E-invoicing in Serbia: who must use the SEF system, from when, deadlines and fines
Serbia's E-Invoicing Act 2026: who must use SEF (VAT payers, public sector), when flat-rate traders must register, 15-day acceptance, 10-year retention, fines.
Who is obliged and who is voluntary
The E-Invoicing Act (Zakon o elektronskom fakturisanju, ZEF) sorts everyone into three groups.
A public sector entity is every budget beneficiary, public enterprise and majority state-owned company (Art. 2(1)(2)). They must issue, receive and keep e-invoices, which is why every supplier to the state has to be in SEF.
A private sector entity is every VAT payer that is not public sector (Art. 2(1)(3)). The Act ignores legal form: sole trader, LLC or association, the obligation arises on VAT registration. They must issue an e-invoice for every supply to another VAT payer and to the public sector (Art. 3(1)).
A voluntary user is a sole trader or legal entity that is not a VAT payer, so in neither of the first two groups, and registers in SEF (Art. 2(1)(4)). Typically: a flat-rate trader, a small company below the RSD 8,000,000 turnover threshold, an association. The voluntariness is conditional: whoever invoices the public sector must register before submitting a payment request (Art. 2). After registration, a voluntary user stays in the system for the current and the following calendar year and in that period has the same rights and obligations as mandatory users (Art. 5(7) and (8)).
The practical consequence for a flat-rate trader: if you work only with private businesses and consumers, SEF does not bind you; the first invoice to a municipality, school, health centre or public enterprise changes that for at least a year and a half.
What goes through SEF and what does not
An e-invoice is issued for supplies of goods and services for consideration between SEF users, including advance invoices and credit and debit notes. The exceptions are in Art. 3(2):
- retail supply and advances for retail supply, recorded by fiscal receipt under the Fiscalisation Act, except sales to a buyer with a corporate card and sales to a public sector entity that requests an e-invoice within seven days (amendment in Sl. glasnik 109/2025, applicable to tax periods from 1 April 2026);
- supplies free of charge;
- public revenue fees and charges;
- costs under court and other decisions;
- certain supplies in defence and electricity.
An invoice to a consumer for a service that is not retail supply (say, a lawyer's or architect's service to an individual) does not go through SEF, because a consumer is not a system user; an ordinary invoice is issued, with a fiscal receipt where the activity is fiscalised.
Registering at efaktura.gov.rs
Registration and the web application are free. The procedure:
- The legal representative (the sole trader in person, the LLC director) signs in at efaktura.gov.rs through the eID electronic identification portal, with a qualified electronic certificate or the ConsentID mobile app.
- Opens the business account (enters the PIB tax number and the registration number; the system pulls data from APR and the Tax Administration) and accepts the terms of use.
- Adds users with roles: the accountant, the employee who issues invoices, a reviewer.
- Optionally generates an API key to connect accounting software, or contracts an information intermediary from the Ministry of Finance list (Art. 13).
Rights and obligations under the Act run from the moment of registration, including the obligation to receive e-invoices: from that day suppliers in SEF send you invoices electronically and the 15-day acceptance clock runs whether or not you look at them.
Acceptance deadline: 15 days
The recipient accepts or rejects an e-invoice within 15 days of receipt (Art. 10(1)). The consequences of silence differ:
- public sector that does not respond: the invoice is deemed accepted (para. 2);
- private sector that does not respond: the system sends a repeat notice, and if there is no response within a further five days, the invoice is deemed rejected (paras. 3 and 4); a rejected invoice can be accepted later (para. 5).
Rejection should be reasoned and used for a genuine error (wrong PIB, amount, period), not as a way to delay payment: the invoice came into existence when issued, and acceptance in SEF confirms receipt, not agreement to the debt. For a VAT-registered buyer acceptance also has a tax effect: input VAT is deductible solely on the basis of an accepted e-invoice (Art. 28(4) of the VAT Act).
VAT record in SEF and the preliminary return
VAT payers, and public sector entities and voluntary users when they are the tax debtor, keep an electronic VAT record in SEF (Art. 4(1)). The calculation for each tax period is recorded by the 12th day of the month following the tax period (Art. 4(5)). This is technically separate from the PPPDV tax return, which goes to the Tax Administration through ePorezi within 15 days after the end of the period (Art. 50 of the VAT Act). The 2026 amendments to the Act (Sl. glasnik 80/2026), applicable from 1 January 2027, provide that SEF prepares a preliminary VAT return from the records; transitional provisions relieve taxpayers of filing the POPDV calculation overview with returns up to the October-December 2026 period.
