Electronic invoice in Serbia

Comprehensive guide to Serbia’s nationwide electronic invoicing mandate – Central SEF platform with mandatory B2G and B2B coverage since 2023

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Overview

Serbia has been running mandatory e-invoicing through its state platform SEF — Sistem elektronskih faktura — since 2022. B2G started in May 2022, G2B in July 2022, and domestic B2B between VAT payers in January 2023. The system is operated by a unit of the Ministry of Finance acting as Central Information Intermediary.

Two features set Serbia apart from every EU country on this site. Peppol is not the national infrastructure and a Peppol message does not discharge the mandate. And unlike Romania or Italy, serving Serbian clients as a regulated provider requires a Serbian legal entity and a permit from the Ministry of Finance — foreign Peppol certification is not a substitute.

UBL 2.1 only

CII is not confirmed as an equivalent domestic SEF syntax

10 years

private-sector retention; public-sector invoices are kept permanently

Local entity

required to act as a licensed information intermediary

Timeline

Serbia rolled out its system quickly — the whole public and private sector was in within eight months. Everything below is already in force.

Already in force

1 May 2022

Public sector and B2G

Public bodies must issue, receive and store e-invoices between themselves, and private suppliers must invoice the public sector through SEF.

1 July 2022

G2B and private-sector receiving

Public bodies must issue e-invoices to private companies, and the private sector must be able to receive and store them — six months before it had to issue them.

1 January 2023

Domestic B2B and electronic VAT records

Issuing and storing e-invoices becomes mandatory between private-sector entities, and electronic VAT records in SEF begin for transactions outside the public sector.

December 2025

Amendments to the E-Invoicing Act

Published in Official Gazette 109/2025 and adopted in January 2026, they add an e-invoice obligation for retail sales to corporate cardholders and require internal invoices to be generated inside SEF.

After 31 March 2026

The new obligations apply

Most of the amended provisions take effect for tax periods beginning after this date, alongside a revised e-invoicing Rulebook.

Ahead

After 31 December 2026

Pre-filled VAT returns

Their introduction was postponed from January 2026 to tax periods beginning after the end of 2026.

No date

Cross-border and ViDA

Serbia has set no date from which export or import invoices must pass through SEF. As a candidate country outside the EU VAT system, it has no ViDA deadline either — see cross-border scenarios.

The platform moves quickly

SEF is under continuous development and the Rulebook is amended several times a year — most recently in Official Gazette 30/2026 in March 2026 and 71/2026 in August 2026, with the internal technical instruction refreshed alongside. SEF release 4.1.0 went into production in August 2026. Any integration needs a process for tracking releases, not a one-off build.

The B2B mandate

A "private-sector entity" in the Act means a Serbian VAT payer that is not part of the public sector. The B2B mandate therefore covers all registered VAT payers, with no separate turnover threshold for e-invoicing. Companies and entrepreneurs not registered for VAT may join voluntarily — and must register in SEF before submitting a payment request to the public sector.

01 The supplier produces UBL 2.1 under the Serbian CIUS

02 It goes to SEF directly or through an approved information intermediary

03 SEF processes it and delivers it to the buyer

04 The buyer accepts or rejects it

05 The XML and its status are retained in SEF or at an approved intermediary

Acceptance deadlines — and silence as a decision

The recipient has 15 days to accept or reject. For the private sector, a reminder follows and if no action is taken within a further five days the invoice is deemed rejected — though it can still be accepted later. For the public sector, silence for 15 days means the invoice is deemed accepted. The same silence produces opposite outcomes depending on who your customer is.

An invoice transmitted through SEF by the supplier or an authorised intermediary also acquires the status of an authentic enforcement document — which makes the channel a debt-collection advantage, not only a compliance duty.

B2G

A Serbian supplier to the public sector registers in SEF, issues a Serbian UBL/CIUS invoice, sends it through SEF and adds budget and procurement references where required.

—The mandate covers not only classic procurement invoices but also certain payment requests to the public sector

—Public budget users are additionally identified by JBKJS, the unique budget-user number, alongside the tax identification number

—Non-VAT-registered entities must register in SEF before submitting a payment request to a public body

Public-sector invoices are stored permanently in SEF, which is a meaningful difference from the private-sector regime described under archiving.

B2C and fiscalisation

There is no general B2C e-invoicing mandate in Serbia. The E-Invoicing Act does not, as a rule, extend to natural persons who are not carrying on an independent business activity. Ordinary retail transactions sit under the fiscalisation system and are documented by a fiscal receipt, not by a SEF invoice.

