The Law on register of administrative procedures (Official Gazette of RS no. 44/2021) (“the Law“) introduces the Register of administrative procedures (“the Register“) which represents a publicly available electronic database of all administrative procedures conducted in the Republic of Serbia.

The Register is not intended for registering data on particular procedures instituted upon client’s request or ex officio (such as e.g. Portals of courts or eCourt), it will rather contain general information on the type of procedure and it will provide interested parties with information related to exercising of their rights or fulfilment of their obligations, to learn what documents they will need, how long the procedure will last, the amount of fees, as well as other elements of relevance for a particular procedure.

The Register is established and managed by the Republic Secretariat for Public Policies along with the Office for Information Technologies and Electronic Administration. The Register is to include all administrative procedures for economic entities and citizens no later than 1 January 2025.

What administrative procedures does the Law apply to?  

Administrative procedures imply administrative and other procedures conducted by state bodies and organisations, bodies and organisations of autonomous provinces and bodies and organisations of local self-government, institutions, public companies, special bodies that regulatory function is realised through, as well as legal and natural persons entrusted with public authorities.

The procedures include the issuance of licences, permits, approvals, consents, decisions, certificates, reports, opinions, information, terms, declarations, records, personal and other documents, as well as excerpts from official records.

In terms of this law, administrative procedure does not imply court procedures and procedures implemented by holders of public offices entrusted by courts, procedures arising from employment in a body, as well as procedures instituted upon request of a body and conducted by another body.

Who needs to register and what are the deadlines for acting?

Entity obliged to register/update information in the Register is a body in charge of preparing draft or proposal regulation when proposer is not the Government and which regulates the procedure.

What information does the Register contain?

The law prescribes that the Register shall, among other, contain:

• Name and registration number of the procedure,
• Name of entity obliged to enter the procedure in the Register,
• Name of body in charge of implementing the procedure and the person responsible for information entered in the Register,
• Name of specific organisational unit in charge of implementing the procedure,
• Level of authority that the procedure is implemented on (republic, autonomous province, local),
• Information whether the procedure refers to economy, citizens or mixed procedure,
• Purpose and description of procedure,
• Manner of institution of procedure and place for submission of application,
• Frequency of procedure (one-time or periodical),
• Prescribed penalty i.e. legal consequence for failure to act in a prescribed deadline,
• Form of application and information obtained by a body ex officio,
• The amount of fees, compensation and other financial expenditures and information for their payment,
• Legal deadline for acting by a body,
• Instruction on legal remedy.

Is there a penalty for failure to act according to the Law and who supervises the implementation of the law?

If an entity obliged to register fails to act in accordance with the stated obligations, the Law stipulates misdemeanour and fine ranging from RSD 20,000.00 to 100,000.00 for a responsible person.

Supervision over the implementation of the law is conducted by the ministry in charge of public administration, through administrative inspection.

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.