Keeping e-invoices
Public sector e-invoices are kept permanently in SEF (Art. 15(1)). E-invoices between private sector entities are kept for ten years from the end of the year of issue, in SEF or with an information intermediary (Art. 15(2) and (3)). The Accounting Act requires five years for other accounting documents and ten for the journal and general ledger (Art. 28), so the e-invoice period is longer than the general one. The original is the electronic record in SEF with its identifier; a printed PDF serves internal control, not as evidence.
Fines
Under Art. 18, for failing to issue an e-invoice when obliged, failing to record VAT in SEF, and failing to receive or keep e-invoices:
| Who | Fine |
|---|---|
| Legal entity, private sector entity or public enterprise | RSD 200,000 to 2,000,000 |
| Sole trader | RSD 50,000 to 500,000 |
| Responsible person in a legal entity | RSD 50,000 to 150,000 |
| Information intermediary (Art. 19) | RSD 200,000 to 2,000,000, responsible person RSD 50,000 to 150,000 |
The provisions on failing to issue an e-invoice for a mandatory supply operate alongside VAT and fiscalisation rules: a missing e-invoice often also entails an offence under the VAT Act or the Fiscalisation Act. Supervision is by the Ministry of Finance, and the Tax Administration compares SEF with the VAT declared during a tax audit.
Relationship to e-fiscalisation
The two systems complement each other without overlapping: e-fiscalisation covers retail supply and issues the fiscal receipt in real time, while SEF covers supplies between businesses and to the public sector. The same sole trader may be in both: a cafe issues fiscal receipts to guests and an e-invoice to the company that ordered catering. The rule in Art. 3(2) is the dividing line: what is fiscalised is not an e-invoice, with two exceptions from 1 April 2026 (corporate card, public sector request within seven days).
This text is an informational overview of the regulations and does not replace an accountant or a tax adviser; technical guides and current notices are at efaktura.gov.rs, and VAT regulations on the Tax Administration website.
What to do
- Check your status: if you are a VAT payer, you are in SEF compulsorily and issue an e-invoice for every supply to another VAT payer or to the public sector (Art. 2(1)(3) and Art. 3(1) of the Act). If you are not VAT-registered (flat-rate trader, small company below RSD 8,000,000 turnover), you have no obligation except towards the public sector.
- If you sell to the public sector and are not VAT-registered, register in SEF as a voluntary user before you submit a payment request; without an e-invoice a public buyer cannot pay you (Art. 2 and Art. 5(7)). Bear in mind that you then stay in the system until the end of the following calendar year (Art. 5(8)).
- Register at efaktura.gov.rs: sign-in goes through the eID electronic identification portal, with a qualified electronic certificate or the ConsentID app, and the legal representative opens the business account and adds users, your accountant included.
- Decide how you will work with SEF: directly in the web application (free), through your accounting software connected by an API key, or through an information intermediary from the Ministry of Finance list (Art. 13). For a few invoices a month the web application is enough.
- Issue every e-invoice in the Serbian e-invoicing standard, with the mandatory elements under Art. 7 (issuer and recipient details, date of supply, base, VAT rate and amount or the ground for exemption). Advance invoices and credit notes also go through SEF.
- Review received e-invoices regularly: the deadline to accept or reject is 15 days (Art. 10(1)). Reject a wrong invoice in time, because an accepted e-invoice becomes the basis for input VAT deduction and for booking (Art. 28(4) of the VAT Act).
- If you are a VAT payer, record the VAT calculation in SEF by the 12th day of the month after the tax period (Art. 4(5)), separately from the PPPDV tax return filed on ePorezi.
- Keep e-invoices for 10 years from the end of the year of issue: SEF stores them, and you may also keep them with an information intermediary (Art. 15(2) and (3)). A paper printout is not evidence; the original is the electronic record.
- Retail sales to consumers remain in e-fiscalisation, through the fiscal receipt, and no e-invoice is issued for them, except to a buyer paying with a corporate card and to a public sector entity that requests an e-invoice within seven days (Art. 3(2), applicable to tax periods from 1 April 2026).
