KPO Knjiga vs Bank Statement: Why the Two Totals Differ

Last updated: August 2026. This guide reflects the Zakon o porezu na dohodak građana (consolidated through "Sl. glasnik RS", br. 6/2026), the Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon), and the Poreska uprava's published answer on how total turnover is counted, carried by Paragraf on 29 January 2026.

Neither total is wrong

A KPO total and a bank total are not two measurements of the same quantity, so a gap between them is the normal state rather than an error. The KPO knjiga is a register of invoices issued for your registered activity. The bank statement is a register of money that moved through one account, in both directions, for any reason at all.

The two overlap only in the middle: invoices you issued that were paid inside the period you are looking at. Everything outside that overlap is a legitimate difference.

The first question is not where the mistake is, but whether one exists. Almost every KPO-versus-bank gap traces to one of the eight causes below.

What the KPO actually holds

The KPO knjiga carries one category of data: prihodi od prodatih proizvoda i izvršenih usluga — revenue from goods sold and services performed (Pravilnik čl. 7). It is the only business book a paušalac is required to keep (ZPDG čl. 43 st. 4).

The prescribed columns are these five:

There is no expense column, no balance, no counterparty field and no account number. A paušalac deducts nothing — the standardised cost allowance is already inside the assessed base in your rešenje — so cost data has nowhere to go in this book.

Each entry must rest on a verodostojna knjigovodstvena isprava, a reliable accounting document (ZPDG čl. 46). The book is kept at the business premises, or at the accounting firm if you outsource it (ZPDG čl. 47), and retained for at least 5 years from the last day of the business year (ZPDG čl. 48).

For the mechanics of the book itself — storno lines, chronology, electronic format — see the KPO guide.

Which date an entry carries

The KPO entry belongs to the period of the business transaction, not to the period of the collection. The Poreska uprava was asked exactly this and answered in print on 29 January 2026: total turnover in a calendar year is made up of income from the activity realised in that period — "(periodu kada je izvršen promet dobara i/ili usluga) i kada je ta poslovna promena dokumentovana (izdat račun) i evidentirana u knjizi o ostvarenom prometu, nezavisno od okolnosti da li je i kada realizovana naplata potraživanja po tom osnovu".

Read the contrast it actually draws: invoice against collection, not invoice against supply date. The period is the one in which the supply was performed, and documented by an issued invoice, and entered in the book.

In ordinary service work those fall together, and the date written in the datum i opis knjiženja column is the invoice date.

An invoice issued on 20 December 2026 and paid on 14 January 2027 is therefore 2026 revenue in the KPO and a 2027 credit on the statement. Both records are correct, and this is why a December-heavy business shows a KPO total above its bank credits.

The mirror case: a January 2026 credit paying a December 2025 invoice belongs to the 2025 KPO and must not be entered again.

One caveat on the source. It is a published answer to a press question, not a numbered mišljenje, so it carries the tax authority's stated reading rather than the force of a binding act. It is also the only direct statement any authority has made on the point.

The 6,000,000 limit is counted on invoices issued

Both statutory thresholds are turnover measures, not cash measures.

For the 6,000,000 RSD limit the point is settled by the answer quoted above: the revenue counts in the year the supply was made and the transaction was documented and recorded, whether or not it was ever collected. An unpaid December invoice still consumes headroom, and a January payment for it does not consume headroom twice.

That answer addresses the paušal limit specifically. It does not restate the VAT rule, but the practical instruction is the same: check the 8,000,000 RSD threshold against your invoice list rather than your bank credits, and remember that crossing it triggers an evidenciona prijava within 5 days (ZPDV čl. 38 st. 1).

The two counts are not built from the same invoices. ZPDV čl. 33 st. 6 limits ukupan promet to the supplies in čl. 28 st. 1 t. 1) and 2) — those taxed in Serbia and those exempt with credit under čl. 24 — and leaves out t. 3), a supply performed abroad.

