Starting January 1, 2024, Serbian businesses will face a significant shift with the implementation of the e-Archive system, following years of postponement. This new system exempts businesses from electronically storing documents already submitted to state agencies or institutions.
Tax advisor Jovan Pavlović explains that from the onset of 2024, businesses are mandated to electronically submit all documents they are legally required to keep. However, documents already submitted electronically, such as invoices on the SEF portal, tax returns to the Tax Administration, financial reports in the APR, and employee registrations in CROSO, are exempt from this requirement.
January will also see updates to the material categories in the archival records. While these changes primarily affect state bodies, businesses are advised to align their categories with the new system for seamless approval from the State Archive of Serbia.
Businesses owning electronic documents not stored with state bodies must ensure secure storage. The Law on Archival Material, effective since 2021, mandates businesses to responsibly maintain archival materials in their original format, whether electronic or paper.
Businesses create documents of archival significance during their operations, preserved as a complete archive. After 30 years, these are handed over to the competent public archive.
Owners are responsible for the documentation’s record-keeping, labeling, classification, dating, and archiving, following legal guidelines for eventual transfer to the archives. Businesses must also ensure the long-term preservation and maintenance of electronic archival materials, including data migration to new formats.
Our expert suggests sorting and storing documentation by type for practicality. Many companies use sequential numbering for easy retrieval, either for internal use or during inspections.
Permanent documents include payroll lists and wage records, while others must be stored as per regulations. For instance, financial statements are retained for 20 years, accounting books and annual business reports for 10 years, and auxiliary books and related documentation for five years. VAT-registered firms must keep relevant documentation, primarily invoices, for 10 years.
The law also specifies methods for document preservation, with some stored electronically and others in paper form. Documents must be kept in their original form, as created and issued.
Inadequate archival maintenance can result in fines up to three million dinars. Legal entities face fines between 100,000 to three million dinars for not preserving accounting records, business books, financial statements, annual business reports, and audit reports as per the Accounting Law. Similarly, failure to maintain daily reports, control tapes, and periodic reports can lead to fines up to two million dinars. Penalties for entrepreneurs are lower, ranging from 50,000 to 500,000 dinars.