Serbia: Law 80/2026 Adds Farmer Purchase Recording and Customs Declaration Lists to the E-Invoicing System

KGT Country Update  |  21 September 2026  |  VAT, e-invoicing and SAF-T monitor

On 31 August 2026 the National Assembly of the Republic of Serbia adopted the Law on Amendments and Supplements to the Law on Electronic Invoicing, published the same day in the Official Gazette of the Republic of Serbia No. 80/2026. The law entered into force on 8 September 2026 and applies from 1 January 2027, with two exceptions that apply from 1 July 2027.

It adds a new electronic recording obligation for purchases from unregistered farmers, gives users of the System of Electronic Invoices access to customs declaration lists for imports and exports drawn from the Customs Administration, and gives the Minister of Finance an express mandate to regulate the preliminary VAT return. The Ministry of Finance published the adopted text on the e-Faktura portal on 1 September 2026.

Background

The Law on Electronic Invoicing has governed the Serbian System of Electronic Invoices (SEF) since 2021 and has been amended six times: Official Gazette Nos. 129/2021, 138/2022, 92/2023, 94/2024, 109/2025 and now 80/2026.

Over that period the statute has moved steadily beyond invoice exchange. Article 4 introduced electronic recording of output VAT, Article 4a electronic recording of input VAT, and Article 3a the obligation to declare a subject status in SEF.

The amendments published in Official Gazette No. 109/2025 on 4 December 2025, which apply to tax periods beginning after 31 March 2026, introduced the preliminary VAT return prepared inside SEF and extended the statute to the retention of documents processed in the system.

KGT reported the amended Rulebook on Electronic Invoicing and the preliminary VAT return on 11 August 2026, and the SEF platform releases 4.0.0, 4.1.0 and 4.1.1 through July and August 2026. The present update concerns the primary legislation rather than the rulebook or the platform: it is the statutory basis on which the next set of subordinate acts will be built.

The Legislative Change

Law 80/2026 makes four substantive additions to the Law on Electronic Invoicing.

First, a new Article 4b creates an obligation of electronic recording of purchases from farmers. A VAT payer that acquires agricultural and forestry products or agricultural services in the Republic of Serbia from a farmer who is not registered for VAT purposes must record that acquisition electronically in SEF.

The recording is made in aggregate for the tax period, after the tax period has ended and at the latest by the 12th day of the calendar month following it, on the same cadence as the existing output and input VAT recordings. Increases and decreases are recorded in the same way and the recording may be corrected. The Minister of Finance is to prescribe the manner, procedure and correction of the recording.

Second, a new Article 4c introduces cross-border traffic into the system. A user of SEF may inspect data on the import or bringing in of goods released for free circulation, and on the export or dispatch of goods, by accessing a list of customs declarations for import and a separate list of customs declarations for export. Both lists are compiled from customs declarations and other documentation relating to customs clearance held in the information system of the Customs Administration. The Minister of Finance is to prescribe the content of each list.

Third, Article 2 is amended to support these functions. A definition of cross-border traffic is inserted as point 5b, meaning the set of data on import and export shown in SEF because of Customs Administration data, and the definition of electronic recording of VAT in point 5a is extended to cover the acquisition of agricultural and forestry products and agricultural services from farmers.

Fourth, Article 5 is amended so that the Minister's rule-making mandate expressly covers the manner of preparing and dealing with the preliminary VAT return. That closes a gap left by the 109/2025 amendments, which created the preliminary return in SEF without a matching delegation for the procedural rules.

The penalty provision follows the substance. Article 18(1)(1b) is extended so that failure to record electronically under Article 4b is an offense alongside Articles 4 and 4a, punishable by a fine of RSD 200,000 to RSD 2,000,000 for a legal person, RSD 50,000 to RSD 500,000 for an entrepreneur, and RSD 50,000 to RSD 150,000 for the responsible person. The existing safe harbour is extended with it: where the taxpayer corrects an electronic recording in which an error has been established before supervision proceedings under Article 16 are initiated, the error is not treated as an offence.

Scope

The farmer recording obligation applies to VAT payers that acquire agricultural and forestry products or agricultural services in Serbia from farmers who are not registered for VAT. In practice, this captures food, beverage, tobacco, timber and agri-processing groups with Serbian procurement, and any group buying primary produce directly rather than through a registered intermediary. The obligation is a recording obligation, not an invoicing obligation: the farmer does not issue an electronic invoice, and the acquirer records the purchase in SEF.

The customs declaration lists are available to users of SEF generally. They are an inspection facility rather than a filing obligation, but they are the data set against which the tax administration will be able to test declared import and export positions, and they will feed the preliminary VAT return.

Nothing in Law 80/2026 changes the existing scope of the e-invoicing mandate itself. Public sector entities, private sector VAT payers and voluntary users remain subject to the obligations already in force.