A service to a business client established outside Serbia has its place of supply in the client's country (ZPDV čl. 12 st. 4). It generally stays outside the 8,000,000 RSD count while counting in full towards the 6,000,000 RSD one.

Čl. 12 sets special rules for particular categories of service, so check an unusual one rather than assuming. Both thresholds are set out in the revenue-limits guide.

One category drops out of the 6,000,000 RSD count entirely: income taxed as drugi prihodi under ZPDG čl. 85 st. 1 t. 17 after a failed independence test does not count towards it (ZPDG čl. 40 st. 5).

Eight reasons the two totals legitimately differ

Three deserve more than a table row.

Bank fees (5). When a correspondent or receiving bank deducts a charge from an incoming payment, the KPO entry is still the amount you invoiced. The fee is a cost, and a paušalac records no costs. The gap between the KPO row and the credit line is therefore permanent and expected; note the fee as the reason for the difference rather than adjusting the book.

Multi-leg bookings (7). Statements from some Serbian banks present a single incoming SEPA payment as several ledger legs sharing one reference. This is an observation about how statements read, not a legal rule, but taken at face value it either doubles a payment or splits it into fragments matching no invoice. Take the net of the legs sharing a reference as the payment. The export guide for Raiffeisen XML shows where these appear in the file.

Aggregated payments (8). A client settling three invoices with one transfer produces one credit against three KPO rows. This is what makes total-versus-total reconciliation fail hardest: the sums can be right while nothing lines up.

Preduzmi imports Raiffeisen XML and generic CSV statements, collapses multi-leg SEPA bookings into a single net transaction, and proposes a match between each credit and an open invoice by date and amount; where amounts differ, you record the reason — bank fee, exchange-rate difference, partial payment, rounding. It is not a substitute for an accountant and gives no advice on your situation.

How to reconcile: per invoice, never per total

Work from the invoice side, because the invoice list is the record the law measures.

1. List the KPO rows for the period — your invoices, in order, with their dinar amounts.
2. Find the credit that settled each one. Match on client, amount and reference, not on date alone; the payment date will usually differ from the entry date.
3. Classify each result. Matched exactly; matched with a difference you can name (fee, exchange rate, partial payment, rounding); or not yet paid.
4. Write the reason down for every difference. A named difference is a reconciled item. An unnamed one resurfaces a year later, when nobody remembers the answer.
5. Then look at the statement rows nothing matched. Most of them are not revenue.

A leftover credit is one of three things: a non-revenue inflow, which never goes in the KPO; a payment for an invoice recorded in an earlier period, already counted; or a payment for work you invoiced but forgot to enter.

Only the third is a KPO problem, and the fix is a new entry with the next redni broj, never an edit to an existing row.

Foreign currency: what the law fixes and what it leaves open

The type of rate is fixed by law; the date is not. For bookkeeping and statistics the zvanični srednji kurs of the National Bank of Serbia applies (ZDP čl. 41 st. 2). Applying the buying rate, the selling rate or the rate your bank used is a prekršaj, and for a preduzetnik it carries 150,000 to 500,000 RSD (ZDP čl. 61 t. 37).

Which date's rate a non-VAT paušalac should use is prescribed nowhere. The three places you would expect to find the rule do not contain it:

• ZPDV čl. 22 ties conversion to the day the tax liability arises, but it governs the VAT base and binds VAT payers, not a paušalac outside the VAT system.
• The Zakon o računovodstvu does not reach him: it defines preduzetnici as those keeping double-entry books (čl. 2 t. 3), and a paušalac keeps only the KPO.
• The KPO pravilnik (čl. 7) sets out no recognition basis, no conversion rule and no rate date.

The common practice is to convert at the middle rate on the invoice date, or on the supply date where the two differ. That is practice, not a rule. The 29 January 2026 answer settles which period the entry falls in; it says nothing about which day's rate converts it.

