A Detailed Overview of the Draft Law on Electronic Dispatch Notes
Serbia’s new draft law on electronic dispatch notes (Закон о електронским отпремницама) is set to revolutionize the way goods are transported and tracked within the country. This law marks a critical step toward digitalizing the logistics and supply chain sectors, improving efficiency, transparency, and compliance for both public and private sector entities. By introducing a centralized electronic system, the law facilitates the automated handling of goods movement documentation and sets the foundation for a seamless transition to a paperless logistics environment.
The law outlines a comprehensive system for managing and processing e-dispatch notes, focusing on the technical aspects of how companies will interact with the government for tracking goods. In this post, we’ll break down not only the core components of the law but also provide a technical insight into how businesses will interface with the system, what data formats are required, and what steps need to be taken for compliance.
Key Aspects of the E-Transport Law
The draft law establishes clear requirements for issuing, sending, receiving, and archiving electronic dispatch notes (e-dispatch notes) for the movement of goods. These electronic documents are crucial for tracking goods during transport within the territory of Serbia and will apply to both public and private sector entities.
1. What is an E-Dispatch Note?
An e-dispatch note is a structured digital document used to accompany goods during their transport, recording key details such as sender and recipient information, details of the goods, and information about the transport method. It is transmitted through an integrated system that enables full automation and compliance with regulatory requirements. The dispatch note is not only used for tracking but also for presenting data during inspections, ensuring that goods are transported legally and efficiently.
The central information system is responsible for processing and archiving these notes, allowing authorities to track goods in real-time, reducing fraud, and improving supply chain visibility.
2. Exemptions and Specific Conditions
While the law mandates the use of e-dispatch notes for most goods, there are notable exemptions, such as:
- Goods transported via transmission networks (e.g., water, electricity, gas).
- Retail goods that fall under specific fiscal regulations.
- Military and sensitive goods, or goods moved under international agreements, may also be exempt.
The Technical Framework for E-Dispatch Notes: How It Works
The heart of this legislative change lies in the Central Information System (Централни информациони посредник), which manages the entire e-dispatch process. This system will handle the submission, processing, storage, and retrieval of dispatch notes and must comply with technical standards set forth by the Ministry of Finance.
1. Data Format and Transmission Requirements
The law mandates that electronic dispatch notes be created and sent in a structured data format compatible with the system. Specifically, the required data format for e-dispatch notes is XML (eXtensible Markup Language), which is widely used for structured document exchanges between businesses and governments. XML provides the necessary flexibility to capture the detailed information required by the government while allowing for automated data processing by various IT systems.
Key elements that must be included in the XML structure are:
- Sender and recipient details: Business names, addresses, tax ID numbers.
- Details of goods: Types, quantities, and special markings (e.g., for excise goods).
- Transport details: Vehicle identification, transporter information, and the planned movement route.
- Verification code: A QR code or barcode that contains an embedded link to the central system for real-time verification.
The XML file must adhere to the specific schema defined by the Ministry of Finance, ensuring consistency and the ability to process the data without manual intervention.
2. Submission and Communication Channels
The law outlines two main methods for submitting electronic dispatch notes:
- Direct submission through API integration: Businesses are encouraged to integrate their internal systems with the Central Information System through an API (Application Programming Interface). This enables automated, real-time submission of dispatch notes without the need for manual data entry. The API will use standard communication protocols, such as HTTPS, to ensure secure data transmission.
- Web portal submission: For companies that do not have the technical resources to develop API integrations, the government will provide a web-based portal. Through this portal, businesses can manually upload their e-dispatch notes in the prescribed XML format. The system will offer functions such as verification, status tracking, and audit trails to ensure compliance.
Once the dispatch note is sent via API or the portal, the system will automatically validate the data, checking for errors or omissions. If any issues are found, businesses will receive feedback to correct the dispatch note before it is officially recorded.
System Requirements and Access
Businesses must register with the central system to gain access. For direct integration, companies will need to obtain authentication keys or certificates to securely communicate with the government’s systems. For the web portal, a secure login process will be provided, allowing businesses to access their dispatch records, view inspection status, and update or correct any documents as needed.
1. Transporter Obligations and System Interaction
Transport companies are also subject to the law’s provisions. They are required to access the system to retrieve the dispatch notes for the goods they are moving. If a transporter does not have access to the system due to technical limitations, a paper version of the e-dispatch note, signed and printed, must accompany the goods. However, this paper note must still be uploaded to the system as soon as connectivity is restored.
In cases of internet or system downtime, the law allows for paper backup methods. The National Bank of Serbia’s Printing Works will provide pre-printed forms that can temporarily replace electronic dispatch notes, but these must be entered into the system within one business day after the system is back online.
Inspection and Compliance Procedures
To ensure compliance, businesses must make their e-dispatch notes available for inspection by authorized bodies. The Central Information System logs all activities, making it easy for inspectors to access historical records, verify document authenticity, and check compliance with goods movement regulations.
Archiving and Data Retention
Under the law, public sector e-dispatch notes must be archived indefinitely, while private sector documents are subject to a 10-year retention period. This long-term archiving ensures traceability and compliance for audits or inspections. The system guarantees that all documents, whether electronic or printed, maintain their integrity throughout the storage period.
Penalties for Non-Compliance
Businesses failing to comply with the new requirements, whether by failing to send dispatch notes or by misusing system data, face significant penalties. Fines range from 200,000 to 2,000,000 Serbian dinars for companies and 50,000 to 500,000 dinars for individual business owners. Specific fines also apply to entities that fail to provide access to electronic dispatch notes during inspections.
Gradual Rollout and Implementation Timeline
While the law provides a comprehensive framework, the implementation of these new obligations will be gradual. Full adoption for goods related to excise products is required by January 1, 2026, with the broader private sector adoption scheduled for October 2027. This timeline allows businesses ample time to integrate with the new system and comply with the technical standards.
Conclusion: Preparing for a Digital Future in Goods Transport
Serbia’s draft law on electronic dispatch notes signifies a major shift toward digitization in the transport and logistics sectors. The integration of XML-based e-dispatch notes, coupled with the Central Information System, will enhance efficiency, transparency, and regulatory compliance across the board. For businesses, this means investing in API integration or using the government’s web portal to ensure that all goods movements are properly documented and compliant with the law.
As the rollout progresses, companies should prioritize adapting their systems and processes to meet these new requirements, leveraging the centralized platform for more streamlined and secure goods tracking.
