Serbia continues to advance the digitalisation of its invoicing and goods transportation processes. Since 1 January 2026, electronic delivery notes have become mandatory for certain transactions, while the general implementation of the requirement for business-to-business (B2B) transactions is scheduled for 1 October 2027.
On 31 August 2026, the Serbian Official Gazette published the Law on Amendments to the Law on Electronic Delivery Notes (No. 80/2026), which entered into force on 8 September. The amendments introduce additional exemptions, revise goods receipt and verification procedures, and extend the transitional period for certain errors in electronic documents.
When will electronic delivery notes become mandatory in Serbia?
Mandatory electronic delivery notes in Serbia are being introduced progressively, with different implementation dates depending on whether transactions involve the public sector, certain excise goods movements or transactions between private businesses.
First phase: 1 January 2026
Since 1 January 2026, electronic delivery notes have been mandatory in several situations, including:
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Goods movements from private businesses to public sector entities.
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Goods movements carried out by public sector entities in the circumstances established by law.
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Certain movements of goods subject to excise duties, including the applicable issuance and receipt obligations for affected private businesses.
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Presentation of electronic delivery notes by carriers during inspections involving transactions covered by this phase.
Second phase: 1 October 2027
From 1 October 2027, the requirement will be extended to general goods movements between private businesses.
From that date, private sector entities within the scope of the legislation will be required to issue and receive electronic delivery notes, while carriers must present the relevant documents during inspections where required.
This second phase will extend electronic document exchange to B2B commercial transactions, completing the gradual implementation of the system.
How does Serbia's electronic delivery note system work?
Serbia's electronic delivery note system, known as eOtpremnica, enables businesses to manage documents accompanying goods movements digitally.
The centralised platform supports the issuance, transmission, receipt, acceptance, rejection and storage of electronic documents, making the relevant information accessible to businesses and competent authorities.
Electronic delivery notes must be generated in a structured format that enables automated data processing.
Before transportation begins, the sender must submit the electronic delivery note through the system.
The recipient must subsequently confirm the physical receipt of the goods and manage the acceptance or rejection of the document through an electronic receipt note (e-prijemnica).
This process creates a digital record of goods movements and any discrepancies identified during delivery.
New rules for confirming and accepting goods deliveries
The legislative amendments introduced in September 2026 revise the procedures for confirming physical receipt and accepting electronic delivery notes.
As a general rule, the recipient must confirm physical receipt of the goods on the day of delivery or no later than three working days after the receipt process begins.
Once physical receipt has been confirmed, the recipient has eight days to accept or reject the delivery note, in full or in part, by submitting an electronic receipt note.
The legislation establishes different consequences when no response is submitted within the applicable deadline:
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Public sector recipients: the electronic delivery note is deemed fully accepted.
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Private sector recipients: the electronic delivery note is deemed fully rejected.
The system also makes it possible to record discrepancies between the goods received and the information contained in the delivery note, facilitating their review and reconciliation between sender and recipient.
Serbia expands exemptions from electronic delivery note requirements
The amendments published in Official Gazette No. 80/2026 introduce additional exemptions for certain goods movements.
The new exemptions include:
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Movements of small quantities of goods purchased from retail outlets that qualify as business representation expenses under VAT legislation.
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Movements of certain items, including value vouchers, excise stamps, legal tender, newspapers and magazines.
The criteria used to determine what constitutes a small quantity of goods under the first exemption must be further defined through implementing regulations.
These new exemptions complement existing exclusions, such as certain supplies transported through distribution networks, retail transactions governed by specific rules and particular movements associated with defence or security activities.
Carriers can present electronic delivery notes using QR codes
Another important development concerns the presentation of documents during inspections.
Carriers that do not meet the conditions required to access the electronic delivery note system directly may present the document using a QR code generated by the platform when the sender submits the delivery note.
This provides an alternative to presenting a signed printed copy of the document.
Where a QR code is used, the sender must upload the external representation of the electronic delivery note to the system before the goods movement begins.
The amendments also introduce a simplified procedure for postal operators. Where the unique electronic delivery note identification number appears on the shipment's address label, postal operators are exempt from certain requirements to retrieve and present the document during postal transportation.
Serbia extends the grace period for document data errors until January 2027
The new legislation extends the transitional period during which certain errors in submitted electronic delivery notes and electronic receipt notes will not be taken into account during inspections.
This regime will remain applicable through 1 January 2027, inclusive.
Its purpose is to help businesses and carriers adapt to the new procedures and address operational issues during the system's initial implementation.
However, the transitional arrangements do not suspend the obligation to issue or present electronic delivery notes where these requirements are already in force.
Failure to comply with the applicable obligations may result in financial penalties under Serbia's Law on Electronic Delivery Notes.
B2B and B2G electronic invoicing in Serbia
Serbia's digitalisation process extends beyond goods transportation. The country also operates a mandatory electronic invoicing system known as the Electronic Invoice System (SEF).
Its implementation began in 2022 and was introduced progressively:
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1 May 2022: the first mandatory electronic invoicing requirements for transactions involving public sector entities entered into force.
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1 July 2022: electronic invoice receipt and storage requirements were extended to private sector entities.
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1 January 2023: electronic invoicing became mandatory for B2B transactions falling within the scope of the legislation.
Through SEF, businesses can issue, receive and manage structured electronic invoices, supporting administrative automation and tax compliance.
In April 2026, the Serbian authorities published updated technical instructions and changes relating to electronic VAT records, strengthening the system's validation and control mechanisms.
It is important to distinguish between SEF, which manages electronic invoices, and eOtpremnica, which manages electronic documents relating to goods movements. Both systems are part of Serbia's broader administrative and tax digitalisation strategy, but they address different compliance requirements.
SERES and electronic document exchange in Serbia
Serbia's regulatory developments reflect a broader international trend towards the digitalisation of business operations, from electronic invoicing to the documentation associated with goods movements.
SERES helps organisations automate electronic document exchange and integrate invoicing processes with their management systems, customers and suppliers.
Through an international electronic invoicing strategy, businesses can address different regulatory requirements and electronic exchange models within a multi-country framework, improving operational efficiency and traceability.
