An e-delivery note is an electronic document that accompanies the movement of goods and contains the information required for their dispatch, transportation and receipt. Instead of relying exclusively on paper documentation, information is exchanged through the centralized Electronic Delivery Notes System, managed by the Ministry of Finance.
To use the Electronic Delivery Notes System, you need to activate this module in the same place where you activated the Electronic Invoicing System, commonly known as SEF.
The purpose of the system is to improve the tracking of goods, simplify data exchange between parties involved in deliveries and make inspection supervision more efficient.
It is important to distinguish between an e-delivery note and an electronic invoice. An e-delivery note accompanies the movement of goods, while an electronic invoice documents the calculation and payment of a delivery, i.e. the business transaction. These two documents serve different purposes and do not replace one another.
When Did the Implementation of E-Delivery Notes Begin?
The implementation of the Law on Electronic Delivery Notes was introduced in phases. The first obligations began to apply on 1 January 2026, while 1 October 2027 has been set as the date for mandatory regular exchange of e-delivery notes between private-sector entities, where the goods are not subject to excise duties.
1. From 1 January 2026 – Public Sector and Excise Goods
As of 1 January 2026, the obligations relating to public-sector entities and the legally prescribed movement of excise goods have become applicable.
This means that a private company cannot automatically assume that it is exempt from using the system until October 2027. If it delivers goods to a public-sector entity or participates in the movement of excise goods in circumstances covered by the law, the obligation may already apply.
Public-sector entities are required to comply with the rules governing the sending and receipt of e-delivery notes. When a private company delivers goods to a public-sector entity, it must check whether the specific delivery is subject to the obligation to issue an electronic delivery note.
Special rules also apply to excise goods, which is why it is necessary to determine the type of goods and the role of each participant in their movement.
2. From 1 October 2027 – General Obligation for the Private Sector
For private-sector entities that send and receive goods between themselves, where the goods are not subject to excise duties and no other statutory obligation applies, the full implementation of mandatory e-delivery note exchange is scheduled to begin on 1 October 2027.
This date is particularly important for companies and entrepreneurs whose business activities involve the delivery, transportation or receipt of goods from other private-sector entities.
Until mandatory implementation begins, such entities may use the system voluntarily, except where a statutory obligation already applies to a specific situation.
What Does This Mean in Practice for Entrepreneurs and Companies?
The obligation is not determined solely by whether a business is registered as an entrepreneur or a limited liability company, nor solely by whether it is registered for VAT purposes.
What matters most is the nature of the company’s business activities, the type of goods being delivered, the recipient of those goods and the manner in which they are transported.
For example, a company selling goods to another private company may be subject to different requirements than a company delivering the same goods to a public enterprise. In addition, if the goods are subject to excise duties, specific obligations may already apply as of 1 January 2026.
For this reason, businesses are advised to review their typical business activities, including deliveries to customers, collection of goods from suppliers, own-account transportation, transfers of goods between locations, and any import or export activities.
E-delivery notes are not being introduced in Serbia for all businesses at the same time. The first obligations, applicable to the public sector and the prescribed movement of excise goods, have applied since 1 January 2026, while 1 October 2027 is scheduled as the starting date for the general mandatory exchange of e-delivery notes between private-sector entities in cases not already covered by the obligation.
The most important step for every business is to determine which rules apply to its specific business activities. Preparing in advance can reduce the risk of documentation errors and make the transition to electronic recording of goods movements easier.