Does a Paušalac Need SEF? Serbia's E-Invoicing Rules in Four Questions

Last updated: August 2026. This guide reflects the Zakon o elektronskom fakturisanju ("Sl. glasnik RS", br. 44/2021, 129/2021, 138/2022, 92/2023, 94/2024 i 109/2025) and the Zakon o elektronskim otpremnicama ("Sl. glasnik RS", br. 94/2024 i 109/2025).

The decision in one table

Four questions settle it, asked in this order. The first "yes" is your answer.

Note what is missing from that list: your revenue, your šifra delatnosti, whether your clients are on SEF, and whether you invoice in EUR. None of them create the obligation.

Question 1: VAT registration

A VAT-registered paušalac must use SEF. ZEF čl. 2 st. 1 t. 3 defines a subjekt privatnog sektora as a VAT payer other than a public-sector entity, and čl. 3 and čl. 5 make the system compulsory for private-sector subjects.

This is the single most common route into SEF for an entrepreneur who started outside it. VAT registration is triggered by turnover of more than 8,000,000 RSD over the previous 12 months (ZPDV čl. 33 st. 1), after which you have 5 days to file the evidenciona prijava (ZPDV čl. 38 st. 1).

The 8-million limit and the 6-million paušal limit are different thresholds under different laws, and only the VAT one reaches SEF. Crossing 6,000,000 RSD costs you paušal status; it does not by itself put you on SEF. The two clocks are explained in the guide to the 6-million and 8-million limits.

Question 2: public-sector clients

Invoicing a public-sector body makes SEF mandatory, and the timing is specific. ZEF čl. 2 st. 2 requires registration "pre podnošenja zahteva za isplatu subjektu javnog sektora" — before you submit the payment request to the public-sector body, not after the invoice is issued and not when the money arrives.

This catches paušalci who never expected to be on SEF: one training contract with a school, one design job for a municipality, one consulting engagement for a public agency. A single public-sector counterparty is enough.

The obligation attaches to the transaction, so it is worth deciding before you sign, not after the work is delivered.

Question 3: a voluntary registration you already made

A dobrovoljni korisnik is bound to use SEF in the current and the following calendar year (ZEF čl. 5 st. 7–8). ZEF čl. 2 st. 1 t. 4 defines the category as a taxpayer on income from independent activity — a paušalac — who has registered.

Registration is what creates the duty. Before it, the law does not reach you; after it, you are treated as a private-sector subject under ZEF čl. 2 st. 3. That means every invoice to a counterparty in the system goes through SEF, and you must receive and store incoming electronic invoices as well as issue them.

Question 4: none of the above

A non-VAT paušalac invoicing private domestic clients is not obliged to use SEF (ZEF čl. 3 st. 1, čl. 5 st. 1). He is not a private-sector subject, not a public-sector entity, and not a tax representative of a foreign person — the three categories the obligation is built on.

The practical consequence: you keep issuing ordinary invoices with the non-VAT notation, and you keep recording them in the KPO knjiga. Nothing about SEF changes what the KPO must contain.

Clients on SEF sometimes ask you to send through the system anyway. You can decline, and you can also accept — but accepting means registering, and registering means the lock-in above. It is a contractual question dressed as a technical one.

The CRF correction: the separate registration duty was repealed

There is no separate CRF filing for a paušalac. ZEF čl. 23 repealed the CRF-registration provisions of the Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama — čl. 2 t. 9, čl. 4a st. 1–4, čl. 4b, čl. 4v, čl. 4g and the matching penalty provisions in čl. 12 — with effect from 30 April 2022.

Note the limits of that. The repeal is partial: the rest of that law, including the payment deadlines it sets for commercial transactions, is still in force. What disappeared is the duty to register an invoice in the Centralni registar faktura as a step of its own, and the creditor deadline attached to it.

The register itself still exists and is now fed from the electronic invoice — ZEF's 138/2022 transitional provisions refer to "elektronske fakture koje se evidentiraju u centralni registar faktura". If a page tells you to register an invoice in the CRF as a separate action within a few working days of issuing it, it is describing the pre-2022 regime.