Pick one basis, apply it to every invoice, and keep the rate you used with the invoice. Whichever date you choose, the bank credits you at its own rate on its own value date, and that difference is a kursna razlika rather than an error in either record. Incoming foreign payments are covered in the foreign-currency guide.

What an inspection compares

An inspector works with three documents: the KPO, the invoices behind it, and the bank statements for the same period.

The KPO-to-invoice tie has to be exact, and the rulebook builds the link in both directions — the redni broj of the entry must also appear on the underlying document (Pravilnik čl. 7). The KPO-to-statement tie is explanatory rather than arithmetic: you are expected to say why a credit differs from an invoice, not to make the annual totals equal.

Failing to keep the required books, or to produce them on request, carries a fine of 50,000 to 500,000 RSD for a preduzetnik (ZPPPA čl. 178b st. 2). ZPDG prescribes no separate offence for the KPO; the sanction runs through ZPPPA.

Key takeaways

1. A KPO total and a bank total measure different things, so a difference is expected and usually needs no correction.
2. The KPO is dated by the transaction, not by the collection, per the Poreska uprava's answer of 29 January 2026 — turnover falls in the period in which the supply was performed, documented by an issued invoice and recorded in the book, whether or not it was ever paid.
3. The 6,000,000 RSD paušal limit counts invoices issued (ZPDG čl. 40 st. 2 t. 4), so an unpaid December invoice consumes headroom and its January payment does not consume it again.
4. Non-revenue credits and every debit row belong to the statement alone — the KPO holds only revenue from goods sold and services performed (Pravilnik čl. 7).
5. Reconcile invoice by invoice and name every difference; totals that agree by coincidence hide errors per-invoice matching exposes.
6. The rate type is fixed and the rate date is not — the zvanični srednji kurs is mandatory (ZDP čl. 41 st. 2, and a preduzetnik applying another rate faces 150,000 to 500,000 RSD under čl. 61 t. 37), while no rule sets the date for a non-VAT paušalac. Converting on the invoice or supply date is practice.
7. Revenue from foreign business clients counts towards the 6,000,000 RSD limit but generally not towards the 8,000,000 RSD VAT threshold, because that count covers only supplies taxable in Serbia (ZPDV čl. 33 st. 6, read with čl. 28 st. 1 and čl. 12 st. 4).
8. Keep the book and its documents for at least 5 years (ZPDG čl. 48); failing to produce them carries a fine of 50,000 to 500,000 RSD (ZPPPA čl. 178b st. 2).

Frequently asked questions

Why does a Serbian paušalac's KPO knjiga total not match the bank statement total?

Because the two records measure different things. The KPO knjiga counts invoices issued for the registered activity, while the bank statement counts every movement of money through the account in both directions. Timing differences, unpaid invoices, non-revenue credits, outgoings, bank fees, currency conversion and aggregated payments all produce legitimate gaps. A difference is the normal state, not evidence of an error.

Does a paušalac record the invoice date or the payment date in the KPO knjiga?

The invoice date, not the payment date. A Poreska uprava answer published on 29 January 2026 puts turnover in the period in which the supply was performed, the transaction was documented by an issued invoice, and it was recorded in the book, regardless of whether and when the receivable was collected. The date the client's money lands in the account does not determine the KPO entry. That is why a December invoice paid in January sits in two different years on the two records.

Is the 6,000,000 RSD paušal limit counted on invoices issued or on payments received?

On invoices issued. ZPDG čl. 40 st. 2 t. 4 sets the limit on total turnover in the preceding year, and the Poreska uprava answer of 29 January 2026 confirms that turnover is counted when the transaction is documented and recorded, not when it is collected. An unpaid invoice still consumes your headroom. Several published guides state the opposite, and the tax authority's own answer contradicts them.

Should a paušalac enter a transfer from a personal account into the KPO knjiga?

