E-Invoicing in Serbia (SEF) 2026: Who Must, Rules & Penalties
If you run a Serbian company that is VAT-registered or deals with the public sector, paper invoices and emailed PDFs are no longer valid in B2B and B2G trade. Serbia mandates electronic invoicing through the SEF (Sistem elektronskih faktura — the System of Electronic Invoices), a central government platform for issuing, sending and receiving invoices in a structured electronic format. In 2026 the scope widens further with e-delivery notes and tighter VAT-recording rules.
This guide explains who must use SEF, how an e-invoice is issued, what changes during 2026, how it affects flat-rate sole traders (paušalac), and the penalties for non-compliance.
What SEF is and why it exists
SEF is an information system run by the Ministry of Finance. An e-invoice passes through it as a structured XML document that the system can read, record and reconcile against tax filings automatically. The state’s goal is straightforward: less paper, less grey economy, and real-time VAT control — the Tax Administration effectively sees transactions as they happen.
For a company this means an invoice is no longer just a document you draft — it must pass through SEF to be valid in trade with other obligors and with the public sector.
Who is obliged to use e-invoices
The obligation to issue and receive e-invoices via SEF applies primarily to:
- public-sector entities (state bodies, public enterprises, schools, institutions) — both issue and receive;
- VAT payers (companies and sole traders in the VAT system) — in mutual trade and with the public sector;
- voluntary users — those not obliged who register themselves.
If you are weighing VAT registration, see our guide on VAT in Serbia for foreign companies — registration brings the e-invoicing obligation with it.
What about flat-rate sole traders (paušalac)?
A paušalac is generally not obliged, because they are outside the VAT system. But there is an important exception: when a paušalac invoices a public-sector entity, they must register on SEF, because public bodies may only receive invoices electronically. Once a paušalac registers (voluntarily or because of the public sector), they become a voluntary user and must then send all invoices through SEF — for the current and the following calendar year. This catches many IT and consulting sole traders working for universities, institutes or local government. More on the regime in our flat-rate vs company guide.
How an e-invoice is issued
In practice an e-invoice is created in one of three ways:
- Directly on the portal
efaktura.gov.rs— manual entry, fine for low invoice volumes. - Through accounting/ERP software connected to SEF via API — automated, for higher volumes.
- Via an information intermediary offering a SEF-connected platform.
Whichever route, the e-invoice must contain the prescribed mandatory elements (issuer and recipient data, tax ID / company number, description of supply, VAT data). If an element is missing, the system rejects it. We handle issuing and recording e-invoices as part of accounting services, so deadlines and format are never missed.
What changes in 2026
The law was amended during 2025, with the key changes taking effect in 2026:
| Change | From | What it means |
|---|---|---|
| E-delivery notes (phase 1) | 1 Jan 2026 | electronic recording of goods movement — first for the public sector and excise goods |
| Tolerance period | 1 Jan – 30 Jun 2026 | data errors in e-delivery/e-receipt notes are not penalised in this window |
| New VAT-recording rules | April 2026 | more precise recording of advances, corrections and specific cases |
| E-delivery notes (phase 2) | 1 Oct 2027 | broader coverage of the private sector |
An e-delivery note is an electronic document tracking goods from sender to recipient — the same data as the old paper delivery note, exchanged through a central system. A new mobile app, MAKS, is introduced for system users. If you trade in goods (retail, distribution), this is not something to skip in 2026. If you supply services only, it does not apply to you — but e-invoicing does.
Penalties
Non-compliance is taken seriously. Fines for e-invoicing breaches are:
- legal entities: RSD 200,000 to 2,000,000,
- sole traders: RSD 50,000 to 500,000.
Because the system is automated and the Tax Administration sees mismatches, “I won’t report it” is no longer an option — a missing or unaccepted e-invoice surfaces quickly.
Frequently asked questions
Is an emailed PDF still a valid invoice? In trade with VAT payers and the public sector — no. Only an e-invoice issued through SEF in the prescribed format is valid. A PDF can serve as an informational copy but does not replace the e-invoice.
Do I need special software?
Not necessarily. For a small number of invoices the free efaktura.gov.rs portal is enough. For higher volumes, SEF-connected software saves time and reduces errors.
I’m a paušalac working only with private firms and individuals — am I obliged? Generally no. The obligation arises only if you invoice the public sector or register on SEF yourself.
Do e-delivery notes apply to services? No — they relate to the movement of goods. Service-only businesses are unaffected by e-delivery notes (but not by e-invoicing).
How we help
We register you on SEF, set up e-invoice issuance, connect it to your VAT records and track the 2026 rule changes — including e-delivery notes if you trade in goods. Contact us and we’ll take the paperwork off your plate.
Note: this article is informational and current as of June 2026. Verify the exact scope, deadlines and format on the eFaktura portal or with an accountant.