Electronic invoice in Serbia
Comprehensive guide to Serbia’s nationwide electronic invoicing mandate – Central SEF platform with mandatory B2G and B2B coverage since 2023
Serbia has rapidly implemented a nationwide electronic invoicing mandate that ranks among the most comprehensive globally. Since 2023, all businesses must issue and receive invoices electronically through the central government platform (SEF). This means the era of paper invoices is essentially over for Serbian B2B and B2G transactions. The system enforces standardized formatting and real-time clearance, providing unprecedented transparency in trade.
Key Milestones
2021
Law on Electronic Invoicing
Serbia passed the Law on Electronic Invoicing (Official Gazette no. 44/2021) in May 2021, establishing the framework for a comprehensive e-invoicing system and the central SEF platform.
May 2022
B2G Mandate Begins
All suppliers to Serbian public sector required to send invoices electronically through the SEF platform. Public entities must receive and store e-invoices.
Jul 2022
G2B Mandate
Serbian public institutions required to issue invoices electronically to businesses via SEF, ensuring two-way electronic flow between government and businesses.
Jan 2023
Full B2B Mandate
E-invoicing extended to entire B2B sector. All transactions between VAT-registered businesses must be invoiced electronically through SEF – one of the first countries globally with such comprehensive coverage.
2024+
System Refinement
Ongoing improvements to SEF platform, updated technical guidelines, and integration with other tax systems for enhanced VAT control.
Key Legislation
Law on Electronic Invoicing (Zakon o Elektronskom Fakturisanju, Official Gazette no. 44/2021) – cornerstone legislation establishing obligations for issuers and recipients.
Continuous Transaction Controls (CTC) – every invoice must be submitted through the central SEF system for clearance and storage..
Key Legal Points:
- Applies to all VAT-registered taxpayers in Serbia, plus public sector entities
- Foreign companies with a local VAT representative must also comply
- SEF is the designated official platform for exchange and storage
- Format based on EN 16931-1 (UBL 2.1 XML structure)
- Invoices must be signed with qualified electronic signature or seal
- 10-year archiving in SEF as per legal requirement
Accept/Reject Workflow:
- B2G: Receiver must accept or reject within 15 days
- B2B: Re-notification after 15 days; if no action after 5 more days, invoice deemed rejected
B2G (Business-to-Government)
Mandatory since May 2022
All invoices to public sector entities (state bodies, municipalities, public companies, schools, hospitals) must be electronic via SEF. Paper/PDF not accepted.
B2B (Business-to-Business)
Mandatory since January 2023
All invoices between VAT-registered businesses must go through SEF. Both seller and buyer need SEF registration. No monetary threshold – applies to all amounts.
B2C (Business-to-Consumer)
Not via SEF
Consumer transactions are controlled by fiscal cash registers, not the SEF platform. Retail sales produce fiscal receipts handled by separate fiscalization system.
Foreign Companies
If you have a VAT representative in Serbia, you must use e-invoicing through your representative. Companies without Serbian tax presence cannot directly access SEF.
Сentralized Clearance Model (SEF)
Serbia operates a centralized clearance model through SEF (Sistem za Elektronske Fakture). All e-invoices are issued, exchanged, and stored through this government-run platform – similar to models in Italy (SDI) and Latin American countries.
How SEF Works
Central Platform
All participants use SEF web portal or API. SEF acts as intermediary: supplier issues invoice to SEF, SEF makes it visible to buyer. Think of it as post office and archive combined.
Technical Formats
XML based on UBL 2.1
conforming to EN 16931. Contains seller/buyer info, VAT IDs, line items, tax breakdowns, payment instructions. Each invoice gets unique ID and timestamp.
Non-Compliance Risks
Monetary fines for failing to issue e-invoices via SEF or evading the system
Tax inspections with potential additional penalties under Tax Procedure code
Public sector buyers will not pay invoices not submitted through SEF
Important Note
Serbia uses SEF data for automated tax audit – the system cross-checks VAT declarations against actual invoices. Non-compliance is easily detected and addressed by authorities.
Is electronic invoicing mandatory in Serbia?
Yes, for both B2G (since May 2022) and B2B (since January 2023). All VAT-registered businesses must use the SEF platform. Paper or PDF invoices are not legally acceptable for these transactions.
What platform is used for e-invoicing in Lithuania?
The platform is called SABIS (Sąskaitų Administravimo Bendroji Informacinė Sistema). It’s the central Lithuanian e-invoice administration system. All e-invoices to the public sector must go through SABIS. Businesses typically access SABIS via a web portal or through a service provider (using API integration or the Peppol network). Essentially, SABIS is the government’s invoice inbox.
How do buyers accept invoices?
Buyers log into SEF (or receive via API) and must accept or reject invoices within 15 days. If they don’t respond after a second notification and 5 more days, the invoice is automatically rejected.
Can I still send PDF invoices by email?
You can send a PDF as a courtesy copy, but it doesn’t fulfill the legal requirement. The official invoice must go through SEF. Sending only by email means non-compliance.
What about foreign companies?
Foreign companies with a Serbian VAT representative must comply through that representative. Companies without Serbian tax presence cannot directly access SEF and may need to work through their local representative or establish presence.
Summary
Serbia has implemented one of the world’s most comprehensive e-invoicing mandates. The centralized SEF platform handles all B2G and B2B invoices, with built-in acceptance workflows and 10-year archiving. The Tax Administration has real-time visibility into all transactions, significantly improving VAT compliance and reducing the shadow economy.
For businesses operating in Serbia, compliance is essential – the system doesn’t allow workarounds. While the adjustment was significant, the benefits include faster invoice dispute resolution, automated bookkeeping, and streamlined payments. Companies should ensure they’re registered on SEF with appropriate digital certificates and either use the portal directly or integrate via API.
Need Help with E-Invoicing Compliance?
As a certified Peppol Access Point, we provide complete e-invoicing solutions for businesses across Europe. Our platform handles format conversion, real-time validation, and seamless integration with national systems.
