The Law Is Clear: E-Delivery Notes Are Mandatory
From January 1, 2026, the Law on Electronic Delivery Notes prescribes clear penalties for non-compliance. Fines vary by type of violation and type of entity.
Penalty Overview by Violation Type
1. Goods Without an E-Delivery Note
The most severe violation — goods begin transport without a registered e-delivery note:
| Entity | Fine |
|---|---|
| Legal entity | 500,000 – 2,000,000 RSD |
| Entrepreneur | 150,000 – 500,000 RSD |
| Responsible person | 50,000 – 150,000 RSD |
2. Late Submission of E-Delivery Note
The e-delivery note must be issued before goods leave the warehouse:
| Entity | Fine |
|---|---|
| Legal entity | 300,000 – 1,000,000 RSD |
| Entrepreneur | 100,000 – 300,000 RSD |
| Responsible person | 50,000 – 100,000 RSD |
3. Failure to Confirm Receipt
The recipient must confirm physical receipt within 3 days and accept/reject within 8 days:
| Entity | Fine |
|---|---|
| Legal entity | 200,000 – 500,000 RSD |
| Entrepreneur | 100,000 – 200,000 RSD |
| Responsible person | 50,000 RSD |
Common Penalty Scenarios
Scenario 1: Driver has no access to e-delivery note
Inspection stops a truck. The driver has no app access, no internet, no paper version with hologram. Fine for the legal entity: up to 2,000,000 RSD.
Scenario 2: Delivery note sent after delivery
Goods arrived at the buyer, but the delivery note is sent the next day. Late submission fine: up to 1,000,000 RSD.
Scenario 3: Recipient doesn't confirm
The recipient received goods but never confirmed in the system. After 8 days — fine for recipient: up to 500,000 RSD.
Grace Period: January–June 2026
Data errors are tolerated during this period, but complete non-use of the system is still a violation. From July 1, 2026 — full penalties without exceptions.
Conclusion
E-delivery note penalties are significant — up to 2,000,000 RSD for legal entities. Don't wait until July — start using the system during the grace period.
Arhivix automates the entire e-delivery note process — generation, submission, receipt confirmation, and 10+ year archiving, all from one system.
