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August 31, 2026

Serbian fintech in August 2026: what actually changed

Serbian fintech in August 2026: what actually changed

On 31 July, Serbia's official gazette (Sl. glasnik) published two subordinate acts that set the stage for the next step in electronic VAT work. The real switch inside SEF has not happened yet. That matters, because chatter in industry groups and on LinkedIn has been running with lines like "SEF now files your VAT return" — that is not true.

While we are at it, we will cover the entrepreneurs' association request to raise the mandatory VAT registration threshold to RSD 12 million, and where the draft Payment Services Law at NBS stands.

What actually changed: the legal base, not the feature

Sl. glasnik RS No. 71/2026 (31 July 2026) contains two rulebooks:

  • Amendments to the Rulebook on Electronic Invoicing (Pravilnik o elektronskom fakturisanju).
  • Amendments to the Rulebook on VAT (Pravilnik o PDV).

Both came into force on 1 August 2026. Both are subordinate acts, not the underlying Law on VAT or Law on Electronic Invoicing themselves. The laws did not change.

What the Rulebook on Electronic Invoicing does: it gives SEF (Serbia's state e-invoicing system) the legal basis for semi-automatic pre-filling of the preliminary VAT return — form PPP PDV with Appendix 1. Data is pulled from e-invoices and the VAT records inside SEF.

"Semi-automatic" is the term Serbia's Ministry of Finance uses in its own June 2026 procurement notices JN 22/2026 and JN 26/2026 for building out the system. Not "automatic". The distinction matters: the system collects and pre-fills, but review and submission stay with the taxpayer.

Why accountants don't see the feature yet: it's postponed

Two clarifications that keep getting lost in English-language coverage.

First. From the Rulebook's own text: the provisions on drafting the preliminary VAT return apply only to tax periods beginning after 31 December 2026. The first live month is January 2027. Legal base since August 2026, actual use from January 2027.

Second. As of 31 August 2026, the preliminary return module is available only in the SEF DEMO environment. The official efaktura.gov.rs announcement from 31 July 2026 is titled, plainly, "Preliminarna poreska prijava na DEMO SEF-u." Practising accountants who say they don't see the feature in live SEF are right — it isn't there yet.

Small but important detail: Appendix 2 (equipment, real estate, investment items) does not automate at all. It stays manual. If you have capex flowing through Appendix 2, "semi-automatic declaration" does not cover the whole picture.

And: through 31 December 2026, unintentional errors in the preliminary return are not penalised. There is an explicit tolerance period written into the rulebook.

What is worth doing before January

The real task through year-end is not "roll out a new feature" but clean up what is already in SEF. Your VAT records and e-invoices are about to become the source the system uses to build the pre-filled draft. Every mislabelled counterparty, every miscoded rate, every invoice sitting in draft status will land in the pre-filled form in the state you left it.

Five months to the first live period is your window for data hygiene.

For your specific setup, talk it through with a licensed tax advisor. The rulebook is dense and how the new workflow lands on top of your existing VAT practice will depend on the business.

The VAT threshold: RSD 8 million stays, but lobbyists want 12

In late August, entrepreneurs' associations publicly asked the government to raise two limits at once:

  • The paušal (flat-tax) limit for sole proprietors from RSD 6 million to RSD 8 million.
  • The mandatory VAT registration threshold from RSD 8 million to RSD 12 million.

Coverage ran 24 August 2026 (Kamatica via Naslovi.net, Kurir, Lokalne novine). This is not a government proposal and not draft legislation. It is a collective position from entrepreneurs' associations, sent to the Ministry of Finance.

What the law says on 31 August 2026: the mandatory VAT registration threshold stays at RSD 8,000,000 (roughly EUR 68,000 at recent NBS rates) of total supplies over the preceding 12 months (Article 33 of the Law on VAT). The 2027 VAT amendments are still under review; the current draft keeps the threshold at the same level, but the final text has not been adopted.

If your trailing turnover is nearing RSD 8 million, plan as though the threshold in 2027 will still be RSD 8 million. For revenue-timing decisions built on that assumption, get advice from a licensed tax advisor.

The draft Payment Services Law at NBS: still a draft

The National Bank of Serbia (NBS) closed public consultation on the draft amendments to the Law on Payment Services on 11 June 2026. Legal analyses from Kinstellar, Karanovic & Partners and others appeared in July and August. This is not law. Final text, Skupština (parliament) submission and effective date are all unknown.

The headline change in the draft: it removes the current restriction that keeps payment institutions, e-money institutions and the public postal operator out of direct participation in significant payment systems, including IPS NBS (Serbia's instant payments system). Under current rules, direct access is limited to banks, the Treasury and NBS itself. Non-bank operators join only indirectly, through a partner bank.

The draft would allow direct participation subject to NBS approval and to operational, governance and safeguarding requirements. It also aligns Serbian law with EU Reg. 2024/886 (instant payments), PSD2, Reg. 2021/1230 (cross-border payments) and the Settlement Finality Directive, and adds compliance obligations for payment institutions: sanctions screening and asset-disposal restrictions tied to terrorism financing.

For a merchant, this is downstream: if the draft passes in something close to its current shape, more providers will be able to work with IPS NBS directly, without a partner bank. More competition in instant payments tends to push acquiring fees down over time. But "close to its current shape," "over time" and "if it passes" are doing a lot of work there. Nothing to act on today. Worth watching in Q4 2026 and early 2027.

What did not change in August

  • AML/KYC. The last amendments to the Law on Prevention of Money Laundering and Terrorism Financing came into force on 14 March 2025. Nothing new in August 2026.
  • Electronic delivery notes (e-otpremnice). The six-month tolerance period ended on 30 June 2026. Phase 1 errors (public sector, transport of excise goods) now attract penalties of RSD 200,000 to 2,000,000.
  • Electronic fiscalisation (eFiskus). No new regulatory acts identified.
  • The Law on VAT itself. Not touched. Last amended in Sl. glasnik 109/2025, December 2025. The August 2026 changes are all at the sub-law level (rulebooks).

In short

  • Sl. glasnik 71/2026 (in force 1 August 2026) gives SEF the legal basis for semi-automatic pre-filling of the preliminary VAT return.
  • Actual use starts January 2027, not now. As of 31 August 2026 the feature is DEMO-only.
  • Appendix 2 (equipment, investments) stays manual.
  • Entrepreneurs' associations publicly asked to raise the VAT threshold from RSD 8M to RSD 12M and the paušal limit from RSD 6M to RSD 8M. Not enacted.
  • The NBS draft Payment Services Law could open direct IPS NBS access to non-bank providers. Still a draft.

Sources

This article is informational, not tax or legal advice. Consult a licensed tax or legal advisor for guidance on your specific situation.

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