Mirovanje vs Brisanje: Pausing or Closing a Serbian Paušal Business

Last updated: August 2026. This guide reflects the Zakon o privrednim društvima ("Sl. glasnik RS", br. 36/2011 … 109/2021), the Zakon o doprinosima za obavezno socijalno osiguranje, the Zakon o porezu na dohodak građana (consolidated through "Sl. glasnik RS", br. 6/2026), and APR's Odluka o naknadama ("Sl. glasnik RS", br. 95/2025), applicable from 1 January 2026.

Pause or close: the decision in one table

The practical difference is reversibility. A prekid leaves your APR registration, PIB, KPO knjiga and business bank account exactly where they are; brisanje removes you from the register and cannot be undone.

Pausing and closing cost the same at the counter. The difference appears only if you later want to trade again: a new preduzetnik registration is a fresh 2,500 RSD filing under the same Odluka o naknadama.

Mirovanje: what a registered prekid actually stops

A registered prekid suspends the obligation to pay social contributions. ZDOSO čl. 50 st. 1 reads: "Preduzetniku koji prekine obavljanje delatnosti u skladu sa zakonom, obaveza plaćanja doprinosa miruje u periodu u kojem ne obavlja delatnost." Stav 2 of the same article adds the option to continue: "Preduzetnik iz stava 1. ovog člana može nastaviti plaćanje doprinosa i u periodu u kojem ne obavlja delatnost."

You do not have to close the business to stop the monthly PIO, health and unemployment contributions.

No 30-day tax return falls due on a prekid either. ZPDG čl. 94 st. 3 puts that return on an obligor who ceases or interrupts the activity, and then excludes paušalci by name — "osim preduzetnika paušalca".

Two qualifications matter. First, the suspension attaches to the registered prekid, not to the fact that you stopped working — quietly not invoicing changes nothing about your obligations. Second, the voluntary continuation in stav 2 exists for a reason: contributions are what keep pension staž and health cover running, and the trade-off is set out in health insurance and pension for paušalci.

What the pause touches, and what it leaves alone:

A prekid does not retire the KPO knjiga: it stays part of your records, and the retention clock in ZPDG čl. 48 runs regardless. See the KPO knjiga guide for what the format has to preserve.

Registering a prekid with APR

A prekid is filed as an ordinary change of registered data. The steps, in order:

1. Post the notice. ZPD čl. 90 obliges the entrepreneur to display a notice about the period of suspension at the place where the activity is performed.
2. File the registraciona prijava promene podataka with APR, together with Dodatak 06 — the annex used for a temporary suspension.
3. Pay 1,400 RSD. This is the standard promena podataka fee (Odluka o naknadama, "Sl. glasnik RS", br. 95/2025, čl. 8 i 9). Additional changes bundled into the same application are charged 700 RSD each.
4. Wait up to 5 radnih dana for the registrar's decision. That deadline binds APR, not you — there is no statutory deadline by which you must register a change.
5. File the eko taksa status change within 15 days with your local tax administration (čl. 138 st. 3). See eko taksa for the form and the office.

No tax clearance certificate is needed for a prekid — that requirement belongs to brisanje only. And the start date cannot be moved backwards: ZPD čl. 90 states that a prekid "se registruje u skladu sa zakonom o registraciji i ne može se utvrđivati retroaktivno". If you stopped working in March and file in July, the months in between were active months.

One blocking condition: APR cannot register changes while a tax audit is in progress or while the PIB is temporarily revoked (ZPPPA čl. 29). If you are mid-audit, the prekid waits.

Duration and repetition of a prekid

ZPD čl. 90 sets no maximum duration for a prekid and no limit on how many times it may be repeated. The article contains two obligations only — post the notice, register the suspension — and one prohibition, that it cannot be established retroactively.

A "two-year maximum" is republished across Serbian and Russian-language sites. That cap does not appear in the text of ZPD čl. 90, and it was not located elsewhere during this research — but "not found" is not the same as "verified as absent". If you are planning a multi-year pause, put the question to APR first.

A different two-year rule does exist, and the two get confused. Under ZPD čl. 91 st. 6 t. 3, an entrepreneur ceases to perform the activity po sili zakona if the business account has been blocked continuously for more than two years, on an initiative to start the deletion procedure filed by the Narodna banka Srbije or the Poreska uprava. The registrar then publishes a notice on the register's website, gives 90 days to unblock the account or remove the cause (st. 7), and after a further 30 days deletes the entrepreneur ex officio (st. 8).

That is the real risk of the informal pause — walking away without registering anything, letting obligations accrue, and having the register close the business for you on someone else's timetable.

Brisanje: closing the business for good

The order of steps is what people get wrong: tax clearance first, APR second. The registrar does not obtain the certificates ex officio, so a deletion application filed without them goes nowhere.

APR requires, for the deletion of an entrepreneur:

No separate statutory deadline governing the final settlement of paušal dues on closure was located in ZPDG. The operative constraint is the certificates: both expire five days after issue, so the clearance, the notary step (if you file electronically) and the APR filing all have to fit inside one short window.