—Retail transactions paid with certain corporate cards now require an e-invoice, following the 2025/2026 amendments

—A retail transaction with a public-sector entity requires a SEF invoice if that entity requests one within seven days

—In those cases the SEF invoice must not be issued before the fiscal receipt has been generated — the order of the two documents is prescribed

These are targeted exceptions closing the gap between company spending and retail. They do not amount to a consumer mandate.

Formats and the Serbian CIUS

Serbia follows the European standard through a national adaptation: SRPS EN 16931-1:2019/A2:2020, based on EN 16931-1:2017+A1:2019/AC:2020 and extended with Serbian business rules and the national UBL extension SrbDtExt.

UBL 2.1 — the working syntax

The official specification is written in UBL paths and references EN 16931-3-2. It covers Invoice and CreditNote, uses the SrbDtExt extension and adds elements for advance payments and foreign-currency invoices.

CII — not confirmed

UN/CEFACT CII does not appear as a supported domestic SEF syntax in the official specification. All technical mapping, XML examples and validation rules are published for UBL 2.1.

Plain EN 16931 compliance is not enough. A domestic SEF invoice must satisfy the Serbian business rules on top of the European semantic model. An invoice that validates against the base standard can still be rejected by SEF.

PDF

A standalone PDF is not an electronic invoice under the Serbian mandate. The Act defines an e-invoice as a document in a structured format allowing fully automated electronic processing through SEF. A PDF may serve as a visualisation, for printing, or as an accompanying file — but it does not replace the mandatory UBL XML. Even where a user prints the invoice, the primary document remains the structured file held in SEF or at an approved intermediary.

The SEF model

SEF is a centralised state mandatory-exchange CTC platform, close to clearance but not identical to it. It is not a reporting portal to which a copy is uploaded after the exchange: for transactions inside the mandate, the structured invoice must reach the recipient through SEF.

The chain

Supplier / ERP → SEF or a Serbian information intermediary → central SEF → buyer

The Act does not require individual VAT approval by the tax authority before each invoice is delivered, so it is more accurate to describe SEF as centralised CTC with mandatory exchange than as classic clearance with a separate tax approval step. The invoice is treated as delivered at the moment it is issued in the system, except during periods of technical unavailability.

Why this is not a Peppol model

There is no four-corner or five-corner architecture and no network of independent access points

SEF has a single central state layer; commercial providers connect to it as nationally approved information intermediaries, not as Peppol access points

Serbia does not appear in the OpenPeppol list of national Peppol Authorities; in such jurisdictions OpenPeppol itself acts as coordinating authority, which does not make it the governing body for SEF

The Peppol code list does contain EAS 9948 — RS:VAT for Serbian VAT numbers, meaning a Serbian VAT identifier can technically be used as a Peppol endpoint. It is not a mandatory SEF identifier, it does not confirm SEF registration and it does not replace national SEF routing. Inside SEF the primary identifier is the Serbian PIB (poreski identifikacioni broj).

VAT records in SEF

Alongside the invoice flow, SEF carries a second obligation that is easy to overlook: electronic VAT records. These are separate records of output VAT, input VAT, reverse-charge transactions, transactions for which no SEF invoice was issued, and corrections.

Invoice flowTransaction-level and near real time — the invoice is delivered as it is issued

VAT recordsCompiled per tax period and submitted by the 12th calendar day of the month following that period — periodic, not real-time

Import dataFed into SEF from the Customs Administration's information system

Internal invoicesUnder the 2025/2026 amendments, taxpayers using SEF must generate internal invoices within the system

A useful safeguard: where an error in an electronic VAT record is corrected before a supervisory procedure begins, the Act allows it in certain cases not to be treated as an offence. Self-correction is worth having as a documented process.

Information intermediaries

This is the section that decides whether a European provider can enter the Serbian market at all. A provider that, on a client's behalf, issues, records, processes, sends, receives or stores e-invoices or maintains VAT records must hold the status of information intermediary with the consent of the Serbian Ministry of Finance. The permit is granted for up to 24 months after a review of legal, organisational and technical conditions.

What the applicant must satisfy

—Be a legal entity registered in the Republic of Serbia — a foreign VAT registration or an EU establishment is not sufficient

—Have no overdue public-revenue liabilities

—Pass the required checks on directors and representatives

—Operate security controls under a formal ICT security act, with internal and published terms of service

—Store SEF data in Serbia

—Carry liability insurance of at least EUR 20,000 per event with an annual aggregate of at least EUR 5,000,000

—Provide a guaranteed service availability level, a complaints procedure, an exit strategy and technical support

—Accept no contractual limitation of the intermediary's liability, and be able to transfer stored invoices to the central intermediary on ceasing operations

Two workable models

1. Establish a Serbian entity, meet the national requirements and obtain the Ministry's consent.

2. Act as a technical contractor without taking on the regulated intermediary role. The Serbian client then connects to SEF directly or uses an already approved Serbian intermediary. The boundary between an ordinary software supplier and a regulated intermediary has to be fixed in the contract and reflected in the technical architecture.

