Serbia has sent a broad package of financial legislation to parliament, combining changes to sovereign guarantees, fuel excise duties and the System of Electronic Invoices (SEF). Although the amendments concern different parts of the financial system, they point in the same direction: closer alignment with European Union rules, greater central control over fiscal risks and a deeper digitalisation of corporate tax reporting.
The proposed changes were submitted to the National Assembly on 7 August 2026 and remain draft legislation until adopted. The most financially significant provisions concern the way the state supports public companies and infrastructure projects through guarantees, the government’s ability to absorb an oil-price shock through lower excise duties, and the conversion of electronic invoicing into a much wider platform for VAT supervision.
Under the proposed amendment to the Public Debt Law, Serbia would change Articles 16 and 18, which regulate the authority and conditions under which the Republic can issue guarantees. The principal change is the introduction of a charge for providing a sovereign guarantee, with application planned from 1 January 2027.
The measure is part of Serbia’s effort to align its public-finance framework with EU state-aid rules. It follows an action plan adopted by the government on 25 June 2026 for bringing existing state-aid schemes into compliance with European standards and is also connected to Serbia’s Reform Agenda covering the business environment and private-sector development.
A sovereign guarantee is not an ordinary administrative approval. It transfers part of a borrower’s credit risk to the state and can materially reduce the interest rate demanded by banks or bond investors. Public enterprises and state-sponsored project companies can therefore obtain financing on terms that would not be available on the strength of their own balance sheets.
Charging for that support introduces a market-based price for the credit advantage created by the state. The guarantee fee should, in principle, reflect the beneficiary’s credit quality, the duration and size of the exposure, the underlying collateral and the probability that the guarantee will be called.
For state-owned enterprises such as Elektroprivreda Srbije, Srbijagas, Transnafta, Serbian Railways infrastructure companies and road-sector entities, the change could make the fiscal value of government backing more visible. It may also affect the financial structure of major energy and transport investments that have traditionally depended on guaranteed loans from commercial banks, bilateral lenders and international financial institutions.
The immediate cash cost of a guarantee fee may be modest compared with total project debt, but the cumulative effect can become material on infrastructure financing measured in hundreds of millions of euros. A fee of 0.5 per cent a year on a guaranteed exposure of €500 million, for example, would create an annual cost of €2.5 million. A fee of 1 per cent would raise that cost to €5 million.
The more important change is institutional. Serbia would be recognising that guarantees represent an economic benefit and a contingent liability rather than a cost-free instrument. That should improve the accounting of fiscal exposure, reduce the risk of guarantees being used as hidden subsidies and place greater pressure on beneficiaries to demonstrate commercial viability.
Pricing the guarantee does not eliminate sovereign risk. The state remains exposed if a guaranteed borrower cannot service its debt. The reform will therefore depend on the methodology used to calculate the fee, the transparency of exemptions and the government’s willingness to differentiate between commercially sound projects and structurally loss-making public enterprises.
A standard fee applied without reference to credit risk would satisfy the formal requirement to charge for guarantees but would do little to improve fiscal discipline. A risk-based system, by contrast, could influence project selection, debt maturities, security packages and the level of equity required from the borrowing entity.
This matters because Serbia continues to use sovereign and state-supported borrowing for large transport and energy projects. The parliamentary pipeline has recently included project loans for the Belgrade–Zrenjanin–Novi Sad motorway, the Požarevac–Golubac expressway, the Bački Breg–Sombor–Kikinda corridor and a sovereign guarantee connected with Transnafta’s Serbia–Hungary oil-pipeline project. The new rules could gradually change the financial treatment of similar transactions concluded after the amendments enter into force.
The second part of the package gives the government considerably greater room to use fuel taxation as a macroeconomic stabilisation instrument. Existing legislation allows it to reduce excise duties on specified petroleum products when rising international crude prices threaten domestic economic stability, but the reduction is capped at 20 per cent of the latest published excise amount.
The proposed amendment would remove that ceiling. The government could temporarily cut excise duties on leaded and unleaded petrol and gas oils, including diesel, without a predetermined percentage limit.
The measure responds to higher crude-oil and refined-product costs associated with developments in the Middle East. Serbia’s dependence on imported crude and petroleum products means an external oil shock quickly enters domestic inflation through retail fuel prices, freight costs, agriculture, construction and industrial logistics.
Diesel is especially important because it is embedded in almost every physical supply chain. A sustained increase in pump prices raises operating costs for road transport, food distribution, farming, mining and civil works. Companies may initially absorb part of that increase through lower margins, but persistent fuel inflation is ultimately transferred to wholesale and consumer prices.
