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SEF e-invoicing in Serbia: a guide for foreign-owned companies

Every VAT payer in Serbia must use SEF, the state e-invoicing system. A VAT payer receives e-invoices in SEF since , and it issues e-invoices to other VAT payers since . A company outside the VAT system has no such duty, but it joins SEF before it sends an invoice to a public sector body.

Last reviewed on

Key facts

TopicRuleLegal basis or source
Who must use SEFEvery VAT payerLaw on Electronic Invoicing (ZEF), Art. 5(1) and (2)
Receive and keep e-invoicesSince ZEF Art. 24(6)
Issue e-invoices to other VAT payersSince ZEF Art. 3(1)(1) and Art. 24(7)
Company outside the VAT systemJoins SEF before it sends a payment request to a public sector bodyZEF Art. 2(2)
Status in SEFWithin 5 days of the entry in the list of SEF users, and within 5 days of a change of VAT statusZEF Art. 3a
Accept or reject an e-invoiceWithin 15 days of receiptZEF Art. 10(1)
E-recording of VATBy the 12th day of the month after the tax periodZEF Art. 4 and Art. 4a
Storage10 years from the end of the year of issueZEF Art. 15(2) and (3)
VAT registrationAbove 8,000,000 RSD of turnover in 12 months, within 5 daysVAT Law, Art. 38(1)
Fines200,000 to 2,000,000 RSD for a company, 50,000 to 500,000 RSD for an entrepreneur, 50,000 to 150,000 RSD for the responsible personZEF Art. 18 and Art. 21

What is SEF?

SEF (Sistem elektronskih faktura) is the state system for e-invoices. The Ministry of Finance runs it, and the Ministry supervises the Law on Electronic Invoicing (Zakon o elektronskom fakturisanju, ZEF).

An e-invoice counts as delivered at the moment of issue. An e-invoice sent through SEF is an authentic document for enforcement.

Who must use SEF, and from when?

The law calls a VAT payer outside the public sector a "subjekt privatnog sektora". The duties started in phases:

  • Since , a VAT payer issues e-invoices to a public sector body.
  • Since , a VAT payer receives and keeps e-invoices.
  • Since , a VAT payer issues e-invoices to other VAT payers, and it records in SEF the VAT that no e-invoice shows.
  • For the tax periods that start after , a VAT payer also records its input VAT in SEF.

The tax representative of a foreign person registered for VAT issues e-invoices too. A company outside the VAT system can join SEF as a voluntary user. It must then use SEF in the current and the next calendar year.

Which sales need no e-invoice?

A retail sale with a fiscal receipt needs no e-invoice. The same applies to a supply without consideration, some defence procurement, some electricity supplies, a fee that is public revenue without VAT, and court costs. A retail sale still needs an e-invoice when the buyer holds a corporate card. The same applies when a public sector body asks for one within 7 days.

When does a new company start in SEF?

A company can register in SEF only when it has a PIB (tax number). APR, the Serbian Business Registers Agency, issues the PIB when it registers the company.

A company with a turnover above 8,000,000 RSD in 12 months applies for VAT registration within 5 days. A smaller company can choose to register. A new company can apply on the APR founding form, with an estimated turnover of at least 8,000,001 RSD.

When a company becomes a VAT payer, SEF registers it automatically, unless the company registered before. The company is a SEF user from the day of that registration.

Within 5 days of its entry in the list of SEF users, the company states in SEF its VAT status and its tax period. After a change of VAT status, it updates the status within 5 days.

How does a company register in SEF?

Only the legal representative of the company, the director, can make the first registration. These are the steps:

  1. Open an account on the Portal for Electronic Identification (eID), and sign in with a qualified electronic certificate or the ConsentID mobile app.
  2. Register the company in SEF with its company registration number (matični broj).
  3. Choose how the company works in SEF. It can work through named users, through its accounting software, or through one information intermediary that the Ministry of Finance approved.

What happens to an incoming e-invoice?

The company accepts or rejects each incoming e-invoice within 15 days of receipt. If a VAT payer does not answer, SEF notifies it again. After 5 more days, the e-invoice counts as rejected, and the company can still accept it later.

The company keeps its e-invoices for 10 years from the end of the year of issue. To check whether a buyer uses SEF, search the public list of SEF users by PIB.

What is the e-recording of VAT?

The e-recording of VAT (elektronska evidencija PDV) covers the VAT that no e-invoice shows. Each record is due by the 12th day of the month after the tax period. These are the records:

  • VAT calculation, summary. The totals per tax rate for the VAT that no issued e-invoice shows (Art. 4(1) to (3)).
  • VAT calculation, one by one. The reverse charge where the buyer is the tax debtor, and the first transfer of new buildings. Also the sales to entrepreneurs and companies outside the VAT system, except retail sales with a fiscal receipt and the special schemes (Art. 4(4) and (5)).
  • Input VAT, summary. Every VAT payer makes it, also when it cannot deduct the VAT (Art. 4a).
  • Purchases from farmers outside the VAT system. The buyer records them from (Art. 4b).

A correction before supervision starts is not an offence. SEF also prepares a preliminary VAT return from its own data.

Can a foreign supplier send an e-invoice?

Yes. A foreign issuer can send an e-invoice under the European standard EN 16931 directly to a Serbian public sector body. Any other recipient can accept it through an information intermediary.

What are the fines?

The Law on Electronic Invoicing sets one range of fines. It applies when a company issues no e-invoice where one is due, or does not set or update its status in SEF. It also applies to a missing VAT record, to a company that does not use SEF, and to a misuse of SEF data. The same fines apply when the company does not give the inspector access to its data, documents and equipment. The fine is 200,000 to 2,000,000 RSD for a company. The responsible person pays 50,000 to 150,000 RSD.

How RNDM handles this

Run your business

We arrange your e-invoices in SEF as part of Accounting and payroll, where your company is in the VAT system. Your director makes the first registration. Then a licensed accounting firm we work with issues and receives your e-invoices and keeps the e-recording of VAT. It accepts or rejects each incoming e-invoice on your approval. The incoming e-invoices also feed the list of due payments in Payments. For a link between SEF and your own systems, see Software and automation.

Our Run tier includes bookkeeping and tax returns, by a licensed accounting firm.

We handle this: see Accounting and payroll Contact usSee the tiers

Sources

This guide gives general information as of the date below. Your case may differ, so ask us before you act.
Last reviewed on . RNDM DOO is responsible for this page.

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