Serbia has been making significant strides in the realm of e-invoicing. The Serbian Ministry of Finance announced the law of electronic invoicing (Official Gazette of RS, No. 44/2021 and 129/2021) in 2021. The new national e-Invoicing system is named Sistem e-Faktura.

Electronic invoicing in Serbia will become mandatory for all businesses and public sectors in January 2023. The implementation process contains three phases, from May 1, 2022, to January 1, 2023.

Recent Updates


The Serbian Parliament on December 9, 2022, adopted amendments—effective January 1, 2023—to the law on electronic invoicing. The law does not apply to individuals who are not payers of self-employment tax. The deadline for electronic recording of VAT calculations is shortened from 15 to 10 days from January 1, 2024. There are also changes to adjustments of customs-related e-invoicing from August 2024.

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Extent of the E-Invoicing System


The e-Invoicing law covers the generation, transition, receipt, processing, and archiving of electronic invoices. Both public and private sector entities (B2G and G2B), transactions between taxpayers (B2B), and also those between public authorities (G2G) are under obligation for each transaction.

Timeline of Implementation


The implementation of the new system will expand gradually, and the timeline will be completed in three phases:

Phase 1 (from May 1, 2022): Private sector entities are mandated to issue e-Invoices to public authorities, while the public authorities are compelled to receive and archive e-documents (B2G transactions). Additionally, public authorities are also obligated to send and receive e-Invoices for any business conducted with other public authorities (G2G transactions).

Phase 2 (from July 1, 2022): Public authorities are obligated to issue and send e-Invoices to private sector entities (G2B transactions). Private sector entities will be obliged to receive and archive e-Invoices.

Phase 3 (from January 1, 2023): Full implementation is complete and electronic invoices become mandatory for the private sector in mutual transactions (B2B transactions).

Technical Details of the New E-Invoice System
 

An electronic invoice must be issued and received in line with the Standards EN 16931-3-2, which is in XML format. Electronic invoices may be transmitted in several ways. Electronic invoices generated or received by public authorities must be permanently archived in the government’s e-Invoice system. On the other hand, the electronic invoices generated and transmitted by private sector entities must be stored for 10 years as of the end of the year in which the electronic invoice was issued in the electronic invoices system or in the service provider’s system (the intermediary’s system).

Fines for non-compliance e-Invoice


Fines are changing between legal entities and their responsible representative. For instance, if the tax authority detects that a legal entity is not complying with the published standards or dates, fines range from EUR 1,701 to EUR 17,011, and the representative range starts from EUR 425 to EUR 1,276.

Conclusion


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