Phased Implementation: Not Everyone Starts at the Same Time
The Law on Electronic Delivery Notes was adopted in December 2024, and the system went live at eotpremnica.mfin.gov.rs. Implementation is phased — not everyone must start simultaneously, but many will be obligated from January 1, 2026.
Phase 1: From January 1, 2026
Public Sector Entities
- Government bodies, public enterprises, institutions, local governments
- Required to send and receive e-delivery notes in mutual trade
Private Sector Supplying the Public Sector
- Any company shipping goods to the public sector must issue an e-delivery note
- This includes suppliers to hospitals, schools, municipalities, and public enterprises
Excise Products — Everyone
- Fuel, alcohol, coffee, tobacco products
- Every movement of excise goods must be accompanied by an e-delivery note
Phase 2: From October 1, 2027
E-delivery notes become mandatory for the entire private sector — all B2B goods shipments.
Grace Period: January–June 2026
The Ministry of Finance has established a grace period from January 1 to June 30, 2026 — errors in data entry will not be penalized during this time.
- This does NOT mean you don't have to send e-delivery notes
- The obligation exists from January 1, 2026
- Only data errors are tolerated, not complete non-compliance
- From July 1, 2026 — full penalties apply
Key Deadlines at a Glance
| Date | What Takes Effect |
|---|---|
| December 2024 | Law adopted and entered into force |
| 2025 | DEMO environment available for testing |
| January 1, 2026 | Mandatory for public sector, public sector suppliers, and excise goods |
| Jan 1 – Jun 30, 2026 | Grace period (data errors not penalized) |
| July 1, 2026 | Grace period ends — full penalties for all Phase 1 entities |
| October 1, 2027 | Mandatory for entire private sector (B2B) |
How to Check If You're Obligated from January 2026
- Do you ship goods to the public sector? → You're obligated
- Do you work with excise products? (fuel, alcohol, coffee, tobacco) → You're obligated
- Are you a public sector entity? → You're obligated
If all answers are "no" — your deadline is October 2027, but preparation should start now.
Conclusion
E-delivery notes cannot be ignored — deadlines are clear and penalties are defined. Use the grace period until June 2026 to learn the system and resolve technical issues.
Arhivix integrates with the e-delivery notes system — automatically generating, sending, and archiving delivery notes directly from the DMS.
