Introduction: Why Are Electronic Delivery Notes Being Introduced?
Starting in 2026, Serbia begins the gradual implementation of the Law on Electronic Delivery Notes. The goal is to record the movement of goods digitally, faster and more precisely, with full automation of transport tracking. Instead of paper, stamps, and manual filling, every shipment of goods will be accompanied by an electronic document that passes through a central state system.
This is one of the largest digitalizations in business in our country and directly affects almost all companies that send, receive, or transport goods.
What Is an Electronic Delivery Note?
An electronic delivery note is a digital document that accompanies goods during transport. It must be created, sent, and received through the official state system, in a structured format that enables automatic processing.
It contains key data, such as:
- Who is sending the goods
- Who is receiving the goods
- What is being sent and in what quantity
- Time and place of departure
- Time and place of delivery
- Who is the carrier
- QR code for verification
The goal of the system is to provide transparent and always available tracking of goods movement, without manipulation or errors.
Who Is Required to Send Electronic Delivery Notes?
The obligation applies to:
- Private sector entities (VAT payers and companies participating in the dispatch of goods)
- Public sector entities
- Transport operators (when maintaining records on behalf of clients)
- Carriers (for collecting and presenting delivery notes during inspections)
Individuals who do not conduct business activities are not covered by the law.
When Do the Obligations Take Effect?
According to the law and its amendments:
- For the public sector -- from January 1, 2026
- For the private sector regarding excise products -- from January 1, 2026
- For the private sector in all goods trade -- from October 1, 2027
Therefore, all companies in Serbia will have to switch to the electronic delivery note system by October 2027 at the latest.
When Is an Electronic Delivery Note Not Required?
The law provides several exceptions. A delivery note is not required in situations such as:
- Delivery of water, electricity, gas, and similar goods through networks
- Retail trade (a fiscal receipt is sufficient)
- Deliveries within the same public entity
- Returning goods using the same transport vehicle
- Deliveries within approved clinical trials
This significantly simplifies operations for retail stores and parts of the public system.
What Does the Process Look Like in Practice?
- The sender creates an electronic delivery note in the system.
- The carrier picks up the delivery note through the system or receives a printed QR display if they are not a system user.
- The recipient confirms physical receipt of goods within 3 business days of delivery.
- Then accepts or rejects the delivery note within 8 days.
If the recipient does not send a receipt confirmation:
- For the public sector -- the goods are considered accepted
- For the private sector -- the goods are considered rejected
This ensures that the movement of goods is recorded without delays and that each party has clear responsibility.
What If the System Is Down or There Is No Internet?
The law provides for this possibility as well: a company can temporarily use a paper delivery note with a holographic sticker issued by the National Banknote Printing Institute.
When internet or the system is restored, the company is required to enter all data into the system by the next business day at the latest.
What Does This Mean for Businesses in Practice?
1. Less Paper, More Digital Business
Paper delivery notes are being replaced by an automated system. Companies need technical adaptation: software, employee training, reliable internet connection.
2. Stronger Control and Transparency
The system allows the state to track the movement of goods in real time. This reduces opportunities for abuse but increases the responsibility of companies.
3. Penalties for Non-Compliance
Penalties are provided for:
- Sending a delivery note outside the prescribed deadline
- Failure to confirm receipt
- Misuse of data
Penalties for legal entities: 200,000 to 2,000,000 RSD
For entrepreneurs: 50,000 to 500,000 RSD
4. Adjustment Period
From January 1 to June 30, 2026, errors in filling out data will not be penalized -- this is a period for learning and process optimization.
5. Simpler Oversight and Proof of Delivery
Everything is digitally archived, easily accessible, without losing papers and without disputes about whether goods were actually delivered.
What Does This Mean for Citizens?
Although the law primarily affects businesses, citizens gain several indirect benefits:
- Safer and more transparent deliveries
- Less room for the gray economy
- Faster and more reliable procurement and delivery processes
- Better consumer protection
Citizens who are not entrepreneurs have no new obligations.
Conclusion
Electronic delivery notes represent a major step in the digitalization of business in Serbia. Although the transition will require time and technical preparation, in the long run they bring less bureaucracy, fewer errors, and faster processes.
This is not just an administrative change -- it is a transition to a more modern, more organized, and more secure system that benefits both businesses and consumers.