For a paušalac invoicing a public-sector body, the sequence is now: register on SEF, issue the electronic invoice, submit the payment request. The CRF entry follows from the SEF record.

Elektronsko evidentiranje: two obligations, and who they bind

Elektronsko evidentiranje obračuna PDV is a separate duty inside SEF, and it is not the same thing as issuing e-invoices. The version of ZEF čl. 4 quoted below has applied to tax periods beginning after 31 December 2024 — in practice, from January 2025 (ZEF, 94/2024, samostalni čl. 14).

For an unregistered non-VAT paušalac, the effect of both is none. There is no monthly filing, no 12th-of-the-month deadline, and nothing to reconcile.

Leaving SEF once you are in

There is no notice period, but there is a lock-in. ZEF čl. 5 st. 8 binds a dobrovoljni korisnik for the current and the following calendar year. The earliest realistic exit is 1 January of the year after the one in which you registered.

The exit is written into the Pravilnik o elektronskom fakturisanju. Čl. 34b names the expiry of the ZEF čl. 5 st. 8 period as one of the grounds for being struck from the lista korisnika.

Čl. 34v says the request goes electronically to the Centralni informacioni posrednik — the unit inside the Ministry of Finance that runs SEF. Professional sources give its address as [email protected].

Verify the current procedure and the current address on efaktura.gov.rs before you send anything — that is your step to confirm, not ours, and the pravilnik is amended every few months.

A VAT-registered paušalac cannot leave at all while VAT registration stands. There the exit is the VAT deregistration, not a SEF request.

E-otpremnice: the dates most pages get wrong

The private-to-private e-otpremnica obligation starts on 1 October 2027, not 1 January 2027. The law is the Zakon o elektronskim otpremnicama ("Sl. glasnik RS", br. 94/2024 i 109/2025), and its čl. 16 sets a separate date for each direction of trade rather than one switch for everybody.

Two dated side-notes come from the 109/2025 amendments, and neither is a phase of the rollout. Formal errors in sent otpremnice and prijemnice are disregarded in supervision from 1 January to 30 June 2026.

The provisions on the paper-form e-otpremnica apply from 1 April 2026. That date is about the paper variant only. It is not, as some summaries have it, the day private-to-public sending began — that was 1 January 2026.

A services-only paušalac is outside the law at every stage. ZEO čl. 2 t. 4 makes a person who is not a VAT payer a subjekt privatnog sektora only where excise goods are involved, and čl. 3 attaches the duty to send to a movement of goods.

If you deliver software, consulting, design, photography or teaching, there is no goods movement to document, so no electronic waybill obligation attaches to you.

The 1 January 2027 date circulating on several accounting blogs is simply wrong, and it has been repeated often enough that it now shows up in AI summaries.

Penalties

For a preduzetnik that is a subjekt privatnog sektora, the fine band is 50,000 to 500,000 RSD (ZEF čl. 18). It covers failures such as not issuing an electronic invoice where one is required and not complying with the rules of the system.

The band applies only to someone inside the scope of the law. For a paušalac that means one of three statuses: VAT payer, supplier to the public sector, or dobrovoljni korisnik. Outside those, there is no SEF obligation to breach.

What changes often, and what does not

SEF mechanics move constantly. The platform has been on version 4.1.0 in production since 2 August 2026, and the Pravilnik o elektronskom fakturisanju was last amended by "Sl. glasnik RS", br. 71/2026, effective 1 August 2026. Screens, XML schemas and API details from a year-old guide are usually stale.

The scope rules have been stable since the 138/2022 amendments. The 109/2025 changes, which apply from tax periods beginning after 31 March 2026, and the deferral of the preliminarna poreska prijava to tax periods beginning after 31 December 2026, do not change a paušalac's position on any of the four questions above.

The practical rule: trust an old article on whether you must be on SEF; verify anything it says about how the screens work.

