On March 12, 2025, the Rulebook on Electronic Dispatch Notes (“Rulebook“) was adopted, providing detailed regulation of the provisions and issues arising from the new Law on Electronic Dispatch Notes (“Official Gazette of the Republic of Serbia,” No. 94/2024, “Law“), which came into force on December 6, 2024. Given that this is a newly enacted regulation introduced to establish a centralized system of electronic dispatch notes, enabling the exchange of dispatch notes in a standardized digital format, the adoption of this Rulebook was necessary to clarify all potential ambiguities in the application of the Law. The Rulebook shall apply as of January 1, 2026.
The Rulebook primarily provides a detailed description of the procedural aspects of applying the Law, prescribing the manner of accessing and using the e-dispatch note system, including registration procedures, the format and method of data entry, transmission, receipt, storage of e-dispatch notes, and handling e-dispatch notes during inspection procedures, among other aspects.
Any entity wishing to use the e-dispatch note system must register via the web interface. Registration is available only to entities possessing a Tax Identification Number (TIN). Registration can be completed through the electronic invoicing system (if the entity is already a registered user) or via direct registration – in the web interface, the entity must enter its type (e.g., company, entrepreneur, association, etc.) and its identification number. The entity becomes a system user on the date of registration. Notably, transport companies, as system users, have the option of using the system through a mobile application specifically designed for transport enterprises.
The list of system users includes the TIN, Unified Register of Public Funds Users (JBKJS) number, registration date, and date of removal from the user list – the central information intermediary may remove a user from the list either ex officio or at the request of the user.
Articles 12-16 of the Rulebook prescribe the minimum content requirements for an electronic dispatch note necessary for processing within the e-dispatch note system. Additionally, if an e-dispatch note is issued for tracking the movement of hazardous materials, it must include a hazardous materials designation. If it is issued for tracking the movement of excise goods, it must include the excise category name.
The sender of an e-dispatch note may assign it the status of “issued” or “canceled.” Automatically, an e-dispatch note may be assigned one of the following technical statuses: draft/sent/invalid.
When the recipient of an e-dispatch note physically receives the goods, they may generate an electronic receipt note, specifying the receipt note number, the expected quantity, and the received quantity of each individual item listed in the electronic dispatch note. The recipient assigns a corresponding status to the electronic receipt note in the system: “accepted” or “rejected.” If the status “accepted” is assigned to the electronic receipt note, the corresponding electronic dispatch note is automatically assigned the status “reconciled.”
Electronic dispatch notes and electronic receipt notes must be stored in a manner that ensures the authenticity of their origin and the integrity of their content.
The central information intermediary manages the system and is responsible for its operation. The central information intermediary also facilitates access to a mobile application for control purposes, enabling authorized personnel to conduct inspection oversight of the electronic dispatch note system.
For additional information or consultations, the Tasić & Partners team is at your disposal.