No separate national e-delivery mailbox is required, but a Serbian legal entity brings with it registered legal representatives, an official electronic submission route through the Ministry's portal and Serbian corporate and tax registration data. A public register of information intermediaries lets you check who already holds a permit before deciding between the two routes.

Cross-border scenarios

Serbia has set no date from which all export or import B2B invoices must pass through SEF. What exists instead is a set of specific situations.

Foreign supplier with a Serbian VAT representativeThe tax representative must issue SEF invoices for transactions with Serbian public- and private-sector entities

Foreign supplier without Serbian registrationAn ordinary foreign invoice, reverse charge at the Serbian recipient, an internal invoice on the recipient's side and separate electronic VAT recording. The foreign invoice does not become a domestic SEF invoice

Direct receipt of a foreign EN 16931 invoiceThe Act obliges the public sector to receive such an invoice and permits the private sector to do so — but only once the corresponding technical conditions exist in SEF

Serbian export to the EU or a third countryOutside the domestic mandate where the buyer is not a Serbian entity and does not act through a Serbian VAT representative. Peppol, EDI, e-mail or a portal may be used — none of which is a domestic SEF transaction

Import of goodsSEF receives import data from the Customs Administration but does not replace the customs declaration, which — together with proof of payment — remains the basis for deducting import VAT

Do not assume the cross-border functionality is available to every foreign supplier simply because the Act provides for it. Check it against your actual connection method and the current SEF release — the law and the platform are not always at the same point.

ViDA

Serbia is an EU candidate country, not a member state. The ViDA package does not apply to it directly and creates no 1 July 2030 obligation. Those dates become legally relevant only on accession or through voluntary alignment with the EU acquis. There is currently no official Serbian ViDA mandate date.

Archiving

Retention differs by sector, which is unusual and worth getting right in the design.

Public sectorInvoices are stored permanently in SEF

Private sectorTen years after the end of the year in which the invoice was issued

WhereIn SEF, or with an approved information intermediary

ConditionAuthenticity of origin and integrity of content must be preserved throughout the whole retention period

A dedicated government decree governs the conditions and manner of storing electronic invoices and making them available for inspection — worth reading before choosing where your archive will live, particularly if you are weighing an approved intermediary against storage in SEF itself.

Penalties

Fines apply for failing to issue e-invoices, failing to use SEF, failing to keep electronic VAT records, or misstating an entity's status.

Private-sector legal entity or public enterpriseRSD 200,000 – 2,000,000

EntrepreneurRSD 50,000 – 500,000

Responsible person of a legal or public entityRSD 50,000 – 150,000

Intermediary endangering SEF security or operationRSD 200,000 – 2,000,000

Responsible person of an intermediaryRSD 50,000 – 150,000

Is the e-invoice the only basis for deducting VAT?

For transactions inside the mandate — yes. The VAT Act provides that where an electronic invoice must be issued, the right to deduct input VAT may be exercised only on the basis of an accepted electronic invoice, including one deemed accepted by operation of law.

—To claim in the relevant tax period, the invoice must be accepted no later than the day before the VAT return is filed, and no later than the 10th day of the month following that period

—Accepted later, the deduction moves to the period of acceptance

The SEF e-invoice is not, however, a universal basis for every kind of input VAT: imports rely on the customs document and proof of payment, reverse charge on an internal invoice and the recipient's calculation, excluded transactions on other documents, and retail on fiscal documents. Beyond the fines, non-compliance also risks blocked deductions, payment delays, disputes about delivery and acceptance, and the loss of the invoice's status as a SEF enforcement document.

How we help

Serbia cannot be reached by adding 9948 to a Peppol routing table. What works is a national integration, combined with the European connection our clients already use:

UBL 2.1 generation and conversion under the Serbian CIUS, including the SrbDtExt extension

Validation against the Serbian business rules before submission, not only against EN 16931

Connection to the SEF API, with API key management and release tracking

Handling of acceptance and rejection statuses, including the 15-day and 5-day deadlines

Advance invoices, foreign-currency invoices and credit notes

Peppol BIS Billing 3.0 for the European side of your business, alongside the Serbian route

Integration via API, SFTP and CSV, with ERP and IDoc source data

A clear split between the software-supplier role and the regulated intermediary role

Frequently asked questions

Can a foreign Peppol access point serve Serbian clients?

