrower than it first appears: Article 6 lets SEF take invoices issued to the European standard directly only where a foreign issuer invoices a public body. Every other recipient relies on an information intermediary.

Two changes are worth planning for. The Rulebook on Electronic Invoicing amended on 1 August 2026 added rules for compiling a preliminary VAT return inside SEF from three forms, one of which is populated automatically from invoices and VAT records already in the system. It applies for tax periods beginning after 31 December 2026. The same amendment set out what happens during an outage: SEF has a daily maintenance window from 01:00 to 06:00, an invoice is treated as delivered when service resumes, and a VAT recording deadline that falls during an outage moves to the first working day afterwards. Separately, the Law on Electronic Delivery Notes runs the eOtpremnica system alongside SEF for goods movements.

Article 18 of the Law on Electronic Invoicing fines a private sector legal person, or a public enterprise, RSD 200,000 to RSD 2,000,000 for breaching the duty to issue an e-invoice, failing to declare or reconcile its subject status, failing to record VAT electronically, not using SEF as required, or using SEF data for purposes the law does not prescribe. An entrepreneur faces RSD 50,000 to RSD 500,000 and the responsible person RSD 50,000 to RSD 150,000. Article 19 applies the same headline range to an information intermediary whose services endanger the security or functioning of SEF, and Article 21 to anyone refusing an inspector access to business data and systems.

There is a safe harbour worth knowing. A VAT recording error counts as no offence where the taxpayer corrects it before a supervision procedure opens, which puts a premium on finding mistakes first. Do not confuse this with the earlier transitional tolerance, under which the Ministry of Finance disregarded errors in VAT records outright. That ran only to 31 December 2025 and has expired. Electronic delivery notes carry their own regime: RSD 200,000 to RSD 2,000,000 under Article 13 of the Law on Electronic Delivery Notes, and a flat RSD 300,000 under Article 14 for obstructing an inspection.