Serbia e-Invoicing 2022


More and more tax countries, not only those in the EU, are requiring electronic filing. It is important to note current changes in the e-invoicing industries in the United States, the Kingdom of Saudi Arabia, and Egypt. Serbia will begin requiring e-invoicing as of May 2022 as the newest nation to do so. It will be used in the public sector during the first phase.

Serbia e-invoicing

Legal Background of Serbia e-Invoicing

The Serbian Parliament adopted the Law on Electronic Invoicing as published in the Official Gazette of the Republic of Serbia no. 44/2021 dated 29 April 2021.

Entry into force and start of application

The Law went into force on 7 May 2021.

Start of application of the Law has been postponed and specifically regulated for public sector entities (general state level and public enterprises) and private sector entities (other VAT payers).

Start of application of the Law for public sector entities is as follows:

  • Obligation for issuing electronic invoices to other public sector entities – 1 January 2022;
  • Obligation of receipt and storage of electronic invoices issued according to the Law – 1 January 2022;
  • Obligation of electronic recording of VAT calculation in the electronic invoices system – 1 January 2022;
  • Obligation for issuing electronic invoices to private sector entities – 1 July 2022.

Start of application of the Law for private sector entities is as follows:

  • Obligation for issuing electronic invoices to public sector entities – 1 January 2022;
  • Obligation of receipt and storage of electronic invoices issued according to the Law – 1 July 2022;
  • Obligation for issuing electronic invoices to private sector entities and performance of other obligations in accordance with the Law – 1 January 2023.

Act No. 44/2021, which took effect on April 29, 2021, is the primary legal justification for the introduction of electronic invoicing in Serbia. These laws cover both the content and the issue, distribution, reception, processing, and storage of electronic invoices. Additionally, it offers a foundation for the electronic billing system, which will be overseen by the Serbian government.

The implementation of mandatory e-invoicing in Serbia will take place in the following phases:

  • From May 2022, a public sector institution will be required to accept and maintain any electronic invoices that are issued, as well as to send an electronic invoice to another public sector company.
  • Beginning on July 1, 2022, public sector organisations will be required to send electronic invoices to private sector organisations.
  • Starting in May 2022, a private sector business must send a public sector entity an electronic invoice.
  • Beginning on July 1, 2022, a private sector business will be required to accept and retain both electronic invoices issued by a public sector organisation and those issued by a private sector entity.
  • Beginning on January 1, 2023, all transactions involving private sector firms shall be subject to the requirement to issue and maintain electronic invoices.
  • Penalties of up to 2 million Serbian dinars may be imposed for failure to comply with the electronic invoicing requirement (around 17,000 euros).

Technical statement

The Serbian e-invoicing system operates essentially in accordance with the so-called clearing model, which is already in use in countries like Italy (SdI). This indicates that the tax authorities’ interface is used for the transmission and first confirmation of electronic invoices. Serbia’s national electronic invoicing
system is known as the Sistem E-Faktura ( In addition, the Sistem za Upravljanje Fakturama (SUF), which is accessible at and, has been introduced as an auxiliary system to assist taxpayers with the processing and storage of invoices.

The specialised portal, which can be accessed at, requires registration before a taxpayer can begin utilising the electronic invoicing system. Authentication using a certified electronic certificate is required for

Serbian Sistem e-faktur

Serbian electronic invoices can be created, sent, and received primarily in one
of two ways:

1) Manually via the e-invoicing website

2) Directly from the ERP system of the taxpayer utilising an application programming interface (API) supplied by the Serbian tax authorities, such as SAP.

The manual alternative could be preferable for small taxpayers who don’t submit many invoices. However, there is no practical alternative to linking their ERP to the national electronic invoicing system through an API for medium-sized and big taxpayers, who are likely to have complete ERP systems.

Serbia einvoice API

REST API, which provides a variety of techniques for facilitating contact with the government’s system, is the format used by the Serbian e-invoicing API. For instance, utilising the “POST” method is required when submitting an invoice. Upon successful completion of this, the taxpayer receives a JSON response with a special invoice identity (salesInvoiceId key). Taxpayers must activate the API and create a unique identification key in order to utilise it.

Serbian electronic invoices must be issued in XML format, which is a requirement for the majority of e-tax systems. Serbian XML e-invoices must follow UBL 2.1 specifications Standard. Purchase orders, invoices, and logistics papers are only a few examples of the standardised XML business documents known as UBL (universal business language). The OASIS Open group is responsible for maintaining the UBL standard.

Serbian e-invoices have demanding content. The XML file must contain hundreds of fields, including information on the seller and the customer, product information about the items, comprehensive VAT information, payment
instructions, and more.

Additionally, each document must include an unique code designating the kind of invoice it represents. For instance, the numbers 380, 384, and 386 denote normal invoices, correction invoices, and advance payment invoices, respectively. Two additional codes are present: 381 and 383, which denote
extremely unique non-standard conditions.

For VAT categories, a unique vocabulary of codes is introduced (the TaxCategory field). For instance, the letters “S” and “AE” stand for standard rate, reverse-charge settlement, and are exempt from VAT, respectively.

High time to start implementation of e-Invoicing

Public sector organisations need to start putting technologies in place now that will allow e-invoice transmission starting in May 2022. The Serbian Ministry of Finance already offers a test environment where taxpayers may verify their systems.

However, businesses who must begin utilising electronic invoices as of July 2022 (G2B) or January 2023 (B2B) should start making preparations immediately. Given how little information there is regarding Serbian
e-invoicing in English, this is very significant. The Serbian tax authorities have released thorough technical guidelines and even instructional videos. All of the materials, though, are in Serbian. For international firms, where many tasks, like IT or tax compliance, are centralised and e-invoicing is frequently controlled by non-local staff, that might be an extra problem

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