Deletion also cannot reach backwards. ZPD čl. 91 is explicit on both halves of this: "Preduzetnik odjavu ne može izvršiti sa danom koji je raniji od dana podnošenja prijave o prestanku rada nadležnom registracionom organu", and "Brisanje iz registra se ne može vršiti retroaktivno."

What a paušalac does not have to file when closing

A paušalac files no final tax return on cessation of activity. ZPDG čl. 94 st. 3 prescribes the 30-day return for an obligor who prestane, odnosno prekine the activity — cessation and suspension alike — but only for obligors "osim preduzetnika paušalca". That is, for knjigaši, not for you. The claim that every closing entrepreneur owes a 30-day final return is one of the most repeated errors on this topic.

A paušalac also files no vanredni finansijski izveštaj. That obligation applies only to entrepreneurs who keep business books. A paušalac keeps only the KPO knjiga, so there is no financial statement to submit.

What you do owe is settlement. Every monthly obligation up to the cessation date must be paid before the certificates can be issued, so reconciling your stanje na kartici in ePorezi against your own payment record — see monthly tax payments — is the first move, not the last.

What survives the deletion

Two things outlive the business.

Your records. ZPDG čl. 48 requires books and records to be kept at least 5 years from the last day of the business year they relate to. Deletion from the register does not shorten that. Keep the KPO knjiga, the invoices and the rešenja for the full period.

Eko taksa in both procedures

The eko taksa fee is not charged for the duration of a registered prekid — Zakon o naknadama čl. 138a st. 1 t. 2 — but the filing obligation remains. Under čl. 138 st. 3, a change of status, including the start of a registered prekid and the cessation of the business, is filed with the local tax administration within 15 days of registering the change.

This is where old debts surface. An LPA that never received the change filings keeps assessing the fee, and the arrears appear exactly when you need a clean local-tax certificate to close. Full procedure: the eko taksa guide. Annual dates: the compliance calendar.

The maternity timing trap

Contact RFZO before filing a prekid where a maternity benefit is intended. APR states this explicitly in its own guidance, because the start date you register determines how the benefit is calculated — and, per ZPD čl. 90, it is the one thing that cannot be corrected afterwards.

The general rules for maternity and sick-leave entitlements are in health insurance and pension for paušalci. The timing question belongs to RFZO, before the APR filing.

Key takeaways

1. A registered prekid suspends social contributions under ZDOSO čl. 50, with an express option to keep paying voluntarily. Closing is not the only way to stop the monthly contributions.
2. Both procedures cost 1,400 RSD at APR from 1 January 2026; a fresh registration afterwards costs 2,500 RSD. Figures of 850, 750 or 1,600 RSD circulating online are pre-2026.
3. A prekid needs no tax clearance; brisanje needs two certificates, each no more than 5 days old, and the registrar does not obtain them for you.
4. Neither a prekid nor a deletion can be backdated — ZPD čl. 90 and čl. 91 both say so in terms.
5. Filing brisanje electronically requires a notary (or an attorney who is the applicant) to digitalise the paper PU certificate; self-digitalisation gets the application rejected.
6. A paušalac owes no final tax return and no vanredni finansijski izveštaj on closure — ZPDG čl. 94 st. 3 excludes paušalci from the 30-day return.
7. Settle everything before deletion: ZPDG čl. 157 st. 3 requires every tax obligation to be met before the register entry goes, and čl. 157 st. 2 makes adult household members subsidiarily liable with their own property for the porez na prihode od samostalne delatnosti.

Preduzmi tracks which obligations stay live through a pause and which fall away, so your calendar reflects your actual status. It does not replace an accountant or a lawyer where a closure is contested, a tax audit is open, or a benefit entitlement turns on the exact start date.

Frequently asked questions

Does a Serbian paušalac pay contributions during mirovanje?

No. Under ZDOSO čl. 50, the obligation to pay social contributions is suspended for the period in which a registered entrepreneur does not perform the activity, and the same article expressly allows the entrepreneur to keep paying voluntarily. The suspension is tied to the prekid being registered with APR, not to the fact that you stopped invoicing. Voluntary payment is the route to keeping pension staž accruing through the pause.

How does a Serbian entrepreneur register mirovanje with APR?

You file a registraciona prijava promene podataka with APR together with Dodatak 06, the annex used for a temporary suspension of activity, and pay the 1,400 RSD fee in force from 1 January 2026. No tax clearance certificate is required for a prekid. The entrepreneur must also post a notice about the suspension period at the place where the activity is performed, as required by ZPD čl. 90. APR decides within five working days.

How long can mirovanje of a Serbian entrepreneur last?

ZPD čl. 90 sets no maximum duration and no limit on how many times a prekid may be repeated; it requires only that the suspension be registered and that notice be posted at the place of business. A two-year cap is widely republished online, but it does not appear in the text of that article. Not finding a cap is not the same as proving that none exists anywhere in Serbian law, so confirm with APR before planning a very long pause.

