The Law on Electronic Delivery Notes (“Law”) entered into force on December 6, 2024. In one of our previous articles (link), we have already discussed the innovations it introduces.

The Law provides for the introduction of the E-Delivery Note System within the framework of the Electronic Invoicing System (known as SEF). It stipulates that the initial compliance obligations will take effect on January 1, 2026, while full implementation is scheduled for October 1, 2027.

To ensure a more precise regulation of the E-Delivery Note System, the Rulebook on Electronic Delivery Notes (“Rulebook”) has recently been adopted. The Rulebook further regulates certain issues and solutions outlined in the Law, including:

1) The procedure for registration and access to the system

• Registration can be carried out: 1) through the SEF or 2) by direct registration within the E-Delivery Note System.
• Registration is only available to entities that possess a Tax Identification Number (TIN). The registration must be completed by the entity’s legal representative or by the entity itself in the case of sole proprietors and other natural persons.
• During registration, the following information regarding the registering entity must be provided: 1) entity type (e.g., company, sole proprietor, association, etc.), and 2) entity identification number (registration number, TIN, and JBKJS for public fund users).
• An entity that becomes a public sector or private sector subject is registered automatically.
• Additionally, system users may designate authorized persons for system access and use, while those classified as transporters can access the system via a mobile application.

2) Content of the system users list, conditions for removal from the list of users, and the process for removal from the system user list

• The central information intermediary carries out the removal of a user upon the request of the E-Delivery Note system user or ex officio if it is discovered that the user no longer exists.

3) Use of the system, format and method of data entry into the system, minimum content of the e-Delivery Note necessary for its processing within the system

• Some of the mandatory elements of the e-Delivery Note include: indication of whether the e-Delivery Note is internal or external, e-Delivery Note number, issuance date, date and time of the commencement of goods movement, planned date and time for completion of dispatch, details about the sender and recipient of the e-Delivery Note, information about the goods being dispatched, destination address, method of dispatch, transport means details, and the unique identification number.
• The system automatically assigns a unique identification number to the e-Delivery Note upon its creation.
• An e-Delivery Note sent for the registration of the movement of excise goods includes the name of the excise category.
• In addition to the mandatory elements, the e-Delivery Note may include, for example, information significant to the sender, or supporting documentation relevant to the issuer may be attached to the e-Delivery Note.

4) Method and procedure for sending, canceling, and receiving the e-Delivery Note

• The sender of the e-Delivery Note creates, sends, or cancels the e-Delivery Note, and it is assigned the status of sent/canceled.
• The sender is allowed to cancel an e-Delivery Note until the recipient confirms the physical receipt of the goods.
• The technical statuses of the e-Delivery Note are – draft, in sending, and incorrect, while a sent e-Delivery Note has the status – received.
• The recipient of the e-Delivery Note assigns it the status of physical receipt by performing an action in the system, after which the recipient can create an e-Receipt.
• The e-Receipt contains the e-Receipt number, the arrived quantity, and the received quantity of each individual item listed in the e-Delivery Note.
• After sending, the e-Receipt has the status of sent, and it can be canceled until the recipient performs the action of accepting the e-Receipt.
• The recipient of the e-Receipt assigns the status of accepted or rejected to the e-Receipt through an action in the system.The e-Receipt can also have one of the technical statuses.
• In a technical status, the e-Delivery Note/Receipt is not considered sent or received.

The Rulebook regulates, among other things, the handling of the e-Delivery Note in paper form, the presentation of e-Delivery Notes within the inspection oversight process, the storage of e-Delivery Notes and e-Receipts, and the procedures followed by the central information intermediary.

DEMO Version of the e-Delivery Note System

The first version of the e-Delivery Note System is available in the DEMO environment for all future users and the interested public.

Access to the DEMO environment can be made through the DEMO version of SEF or directly via the following address: https://demoeotpremnica.mfin.gov.rs.

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.