Country deep dive
Serbia's e-invoicing rollout began with the public sector: suppliers to public-sector buyers were required to issue e-invoices via SEF from 1 May 2022, with public-sector entities required to issue to companies from 1 July 2022. The general B2B mandate followed on 1 January 2023, making e-invoicing (issuance and receipt) compulsory across the entire private sector for VAT-registered taxpayers. A separate law, the Zakon o elektronskim otpremnicama, now adds a parallel e-delivery-note system, rolling out in two phases: public sector, excise-goods traders, and carriers from 1 January 2026, extending to general private-sector B2B goods movement from 1 October 2027.
From 1 May 2022, every private-sector supplier to a Serbian public-sector buyer has been required to issue invoices electronically through SEF (Sistem elektronskih faktura), the government's central e-invoicing platform, under the Zakon o elektronskom fakturisanju ("Sl. glasnik RS" br. 44/2021, 129/2021, 138/2022).
From 1 July 2022, Serbian public-sector entities themselves became required to issue e-invoices to private companies through SEF, completing the B2G/G2B leg of the rollout ahead of the general B2B mandate that followed on 1 January 2023.
From 1 January 2023, e-invoicing (both issuance and receipt) became mandatory across Serbia's entire private sector, for all VAT-registered taxpayers -- no company-size or revenue threshold was found in the law's text. Every invoice is submitted to and validated by SEF before reaching the recipient, a centralized clearance (CTC) model functionally similar to Italy's SDI, using XML based on UBL 2.1 with a Serbia-specific CIUS aligned to EN 16931.
Alongside the general B2B e-invoicing mandate, VAT-registered taxpayers also became required to electronically record their VAT self-assessment calculation within SEF from 1 January 2023, under Art. 4 of the core e-invoicing law. This is a VAT-recording obligation layered on top of the e-invoicing mandate, not a separate invoicing requirement in itself.
A separate statute, the Zakon o elektronskim otpremnicama ("Sl. glasnik RS" br. 94/2024 i 109/2025), makes electronic delivery notes mandatory from 1 January 2026 for public-sector entities, traders in excise goods (fuel, alcohol, tobacco, e-cigarettes, electricity, coffee), and carriers presenting waybills at roadside inspection. This is a goods-movement documentation requirement, distinct from the e-invoicing mandate -- a grace period ran to 30 June 2026 before full inspection enforcement began.
From 1 October 2027, the e-otpremnica obligation extends beyond Phase 1's public-sector/excise-goods/carrier scope to general private-sector B2B (and B2C receipt) movement of goods. Note: this is a distinct development from a separately-reported "expanded B2B e-invoicing reform" package (new SEF invoice fields, stricter validation, full document archiving, a new penalty regime) that secondary sources describe as postponed to "end of 2026" -- that reform's exact date could not be confirmed against a primary Ministry of Finance announcement as of this writing.
A SEF-compliant e-invoice is XML based on UBL 2.1, with a Serbia-specific CIUS aligned to the EU's EN 16931 semantic standard. Transmission is a centralized clearance (CTC) model -- every invoice is submitted to and validated by SEF (Sistem elektronskih faktura) before reaching the recipient, functionally similar to Italy's SDI, with SEF also acting as the invoice repository. The e-otpremnica system uses the same UBL 2.1-based approach, managed by a "Central Information Intermediary," accessible via the national eID portal, web UI, mobile app, or API.
Unlike Slovenia's decentralized ZIERDED model, Serbia's SEF is a true government clearance platform -- there is no alternative permitted transmission channel for the core e-invoicing mandate.
SEF v4.0.0's production deployment was officially postponed (announced 24 Jul 2026) with no new date given -- v4.1.0's relationship to the delayed v4.0.0 release was not independently confirmed in this research; verify current version behaviour directly with SEF before relying on this note.
The e-invoicing mandate applies to all VAT-registered taxpayers and all entities using the public procurement system, with no company-size or revenue threshold identified in the law's text -- foreign companies operating via a local tax ID or fiscal representative are included. The e-otpremnica mandate is instead phased by category of activity: Phase 1 covers the public sector, excise-goods traders, and carriers; Phase 2 (1 October 2027) extends to general private-sector B2B goods movement. Whether B2C/fiscal-receipt invoicing sits inside or outside the core e-Faktura mandate was not independently confirmed in this research.
Whether B2C (consumer/retail, fiscal-receipt) invoicing falls inside or outside the e-Faktura mandate was not independently confirmed against the law's text in this research -- secondary sources suggest it is governed separately by fiscal cash-register rules, but treat this as unconfirmed.
Do not conflate e-otpremnica's Phase 2 with the separately-reported "expanded B2B" e-invoicing reform package (new SEF fields, stricter validation, full document archiving, a new penalty regime) -- secondary sources describe that package as postponed to "end of 2026," a distinct development whose exact date could not be confirmed against a primary Ministry of Finance announcement.
Most businesses trading with Serbia already have a live SEF e-invoicing obligation -- the mandate has been in force since 2023. The newer work is the e-otpremnica (e-delivery note) system: businesses in the Phase 1 categories (public sector, excise goods, carriers) needed to be ready by 1 January 2026 with inspection enforcement now fully live, while other businesses moving goods B2B should plan ahead of the 1 October 2027 Phase 2 date.
This has been mandatory for B2B trade with Serbian counterparties since 1 January 2023 -- confirm your invoicing software or provider is SEF-connected, not relying on paper or plain PDF.
Phase 1 of the e-delivery-note mandate (public sector, excise-goods traders, carriers) has applied since 1 January 2026, with full inspection enforcement now live after the 30 June 2026 grace period.
From 1 October 2027, the e-delivery-note obligation extends to general private-sector B2B goods movement -- test your process well before that date.
The Ministry of Finance postponed SEF v4.0.0's production deployment (announced 24 Jul 2026) without giving a new date, while a v4.1.0 release went live 2 Aug 2026 -- confirm with SEF support which version applies to your integration.
New invoice fields, stricter validation, full document archiving, and a new penalty regime have been reported by secondary sources as targeting "end of 2026," but this has not been confirmed via a primary government announcement -- do not commit engineering resources against an unconfirmed date.
Serbia backs both statutes with real, tiered fines. The e-invoicing law (Arts. 18-21) and the e-delivery-note law (Arts. 13-14) both set penalty ranges by offender category (legal entities, entrepreneurs, responsible individuals), sourced here via Paragraf.rs's consolidated legal text -- a reputable secondary compiler, not the raw gazette itself, so article-by-article attribution should be treated as indicative pending direct verification of the gazette text.
Other countries in the same region, ordered by their next dated milestone. Each links to a full briefing.