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

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). The production system is at efaktura.mfin.gov.rs.

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 2022-05-01, a VAT payer issues e-invoices to a public sector body.
• Since 2022-07-01, a VAT payer receives and keeps e-invoices.
• Since 2023-01-01, 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 2024-08-31, 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. Step 1 Open an account on the Portal for Electronic Identification (eID). Sign in at the high assurance level, with a qualified electronic certificate or with the ConsentID mobile app. A username and a password do not give access to SEF.
2. Step 2 Open the SEF Admin module and select the type of subject, for a d.o.o. "Privredno društvo". Type the company registration number (matični broj) and select "Registruj kompaniju".
3. Step 3 Accept the terms of use and activate the eFaktura module.
4. Step 4 Choose how the company works in SEF. It can work in the browser through named users with roles, or through the API with an API key for its accounting software. It can also work 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 2027-07-01 (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.