Serbia Adopts Key Amendments to Electronic Invoicing and VAT Laws in 2026

On January 12, 2026, Serbia officially adopted significant amendments to its Law on Electronic Invoicing and the Law on VAT. Published in the Official Gazette No. 109/2025, these changes introduce new obligations for retail transactions involving corporate cards, mandate internal invoicing within the SEF system, and postpone the rollout of pre-filled VAT returns.

Expanded E-Invoicing Obligations for Retail

The recent amendments clarify and expand the scope of mandatory electronic invoicing, particularly regarding retail sectors. A key change involves the interaction between fiscalization and e-invoicing.

Retail Sales to Corporate Cardholders

Under the new regulations, there is now an explicit obligation to issue an electronic invoice for retail sales made to corporate cardholders. This requirement encompasses any advance payments received for such sales. Crucially, the legislation specifies the timing: the e-invoice must be issued after the fiscal receipt has been generated in accordance with fiscalization laws.

Public Sector Transactions

Similarly, for retail sales made to public sector entities, an e-invoice is mandatory if the public entity requests it. This request must be initiated by the public sector entity, typically within the standard 7-day period following the transaction, as per the clarified interaction between the Law on Fiscalization and the Law on Electronic Invoicing.

Postponement of Pre-filled VAT Returns

In a move to provide taxpayers with more preparation time, the implementation of pre-filled VAT returns has been rescheduled. Originally set for the January 2026 tax period, the start date has been pushed back.

The pre-filled VAT return system will now apply to tax periods beginning after December 31, 2026. Consequently, the first tax period to be affected will be January 2027.

Changes to VAT Law and SEF Integration

A significant new requirement introduces the obligation for internal invoices to be generated directly within the SEF system. This applies specifically to taxpayers who are existing users of the SEF platform, ensuring that internal accounting documents are centralized and traceable within the national infrastructure.

Businesses must prepare for the upcoming applicability dates:

• April 1, 2026: Most provisions, including the new e-invoicing requirements for retail and the mandatory internal invoicing in SEF, will become applicable for tax periods starting after March 31, 2026.
• Immediate Effect: The provisions regarding the postponement of pre-filled VAT returns are effective immediately upon the law's entry into force.

There’s more you should know about e-invoicing in Serbia – learn more about the new and upcoming regulations.