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 are they being introduced?
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 is required to issue electronic delivery notes?
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?
Certain categories of goods and transactions are exempt from the e-delivery note obligaton, 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.
Commencement of the implementation of the Law on electronic delivery notes
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 does the electronic delivery note system work?
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 if a technical issue occurs?
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.
Obligations and deadlines in the electronic delivery note system
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.
Types of electronic delivery notes
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 as an integral part of the electronic delivery note
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:
- 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)
- MAK – Mobile application for control/inspection, and
- 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
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
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 with other electronic systems
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 penal provisions
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.
A novelty introduced is a fixed monetary fine of 300,000.00 dinars in the event that a legal entity (sender, recipient, or transporter) fails to ensure unobstructed inspection or data collection relevant for such inspection, or presents an e-delivery note that is not authentic. For such offenses, the responsible person within the legal entity shall be fined 50,000.00 dinars, and if the offense is committed by an entrepreneur, the fine shall amount to 150,000.00 dinars.
Recommendations for compliance with the Law
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 – A challenge, but also an opportunity
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.
