E-Invoicing and SEF in Serbia 2026: April Changes, e-VAT and Fines

E-invoicing in Serbia in 2026 brings the biggest change since the electronic invoicing system (SEF) was introduced. Amendments to the Law on Electronic Invoicing were adopted in December 2025 and apply to tax periods beginning after March 31, 2026. In short: from April 2026, VAT calculations are recorded electronically in SEF within 10 days after the end of the tax period, internal invoices are created inside SEF itself, and fines for non-compliance go up to RSD 2,000,000. Below: who must comply, what changes, and a worked example.

Who must use SEF in 2026

The scope has not changed, but this is where most mistakes happen.

• Public sector entities, for all transactions among themselves and with the private sector.
• Private sector entities registered for VAT, for all B2B and B2G transactions (between companies and entrepreneurs, and toward the public sector).
• Private sector entities not registered for VAT that invoice the public sector. They must register in SEF at least for those invoices.
• Voluntary users: entities outside VAT who registered on their own. All obligations and deadlines apply to them too.
• Tax representatives of foreign entities that are VAT payers in Serbia.

A flat-rate entrepreneur outside VAT who works only with private companies and foreign clients has no SEF obligation until entering VAT. We explained when VAT registration becomes mandatory in our VAT registration guide.

What changes from April 1, 2026

1. Electronic VAT recording within 10 days

This is the central change. The VAT calculation, both individual and summary records, is recorded electronically in SEF within 10 days after the end of the tax period. For monthly filers this means the April records are completed by May 10, while the VAT return (PPPDV) is filed by May 15. For quarterly filers, the second quarter records are due by July 10. Records cover full tax periods only (a month or a quarter), never partial periods.

2. Internal invoices are created inside SEF

Internal VAT calculations (for example on services bought from foreign suppliers, or purchases where you are the tax debtor) used to be prepared in accounting software and uploaded to SEF as a finished document. From April 1, 2026, the individual VAT record for internal invoices is created directly inside SEF. The internal invoice number is entered as "0". The system automatically transfers data from internal invoices with the status "recorded" and "reversed" into the input VAT records.

3. Reversal replaces cancellation

The status "cancelled" has been replaced by "reversed" for summary records and individual records. If you made an error in fields that may be corrected, you correct. If the record should not have existed, or the error is outside those fields, you reverse. Choosing the wrong option is treated as non-compliance.

4. Retail sales paid with corporate cards

If a customer pays with a corporate payment card in retail, that transaction enters SEF. An e-invoice for such a sale cannot be issued before the fiscal receipt. If no e-invoice is issued by the 12th of the following month, the sale is recorded through the summary VAT record. For sales to the public sector, a 7-day deadline applies for requesting an e-invoice.

5. Other changes

• Foreign currency amounts are shown individually in the currency, with totals in dinars.
• Negative amounts are allowed only in the category "N, annulment".
• SEF is being connected with the e-delivery note system and with the systems of the Tax Administration and Customs, which means more automatic cross-checking.

Official instructions and technical specifications are published at efaktura.mfin.gov.rs.

Fines for non-compliance

Entity	Fine range
Legal entity	RSD 200,000 to 2,000,000
Entrepreneur	RSD 50,000 to 500,000

The responsible person in a legal entity is fined as well; check the current amount in the law. Punishable failures include: not issuing an e-invoice when required, not recording the VAT calculation within 10 days, inaccurate recording, wrong reversal, and not accepting or rejecting a received e-invoice on time. Fines are imposed per offense, not per period, so failures add up.

Worked example: a monthly filer in May 2026

Primer d.o.o. is a monthly VAT filer. For April 2026 it has 40 outgoing e-invoices, 3 services received from foreign suppliers and 25 incoming e-invoices. The schedule looks like this:

1. During April: it issues e-invoices through SEF and accepts or rejects incoming e-invoices within 15 days of receipt, because an unprocessed invoice moves into the further procedure defined by law.
2. By May 10: it creates 3 internal invoices in SEF for the foreign services (individual records) and, if needed, a summary record for sales not covered by e-invoices, such as retail paid with corporate cards.
3. By May 15: it files the PPPDV return on ePorezi and pays the VAT.

If on May 5 it notices a wrong amount on an internal invoice, it makes a correction. If an internal invoice was created for a service never received, it reverses it. If May 10 passes with the records unfinished, the company is in breach, with a fine starting at RSD 200,000.

How to prepare

• Confirm that your accounting software supports creating internal invoices in SEF and the new statuses (recorded, reversed).
• Set an internal deadline: all internal invoices and the summary record completed by the 7th of the month, three days before the legal deadline.
• Assign one person responsible for SEF and one backup. Absence in the first week of the month does not extend the deadline.
• If you buy services from abroad (software, advertising, consultants), list those suppliers, because each service requires an internal invoice.

Common mistakes

• Leaving VAT recording for the 14th or 15th, together with the PPPDV return, and missing the 10-day deadline.
• Still preparing internal invoices in the ERP and importing them as XML instead of creating them in SEF.
• Using reversal to fix an amount, or a correction for a document that should have been reversed.
• Not tracking retail sales paid with corporate cards, so the sale ends up in neither an e-invoice nor the summary record.
• Incoming e-invoices left unaccepted for weeks, so input VAT for that period cannot be deducted.

Frequently asked questions

Does the 10-day deadline apply to quarterly filers?

Yes. Records for the second quarter of 2026 (April, May, June) must be completed by July 10, 2026. The deadline is 10 days after the end of the tax period, whether that period is a month or a quarter.

What about March 2026 invoices processed in April?

The old rules apply to them, because the amendments cover tax periods beginning after March 31, 2026. March is the last period under the old regime, even though the March records and return are prepared in April.

My company is outside VAT and works only with private companies. Must it use SEF?

No, as long as it stays below the VAT threshold of RSD 8,000,000 and does not invoice a public sector entity. If you are considering voluntary VAT registration, keep in mind that it brings all SEF obligations with it, as we explain in our article on voluntary VAT registration.

Who pays the fine if the accountant is late?

Liability rests with the taxpayer, meaning the company and its responsible person. Ask your accountant for a clear internal deadline and confirmation that the records are complete.

How NOTA GROUP can help

We have handled SEF for our clients since the system launched: issuing and accepting e-invoices, internal invoices, VAT recording within 10 days and reconciliation with the PPPDV return. Our accounting services include a check of whether your software is ready for the April 2026 rules. Book a consultation or contact us and we will walk through your process step by step.