Serbia has updated its Rulebook on Electronic Invoicing, introducing revised procedures for system access, VAT recording, invoice issuance, and compliance deadlines — with the changes taking effect from tax periods beginning 1 April 2026.

RF Report

Serbia’s Ministry of Finance has approved amendments to the Rulebook on Electronic Invoicing, published in Official Gazette No. 30/2026, with the changes applying from tax periods commencing 1 April 2026.

The regulations define the mandatory procedures for registering and accessing the electronic invoice system (SEF), specifying that entities must use a high-security electronic identification portal. It details the technical standards and essential elements required for a valid electronic invoice, including specific tax categories and the handling of advance payments. Furthermore, the rulebook outlines the protocols for electronic VAT recording, requiring taxpayers to submit both summary and individual records within strictly defined legal deadlines.

Key regulatory aspects of electronic invoicing and VAT recording

The Rulebook on Electronic Invoicing provides a comprehensive framework for the digital management of value-added tax (VAT) and invoicing within the Republic of Serbia. It details the specific obligations regarding VAT recording, invoice issuance, and system statuses as defined by the latest regulations.

Obligation of electronic recording of VAT

The electronic recording of VAT in the system of electronic invoices (SEF) is mandatory for tax debtors in accordance with the Law on VAT. This obligation applies to:

  • VAT payers.
  • Public sector entities and voluntary SEF users who are not VAT payers but act as tax debtors.

Exceptions to this obligation include instances where a VAT payer has already issued an e-invoice with VAT shown, or where the tax debtor is involved in the import of goods.

Issuing advance e-invoices

An advance invoice is issued based on payments received for future supplies of goods or services. If the advance is received on the same day the supply is actually performed, the issuer must provide a standard invoice, though they may also choose to issue an advance invoice.

When recording these transactions, the VAT is recorded for the period in which the advance was received. For the period in which the final supply is made, the recorded amount is the difference between the total VAT for the supply and the VAT previously recorded for the advance payment.

Currency requirements

Data in an electronic invoice must be expressed according to the following rules:

  • Dinars (RSD): If the collection is performed fully or partially in dinars.
  • Foreign Currency: If the collection is performed entirely in a foreign currency.
  • Dual Reporting: Even if the collection is entirely in a foreign currency, the total remuneration, tax base, and VAT amount must also be expressed in RSD.

Minimum period and deadlines for electronic recording

Electronic recording of VAT (both summary and individual) is generally performed after the expiration of the tax period, no later than the 12th day of the following month. While individual recording can be performed during the tax period, summary recording cannot be done for a period shorter than the tax period (a calendar month or quarter, depending on the entity’s status).

Individual VAT record – Internal invoice

The Individual VAT Record (often referred to as an internal invoice) is used when the recipient of goods or services is the tax debtor. Key elements of this record include:

  • The internal invoice number and recording date.
  • Identification of the person performing the supply (PIB or foreign tax number).
  • The tax base and calculated VAT are categorised by tax rate (e.g., 20% or 10%). If an internal invoice was created outside the SEF, its original number is used; if created within the system as a primary record, the number “0” is assigned.

Status of electronic recording of VAT

Records within the VAT modules of the SEF can be assigned one of three statuses:

  1. Recorded: Assigned upon the initial successful entry.
  2. Corrected: Assigned if the user modifies previously recorded data due to errors or omissions.
  3. Annulled: Assigned if the record is cancelled because it should not have been recorded or contains uncorrectable errors.

Annulment and cancellations in input VAT records

An issuer can annul an electronic invoice received through the system unless prohibited by specific laws. For VAT recording purposes, annulment leads to an entry of an increase or decrease in the tax base and VAT in the summary records for the relevant period.

In the Input VAT Records, data from annulled e-invoices and internal invoices are automatically entered to reflect the changes in the tax base. The system utilises a specific tax category “N” for annulment, where negative numbers are recorded to adjust the totals.

To further enhance your understanding of the Rulebook on Electronic Invoicing, here are additional critical details regarding system access, tax status, customs integration, and the automated recording of input VAT.

Subject status and tax periods

A critical step for users is defining their status within the SEF. Entities must declare whether they are a VAT payer or not a VAT payer.

  • Tax period selection: VAT payers must specify their tax period as either a calendar month or a calendar quarter.
  • Updating Status: If an entity’s VAT status or tax period changes, they are obligated to harmonise this information within the SEF within the legally prescribed deadline.

List of customs declarations

For entities involved in importing goods, the SEF automatically generates a List of Customs Declarations.

  • Source of data: This list is compiled based on documentation from the Customs Administration regarding goods released into free circulation.
  • Content: It includes the year, customs office code, declaration type, customs account number, and the total amount of VAT calculated for the import.
  • Visibility: Users can view details for individual imports, including the calculation of duties and payment records.

Electronic recording of input VAT (Previous tax)

A key feature of the SEF is the electronic recording of input VAT, which must be completed by the 12th day of the following month. The system automatically imports data from electronic invoices and internal VAT records, while manually entered data is required for external sources such as fiscal receipts and other invoices, recorded in summary form by source type.

Procedures during system downtime

The SEF is generally available 24/7, except during maintenance (typically 01:00 to 06:00).

  • Downtime protection: If a system failure occurs on the last day of a deadline for accepting/rejecting an invoice or for VAT recording, the deadline is extended to the first following working day after the system is restored.
  • Status adjustments: If a failure causes an invoice to be automatically “accepted” against a public sector user’s intent, they can notify the Central Information Intermediary to change the status to “rejected”.