Removing the 20 per cent ceiling gives the government a larger buffer. Instead of allowing the full international price shock to reach households and companies, it could surrender part of the excise-tax revenue and stabilise retail prices. The measure could also reduce pressure for direct subsidies or administratively imposed price controls, both of which can distort supply and create payment delays.
That flexibility has a clear fiscal cost. Excise duties on petroleum products are an important and relatively predictable source of budget revenue. A deeper reduction would weaken revenue at the same time that higher energy prices may be increasing other public expenditures.
The amendment therefore does not promise permanently cheaper fuel. It creates an option to redistribute the cost of an oil shock from motorists and companies to the state budget. The scale of any intervention will depend on crude prices, refinery economics, exchange-rate movements and the government’s assessment of available fiscal space.
The annual indexation mechanism would also be adjusted. 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 base. This provision is intended to preserve a clear statutory reference point even when the government has temporarily lowered the amount actually collected.
The distinction is important. A temporary excise reduction may soften a crisis without permanently lowering the tax base from which future inflation indexation is calculated. Once the intervention expires, the statutory burden could return to a considerably higher level. Companies should therefore avoid treating a temporary reduction as a structural improvement in transport or production costs.
The third legislative component would substantially expand Serbia’s electronic tax infrastructure. The System of Electronic Invoices, introduced in phases from 1 May 2022, was initially centred on issuing, receiving and storing electronic invoices in public- and private-sector transactions. It has progressively developed into a mechanism for recording VAT liabilities and input VAT.
The new amendments would move SEF closer to an integrated tax-control environment. They would enable the presentation of export-related data, introduce a new method of VAT recording and prepare the system for a preliminary VAT return.
The preliminary return is particularly significant. It suggests a transition from a system in which the taxpayer compiles and reports its own VAT position towards one in which the tax administration can generate or pre-populate part of that position using transaction-level information already held by the state.
Data from invoices, customs declarations, input-VAT records and other electronic systems could be cross-checked before the final VAT return is filed. This would reduce the space for discrepancies between accounting books, SEF records, customs data and the taxpayer’s return.
For companies, the practical effect will be a shorter distance between an operational error and its detection by the tax authorities. Incorrect tax categories, inconsistent supply dates, missing export evidence, duplicate invoices and mismatches between customs and accounting records will become easier to identify automatically.
The change will be especially relevant to exporters. From 1 July 2027, SEF is expected to provide access to information on exports and dispatches through a list of customs declarations. That should improve verification of whether transactions presented as exports are supported by the corresponding customs documentation.
Exporters normally apply a zero VAT rate, but only when they possess the prescribed evidence. Automated connections between SEF and customs records can reduce manual reconciliation, yet they can also expose timing differences and documentation gaps that previously remained within separate systems.
The reform places greater importance on master-data quality across enterprise-resource-planning software, customs procedures, warehouse records and SEF. Companies with high transaction volumes will need automated reconciliation controls rather than relying on month-end manual corrections.
Another change concerns purchases of agricultural and forestry products and agricultural services from farmers covered by the VAT rules. Electronic recording of these purchases would become mandatory from 1 July 2027, with information submitted on an aggregated basis.
This brings a part of the supply chain that has traditionally relied on fragmented or partly manual documentation into the electronic tax-control perimeter. Food processors, wholesalers, agricultural cooperatives, timber companies and other buyers dealing with primary producers will need to adapt their procurement and accounting systems.
Most of the electronic-invoicing amendments are intended to apply from 1 January 2027, while the rules concerning agricultural purchases and access to export-customs declarations would begin on 1 July 2027. The phased implementation provides some preparation time, but the required work extends beyond a routine accounting-software update.
Companies will need to map VAT treatments at transaction level, reconcile SEF with general-ledger and customs data, establish responsibility for correcting rejected or inconsistent records and test whether their existing enterprise systems can support the expanded reporting structure. Larger exporters should treat the change as a tax-data governance project involving finance, procurement, sales, logistics, customs and IT teams.
Together, the amendments reveal two different sides of Serbia’s fiscal policy. The government is seeking more discretion to respond to external shocks through potentially deeper fuel-tax reductions, while simultaneously tightening control over state guarantees and corporate VAT data.
The public-debt reform should make state-backed financing more transparent, but it could modestly increase the cost of capital for public enterprises and infrastructure borrowers. The excise amendment provides a stronger anti-inflation tool, but shifts more of the oil-price risk onto the budget. The e-invoicing reform may eventually reduce administrative duplication, though its near-term effect will be higher compliance and systems-integration costs for companies.
Serbia is effectively moving towards a public-finance model in which state support remains available but is more explicitly priced, fiscal intervention remains flexible but carries a visible revenue cost, and corporate transactions become increasingly transparent to the tax administration in near-real time.
