Serbia: Law on the Electronic Delivery Note System for the Movement of Goods

Serbia has published the final version of its law on electronic delivery notes.
Starting January 1, 2026, public entities will be required to send and receive electronic delivery notes.
Beginning October 1, 2027, private companies involved in B2B transactions must also send and receive electronic delivery notes.
The Serbian Ministry of Finance has released the final version of the law along with technical specifications governing the use of electronic delivery notes. Under the current regulation, both private and public entities are required to issue electronic delivery notes for every movement of goods before transportation begins. Transporters must then present these electronic notes during inspections.
The law sets forth specific requirements for issuing, sending, receiving, and archiving electronic delivery notes (electronic shipping notes) for the movement of goods. These electronic documents are critical for tracking goods during transport throughout Serbia and apply to both the public and private sectors.
Implementation Timeline for General Goods Movement
From January 1, 2026
- Public entities must send and receive electronic delivery notes in G2G, G2B, and B2G transactions.
- Private entities must send electronic delivery notes in B2G transactions.
From October 1, 2027
- Private entities must send and receive electronic delivery notes in B2B and B2G transactions.
In all cases, transporters must present electronic delivery notes during inspections.
How Electronic Delivery Notes Work in Serbia
The Serbian Ministry of Finance has issued a draft law regarding electronic transport documents or delivery notes. The law is set to make the use of electronic delivery notes mandatory from January 2026.
The draft law establishes clear guidelines for issuing, sending, receiving, and archiving electronic delivery notes for goods transportation. These electronic documents will play a key role in tracking goods during transit across Serbia and will apply to both public and private entities.
The Ministry will provide a centralized platform where the issuer must register the electronic delivery note in XML format before the shipment of goods. The recipient must confirm the physical receipt of the goods on the same day or within two business days at the latest. Acceptance or rejection of the electronic delivery note must be done by issuing an electronic receipt confirmation within eight days of receipt.
While most goods will be subject to this requirement, some exceptions apply:
- Goods transported via utility networks (e.g., water, electricity, gas).
- Retail goods subject to specific tax regulations.
- Military and sensitive goods, or those transported under international agreements, may also be exempt.