Serbia has submitted to parliament a package of financial-law amendments that would alter the treatment of sovereign guarantees, give the government broader powers to reduce fuel excise duties, and significantly expand the role of the System of Electronic Invoices (SEF) in VAT administration.
- Sovereign guarantees to carry a new charge
- State-backed infrastructure financing faces greater cost visibility
- Government seeks wider discretion over fuel excise duties
- Fuel-price intervention would carry a budget cost
- SEF moves toward integrated VAT monitoring
- Exporters face closer customs and VAT reconciliation
- Agricultural transactions enter the electronic reporting system
- Fiscal policy combines greater flexibility with tighter oversight
The proposals were submitted to the National Assembly on 7 August 2026 and remain draft legislation pending adoption. Their implementation would combine tighter control over state-backed borrowing with greater flexibility in responding to oil-price shocks and more extensive digital monitoring of corporate tax transactions.
The changes form part of Serbia’s broader alignment with European Union standards. The guarantee reforms follow the government’s 25 June 2026 action plan for bringing existing state-aid schemes into compliance with EU requirements, while the SEF amendments continue the digitalisation of tax administration.
Sovereign guarantees to carry a new charge
Amendments to the Public Debt Law would modify Articles 16 and 18, which establish the authority and conditions for issuing state guarantees. The key change would be the introduction of a fee for sovereign guarantees, with the new system scheduled to apply from 1 January 2027. A state guarantee transfers part of a borrower’s credit risk to the government and can lower the financing cost available from banks or bond investors. Public enterprises and state-supported project companies can consequently obtain borrowing terms that may not be available solely on the basis of their own financial position.
Introducing a fee would place an explicit financial value on that state support. The charge could take account of the beneficiary’s creditworthiness, the size and maturity of the guaranteed exposure, available collateral and the probability that the guarantee could ultimately be called. The change could affect state-owned companies including Elektroprivreda Srbije, Srbijagas, Transnafta, Serbian railway infrastructure companies and road-sector entities. These organisations have used guaranteed borrowing from commercial banks, bilateral lenders and international financial institutions to support major energy and transport investments.
Even a relatively small annual charge can become significant when applied to large infrastructure debt. A 0.5 per cent fee on a €500 million guaranteed exposure would amount to €2.5 million per year, while a 1 per cent charge would increase the annual cost to €5 million.
State-backed infrastructure financing faces greater cost visibility
The proposed system would treat guarantees as both an economic benefit for borrowers and a contingent fiscal liability for the state. That would make the fiscal exposure associated with government-backed financing more explicit and could reduce the scope for guarantees to function as implicit subsidies.
The financial effect will depend heavily on how the guarantee fee is calculated and whether exemptions are applied. A uniform charge unrelated to borrower risk would provide limited differentiation between financially sound projects and structurally loss-making public companies. A risk-based methodology could instead influence project selection, financing structures, maturities, collateral requirements and the amount of equity contributed by borrowers. Serbia continues to use state-supported borrowing for major transport and energy schemes. Recent parliamentary financing proposals have included loans for the Belgrade–Zrenjanin–Novi Sad motorway, the Požarevac–Golubac expressway, the Bački Breg–Sombor–Kikinda corridor, as well as a sovereign guarantee associated with Transnafta’s Serbia–Hungary oil-pipeline project.
The new guarantee regime could therefore change the financial treatment of comparable transactions concluded after the amendments take effect.
Government seeks wider discretion over fuel excise duties
The proposed fuel-tax changes would give the government considerably greater room to respond to international oil-price increases. Current legislation permits excise reductions on specified petroleum products when higher crude prices threaten domestic economic stability, but limits the reduction to 20 per cent of the latest published excise amount. The amendment would remove that ceiling. The government would be able to temporarily reduce excise duties on leaded and unleaded petrol and gas oils, including diesel, without a predetermined percentage limit.
The measure is linked to higher crude-oil and refined-product costs associated with developments in the Middle East. Because Serbia depends on imported crude and petroleum products, international energy-price movements feed into domestic fuel prices and subsequently into freight, agriculture, construction and industrial logistics.
Diesel has a particularly broad effect across physical supply chains. Higher pump prices increase operating costs for road transport, food distribution, agriculture, mining and civil construction. Companies can initially absorb some of the increase through lower margins, but sustained fuel-cost inflation can ultimately reach wholesale and consumer prices.
Removing the 20 per cent limit would give the government a larger fiscal buffer with which to moderate the transmission of an international oil shock to households and businesses.