Not on the basis of Peppol certification alone. To take on the regulated role of information intermediary you need a legal entity registered in Serbia, consent from the Ministry of Finance, SEF data stored in Serbia, liability insurance and the other national conditions. The alternative is to act as a technical contractor while the Serbian client connects to SEF directly or uses an approved Serbian intermediary — with the boundary between the two roles set out in the contract.

Does sending via Peppol satisfy the Serbian mandate?

No. SEF is the mandatory channel, and neither the E-Invoicing Act nor the national technical documentation designates Peppol as a required transport mechanism. A Peppol message does not discharge the domestic obligation unless the invoice has properly been transmitted through SEF. EAS 9948 exists for Serbian VAT numbers in the Peppol code list, but it is not a SEF routing identifier and does not confirm SEF registration.

What happens if my customer does nothing with the invoice?

It depends who they are. A private-sector recipient has 15 days to accept or reject; a reminder follows, and if nothing happens within a further five days the invoice is deemed rejected — though it can be accepted afterwards. A public-sector recipient that stays silent for 15 days is deemed to have accepted. Build alerting around the private-sector case; silence there works against you.

Can I send CII instead of UBL?

Treat UBL 2.1 as the only safe answer. CII is not listed as a supported domestic SEF syntax in the official specification, and all mapping, XML examples and validation rules are published for UBL. CII should not be treated as an equivalent domestic format without separate confirmation from the Ministry of Finance. EN 16931 CII may matter for the future scenario of receiving a foreign invoice directly, which is a different case.

Is there a B2C e-invoicing obligation?

There is no general one. The Act does not, as a rule, extend to natural persons outside an independent business activity, and ordinary retail sits under fiscalisation with a fiscal receipt. Recent amendments added targeted exceptions: retail transactions paid with certain corporate cards, and retail transactions with a public-sector entity that requests a SEF invoice within seven days. In those cases the SEF invoice must not be issued before the fiscal receipt.

Do I need an accepted e-invoice to deduct VAT?

For transactions where an e-invoice must be issued, yes — the deduction may be exercised only on the basis of an accepted electronic invoice, including one deemed accepted by law. To claim in the relevant period, acceptance must occur no later than the day before the VAT return is filed and no later than the 10th day of the following month; otherwise the deduction moves to the period of acceptance. Imports, reverse charge, excluded transactions and retail rely on other documents.

How long must invoices be kept, and where?

Public-sector invoices are stored permanently in SEF. Private-sector invoices must be kept for ten years after the end of the year of issue, either in SEF or with an approved information intermediary, with authenticity of origin and integrity of content preserved throughout. A dedicated government decree sets out the conditions for storage and for making invoices available for inspection.

Does ViDA apply to Serbia from 2030?

No. Serbia is an EU candidate country, not a member state, so the ViDA package does not apply directly and creates no 1 July 2030 deadline. Those dates would become relevant on accession or through voluntary alignment with the EU acquis. There is currently no official Serbian ViDA mandate date, and Serbia has likewise set no date for putting export or import invoices through SEF.

Summary

Serbia has been fully live for years: B2G since May 2022, domestic B2B between VAT payers since January 2023, all of it running through the state SEF platform under the Ministry of Finance. The model is centralised mandatory exchange, the format is UBL 2.1 under the Serbian CIUS, and a standalone PDF is never the original.

The market-entry question is different from every EU country. Acting as a regulated information intermediary requires a Serbian legal entity, a Ministry permit valid for up to 24 months, data storage in Serbia and liability insurance up to EUR 5 million in aggregate. A European provider either builds that, or works as a technical contractor alongside a licensed Serbian intermediary.

Two details repay attention early: silence from a private-sector customer means the invoice is rejected, and SEF changes several times a year. Neither is a one-off configuration — both need monitoring built into the process.

Resources

efaktura.gov.rs — the official SEF portal The Ministry of Finance's site for the electronic invoice system, with news and release notes The Serbian CIUS specification The adapted application of EN 16931-1 for domestic invoices, with the Serbian business rules SEF API specification The interface for direct access to the electronic invoice system Decree on consent for information intermediaries The procedure and conditions for granting and withdrawing the Ministry's permit Register of information intermediaries Who currently holds a permit — useful before choosing a partner Decree on storing electronic invoices Conditions for retention and for making invoices available for inspection List of SEF users Check whether a business partner is registered in the system SEF — the production system Where registered users log in to send and receive invoices

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