Serbian electronic delivery notes: a guide for companies

Short answer: Serbian electronic delivery notes (eOtpremnice) are delivery notes sent electronically through the state Electronic Delivery Note System. Since January 1, 2026 they are mandatory for the public sector, for deliveries to the public sector and for excise goods. From October 1, 2027, every private sector company receives them for every movement of goods and sends them to other private companies. To start, the company's legal representative registers the company in the system; notes are then sent by hand, from your software or through an intermediary portal.

What an electronic delivery note is

An electronic delivery note is the same document that accompanies goods today, except that it is not drawn up on paper but sent through the Ministry of Finance's Electronic Delivery Note System. The recipient confirms receipt of the goods in the same system with a document called an e-receipt (ePrijemnica). The system accepts notes in UBL 2.1, an international XML standard for business documents, so software can send them automatically.

The Law on Electronic Delivery Notes was passed in November 2024 (Official Gazette no. 94/2024) and has been amended twice so far, in 2025 and in August 2026.

When e-delivery notes become mandatory

The obligation comes in two phases, under article 16 of the law and the transitional provisions of the amendments:

Obligation	Applies from
the public sector sends and receives electronic delivery notes	January 1, 2026
the private sector sends notes to the public sector	January 1, 2026
excise goods: sending and receiving in the private sector	January 1, 2026
provisions on the electronic delivery note in paper form	April 1, 2026
data errors are not taken into account in inspections	until January 1, 2027
the private sector receives notes for every movement of goods	October 1, 2027
sending between two private sector companies	October 1, 2027

If you sell excise goods or deliver to state institutions in Serbia, the obligation already applies. If you deal only with private companies, you have until October 1, 2027, but it is better to try the system earlier, while errors are not yet part of inspections.

Who the law does not apply to

The law does not apply to individuals who are not taxed on income from self-employment (article 1). And because a delivery note follows the movement of goods, a company that only provides services, with no delivery of goods, does not issue them. If you are not sure where you stand, check with an accountant in Serbia before changing how you work.

Getting started, step by step

1. The legal representative's account. The company's legal representative needs an account on Serbia's electronic identification portal, plus a qualified electronic certificate or the activated ConsentID app.
2. Registering the company. After logging in, you choose the type of entity and enter the tax number (PIB), the registration number, or the JBKJS code for public funds users. The system checks the data against the registers of the Treasury, the Business Registers Agency and the Tax Administration.
3. Rights for employees. Through the administrator module you assign rights to employees. Rights to work with e-delivery notes and rights to the administrator module are assigned separately, and the Ministry recommends that at least two people have administrator rights.
4. Choosing how to send. Notes can be sent by hand, through the state portal; from the software you already use, with the company's API key; or through an intermediary portal, which does the same without your own software.
5. Testing. The Ministry of Finance runs a demo environment where the whole flow can be tested without real documents. Connect your software and check it there before the first real note.
6. Receiving. When goods arrive, the recipient confirms receipt with an e-receipt. Agree with suppliers and customers who sends and confirms what, and when, so documents do not pile up without a status.

Common mistakes

• Rights assigned in only one place. An employee has rights to e-delivery notes but not to the administrator module, or the other way round. According to the Ministry, this confused a large number of users.
• A single administrator. When that person is away, nobody can add an employee or change settings.
• Shipping tied to one ID card. If notes are sent only through the state portal with one person's certificate, shipping stops when that person is out. Sending with an API key solves this.
• Retyping items. The goods have already gone through the register or warehouse, yet the items are typed in again. Software or a portal should pick them up itself, for example from the QR code on a fiscal receipt.
• Relying on the transition period. Until January 1, 2027, data errors are not part of inspections, but that is temporary. Check each note with the state validator before sending, while mistakes still have no consequences.

How software gets connected

Software that already knows your goods, such as a point of sale or warehouse program, can create and send delivery notes itself. The company generates an API key in the system, and the software uses it to send documents in UBL 2.1 and to fetch incoming notes and statuses. The technical guide and API documentation are on the system's portal, and the whole flow is tested in the demo environment.

That is how BKC Soft's fiscal cash register software works: it sends delivery notes through the efakture.exe service I wrote, and more than 5,000 e-delivery notes have gone through it so far. The same service also sends e-invoices to SEF, Serbia's e-invoicing system, so the software uses one place for both.

How I handle this for clients

For companies with no software of their own I built the eOtpremnice portal: the company enters its API key once and sends notes even from a phone, with no card reader, and items are imported by scanning the QR code on a fiscal receipt. The first 3 months are free. If you have software, I connect it to the system; price and timeline are on the e-delivery notes page.