Electronic Delivery Notes in Serbia: A Step Toward Greater Efficiency

Updated: October 2026. | Next review: April 2027.

In today's dynamic business environment, where digitalization is increasingly recognized as a key driver of operational improvement and efficiency, Serbia has taken significant strides toward modernization. Digital advancement is no longer a choice, but a necessity, enabling faster, safer, and more transparent management of business processes.

One of the latest and most impactful developments in this direction is the introduction of electronic delivery notes. This new system represents a major shift in the way the movement and documentation of goods are tracked in Serbia.

The overarching goal of this system is to reduce the number of paper-based documents, accelerate data processing, and enhance transparency in the movement of goods.

In the following sections, we will explore what electronic delivery notes mean for the business community, their key benefits and challenges, and how this system fits into Serbia's broader digitalization agenda, especially in connection with prior reforms such as the introduction of mandatory electronic invoicing.

What Are Electronic Delivery Notes and Why Is Serbia Introducing Them?

TL;DR: Electronic delivery notes are digital documents that accompany goods in transit and enable real-time tracking of their movement. Deliveries are recorded and processed automatically in an information system, eliminating errors caused by manual data entry and paper documents.

Electronic delivery notes are digital documents that accompany goods in transit, with the goal of enabling simpler and more accurate real-time tracking of goods movement. This system ensures that the delivery process is recorded and automatically processed through an information system, thereby eliminating errors that commonly occurred due to manual data entry or the use of paper-based documents.

Who Must Issue Electronic Delivery Notes in Serbia?

TL;DR: The obligation applies to all entities that handle goods and to transporters acting on their behalf. E-delivery notes cover sales, distribution, transport, imports and exports, public sector transactions and internal transfers within a company.

The obligation to issue electronic delivery notes applies to all entities that handle goods, as well as transporters acting on behalf of and for the account of these entities (principals).

Transactions that require electronic delivery notes include:

• Sale of goods: When a company sells products, whether through wholesale, retail, or e-commerce;
• Distribution of goods: Companies engaged in transferring products between warehouses, retail outlets, or to end customers;
• Transportation of goods: Any transaction involving the physical transport of goods from the seller to the buyer, or between different locations;
• Import and export: Electronic delivery notes are mandatory for international trade transactions involving cross-border movement of goods, both imports and exports;
• Transactions involving the public sector: When goods are handled or transported for the needs of public institutions or state-owned enterprises;
• Internal transfers within a company: E-delivery notes may be used to track the movement of goods within the same legal entity or between different business units.

Who Is Exempt from Issuing Electronic Delivery Notes in Serbia?

Certain categories of goods and transactions are exempt from the e-delivery note obligation, such as:

• Water, electricity, gas, heating, and cooling;
• Goods sold directly to end customers in retail stores (retail sales);
• Goods sent as part of international aid or cooperation;
• Military and security-sensitive equipment (procurement, repair, or modernization);
• Goods transferred between government institutions.

When Does the Law on Electronic Delivery Notes Take Effect?

TL;DR: The Law entered into force in December 2024 and applies in two phases. From January 1, 2026, the obligation covers the public sector, entities trading in excise goods and private entities dealing with the public sector, and from October 1, 2027, it also covers transactions between private sector entities.

The Law on electronic delivery notes (hereinafter: the Law) entered into force in December 2024 and stipulates that all companies engaged in the trade of goods must use them. This process is considered essential for increasing business efficiency and reducing administrative costs.

A phased implementation of this Law is foreseen: the first phase begins on January 1, 2026, while the second phase begins on October 1, 2027.

The obligation to receive, send, and present electronic delivery notes for public sector entities, as well as for private sector entities that trade in excise goods, regardless of the legal basis, applies from January 1, 2026. The same obligation applies to private sector entities that are in business relationships with public sector entities, also starting from that date.

