Serbia is introducing mandatory e-invoicing from January 2022. This is primarily based on law no. 44/2021 passed on 29th April 2021. As early as May 2022, public sector entities will need to start implementing solutions so suppliers can send e-invoices to public sector customers (B2G). The Serbian ministry of finance has already provided a demo environment for this. Find out more below.
This post is an update to our blog article of 7th July 2021, Compulsory E-Invoicing for B2G and B2B Transactions in Serbia from 2022.
The Serbian e-invoicing system
The Serbian name for their national e-invoicing system is Sistem E-Faktura, generally shortened to SEF (www.efaktura.gov.rs). SEF is an IT solution provided by the Serbian state – to be exact the Ministry of Finance – for sending, receiving, capturing, processing and storing electronic invoices. The Sistem E-Faktura is a portal which the Serbian Law on Electronic Invoicing has made mandatory for the public and private sectors.
In introducing the SEF, a clearance e-invoicing model with similarities to the SdI invoice exchange system used in Italy since 2019, Serbia is in line with the general global trend towards Continuous Transaction Controls (CTC). This means that e-invoices have to be transmitted and pre-audited over a platform regulated by the tax authorities.
The Serbian e-invoicing system, as described elsewhere on our blog, will be made mandatory in three stages.
- From 1st May 2022 all public and private invoice issuers will be legally required to send their invoices to public authorities as an e-invoice. (B2G and G2G).
- From 1st July 2022, government agencies will be required to send electronic invoices to private sector businesses (G2B). These which will need to be able to receive and process electronic invoices.
- From 1st January 2023, these rules will apply to all transactions between private sector companies (B2B).
Who is required to adopt e-invoicing?
The following are affected by the legal e-invoicing requirement
- Transactions between government bodies (G2G),
- Private companies invoicing public authorities (B2G),
- Public authorities invoicing private companies (G2B),
- Transactions between private companies (B2B) and
- Transactions with the private and public bodies by tax representatives for foreign companies within the Republic of Serbia as per VAT law.
VAT-exempt entities are not legally obliged to use SEF. However, they may voluntarily sign up to it. Voluntary SEF users are also obliged to receive, send and save invoices in the same way as entities liable to Serbian VAT.
Cross Border Invoices do not need to be entered into SEF if these have been issued by a VAT-exempt entity. This of course doesn’t apply if these have voluntarily signed up to SEF.
E-Invoice archiving regulations in Serbia
Any electronic invoice issued or received by a public entity, such as a government agency, is permanently stored in the Serbian electronic invoicing system (SEF).
An electronic invoice issued or received by a private company is stored for ten years after the end of the year in which the electronic invoice was issued. The invoice may be stored in either an electronic invoicing system or in an information exchange system used by the private company for this purpose.
- Before a user can send and receive invoices over the e-invoicing system, they need to be on-boarded.
Onboarding process for issuing e-invoices
In order to use the Serbian e-Invoicing system, the taxpayer first needs to register through a special portal accessible through www.eid.gov.rs. There, a distinction is made between Serbian and foreign citizens. In order to register, you need a user name, password and a copy of your passport.
Another option is to register to SEF with a qualified digital certificate. This can be applied for via the Serbian electronic identification portal at
- https://www.eid.gov.rs/sr-Cyrl-RS/registracija-kvalifikovanim-elektronskim-sertifikatom or
This certificate needs to be correctly installed before you can use it to exchange e-invoices via SEF. The software required is available on the certification website.
Onboarding process for receiving e-invoices
In order to support the recipients of the e-invoices, the Serbian Information Technology and Electronic Administration Office has introduced a type of invoice management system, Sistem za Upravljanje Fakturama (SUF). This system helps users manage the e-invoices they receive by letting them receive, store, approve and prepare e-invoices to be entered into their bookkeeping system. The licensed software is available to an unlimited number of system users and is based on the company’s internal accounting software KJS.
You can find all the information you need on using SUF free of charge on the sites below:
These pages contain comprehensive information on the onboarding process for SUF . Users can also send a written request for a SUF training course, and are allocated a date within a few days.
SUF currently exists in both a demo and a productive environment. You log on to the demo environment with a user name and password.
In order to log on to the productive version of SUF, you either need a qualified digital certificate, or to activate two-factor authentication (2FA). The advantage of using two-factor authentication is that users do not need a digital certificate. Instead, SUF provides them with an app to install on a mobile device such as a cell phone or tablet.
Once registered, a user can log in on https://suf.gov.rs/login/. This page is available in various languages.
Users need to successfully complete the onboarding process before they can start e-invoicing. And Serbian e-invoicing is not the easiest system.
