The amendments to the Law on Electronic Delivery Notes entered into force on 12 December 2025, following their publication in the Official Gazette of the Republic of Serbia No. 109/2025. With their adoption, the legal framework for the introduction of the electronic delivery note system has been further clarified, the mandatory application of which begins on 1 January 2026 for certain categories of entities.
What Preceded the Adoption of the Amendments to the Law on Electronic Delivery Notes
In our previous articles, we closely followed the process of adopting the Law on Electronic Delivery Notes (“Law”), from the publication of the draft Law and the opening of the public consultation, through to its adoption (link). We are now in the phase preceding the start of its application.
As the deadline for the start of application of the new system approached — specifically, 1 January 2026 for certain categories of entities, the Ministry of Finance published a draft Law on Amendments and Supplements to the Law, which we also covered in one of our previous articles.
Below, we provide an overview of the most important solutions introduced by the finally adopted amendments and supplements to the Law, with particular emphasis on the deadlines for their application.
New Application Deadline
The amendments to the Law introduce a special deadline for the application of provisions relating to the electronic delivery note in paper form, with their application scheduled to begin on 1 April 2026. These provisions relate to the use of an electronic delivery note in paper form in emergency situations, such as a temporary disruption of the system or internet connection, when system users are unable to create and exchange electronic delivery notes through the system.
In such circumstances, the Law specifies the obligations of the sender and the recipient regarding the number of copies of the electronic delivery note in paper form, the subsequent recording of data in the system, and the sending of an electronic receipt once the connection has been re-established.
Commencement of the Application of the Law
Although other application deadlines under the Law have not been changed, it is important to reiterate them.
Obligations related to the receipt, sending, and presentation of e-delivery notes for public sector entities, as well as for private sector entities engaged in the trade of excise goods or in business relations with the public sector, apply as of 1 January 2026.
Obligations that apply exclusively to private sector entities, as well as to carriers within the scope of inspection supervision, apply as of 1 October 2027.
This article is to be considered as exclusively informative, with no intention to provide legal advice. If you should need additional information, please contact us directly.
Author:
Ana Stojak, Junior Associate
ana.stojak@prlegal.rs; legal@prlegal.rs;