March 13, 2026

Important information regarding obligations related to e-delivery notes

The legal obligation has come into force

Dear clients,

Considering that on January 1, 2026, the Law on Electronic Delivery Notes came into force, and following the successfully conducted training sessions we held, we would like to provide you with additional clarifications and the most important information regarding its implementation.

Who has obligations from January 1, 2026?

Public sector entities:

  • They are required to send and receive e-delivery notes in all cases.
  • If they deliver goods to a private sector entity that is registered in the system, they are required to send an e-delivery note (the private entity is not obligated to receive it before October 1, 2027).

Private sector entities:

They have obligations from January 1, 2026 only in the following cases:
  • if they participate in the movement of excise goods (e.g. fuel, alcohol, coffee, tobacco),
  • if they deliver goods to public sector entities.

For the movement of excise goods, an e-delivery note is mandatory from January 1, 2026, regardless of the type of buyer or seller.

Carriers:

Carriers may have obligations in the e-delivery note system when they are listed as participants in the transport, particularly in cases of capillary transport and the movement of excise goods.

Capillary transport – who issues which e-delivery note:

In situations where the seller engages a transport operator who further organizes the transport (unknown route, multiple vehicles, transshipments):

  • The sender of the goods issues the so-called umbrella e-delivery note (indicating the origin and final destination).
  • The transport operator issues related (internal) e-delivery notes marked as “third-party goods.”
  • After delivery, both e-delivery notes must be closed (physical receipt + electronic receipt confirmation).

This is a common situation in logistics, wholesale, and distribution.

Who has obligations starting from January 1, 2026?

  • Retail sales with a fiscal receipt
  • Supply of water, electricity, gas, and similar utilities
  • Movement of goods within a single public sector entity
  • Deliveries to individuals or entities outside the scope of the Law

Connection between e-delivery notes and e-invoices

  • An e-invoice may, but does not have to, be created based on an e-delivery note.
  • An e-invoice may be issued only after the transaction has occurred in accordance with VAT regulations.
  • The actual date and time of dispatch stated on the e-delivery note must correspond to the actual situation.

Triangular sale (chain supply)

When there are three participants, two invoices, but only one physical movement of goods, the method of issuing e-delivery notes depends on the moment when ownership is transferred:
  • If ownership of the goods passes to the intermediary before the transport → the capillary model is applied (umbrella + related e-delivery note).
  • If ownership passes to the intermediary only upon delivery to the final buyer → two external e-delivery notes are issued, even though there is only one physical movement.

Discrepancy upon receipt of goods

The recipient of the goods may:
  • accept or reject the shipment in full,
  • partially accept the goods (shortage, damage, poor quality).
In case of discrepancies, the differences are recorded through an e-receipt, and it is possible to leave comments per item and attach supporting documents (photos, reports).

Return of goods – most common scenarios

The return of goods is recorded in one of the following ways:
  • return using the same transport with an e-receipt,
  • return using the same transport without an e-receipt (with an internal e-delivery note),
  • subsequent return organized by the recipient or the sender.
If the e-receipt includes the returned quantity, the system enables the option “Create goods return”, which automatically prepares a new e-delivery note.

Mobile applications

For easier work in the field, the following are available:

MATP application – for carriers and own transport (trip overview and trip start),

MAP application – for goods recipients (physical receipt and sending the e-receipt).

Transitional period – initial relief

During the period from January 1, 2026 to June 30, 2026, the so-called relaxation provision applies:

  • the obligation to send and receive e-delivery notes exists,
  • however, errors in the data within e-delivery notes and e-receipts are not penalized.

Note: this relief does not mean that documents do not have to be sent, but only that data errors are tolerated during the transitional period.

⚠️ Penalties

For non-compliance with the obligations, the following financial penalties are prescribed:

  • for legal entities: 200,000 to 2,000,000 RSD,
  • for responsible persons and entrepreneurs: 50,000 to 500,000 RSD, depending on the violation.
If you have questions about how the new rules apply to your specific business operations or would like to verify whether you fall under mandatory application starting from January 1, 2026, we remain at your disposal.

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