It is important to highlight here one significant distinction between users of the e-invoicing system and the e-delivery note system. In the e-delivery note system, all those who trade in excise goods must participate, regardless of whether they are on the buyer's or supplier's side, even if they are not VAT registered.

The obligation for private sector entities, in cases involving the movement of goods, to receive an e-delivery note, as well as the obligation to send an e-delivery note when both the sender and the recipient are private sector entities, and the obligation of the transporter to present the e-delivery note during movement of goods within inspection control, applies from October 1, 2027.

How the Electronic Delivery Note System Works

TL;DR: E-delivery notes are sent and received through a dedicated information system, and all delivery data must be submitted before goods leave the warehouse. The Law also introduces the electronic receipt note, confirming quantity and quality, and the confirmation of physical receipt at the correct location.

Electronic delivery notes must be sent and received through a dedicated information system, enabling fully automated processing. All delivery data must be submitted before the goods leave the warehouse premises, ensuring timeliness and accuracy of the transaction.

In addition to the electronic delivery note, the Law introduces two additional key concepts within this new system: electronic receipt note and confirmation of physical receipt.

• Electronic receipt note is a document issued by the recipient to the sender, confirming that the goods were received in the correct quantity and quality.
• Confirmation of physical receipt is an action performed by the recipient upon the goods' arrival, confirming that the delivery was completed at the correct physical location.

What Happens If a Technical Issue Occurs?

TL;DR: In case of an internet outage or other technical issue, the sender may print the e-delivery note, marked with a special holographic label. The printed version is temporarily valid and must be registered in the system as soon as the issue is resolved.

As with any digital business process, the risk of technical disruptions exists. For this reason, the Law also provides for the temporary use of a paper version of the electronic delivery note. In the event of an internet outage or other technical issue with the system, the sender is permitted to print the electronic delivery note, which must be marked with a special holographic label. This printed delivery note has temporary legal validity, but it is mandatory to register it in the system as soon as the issue is resolved.

Key Obligations and Deadlines for Electronic Delivery Notes

TL;DR: The sender must send the e-delivery note before goods are dispatched, and the transporter must be able to present it during inspection. The recipient has eight days from physical receipt to accept or reject it, and the note becomes invalid if receipt is not confirmed within 30 days.

Unlike the previous mode of operation, where deadlines for recording the movement of goods were more flexible, in the new system, business entities have strict deadlines.

The sender is obligated to send the electronic delivery note before the goods are dispatched, and transporters are responsible for having it with them and being able to present it in case of any inspection.

On the other hand, the recipient has a deadline of eight days from the moment of physical receipt to review the received delivery note and decide whether to accept or reject it. These changes require companies to adequately prepare for timely sending, review, and archiving of data. The electronic delivery note becomes invalid if the recipient does not confirm receipt within 30 days. In addition, the sender may cancel it before the recipient confirms receipt.

QR code as an alternative for carriers

The September 2026 amendments to the Law resolved the issue of carriers who are unable to access and use the e-delivery note system. Such carriers may now present the e-delivery note by displaying a two-dimensional barcode (QR code), which the system automatically generates when the delivery note is sent.

However, this option also entails an additional obligation for the sender. If the carrier uses the QR code, the sender must attach the external display (visual representation) of the e-delivery note through the system, together with the e-delivery note, no later than before the movement of goods begins. Failure to meet this deadline constitutes a misdemeanour under a new penalty provision introduced by the same amendments.

In practice, this change makes it easier to work with carriers who are not directly connected to the system. Nevertheless, companies shipping goods should make sure that the external display of the delivery note is always attached on time, and never afterwards.

Types of Electronic Delivery Notes in Serbia

TL;DR: An external e-delivery note accompanies goods transferred from one legal entity's ownership to another, typically with an invoice. An internal e-delivery note is used for moving goods between locations of the same legal entity, without a change of ownership.