Fuel-price intervention would carry a budget cost
The broader discretion would also expose the budget to a larger loss of excise revenue. Petroleum excise duties provide a relatively predictable source of government income, meaning deeper reductions could weaken public revenue while higher energy prices potentially increase other spending requirements. The amendment therefore creates an option for transferring part of an oil-price shock away from motorists and companies and onto the state budget. The extent of any intervention would depend on crude prices, refinery economics, exchange-rate movements and the government’s assessment of available fiscal space.
The legislation would also adjust the annual indexation mechanism. When excise amounts are aligned with the previous year’s consumer-price index, the calculation would use the latest published inflation-adjusted excise amounts as the reference base. This would maintain a statutory reference point even when the government had temporarily reduced the amount actually collected. A temporary cut could therefore moderate fuel costs during an external shock without permanently lowering the tax base used for subsequent indexation.
SEF moves toward integrated VAT monitoring
The third component of the legislative package would substantially expand Serbia’s electronic tax infrastructure. The System of Electronic Invoices, introduced in stages beginning 1 May 2022, initially focused on issuing, receiving and storing electronic invoices in public- and private-sector transactions. It has since become increasingly important for recording VAT liabilities and input VAT.
The proposed amendments would take SEF closer to an integrated tax-control system by enabling export-related data to be presented, introducing a new VAT-recording method and preparing the platform for a preliminary VAT return.
The preliminary return would represent a further shift toward a tax system in which the administration can use transaction-level information already available to it to generate or pre-populate elements of a taxpayer’s VAT position. Invoice information, customs declarations, input-VAT records and other electronic data could be compared before companies submit their final VAT returns. This would make discrepancies between accounting records, SEF information, customs documentation and tax filings easier to identify.
For businesses, the practical consequence would be a shorter interval between a transaction error and its detection. Incorrect VAT classifications, inconsistent transaction dates, missing export documentation, duplicate invoices and differences between customs and accounting data could increasingly be identified electronically.
Exporters face closer customs and VAT reconciliation
The changes are particularly relevant to exporters. From 1 July 2027, SEF is expected to provide access to export and dispatch information through a list of customs declarations. Export transactions generally qualify for a zero VAT rate, provided the required evidence is available. Linking SEF more closely with customs information would reduce manual reconciliation but could also expose differences in timing, quantities and supporting documentation.
The reforms consequently increase the importance of consistent master data across enterprise-resource-planning systems, customs processes, warehouse records and SEF. Companies with large transaction volumes will increasingly need automated reconciliation rather than relying on manual corrections at the end of each reporting period.
Agricultural transactions enter the electronic reporting system
The proposed framework would also introduce mandatory electronic recording for purchases of agricultural and forestry products and agricultural services from farmers covered by the VAT system. The requirement would apply from 1 July 2027, with the relevant information submitted on an aggregated basis. Food processors, wholesalers, agricultural cooperatives, timber companies and other businesses purchasing directly from primary producers would therefore need to incorporate these transactions into their electronic procurement and accounting processes.
Most of the electronic-invoicing amendments are scheduled to apply from 1 January 2027, while the agricultural-purchase provisions and access to export customs declarations would begin on 1 July 2027.
The transition will require more than an accounting-software modification. Companies will need to map VAT treatment at transaction level, reconcile SEF data with general-ledger and customs information, assign responsibility for correcting rejected or inconsistent records and establish whether existing enterprise systems can support the expanded reporting requirements. For larger exporters, implementation will involve finance, procurement, sales, logistics, customs and IT functions rather than accounting departments alone.
Fiscal policy combines greater flexibility with tighter oversight
The three legislative changes address different fiscal risks but establish a common direction in public financial management. The sovereign-guarantee reform would make government-backed borrowing more explicitly priced and expose the fiscal value of state support. The fuel-excise amendment would give the government greater discretion to absorb external energy-price shocks, while accepting a corresponding reduction in potential budget revenue. The SEF changes would provide tax authorities with more detailed and more closely integrated corporate transaction data.
For public enterprises and infrastructure borrowers, the guarantee fee could modestly increase financing costs. For businesses exposed to fuel prices, the excise changes would provide a potential mechanism for moderating sudden cost increases. For companies subject to VAT reporting, the expanded SEF framework would increase compliance and systems-integration requirements. The proposed package thus combines continued availability of state support with more explicit pricing of government-backed financing, broader fiscal flexibility during energy shocks and increasingly automated access by the tax administration to corporate transaction data.
