Regulatory updates - Serbia

The amendments to the Rulebook published in the Official Gazette No. 71/2026 focus primarily on VAT record-keeping, preliminary VAT return generation, input VAT reporting, and related SEF functionality enhancements, rather than expanding the scope of mandatory e-invoicing. 

Key updates include, among others: 

• Preliminary VAT Return: SEF will generate a preliminary VAT return based on e-invoices, VAT records, and input VAT records maintained in the system. The new framework applies to VAT periods beginning after December 31, 2026.  

• Enhanced VAT reporting: New data fields and reporting rules have been introduced for taxable amount and VAT increases/decreases, advance payment reductions, cancellations (storno), and corrections.  

• Input VAT records: Input VAT reporting must be submitted by the 12th day of the month following the VAT period. The Rulebook also introduces new rules for automatic population, corrections, updates, and interaction with the preliminary VAT return process.   

• Correction and update mechanisms: Detailed procedures clarify how input VAT records may be corrected or updated, including restrictions once the preliminary VAT return or VAT return has been submitted.  

• SEF outages: New procedures clarify how temporary SEF interruptions are handled, including user notifications and deadline change where outages prevent timely VAT reporting. 

Taxpayers should evaluate the impact on their VAT reporting, correction procedures, and SEF-related compliance processes ahead of the new preliminary VAT return functionality becoming effective in 2027. 

The National Assembly of the Republic of Serbia adopted amendments to the law on e-invoicing. Some of the key changes are:   

• Introduction of the obligation to issue an e-invoice for retail sales made to a corporate cardholder, including any advance payments received for these sales, and for retail sales made to public sector entities if the public entity requests an e-invoice within seven days from the date of sale 

• For the retail sales mentioned above, the e-invoice must only be issued after a fiscal receipt has been issued in accordance with fiscalization laws  

• The implementation of pre-filled VAT returns has been postponed from the  January 2026 tax period to tax periods beginning after December 31, 2026 (i.e from the January 2027 tax period) 

The law entered into force on December 12, 2025, and will become applicable to tax periods starting after March 31, 2026, except for the pre-filled return provision applying from the law’s entry into force. 

Additionally, the Law on Amendments to the Law on VAT (VAT) was adopted and published in the same Official Gazette, No. 109/2025. Among other changes, the law introduces a requirement for internal invoices to be generated within the e-invoicing system (SEF) where the taxpayer is a user of SEF. The law entered into force on December 12, 2025, and its application starts on April 1, 2026.  

In the past, the SEF has gone through several upgrades. The latest upgrade is to SEF version 3.14.0. The new version plans to introduce several enhancements to the functionality, validation, and user experience of the SEF.

The main updates include:

• Mandatory delivery dates: all e-invoices must now include a delivery date
• Issue date vs transaction dates: the transaction date cannot be later than the issue date. This also applies to credit, debit, and advance invoices
• VAT consistency: new validation checks require alignment between VAT liability and tax category (S10/S20) with specific codes
• Totals display: total reduction and increase amounts have been added to the external display of reduction and increase documents in foreign currency
• Recipient notification about previous tax: recipients can send notifications about their previous tax input through SEF.

This new version is currently only available in the DEMO environment. The Internal Technical Manual, showing the changes, has been updated to version 15.08.2025.