Electronic delivery notes can be categorized based on their purpose, characteristics, or use case:

1. External Electronic Delivery Note

This type is used when goods are transferred from the ownership of one legal entity to another. A typical example is the delivery of goods from a seller to a buyer, accompanied by an invoice. The delivery note is issued at the moment when the right of disposal over the goods is transferred to the other party, either before or after transportation.

2. Internal Electronic Delivery Note

Used for the movement of goods between different physical locations within the same legal entity. In this case, ownership of the goods does not change, the goods are merely transferred internally. This is particularly useful for companies that operate multiple warehouses or production facilities.

Electronic Signature: A Key Element of the Electronic Delivery Note

TL;DR: The electronic signature, given via tablet or mobile phone, is an essential part of the system and records the time and location of signing, although it is not a qualified signature. The system also defines three mobile apps: MAP for businesses, MAK for inspection and MATP for persons who transport goods.

The electronic signature is an essential component of the electronic delivery note management system. Its use via tablet or mobile phone is simple and efficient, enabling the tracking of all signed delivery notes and real-time updates on the delivery status of goods. Although the electronic signature used in this context is not a qualified electronic signature, it still provides relevant metadata such as the time and location of signing, significantly improving the transparency and security of the entire process.

Given that the Ministry of Finance of the Republic of Serbia has announced the implementation of electronic delivery notes as part of the broader e-invoicing system, it is expected that the issue of signing at the point of delivery will be properly addressed in the near future.

The new system defines three distinct types of mobile applications, each with specific functionality depending on the role of the user:

1. MAP: Mobile application for businesses that introduces the following functionalities for business entities: access to the system, viewing the list of received e-delivery notes, confirmation of physical receipt of goods, creation and modification of e-receipt notes, and sending the e-receipt note to the Central Register System (SCR).
2. MAK: Mobile application for control/inspection, and
3. MATP: Mobile application for persons who physically transport goods. While the MATP application is intended for quick receipt of goods by persons who receive and transport goods, MAP is the key application for business entities in Serbia.

Central Information Intermediary

TL;DR: The system is managed by the Central Information Intermediary, the competent unit of the Ministry of Finance, which is responsible for security and technical functioning, monitors activities, archives data and manages user access.

The electronic delivery note system is managed by the Central Information Intermediary, i.e. the competent unit of the Ministry of Finance, which is responsible for the security and technical functioning of the system. The Information Intermediary enables access to all registered users, monitors all activities, and ensures that all data is properly recorded and archived. This system also provides user support and manages their access to the system. Access to the demo version of the system is available via the following link.

Storage and Archiving of Electronic Delivery Notes: Key Requirements

TL;DR: All e-delivery notes must be stored for at least ten years, while public sector entities must store them permanently. The digital archive makes documents easier to access and search and reduces physical archiving costs.

The digital archive used for storing all delivery notes provides additional security.

All electronic delivery notes must be stored for at least ten years. On the other hand, public sector entities in Serbia are required to store e-delivery notes permanently, which means they must retain all electronic business documents, including delivery notes, without time limitations. This solution allows easier access to documents, faster search, and reduces the costs of physical archiving.

These obligations aim to ensure transparency, legal certainty, and efficient control of all business transactions, in order to enable inspections, audits, and other supervisory procedures.

Integration of Electronic Delivery Notes with Other E-Systems

TL;DR: The e-delivery note system is connected with the e-invoicing system, so an invoice is issued once the recipient confirms receipt. It is also integrated with the e-excise system, for excise stamp data, and the e-customs system, for transport of imported goods from customs warehouses.

The electronic delivery note system does not function in isolation but is closely connected with the e-invoicing system. This system, which has already become mandatory for all companies, enables automatic alignment between the delivery note and the invoice. The sender issues an electronic delivery note before the goods leave the warehouse, and once the recipient confirms receipt, an electronic invoice is issued. This process allows easier control and monitoring of business transactions, while obligations are fulfilled more efficiently and in real time.

The combination of e-delivery notes and e-invoices leads to full digitalization, enabling faster cash flow and better tracking of goods movement.

