Draft Electronic Invoicing Act


Draft Electronic Invoicing Act is open for public debate on 18th and 23rd February 2021, and is expected to apply to public-sector entities from 1st July 2021 and to private-sector enterprises from 1st July 2022. Here are the main points introduced by the draft:

  • The draft requires electronic invoices to be issued, delivered, received, processed and stored for transactions conducted between government and private entities, between state-owned entities, and between privately held enterprises.
  • The transactions, whether a fee is charged or not, for which it is currently not mandatory to issue electronic invoices, must now have their VAT calculations recorded electronically in the system of electronic invoices.
  • The draft specifies the compulsory elements of every electronic invoice.
  • By accessing the system of electronic invoices the invoice recipient reviews and either accepts or rejects an invoice within a period of 8 (eight) days from the date of receipt. If the invoice is not confirmed and/or rejected by a government entity within this deadline, the invoice is deemed accepted. If a privately held company fails to accept or reject the invoice, the buyer will be presented with a notice that an electronic invoice has been issued. If the private company does not react within 3 (three) days from the date of receiving this notice, the invoice is considered rejected.
  • This draft Electronic Invoicing Act introduces penalties for violating the provisions of this Act, requiring that a public or private enterprise pay between RSD 200,000 and RSD 2,000,000 in fines and the responsible person within that legal entity between RSD 50,000 and RSD 150,000.

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