What it costs
Using SEF through the web application is free; a cost arises if you use an information intermediary or a paid module of your accounting software, and through your accountant's time. Fines cost more: for failing to issue, accept or keep an e-invoice, a legal entity is fined RSD 200,000 to 2,000,000, a sole trader RSD 50,000 to 500,000, and the responsible person in a legal entity RSD 50,000 to 150,000 (Art. 18 of the E-Invoicing Act). In addition, without an accepted e-invoice a VAT-registered buyer loses the input VAT deduction (Art. 28(4) of the VAT Act).
FAQ
Who must use e-invoices in Serbia in 2026?
Mandatory SEF users are public sector entities (budget beneficiaries, public enterprises, majority state-owned companies) and private sector entities, which by definition means every VAT payer (Art. 2(1)(2) and (3) of the Act). An e-invoice must be issued in private-to-private, private-to-public, public-to-private and public-to-public transactions, and where a tax representative acts for a foreign company (Art. 3(1)). Whoever is not VAT-registered is not a private sector entity and need not issue e-invoices to other businesses, but must register as a voluntary user when invoicing the public sector.
Does a flat-rate (paušal) trader have to register in SEF?
No, if the trader deals only with private businesses and consumers: a flat-rate trader is not a VAT payer and so is not a private sector entity under the Act. Yes, if the trader invoices anything to the public sector: then it registers as a voluntary user before submitting the payment request (Art. 2 and Art. 5(7)), because the public sector receives and pays e-invoices only. Registration is free but binding: a voluntary user stays in the system for the current and the following calendar year and in that period has the same rights and obligations as mandatory users, including issuing all invoices to other SEF users electronically (Art. 5(8)). A flat-rate trader who registers for VAT automatically becomes a mandatory user.
What is the deadline for accepting an e-invoice?
The recipient accepts or rejects an e-invoice within 15 days of receipt (Art. 10(1)). If a public sector entity does not respond, the invoice is deemed accepted (para. 2). If a private sector entity does not respond, the system sends a repeat notice, and if there is still no reaction within the next five days, the invoice is deemed rejected (paras. 3 and 4); a rejected invoice can be accepted later (para. 5). The deadline is not merely technical: an accepted e-invoice is the sole basis for input VAT deduction under Art. 28(4) of the VAT Act, so an automatically rejected invoice also means losing the deduction until it is accepted.
How long must e-invoices be kept?
An e-invoice issued or received by a public sector entity is kept permanently in SEF (Art. 15(1)). An e-invoice between private sector entities is kept for ten years from the end of the year in which it was issued, in SEF or in an information intermediary's system (Art. 15(2) and (3)). That is longer than the general five-year period for accounting documents under the Accounting Act (Art. 28(8)), so accounting records in e-invoice form follow the longer period. A printed e-invoice is not the original.
What are the fines for not issuing an e-invoice in 2026?
A legal entity, private sector entity or public enterprise, that fails to issue an e-invoice when obliged, does not record VAT in SEF, or does not receive or keep an e-invoice is fined RSD 200,000 to 2,000,000; a sole trader RSD 50,000 to 500,000; the responsible person in a legal entity RSD 50,000 to 150,000 (Art. 18). The same fines apply to an information intermediary (Art. 19). Proceedings are brought by the Ministry of Finance, and the practical consequence is often heavier than the fine: the buyer cannot pay, or loses the VAT deduction.
For sales to consumers, is it an e-invoice or a fiscal receipt?
A fiscal receipt. Retail supply, and an advance received for retail supply, is exempt from the e-invoicing obligation (Art. 3(2)) and falls under e-fiscalisation per the Fiscalisation Act (Zakon o fiskalizaciji, Sl. glasnik RS Nos. 153/2020, 96/2021, 138/2022 and 80/2026). Two exceptions apply to tax periods from 1 April 2026: an e-invoice is issued to a buyer paying with a corporate card and to a public sector entity that requests one within seven days of the supply. Supplies free of charge, public revenue charges and costs under court decisions also stay outside SEF.
What is the electronic VAT record in SEF and who keeps it?
It is the obligation to record the VAT calculation for each tax period in SEF, separately from the PPPDV tax return filed with the Tax Administration through ePorezi. It is kept by VAT payers, and by public sector entities and voluntary users who are not VAT payers when they are the tax debtor (Art. 4(1)). The deadline is the 12th day of the calendar month following the tax period (Art. 4(5)). The 2026 amendments, applicable from 1 January 2027, provide that SEF prepares a preliminary VAT return from these records, so the accuracy of the record becomes the basis of the return itself.