The National Assembly of the Republic of Serbia adopted the Law on Amendments to the Law on Electronic Delivery Notes (the Law). The Law was published on 4 December 2025 in the Official Gazette of the Republic of Serbia No. 109/2024.
The Law enters into force on 12 December 2025, and shall apply as of 1 January 2026, except for the provisions related to electronic delivery notes in paper form, which will apply as of 1 April 2026.
The most important changes are presented below.
Obligation to send an electronic delivery note
Amendments to the Law stipulate that there is no obligation to send an electronic delivery note for:
- Refueling and lubricating of aircraft when the place of dispatch and the place of receipt are the same airport.
- The movement of goods where the goods or part of the goods are returned by the same means of transport immediately after delivery, provided that the recipient of the electronic delivery note has sent an electronic receipt note specifying the goods being returned.
- The movement of goods based on approved clinical trials of medicines or medical devices, in accordance with regulations governing medicines or medical devices.
Delayed verification of accuracy data in sent electronic delivery notes and electronic receipt notes
It is prescribed that in the period from 1 January 2026 until 30 June 2026, the Ministry of Finance will not take into account errors in the data reported in submitted electronic delivery notes and electronic receipt notes.
Users of the electronic delivery note system
It is prescribed that the system is also used by a public sector entity, as a contracting party to a framework agreement (in accordance with public procurement regulations), for receiving, storing, and reviewing electronic delivery notes and electronic receipt notes created in connection with the execution of such agreements.
Electronic delivery notes in paper form
In the case of issuing an electronic delivery note in paper form, due to a temporary disruption of the connection with the system, the sender of the electronic delivery note is required to print three copies of the electronic delivery note in paper form, retaining one copy for themselves and handing over two copies to the carrier or transport operator.
It is additionally prescribed that the recipient of the electronic delivery note in paper form is required to send an electronic receipt note within the deadline prescribed by this law, or on the first following working day after the connection with the system has been re-established, if they were unable to do so within the prescribed deadline due to a disruption in the connection.
Amendments to the Law on Electronic Delivery Notes adopted
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