Timeline

• 31 August 2026 the National Assembly adopts the Law; it is published in Official Gazette of the Republic of Serbia No. 80/2026.
• 8 September 2026 the Law enters into force, on the eighth day after publication. The rule-making powers are exercisable from this date.
• 1 January 2027 general application, including the amended definitions, the Article 5 mandate on the preliminary VAT return, and the list of customs declarations for import.
• By 8 March 2027 the subordinate acts under Articles 2 and 3 of the amending law are to be adopted, within six months of entry into force.
• 1 July 2027 application of the provisions on electronic recording of purchases from farmers and of the provisions on the list of customs declarations for export or dispatch of goods.

Businesses Affected

Multinationals with a Serbian VAT registration and any direct procurement of agricultural or forestry products or agricultural services are the primary population. So are groups whose Serbian entities import or export goods, since the customs declaration lists will become part of the data set the administration uses to assess them.

Shared service centers and outsourced accounting providers operating Serbian compliance on behalf of a group are affected in the same way, and information intermediaries will need to extend their SEF integrations to the new recording type once the implementing rulebook defines it.

Required Actions

• Identify Serbian purchases from unregistered farmers in the ERP. This is usually a vendor master data question rather than a transactional one: the population is defined by the counterparty's VAT status, so the vendor master must carry a reliable flag distinguishing registered farmers, unregistered farmers and other suppliers. Where purchases from primary producers are currently booked through a collection point or a general expense account, that population will need to be separated before it can be reported.
• Confirm that the tax period aggregation and the 12th-day deadline can be met for a third recording type. Serbian VAT recording already runs on a compressed timetable after period close; adding a third aggregate recording to the same window is an operational change, not a configuration change.
• Plan the customs declaration reconciliation. The import list becomes available from 1 January 2027 and the export list from 1 July 2027. Groups should decide now whether they will reconcile SEF customs data against their own import and export records as a control, and who owns the exception process where the two disagree.
• Track the subordinate acts. The content of the recording and of the two lists is left to ministerial acts due by 8 March 2027. Nothing can be configured with confidence until they are published.
• Review the penalty exposure and the correction protocol. The safe harbor only operates where the correction is made before supervision begins, which makes proactive detection of recording errors materially more valuable than responding to an audit query.

Practical Implications

The direction of travel in Serbia is now unmistakable. SEF began as an invoice exchange platform, became a VAT recording platform, and is becoming the data layer from which the tax administration will construct a proposed VAT return. Law 80/2026 adds the two data sets that were missing from that picture: purchases from a population that does not issue electronic invoices, and cross-border movements that never passed through SEF at all. Once the preliminary VAT return is populated from output VAT recording, input VAT recording, farmer purchase recording and customs data, the residual space in which a taxpayer's own figures can legitimately differ from the administration's becomes narrow and explicable only by reference to specific transactions.

That has a practical consequence for finance functions. The controlling risk in Serbia is shifting from late or failed submission to unexplained divergence. A group that can reconcile its own VAT return to the SEF data set, line by line, will be able to answer a query in days. A group that cannot will be answering it from the general ledger, under time pressure, against a tax administration that already holds a complete view of the invoice and customs population.

The farmer recording obligation deserves particular attention because it sits outside the invoice flow. It is the first Serbian recording obligation that is triggered by a counterparty's absence from the system rather than its presence in it, and it will not be captured by any control built around electronic invoice receipt. It has to be built from purchase data.

Finally, the eighteen-month runway to 1 July 2027 is generous by the standards of this region, and it should be read as the period in which the master data work is done rather than as slack. The master data question which suppliers are unregistered farmers is the part that cannot be solved by a software release.

Expected Next Steps

The instruments to watch are the ministerial acts due by 8 March 2027: the act prescribing the manner, procedure, and correction of the electronic recording of purchases from farmers, the act prescribing the content of the two customs declaration lists, and the act prescribing the manner of preparing and dealing with the preliminary VAT return. Each will carry the field-level detail that determines what has to be extracted from the ERP.

In parallel, the Internal Technical Instruction and the SEF API specification will have to be updated to carry the new recording type, and a SEF platform release will be needed before 1 July 2027. On the release cadence observed through 2026, that work will surface on the e-Faktura portal several months in advance and will be accompanied by a demo environment.

KGT will report the subordinate acts and the corresponding technical artifacts as they are published.

How Can KGT Support You?

KGT delivers SAP-integrated electronic invoicing and statutory reporting. Our SAP add-on for Serbia produces the Serbian standard electronic invoice from SAP billing data, manages authentication and the SEF interface, and handles the electronic VAT recordings as a controlled process from SAP data rather than as a manual portal entry. The same framework extends naturally to the new farmer purchase recording, because it is built on the purchase document rather than on an inbound invoice.

For clients running SAP Document and Reporting Compliance we support scoping, configuration, country activation, and the reconciliation controls between SEF, the VAT recordings and the Serbian VAT return which is the control that will matter most once the preliminary return is populated from the administration's own data. Where a client is choosing between an add-on and a DRC country version, we give an even-handed assessment of which fits their landscape and release calendar.

This country update is provided for general information only and does not constitute tax, legal or professional advice.