No. The KPO holds only revenue from goods sold and services performed under the registered activity, as prescribed by čl. 7 of the Pravilnik. Money moved from your own personal account, a loan, a refund from a supplier and a reversed transaction are all credits on the statement that never belong in the book. Recording them inflates your apparent turnover and pushes you artificially towards the revenue limits.

How does a paušalac reconcile a bank statement with the KPO knjiga?

Per invoice, never per total. List the KPO entries for the period, find the credit that settled each one by client, amount and reference rather than by date, then classify each result as matched exactly, matched with a nameable difference, or unpaid. Write down the reason for every difference. Finally, look at the statement rows nothing matched, which are usually non-revenue inflows or payments for invoices already recorded in an earlier period.

What does a paušalac record in the KPO when the bank deducts a fee from an incoming payment?

The invoiced amount, not the net credit. A bank charge is a cost, and a paušalac records no costs in the KPO because the standardised cost allowance is already inside the assessed base in the rešenje. The result is a permanent gap between the KPO row and the credit line, and the correct response is to note the fee as the reason for the difference rather than to adjust the entry.

Which exchange rate date does a Serbian paušalac use for a foreign-currency invoice in the KPO?

The law does not prescribe one. The type of rate is fixed, because the zvanični srednji kurs of the National Bank of Serbia applies for bookkeeping and statistics under ZDP čl. 41 st. 2 and applying a different rate is a prekršaj. No rule sets the date for a non-VAT paušalac: the VAT law's conversion rule binds VAT payers, the accounting law covers only entrepreneurs keeping double-entry books, and the KPO pravilnik prescribes no conversion rule at all. Common practice is the middle rate on the invoice or supply date, which is practice rather than law, so choose one basis, apply it consistently, and keep the rate you used together with the invoice.

Does a paušalac have to enter unpaid invoices in the KPO knjiga?

Yes. The entry follows the transaction and its invoice, not the collection, so an invoice that is never paid is still recorded and still counts towards the 6,000,000 RSD limit. This is the main reason a KPO total can legitimately exceed the money that reached the bank account. If the invoice is later cancelled, the correction is a storno line with the next sequential number, never an edit to the original row.

Is there a deadline for a paušalac to enter an invoice in the KPO knjiga?

No per-entry deadline applies to the KPO. The often-quoted rule requiring an entry by the following day comes from ZPDG čl. 45, which is addressed to a preduzetnik poljoprivrednik and a preduzetnik drugo lice, not to a paušalac. Entries must still be sequential, documented by a reliable accounting document under ZPDG čl. 46, and available when the tax authority asks for them.

Does a paušalac have to close and print the KPO knjiga at the end of the year?

No. There is no prescribed closing procedure and no statutory closing date for the KPO, because čl. 13 st. 1 of the Pravilnik prescribes closing only for the PK-1 book. Totalling and signing at 31 December is sensible practice rather than a legal requirement. Printing is not routinely required either, since the book may be kept on a data-processing medium provided it can be printed or displayed on screen on request.

Sources

• Zakon o porezu na dohodak građana — čl. 40, 43, 45, 46, 47, 48 and 85 ("Sl. glasnik RS", consolidated through br. 6/2026)
• Pravilnik o poslovnim knjigama i iskazivanju finansijskog rezultata po sistemu prostog knjigovodstva — čl. 4, 7 and 13 ("Sl. glasnik RS", br. 140/2004 i 44/2018 – dr. zakon)
• Poreska uprava's answer on how total turnover is counted, published 29 January 2026 — carried by Paragraf from Biznis i finansije, 27 January 2026
• Zakon o porezu na dodatu vrednost — čl. 12 st. 4, čl. 22, čl. 28 st. 1, čl. 33 and čl. 38
• Zakon o deviznom poslovanju — čl. 41 st. 2 (zvanični srednji kurs) and čl. 61 t. 37 (the prekršaj for applying another rate)
• Poreska uprava — Preduzetnici paušalci
• Narodna banka Srbije — zvanični srednji kurs