Key takeaways

1. A non-VAT paušalac invoicing private domestic clients has no SEF obligation — ZEF čl. 3 st. 1 and čl. 5 st. 1 build the duty on categories he does not fall into.
2. VAT registration makes SEF mandatory, because ZEF čl. 2 st. 1 t. 3 defines a private-sector subject as a VAT payer; crossing 8,000,000 RSD over the previous 12 months (ZPDV čl. 33 st. 1) is what usually gets you there.
3. One public-sector client makes SEF mandatory, and registration must happen before the payment request is submitted (ZEF čl. 2 st. 2).
4. Voluntary registration binds you for the current plus the following calendar year (ZEF čl. 5 st. 7–8), and turns you into a private-sector subject who must also receive and store incoming e-invoices (ZEF čl. 2 st. 3).
5. The separate CRF registration duty was repealed as of 30 April 2022 (ZEF čl. 23); the repeal is partial — the payment deadlines in that law stand, and the register is now fed from the electronic invoice.
6. E-otpremnice reach private-to-private trade on 1 October 2027 (ZEO čl. 16 st. 8), while sending to the public sector has been due since 1 January 2026 (čl. 16 st. 5); a services-only paušalac is outside the law at every stage.
7. Whether a voluntarily registered non-VAT paušalac must file monthly evidentiranje obračuna PDV as a reverse-charge tax debtor is unresolved — get a written opinion before you register.

Frequently asked questions

Does a Serbian paušalac have to register on SEF?

In most cases no. A paušalac who is not registered for VAT and invoices only private domestic clients is not a subjekt privatnog sektora under ZEF čl. 2 st. 1 t. 3, so the system of elektronske fakture is not compulsory for him (ZEF čl. 3 st. 1, čl. 5 st. 1). The obligation appears only if he registers for VAT, invoices a public-sector body, or signs up voluntarily. Registering voluntarily is what turns an optional system into a legal duty.

When does SEF become mandatory for a Serbian paušalac?

SEF becomes mandatory in three situations. First, when the paušalac registers for VAT, because ZEF čl. 2 st. 1 t. 3 defines a private-sector subject as a VAT payer and čl. 3 and čl. 5 make the system compulsory for one. Second, when he invoices a public-sector body: ZEF čl. 2 st. 2 requires registration before submitting the payment request. Third, when he has already registered voluntarily, which binds him under ZEF čl. 5 st. 7-8.

What happens if a Serbian paušalac registers on SEF voluntarily?

He becomes a dobrovoljni korisnik under ZEF čl. 2 st. 1 t. 4 and is bound to use the system in the current and the following calendar year (ZEF čl. 5 st. 7-8). From then on he is treated as a private-sector subject: every invoice to a counterparty in the system goes through SEF, and he must receive and store incoming electronic invoices (ZEF čl. 2 st. 3). Voluntary registration is therefore a commitment measured in years, not a setting you can switch off.

Can a Serbian paušalac deregister from SEF at any time?

No. There is no notice period to observe, but the statutory lock-in runs for the current plus the following calendar year (ZEF čl. 5 st. 8), so the earliest realistic exit is 1 January of the year after the one in which you registered. Deletion is requested from the Ministry of Finance at [email protected] under the procedure in the Pravilnik o elektronskom fakturisanju (čl. 34b-34v). Confirm the current procedure on efaktura.gov.rs before you send anything, because that pravilnik is amended every few months.

Does a Serbian paušalac have to register in the CRF?

No. The separate duty to register invoices in the Centralni registar faktura was repealed: ZEF čl. 23 struck the CRF-registration provisions out of the Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama with effect from 30 April 2022. The repeal is partial, so the payment deadlines in that law still stand; what went is the separate filing and the creditor deadline attached to it. The register itself still exists and is fed from the electronic invoice, so pages that still describe a manual CRF registration are out of date.

Do e-otpremnice apply to a Serbian paušalac?

