Regulatory updates - Serbia

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.

The Serbian Parliament adopted amendments to the VAT law. One of the key changes is the introduction of pre-filled VAT returns starting from January 2026. 

Pre-filled VAT returns  

A pre-filled VAT return is data on the turnover of goods, trade in services, import of goods and other transactions and activities that determine the VAT payer’s tax liability. 

Starting from the January 2026 VAT period:  

• The Tax Authority will generate pre-filled VAT returns in the electronic invoicing system (SEF) using information available in the system.  

• Pre-filled VAT returns will not be generated for periods in which VAT activity begins or ends. 

• Taxpayers will be required to submit their VAT returns together with a pre-filled tax return as an annex to the tax return.  

• If the taxpayer fails to submit the return within the deadline, the Tax Authority may use the pre-filled VAT return as final.  

The requirement to file the VAT calculation overview for each tax period will be eliminated starting with the January 2026 tax period.