The Republic of Serbia Strengthens Sanctions for Fiscal Invoice QR Code Manipulation

The Republic of Serbia has amended its fiscal law through Article 12(6), which introduced penalties for taxpayers who manipulate QR codes on delivered invoices. The amendment will come into force on September 8, 2026, and prescribes a one-year prohibition of business activities for such violations.

The Fiscal Law already allows authorities to impose sanctions that may result in the prohibition of business activities, although they typically apply these penalties progressively. Authorities may first prohibit a taxpayer from conducting business for 15 days, then for 90 days in the event of a repeated violation, and ultimately for up to one year if further non-compliance occurs. Under the new amendment, however, authorities may impose a one-year prohibition immediately.

QR code manipulation includes using:

• a QR code that was not generated through the Tax Administration’s electronic fiscalization system;
• a QR code that contains a URL that does not lead to the Tax Administration’s portal;
• a QR code that leads to a fiscal invoice unrelated to the actual recorded turnover;
• a QR code that displays another invoice, amount, date, items, or other taxpayer data;
• a QR code on a document that has been subsequently modified, combined with other content, or technically prepared to misrepresent the original fiscal invoice.

The severity of this penalty reflects the important role QR codes play in Serbia’s fiscalization system.

Instant invoice verification right after scanning a QR code

Before issuing an invoice, the system fiscalizes it by applying a digital signature and encryption in accordance with fiscalization requirements. The system then transmits the invoice data to the Tax Authority’s database for audit purposes. If connectivity is unavailable, the point-of-sale system securely stores the fiscalized invoice and automatically transmits it once the connection is back.

Every fiscal invoice contains a QR code that enables invoice verification. By scanning the QR code, a buyer, inspector, taxpayer, or any other person with access to the invoice can immediately verify whether it is valid. The QR code directs users to the Tax Administration’s verification portal, where the system immediately verifies the status of the issued invoice, regardless of whether the transaction occurred online or offline. The verification application also allows users to provide additional information or feedback regarding the invoice.

In Serbia, the QR code serves a purpose beyond invoice verification. In addition to the verification URL, it contains encrypted internal invoice data. As a result, the QR code is slightly larger than those used solely for verification purposes.

The critical role of QR codes in Serbia’s fiscalization framework

When a user scans an issued invoice, the Tax Administration’s system verifies whether the central invoice database already contains a record of that invoice, regardless of whether the point-of-sale system issued it online or offline. If the database does not yet contain the invoice, the system uses the encrypted information embedded in the QR code to create a new record. Although the system may not receive the invoice image or journal until the standard transmission process is completed, it can use the encrypted data to record the transaction and determine the corresponding tax obligations.

In practice, this means that invoice verification serves not only as a validation mechanism for buyers and inspectors, but also as an additional source of invoice data for the Tax Administration. Even when the standard transmission process is temporarily unavailable, scanned offline invoices can contribute to the completeness of the fiscal database and help identify recorded and potentially missing transactions much earlier than would otherwise be possible.

This mechanism significantly improves the completeness and accuracy of fiscal records. The system can identify information about issued invoices, as well as potential gaps in invoice sequences, and record it before a regular remote audit or a forced local audit takes place, reducing the risk of incomplete reporting and improving visibility into taxpayer activity.

Beyond verification and audit support, the Tax Authority can also use QR code scanning in the fiscal lottery programs in Serbia, which encourage consumers to request, verify, and retain fiscal invoices after each purchase.

Given the central role QR codes play in invoice verification, audit processes, data collection, and consumer participation programs, the Republic of Serbia now treats QR code manipulation as a serious fiscal offence subject to some of the strictest penalties available under the Fiscal Law.