A paušalac who sells services only is outside the scope of the Zakon o elektronskim otpremnicama (čl. 2 t. 4, čl. 3, čl. 4). That law attaches its obligations to the movement of goods, and a person who is not a VAT payer counts as a subjekt privatnog sektora only where excise goods are involved. If you deliver software, consulting, design or teaching there is no goods movement to document, so no electronic waybill obligation attaches to you at any stage of the rollout.

When does the e-otpremnica obligation reach private companies in Serbia?

The private-to-private stage starts on 1 October 2027, not 1 January 2027 as several accounting blogs state, and the same date governs a private-sector subject's duty to receive an electronic waybill on an ordinary movement of goods. From 1 January 2026 the obligation already covered the public sector, private-sector subjects moving excise goods, and private-sector subjects sending to the public sector. An error-tolerance window ran from 1 January to 30 June 2026, and the separate provisions on the paper-form e-otpremnica apply from 1 April 2026. The governing law is the Zakon o elektronskim otpremnicama, Sl. glasnik RS 94/2024 i 109/2025, član 16.

What is the penalty if a Serbian paušalac fails to use SEF when required?

For a preduzetnik that qualifies as a subjekt privatnog sektora, ZEF čl. 18 sets a fine of 50,000 to 500,000 RSD. The band covers failures such as not issuing an electronic invoice where one is required and not complying with the rules of the system. It bites only someone who is actually inside the scope of the law, which for a paušalac means a VAT payer, a supplier to the public sector, or a dobrovoljni korisnik.

Does a Serbian paušalac have to do elektronsko evidentiranje obračuna PDV?

An unregistered non-VAT paušalac does not. ZEF čl. 4 st. 1, in force since 1 January 2025, places the obligation on a poreski dužnik who is a VAT payer, and on persons outside the VAT system who are either public-sector entities or dobrovoljni korisnici of SEF; the deadline is the 12th of the month following the tax period. Elektronsko evidentiranje prethodnog poreza under ZEF čl. 4a applies only to VAT payers. Whether a voluntarily registered non-VAT paušalac who is a reverse-charge tax debtor is caught remains an open question with no official opinion.

Does crossing 8,000,000 RSD put a Serbian paušalac into SEF?

Indirectly, yes. Crossing 8,000,000 RSD of turnover over the previous 12 months makes you a VAT payer under ZPDV čl. 33 st. 1, and you then have 5 days to file the evidenciona prijava under ZPDV čl. 38 st. 1. Once registered for VAT you are a subjekt privatnog sektora under ZEF čl. 2 st. 1 t. 3, and SEF becomes compulsory. The 6,000,000 RSD paušal limit is a different threshold under a different law and does not by itself put you on SEF.

If you invoice clients abroad, the place-of-supply rules that decide what counts toward the 8-million threshold are covered in the guide to invoicing foreign clients.

Sources

• Zakon o elektronskom fakturisanju — consolidated text, "Sl. glasnik RS", br. 44/2021, 129/2021, 138/2022, 92/2023, 94/2024 i 109/2025 (čl. 2, čl. 3, čl. 4, čl. 4a, čl. 5, čl. 18, čl. 23)
• Pravilnik o elektronskom fakturisanju and the amendments effective 1 August 2026, "Sl. glasnik RS", br. 71/2026
• Zakon o rokovima izmirenja novčanih obaveza u komercijalnim transakcijama — the law whose CRF-registration articles ZEF čl. 23 repealed
• Elektronsko evidentiranje obračuna PDV u SEF and elektronsko evidentiranje prethodnog poreza — Ministry of Finance guidance
• SEF ažuriranja i verzije — the release log behind the version dates
• Zakon o elektronskim otpremnicama — consolidated text, "Sl. glasnik RS", br. 94/2024 i 109/2025 (čl. 1, čl. 2 t. 4, čl. 3, čl. 4, čl. 16, and the samostalni članovi of 109/2025)
• Zakon o porezu na dodatu vrednost — "Sl. glasnik RS", br. 84/2004, with amendments (čl. 33, čl. 38)