Integration with the e-excise system provides information on e-delivery notes containing excise goods, and enables receipt of information about excise stamps that need to be linked to the appropriate e-delivery note.

Integration with the e-customs system enables receipt of information about imported goods from the Customs system, based on which the goods owner would create an e-delivery note for transport of goods from the customs warehouse to their own warehouse.

Supervision and Penalties for Non-Compliance

TL;DR: Supervision is carried out by the Ministry of Finance, and all participants must provide inspectors with access to their documentation and equipment in order to avoid fines.

Supervision over the implementation of the Law is carried out by the Ministry of Finance, while inspection oversight may also be conducted by other state authorities within the scope of their competences.

All participants in the electronic delivery note process (sender, recipient, transporter, etc.) are required to allow the inspection access to documentation and related technical equipment connected to the e-delivery note.

Compliance Tips for the Law on Electronic Delivery Notes

TL;DR: The transition requires timely preparation: improving internal processes, training employees in logistics, warehousing and IT, and consulting legal and tax advisors. Companies already using e-invoices have an advantage.

The introduction of electronic delivery notes requires timely preparation. It is recommended that entrepreneurs and managers improve internal business processes to ensure a smooth transition to the new system. Training of employees, particularly those working in logistics, warehousing, and IT sectors, will be crucial for successful implementation. It is also advisable to consult with legal and tax advisors in order to ensure full compliance with all legal obligations.

Companies that have already aligned their operations with the e-invoice system have an advantage, as they are already operating in a digital environment. For them, integration with the electronic delivery note system will be much easier.

Conclusion: Electronic Delivery Notes (From Compliance Challenge to Business Opportunity)

TL;DR: E-delivery notes bring fewer errors, faster turnover and better control with a lower administrative burden. For companies trading in goods, the key to success is timely preparation of internal processes and software, and consulting with professionals.

The implementation of electronic delivery notes represents a significant challenge, but also an opportunity to improve business operations in Serbia. The digitalization of goods flows contributes to error reduction, faster turnover, and better control, while also reducing administrative burdens. Although the transition to this system may seem demanding, experience with e-invoices shows that companies that adapted quickly have achieved long-term benefits.

For companies engaged in the trade of goods, the key to success lies in timely preparation. We recommend adjusting internal processes, implementing suitable software tools, and consulting with professionals to avoid complications during the transition to the new system.

Electronic delivery notes are not only a legal obligation but also a step toward faster, safer, and more efficient business operations.

Frequently Asked Questions

What is an electronic delivery note?

An electronic delivery note is a digital document that accompanies goods in transit and enables simpler and more accurate real-time tracking of goods movement. The delivery process is recorded and automatically processed through an information system, eliminating errors caused by manual data entry or paper-based documents.

When does the electronic delivery note obligation apply?

The Law on electronic delivery notes applies in phases. From January 1, 2026, the obligation applies to public sector entities, private sector entities trading in excise goods and private entities in business relationships with the public sector. From October 1, 2027, it also covers transactions between private sector entities.

Which goods do not require an electronic delivery note?

The obligation does not apply to water, electricity, gas, heating and cooling, goods sold directly to end customers in retail stores, goods sent as part of international aid or cooperation, military and security-sensitive equipment, or goods transferred between government institutions.

How long does the recipient have to confirm an e-delivery note?

The recipient has eight days from the moment of physical receipt to review the delivery note and decide whether to accept or reject it. The electronic delivery note becomes invalid if the recipient does not confirm receipt within 30 days, and the sender may cancel it before the recipient confirms receipt.

How long must electronic delivery notes be stored?

All electronic delivery notes must be stored for at least ten years. Public sector entities are required to store them permanently, without time limitations.

What are the penalties under the Law on electronic delivery notes?

Legal entities, responsible persons within legal entities, and entrepreneurs who fail to allow inspection supervision to be carried out unhindered, or who present an e-delivery note that is not authentic, are subject to high fines.