Serbia uses a complex e-invoicing standard
The Serbian tax authorities have issued a set of rules on what an e-invoice must contain as a minimum. These rules are based on the EU e-invoice standard EN 16931-1. Serbian e-invoices need to be issued in an XML format and comply with UBL 2.1 Standard (Syntax Universal Business Language). To this end, the Serbian tax authorities published an updated specification on 27th September 2021 on their government platform to enable user-defined application of the EU norm EN 16931-1. This also includes details of a Core Invoice Usage Specification (CIUS) aligned to the SRPS EN 16931-1: 2019 / A2: 2020 standard.
There are a number of fields to fill out on an electronic invoice. These include seller and buyer details, product details for goods, detailed VAT information, payment instructions, and more.
Each invoice is assigned a code by type:
- 380 refers to a standard invoice,
- 384 refers to an amended invoice,
- 386 refers to a pre-payment invoice,
- 381 and 383 refer to extremely specific non-standard scenarios.
There is a further coding system for VAT categories, including
- ‘S’ for standard rate,
- ‘AE’ for reverse charge billing
- ‘E’ for VAT-exempt.
Methods used to create, send and receive Serbian e-invoices
Methods used in sending invoices
The methods available for issuing an e-invoice are aimed at both users sending a large number of invoices and occasional issuers or companies without the IT infrastructure needed to issue e-invoices.
- It is recommended that companies issuing several invoices send these through a dedicated application programming interface (API).
Companies with a high number of outgoing invoices can send them directly from their ERP system via a dedicated API provided by the Serbian Tax Agency.
Tax authorities worldwide have been increasingly providing APIs to integrate with their government systems. Examples include India‘s Invoice Registration Portal (IRP), Poland‘s Krajowego Systemu e-faktur (KSeF) and Serbia‘s Sistem E-Faktura.
The Serbian E-Invoicing-API is a REST API which employs several methods to let users communicate with the governmental systems. An invoice is issued using an http POST request. The user then receives a JSON response containing a unique invoice identifier (SalesInvoiceId). Users enable the API by applying for and receiving a dedicated identification key through the e-invoice portal www.efaktura.gov.rs.
- If you only send a few Serbian invoices per year, you can save on complex system integration and enter these manually to SEF.
Taxpayers with a relatively small number of invoices or without the right technical set-up for automated transmission can enter invoices manually into the Serbian e-invoicing portal.
Methods for receiving e-invoices
As above, there are different options for receiving Serbian e-invoices depending on your needs.
- It is recommended that companies with a large volume of incoming invoices use a dedicated application programming interface (API).
Companies with a high volume of incoming invoices can have these delivered straight to their ERP system through a dedicated API provided by the Serbian tax authorities, just as for outgoing invoices.
Alternatively, you can use the Sistem za Upravljanje Fakturama (SUF) free of charge to receive invoices.
- It is recommended that companies with a small volume of incoming invoices use SUF.
The SUF invoice management system builds on the SEF with extra additional functions for receiving invoices. SUF is a web platform accessible through www.suf.gov.rs. There is no installation required. Incoming invoices are automatically received in the SUF via the e-invoice portal (SEF). This means that the user doesn’t need their own connection between the two platforms to use SUF.
SUF supports invoice recipients in receiving, archiving (for the legal archiving period), PDF visualisations, approving and preparing the invoice to enter into a bookkeeping system.
Start preparing now for Serbian e-invoicing
Companies that do not need to start dealing with e-invoices until July 2022 (G2B) or January 2023 (B2B) should take steps now to implement e-invoicing. The reason for this is that there is not much information about Serbian e-invoicing in English. The Serbian tax authorities have published detailed technical instructions, including as films. However, these instructions are only available in Serbian. This could be a challenge for multinational corporations. Many functions such as IT or tax compliance are centralized, meaning that e-invoicing may well be managed by non-local staff. Furthermore, alongside Serbia‘s complex e-invoicing standard, a company also needs to get to grips with modern API technology to successfully automate sending their invoices.
The SEEBURGER BIS e-invoicing solution lets you integrate any ERP system and automate the processing of both your incoming and outgoing invoices. We have the tools and knowledge to ensure your API integration and API management is transparent and secure. An established provider of global e-invoicing solutions, we also have the experience to help you comply with EU-wide and international e-invoicing regulations.
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Written by: Andreas KillingerAndreas Killinger joined SEEBURGER in 2014 and is a product manager, responsible for EDI services and software applications. He specialises in SAP solutions, as well as electronic invoicing (e-invoicing) for globally active customers. Following an apprenticeship as an industrial mechanic and a degree in law and administration, he had various roles in the public sector. He then worked for IBM as an SAP Senior Consultant and SAP Project Manager in international SAP projects from 1999 to 2013. Born in Berlin, Andreas has lived in the Black Forest since childhood, and loves the area all year round, whether mountain biking or skiing. He enjoys exploring the Rhine and the many lakes in the area on his yacht. He lives with his family and his dog in a former inn from 1749, which he has been lovingly renovating over the past couple of years.