Pursuant to the Law on Electronic Invoicing (that we analysed in the article available here), several by-laws have been recently adopted and published in the Official Gazette of RS no. 69 of 9 July 2021:

• Regulation on conditions and manner of using the invoice management system
• Regulation on conditions and manner of keeping and placing at insight electronic invoices and the manner of securing credibility and integrity of paper invoice contents
• Regulation on the procedure and conditions for granting and revoking consent for performing the activities of information mediator
• Rulebook on the manner of operation of central information mediator
• Rulebook on the manner and procedure of registration for access to electronic invoice system, manner of accessing and using the electronic invoice system and manner of using the information available in the electronic invoice system
• Rulebook on elements of electronic invoice, form and manner of submitting supporting and other documentation through electronic invoice system, manner and procedure for electronic registration of VAT calculation in electronic invoice system and manner of changing the electronic invoicing standard (“the Rulebook”).

We shall particularly consider the Rulebook since it regulates the content of electronic invoice.

What an electronic invoice needs to contain?

Under the Rulebook, an electronic invoice shall contain:

• Name, address and tax identification number of the issuer if the issuer is a legal entity i.e. taxpayer of income from self-employment in terms of the law regulating citizens’ income tax;
• Single number of public funds beneficiary (“SNPFB”) of the issuer, if the issuer is a beneficiary of public funds enlisted as beneficiary of public funds in terms of the Law on Budget System;
• Business account of the issuer;
• Name, address and tax identification number of the recipient if the issuer is a legal entity i.e. taxpayer of income from self-employment in terms of the law regulating citizens’ income tax;
• SNPFB of the recipient, if the issuer is a beneficiary of public funds enlisted as beneficiary of public funds in terms of the Law on Budget System;
• Ordinal number and date of electronic invoice;
• Date of advance payment, if the invoice refers to advance payment, or delivery date for goods/services, if the invoice does not refer to advance payment;
• Code and/or name of goods/services for each item on the electronic invoice, quantity and unit of measurement for the delivered goods/scope of rendered services for each item on the electronic invoice;
• Value for each item on the electronic invoice;
• Total amount of electronic invoice;
• Amount of advance payment, if any of such payments referred to one or more items on the electronic invoice.

The Rulebook also regulates the contents of electronic invoice that represents a document on decrease/increase of fee and electronic invoice that only represents reverse invoice, as types of documents that are necessarily linked to one or more other electronic invoices.

Serbian standard for electronic invoicing

The Law on Electronic Invoicing stipulates that electronic invoice shall be issued and received in accordance with Serbian standard for electronic invoicing.

The Rulebook specifies that the Serbian standard for electronic invoicing – SRPS EN 16931-1:2019/A2:2020 is based on the European standard for electronic invoicing harmonised with the European Union Directive on electronic invoicing in public procurement and implies the form of invoices based on the UBL (Universal Business Language) structure, whereas it is established by the Institute for Standardisation of Serbia.

Draft standard – naSRPS EN 16931-1 entered public discussion phase that started on 2 August 2021 and will last until 1 October 2021. The draft is currently available at the following link. All interested parties can, with prior registration, comment on the draft text and propose the changes for its content by filling an online form on the same link.

This standard is actually a translation of the Serbian standard adopted in 2019 in the English language (available here), along with the amendment adopted in 2020 (available here).

Following its adoption, the standard will, in accordance with the decision of the European Commission, be available for downloading from the website of the Institute for Standardisation of Serbia.

This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.