How much does it cost to pause or close a paušal business at APR in 2026?

Registering a prekid costs 1,400 RSD, because it is filed as a registracija promene podataka, and brisanje also costs 1,400 RSD. Registering a new entrepreneur costs 2,500 RSD, which is what you would pay if you close now and start again later. These amounts come from APR's Odluka o naknadama published in Sl. glasnik RS br. 95/2025 and apply from 1 January 2026. Figures of 850, 750 or 1,600 RSD still circulating online are pre-2026 and no longer correct.

Does a Serbian paušalac file a final tax return when closing the business?

No. The 30-day return in ZPDG čl. 94 st. 3 covers an obligor who ceases or interrupts a self-employed activity, but it is addressed to obligors other than a paušalac, in the statutory wording osim preduzetnika paušalca. A paušalac is also not required to file a vanredni finansijski izveštaj, because that obligation applies only to entrepreneurs who keep business books. What must happen before deletion is settlement of the outstanding tax and contributions, which is exactly what the clearance certificates prove.

What documents does APR require to delete a Serbian entrepreneur from the register?

APR requires the deletion application, proof that the 1,400 RSD fee was paid, a Poreska uprava certificate showing no outstanding porez na prihode od samostalne delatnosti and PIO contributions, and the same kind of certificate from the local tax administration. Both certificates may be no more than five days old when the application is filed. The registrar does not obtain them ex officio, so you collect them first. Deregistration from the VAT register is checked ex officio and is a precondition.

Can a Serbian entrepreneur file the brisanje application electronically?

Yes, but there is a trap in it. The Poreska uprava certificate is issued on paper only, and for an electronic application it must be digitalised by a notary, or by an attorney who is also the applicant. If you scan and digitalise it yourself, the application is rejected. Plan the notary step into the schedule before you start the electronic filing, because the certificate is also only five days valid.

Does a Serbian paušalac pay eko taksa during a registered prekid?

No fee is charged for the duration of a registered prekid under čl. 138a st. 1 t. 2 of the Zakon o naknadama za korišćenje javnih dobara, but the filing obligation itself remains. A change of status, including the start of a registered prekid and the cessation of the business, must be filed with the local tax administration within 15 days of registering the change, under čl. 138 st. 3. Skipping that filing is the usual reason old eko taksa debts surface when someone finally tries to close the business.

Can mirovanje or brisanje of a Serbian entrepreneur be backdated?

No, in neither case. ZPD čl. 90 states that a prekid is registered under the registration law and cannot be established retroactively. For closure, ZPD čl. 91 states that an entrepreneur cannot deregister with a date earlier than the day the cessation application was filed with the registration authority, and that deletion from the register cannot be carried out retroactively. Any period before the filing date therefore still counts as an active business.

Who is liable for a Serbian entrepreneur's unpaid taxes after brisanje?

ZPDG čl. 157 st. 3 requires an entrepreneur who ceases the activity to settle every tax obligation arising from it before deletion from the register, and makes anyone who takes over the business assets jointly and severally liable for those obligations up to the value of what was taken over. Separately, ZPDG čl. 157 st. 2 makes all adult members of the entrepreneur's household subsidiarily liable with their own property for the porez na prihode od samostalne delatnosti, the household being the one that existed when the obligation arose. Subsidiary liability means the tax authority turns to them only where the obligation cannot be collected from the entrepreneur. This is the strongest practical reason to reconcile every tax account before filing for deletion rather than after.

Sources

• Zakon o privrednim društvima — čl. 90 (prekid obavljanja delatnosti, no retroactive registration), čl. 91 (gubitak svojstva preduzetnika, no retroactive deletion, ex officio deletion after a two-year account block). "Sl. glasnik RS", br. 36/2011, 99/2011, 83/2014 – dr. zakon, 5/2015, 44/2018, 95/2018, 91/2019 i 109/2021.
• Zakon o doprinosima za obavezno socijalno osiguranje — čl. 50 (contribution obligation suspended during a prekid; voluntary continuation).
• Zakon o porezu na dohodak građana — čl. 48 (5-year record retention), čl. 94 st. 3 (30-day return on cessation or interruption, excluding paušalci), čl. 157 st. 2 (subsidiary liability of adult household members for the porez na prihode od samostalne delatnosti), čl. 157 st. 3 (settlement before deletion; joint liability of a transferee of the business assets).
• Zakon o naknadama za korišćenje javnih dobara — čl. 138 st. 3 (15-day status-change filing), čl. 138a st. 1 t. 2 (no fee during a registered prekid).
• APR — registracija promena za preduzetnike — the prijava promene podataka and Dodatak 06.
• APR — brisanje preduzetnika — required documents, the 5-day certificate rule, the notarial digitalisation requirement for electronic filing.
• APR — naknade za preduzetnike — Odluka o naknadama, "Sl. glasnik RS", br. 95/2025, applicable from 1 January 2026.