Download frequently asked questions
15 most frequently asked questions
- When attempting to log in, a notification appears that I am not an authorized user, even though I have written authorization from the director of the company/institution. What is the problem?
In accordance with the provisions of the Rules on the method and procedure for registering for access to the electronic invoice system, the method of accessing and using the electronic invoice system and the method of using data available in the electronic invoice system, registration for access to the electronic invoice system is exclusively carried out by the legal representative of the business entity, or the business entity itself in the case where the business entity is a natural person. This means that, for business entities, registration can only be carried out by a person registered in the appropriate register of the Business Registers Agency as the legal representative of the legal entity. Similarly, in state administration bodies, registration can only be carried out by the person who, by law, manages the body. - I am the legal representative of several companies, how do I register for each company in the electronic invoice system?
In accordance with the provisions of the Regulations on the method and procedure for registering for access to the electronic invoice system, the method of accessing and using the electronic invoice system and the method of using data available in the electronic invoice system, when registering for the electronic invoice system, it is allowed to enter multiple companies in which a specific natural person is the legal representative. On the electronic invoicing system control panel, in the upper right corner, by clicking on the company name, the user opens a window with the option "add new company". - How do I add a user or delete a user from the electronic invoice system?
In accordance with the provisions of the Regulations on the method and procedure for registering for access to the electronic invoice system, the method of accessing and using the electronic invoice system and the method of using data available in the electronic invoice system and the internal technical instructions for using the system, deleting added users in the electronic invoicing system is not provided for, but changing the user status to "inactive" is provided for. Therefore, by changing the status of a specific user from "active" to "inactive", their account is deactivated. - Can an administrator be someone who is not a legal representative?
A legal representative can assign the role of "administrator" to another user through the system who does not have to be a legal representative. - How will foreign companies doing business with companies in the Republic of Serbia use the electronic invoice system? How can a legal representative who is a foreign citizen register and log in to the electronic invoice system?
In accordance with the provisions of the Regulation on the method and procedure for registering for access to the electronic invoice system, the method of accessing and using the electronic invoice system and the method of using data available in the electronic invoice system, in order to access the electronic invoice system, the user must have an electronic identification (eID). Only after that, the user can log in to the electronic invoice system.
More information regarding the registration of foreign citizens to the electronic identification portal can be found at : www.eid.gov.rs. - Do we have to create an eID account again even though we already have an eGovernment account?
You don't have to. An eGovernment account also applies to an eID. Important note: the electronic invoice system requires two-factor authentication or authentication with a qualified electronic certificate, so the account needs to have a high level of login trust (more information at: https://eid.gov.rs) . - Is our institution (primary school, secondary school, health center, local community, etc.), given that it does not have an outgoing invoice, obliged to use the Electronic Invoice System?
Yes, since it belongs to the group designated as the general level of the state in the sense of the law regulating the budget system, or a public enterprise in the sense of the law regulating public enterprises, which is not covered by the general level of the state. The Law on Electronic Invoicing ("Official Gazette of the Republic of Serbia", No. 44/2021, 129/2021) provides for the phased introduction of the obligation to issue and receive electronic invoices. First, on May 1, 2022, the obligation of a public sector entity to receive and store an electronic invoice, as well as the obligation to issue an electronic invoice to another public sector entity, will come into effect. At the same time, the obligation of a private sector entity to issue an electronic invoice to a public sector entity will come into effect. The obligation of a private sector entity to receive and store an electronic invoice issued by a public sector entity, as well as electronic invoices issued by a private sector entity, applies from 1 July 2022. Finally, the obligations to issue and store an electronic invoice in transactions between private sector entities come into effect from 1 January 2023. - We are registered in the Register of Users of Public Funds. Do the obligations under the Law to use the electronic invoice system in accordance with the deadlines for public entities or private sector entities apply to us?
Belonging to a certain group of users of public funds is not a fact of importance for the start of the application of the obligations under the Law on Electronic Invoicing, but rather a criterion for whether it is a public or private sector entity (defined in Article 2 of the Law on Electronic Invoicing). If you have a dilemma as to whether your organization or company is a public or private sector entity, the correct way would be to contact the Ministry of Finance with a request for an expert opinion in accordance with the described procedure: https://mfin.gov.rs/sr/usluge-1/davanje-strunog-miljenja-1 . - The mayor is the legal representative of the municipality. Does the person who opens the first account always have to be the legal representative (of the user of public funds, e.g. municipality, directorate, local community, etc.)?
Only the legal representative (in the case of a municipality – the mayor) can open the first account for a unique number of users of public funds that designates that municipality. Similarly, given the fact that local communities have the status of legal entities, the president of the local community council, as the legal representative, opens the first account for the local community. - When does the obligation of the private sector to use the electronic invoice system come into force?
The Law on Electronic Invoicing provides for a phased introduction of the obligation to issue and receive electronic invoices. First, on May 1, 2022, the obligation of a private sector entity to issue an electronic invoice to a public sector entity will come into force. The obligation of a private sector entity to receive and store an electronic invoice issued by a public sector entity, as well as electronic invoices issued by a private sector entity, will apply from July 1, 2022. Finally, the obligations to issue and store electronic invoices in transactions between private sector entities will come into force from January 1, 2023. - Is bulk entry and sending of invoices in XML format supported?
If you access the electronic invoice system directly, bulk entry and sending of invoices in XML format is not supported. - Will the Central Invoice Registry portal still be in use?
The electronic invoice system automatically registers invoices whose recipient is a public sector entity in the Central Invoice Registry. The Central Invoice Registry will no longer be accessed directly. - Who can perform the activities of an information intermediary?
In accordance with the provisions of the Regulation on the procedure and conditions for granting and withdrawing consent to perform the activities of an information intermediary, consent to perform the activities of an information intermediary may be obtained by a legal entity that meets the following conditions:
1) that the legal entity is registered in the Republic of Serbia;
2) that on the date of submitting the application, there are no outstanding public revenue obligations based on the performance of the activity, as determined by the Tax Administration;
3) that there is no legal or other representative who has been legally convicted of a criminal offense against property, economy, computer data security, state bodies, legal traffic and against official duty;
4) that as a legal entity, it has not been legally convicted of a criminal offense;
5) to apply protection measures relating to the operator of ICT systems of special importance and to have adopted an act on the security of ICT systems of special importance in accordance with the regulations governing information security;
6) to have not previously been revoked the consent to perform the tasks of an information intermediary;
7) to have adopted an act on the general conditions for providing information intermediary services;
8) to have adopted an act on the internal rules for providing information intermediary services, which must include the method of storing data within the electronic invoice system and in which the place of storage of such data is determined in the Republic of Serbia.
Article 5 of the Regulation stipulates that, together with the request for obtaining consent to perform the tasks of an information intermediary, evidence of compliance with the above conditions shall be submitted to the Ministry of Finance. At the same time, the body that decides on the request by decision is not prohibited from verifying that the submitted evidence corresponds to the factual situation at the time of the decision. - Is there a list of information intermediaries?
The Register of Information Intermediaries, which, in accordance with the Regulation on the Procedures of the Central Information Intermediary, is maintained by the Central Information Intermediary, does not contain any data, and therefore has not been published. In accordance with the Regulation, the aforementioned register is a publicly available record, and when it contains data, it will be publicly available on the website of the Ministry of Finance. - Is it mandatory to have an information intermediary for sending and receiving electronic invoices?
An information intermediary is not legally required, and the electronic invoice system allows direct access to the system without any fees for end users.