e-Invoicing in Serbia: Timeline, Guidelines, Process and Steps for Implementation

Serbia has successfully implemented mandatory electronic invoicing, positioning itself as one of the pioneers in Europe to transition away from paper invoices fully. The Serbian Ministry of Finance is the governing authority responsible for implementing and managing e-invoicing through the national platform called eFaktura (SEF—Sistem Elektronskih Faktura). 

The system uses UBL 2.1 XML format and follows a central clearance model, providing benefits like reduced tax fraud and improved administrative efficiency. This blog explores the timeline, process, and compliance requirements for businesses operating in Serbia.

What is e-Invoicing in Serbia?

e-Invoicing in Serbia refers to the electronic issuance, transmission, and receipt of invoices through the government's centralized platform eFaktura (SEF). According to the Law on Electronic Invoicing (RS 44/2021, 129/2021), an electronic invoice is defined as "an invoice in electronic format containing all the information required by law, which is signed with a qualified electronic signature and/or delivered through a secure electronic channel.

The system operates on a central clearance model where all e-invoices must be processed through the SEF platform to be considered legally valid and compliant documents.

e-Invoice Implementation Timeline

Serbia implemented e-invoicing in three strategic phases:

• May 1, 2022: All suppliers to public sector entities (B2G) must send invoices electronically, and government entities must be able to receive and store them.
• July 1, 2022: Serbian public entities are obligated to send electronic invoices to companies (G2B), which must be able to receive and process them.
• January 1, 2023: e-Invoicing became mandatory for the entire B2B sector, completing the nationwide implementation.

Recent developments include amendments to the e-invoicing law passed by the National Assembly on November 27, 2024, which will come into effect on December 15, 2024, with full application starting January 1, 2025.

e-Invoicing Process in Serbia

The e-invoicing process in Serbia follows these steps:

1. Registration: Businesses must register on the eFaktura portal using a qualified electronic signature.
2. Invoice Creation: Companies can generate e-invoices either:
   • Manually through the eFaktura portal
   • Directly from their ERP systems using the API provided by Serbian tax authorities
3. Validation: The eFaktura platform validates the documents before they are transmitted to recipients.
4. Electronic Signing: All e-invoices must be signed with a qualified electronic signature.
5. Transmission: The validated and signed invoice is sent to the recipient through the eFaktura system.
6. Archiving: Businesses must store e-invoices for 10 years from the end of the year in which the invoice was issued.

e-Invoicing Compliance Guidelines

To comply with Serbian e-invoicing regulations, businesses must:

• Use XML format in accordance with UBL 2.1 standard and comply with CIUS specifications outlined in the EU's EN 16931 standard.
• Include all mandatory information in the invoice:
  • Unique Invoice Number
  • Supplier's name, address, and Taxpayer's Identification Number (TIN)
  • Recipient's name, address, and TIN
  • Applied tax rate
  • Amount of VAT
• Ensure authenticity of origin and integrity of content through proper formatting and storage.
• Non-compliance penalties can reach up to 2 million Serbian dinars (approximately €17,000).

Types of e-Invoices in Serbia

Serbia's e-invoicing system supports several transaction types:

• B2G (Business to Government): Invoices from private businesses to public entities
• G2B (Government to Business): Invoices from public entities to private businesses
• B2B (Business to Business): Invoices between private sector entities
• Invoice Messages: Standard invoices and credit notes

e-Invoicing Model and Framework

Serbia employs a centralized e-invoicing model:

• Central Clearance Model: All e-invoices must pass through the eFaktura (SEF) platform, which authenticates, validates, and stores tax data.
• Standards: The system is based on the Serbian electronic invoicing standard (SRBEFN), derived from the European e-invoicing standard, and also supports Peppol BIS 3.0.
• Access Options: Businesses can connect directly or use authorized information intermediaries certified by the government.
• Attachments: The system allows attaching up to three PDF documents (such as purchase orders or contracts) with a total size of up to 75 MB.

Who Needs to Comply with e-Invoicing in Serbia?

The following entities must comply with Serbian e-invoicing regulations:

• All VAT-liable companies that conduct business in Serbia7
• Both domestic companies and foreign businesses with local fiscal representatives712
• Public sector entities

Exemptions include: Flat-rate taxpayers who are not VAT-liable and are not public sector suppliers, though they may use e-invoicing voluntarily.

Benefits of e-Invoicing in Serbia

Implementing e-invoicing in Serbia offers numerous advantages:

• Reduced Tax Fraud: Enhanced transparency and real-time monitoring help combat tax evasion.
• Streamlined Processes: Automation of invoice processing reduces administrative burden.
• Improved Efficiency: Faster processing and reduced errors in invoice management.
• Digital Transformation: Serves as a foundation for broader administrative digitalization.
• Cost Reduction: Eliminates expenses related to paper, printing, and physical storage.
• Enhanced Data Accuracy: Reduces manual errors in invoice processing.
• Environmental Impact: Reduces paper consumption and carbon footprint.

How can ClearTax help a business with e-Invoicing in Serbia?

ClearTax offers comprehensive e-invoicing solutions for businesses operating in Serbia:

• System Integration: Seamless connection between your existing ERP systems and the Serbian eFaktura platform
• Validation & Data Enrichment: Automatic validation of invoices against Serbian compliance requirements
• Cloud-Based Portal: Centralized dashboard for tracking, management, and reconciliation
• Automated E-Invoice Generation: Streamlined creation and submission of compliant e-invoices
• Vendor & Buyer Data Management: Simplified management of trading partner information
• Error Alerts: Immediate notifications for compliance issues or validation errors
• Compliance Automation: Up-to-date adaptations to changing regulations
• Comprehensive Reporting: Detailed analytics and tracking of all e-invoicing activities

Government References for e-invoice Serbia

Conclusion

Serbia has successfully implemented a comprehensive e-invoicing system that is now mandatory for all B2B, B2G, and G2B transactions. With its phased approach completed in January 2023, businesses operating in Serbia must comply with the requirements or face significant penalties.

For businesses still adapting to this digital transformation, it's essential to:

• Ensure your systems are compatible with the UBL 2.1 XML format
• Register on the eFaktura platform with a qualified electronic signature
• Implement proper archiving procedures for the required 10-year retention period
• Consider working with a solution provider like ClearTax to streamline compliance

With upcoming amendments taking effect in January 2025, businesses should stay informed about evolving requirements and ensure their e-invoicing processes remain compliant. Early adoption and proper implementation will not only ensure legal compliance but also deliver significant efficiency and cost benefits.