eOtpremnica: new dates and rules for electronic delivery notes in Serbia
Event: 31 August 2026 · Published: 17 September 2026
For a trading company, an electronic delivery note is not just an accounting task. It connects dispatch, transport and receipt of goods, so a poorly organised process affects several people at once. The eOtpremnica rules changed again in August 2026. We explain how to distinguish a future stage from obligations already in force.
What changed at the end of August
The amendments were published on 31 August 2026 in the Official Gazette of the Republic of Serbia, No. 80/2026. The current law provides for the general mandatory stage of receiving electronic delivery notes in the private sector and exchanging them between private entities from 1 October 2027. Through 1 January 2027 inclusive, a special regime applies to the treatment of errors in data in documents already sent during inspections. This is not the same as cancelling the obligation to send documents. The basis is the official publication of the law with amendments.
The first mandatory scenarios took effect on 1 January 2026: the public sector, relevant supplies to it and transactions involving excise goods. The launch is described in the Ministry of Finance announcement. Relying only on the 2027 date is therefore risky: your transaction may already require an electronic document.
Where to start checking your company
Our approach is to map the movement of goods first, then choose a technical solution. List three to five regular scenarios: delivery to a customer, transfers between warehouses, returns, imports and dispatch to a public-sector customer. These examples do not necessarily all fall under the same requirements. Check the actual transaction, the parties' status and the goods.
For each situation, answer simple questions: who controls the goods, who transports them, where are they dispatched from, who receives them and which documents are already prepared? This review reveals any part of the process that has not yet been defined. Buying software alone does not remove that uncertainty.
Why assigning everything to the accountant is not enough
An accountant may record transactions correctly without knowing the precise dispatch time or the actual items received. That information sits with the warehouse, logistics staff and recipient. We recommend assigning responsibility for providing the initial data, preparing the document and checking that the transaction is complete.
It is particularly useful to agree on what happens when there are discrepancies: some goods are not accepted, the vehicle changes, delivery is delayed or a return is needed. These are practical scenarios for an internal procedure. It is better to review them with a specialist in advance than to improvise after dispatch.
Access and setup
The official portal states that registration requires the legal representative to have eID and a qualified certificate or ConsentID. User permissions are assigned after registration. Rights in the SEF administration module and the delivery note system are granted separately. For a foreign representative, check that their details match across the registers and electronic identification tools. The procedure is described in the eOtpremnica FAQ.
The practical implication is to check not just that the director can log in, but that the employees who will actually handle deliveries can work in the system. Access to electronic invoices should not be treated as automatic confirmation of full readiness for delivery notes.
Readiness checklist
A list of transactions has been prepared and the obligations applying to each have been identified.
People responsible for dispatch, transport data and receipt have been assigned.
The company's and legal representative's registration details have been checked.
Employees' permissions have been granted and tested, with cover arrangements in place.
A procedure has been agreed for returns, quantity discrepancies and technical problems.
The accountant, warehouse and manager know where to see the current status.
We recommend testing this list against one typical order from start to finish. A small company needs a clear process and assigned responsibilities. With large dispatch volumes, integration with the existing accounting system and the workload on employees should be assessed separately. The review should produce a short list of specific fixes with named responsibilities.
What the owner should do now
There is no need to stop preparing because the general date is later, or to restructure the whole business around someone else's template. Start by checking which requirements apply. Then separate the current mandatory steps from preparation for the next stage and allocate the budget between the two.
RICS Consulting will help organise a review of your company's transactions and coordinate document flows with your accountant and specialist partners. Contact us for business support in Serbia: we will prepare a specific plan for your goods, counterparties and workload.