New Classification of Activities in Serbia Adopted - What Could It Mean for Fiscalization Exemptions?

Serbia has adopted Classification of Activities 2025, which will apply from January 1, 2027. It does not itself amend fiscalization rules, but the change matters because some current exemptions from using Electronic Fiscal Devices are linked to activity classifications and codes.

Serbia has adopted a new Classification of Activities 2025 (KD 2025), creating a point that businesses subject to Serbian fiscalization should monitor before 2027. The Government adopted the new Regulation on the Classification of Activities on September 17, 2026, and it was published in Official Gazette of the Republic of Serbia No. 91/2026 on September 23. The Regulation enters into force on October 1, while KD 2025 starts to apply from January 1st, 2027.

KD 2025 is Serbia’s national version of NACE Rev. 2.1 and replaces the classification currently based on KD 2010. The Statistical Office states that the revision reflects developments such as digitalization, new technologies and changes in economic activities.

Note that this is not a new fiscalization requirement and does not currently change the Electronic Fiscal Device, ESIR, PFR or any fiscalization process. Its relevance for fiscalization comes from another direction: Serbia’s current rules exempting certain activities from recording retail turnover through an Electronic Fiscal Device still refer to activities and codes under the existing classification framework.

Why can KD 2025 matter for fiscalization?

Under the Serbian Law on Fiscalization, businesses carrying out retail turnover are generally required to record that turnover through an Electronic Fiscal Device, unless the relevant activity or transaction falls under an exemption established by regulation. The Tax Administration confirms that exempt activities are determined through the Regulation on activities for which there is no obligation to record retail turnover through an Electronic Fiscal Device.

The currently applicable exemption Regulation, most recently amended through Official Gazette No. 110/2025, continues to define a number of exemptions by reference to particular activities, activity groups and descriptions originating from the existing classification system.

For example, specific activities within code 47.99 – Other retail sale not in stores, stalls or markets are exempt, including certain itinerant and street sales. The exemption does not automatically cover everything registered under 47.99. The Tax Administration has previously clarified that sales through vending machines classified under the same activity code are subject to fiscalization.

A similar distinction exists for 96.09 – Other personal service activities not elsewhere classified. The Regulation exempts particular activities within this group rather than treating the entire code as automatically exempt.

This already shows why the transition to KD 2025 requires careful treatment: a registered activity code alone may not determine whether a business is exempt from fiscalization. The precise activity described by the fiscalization Regulation remains relevant.

What happens to registered activity codes?

The transition to KD 2025 will not require businesses to individually re-register their activity merely because of the new classification.

The Statistical Office states that the Business Registers Agency (APR) and authorities maintaining other special registers must align registered activity codes and descriptions with KD 2025 using the official correlation tables between KD 2010 and KD 2025. This conversion will be performed without a fee and without issuing a separate individual decision, within 60 days after the Regulation enters into force.

However, an automatic change in an APR activity code should not be interpreted by itself as either creating or removing a fiscalization exemption.

As of September 30, the Ministry of Finance and Tax Administration continue to publish the existing fiscalization exemption Regulation, and no corresponding amendment aligning its references with KD 2025 has yet been identified on their official fiscalization pages. Further regulatory alignment or official clarification may therefore be needed before the practical treatment from January 2027 is fully clear.

Additionally, a separate issue also arrives on January 1, 2027 as its final deadline:

There is another fiscalization deadline occurring at almost exactly the same time, but businesses should not confuse it with KD 2025.

Under the current Regulation, fiscalization taxpayers selling goods and services at market stalls and similar facilities are temporarily exempt from recording retail turnover and advances through an Electronic Fiscal Device through December 31, 2026.

The two developments have different legal bases. KD 2025 does not itself terminate, extend or change the market-stall exemption. Nevertheless, the common January 2027 timing makes future Ministry of Finance amendments particularly relevant for businesses operating in these areas.

What is the impact on retailers and POS providers?

For most retailers already required to fiscalize their retail transactions, KD 2025 currently requires no changes to POS/ESIR, PFR or any of the fiscalization processes.

The more immediate compliance question concerns businesses whose current treatment depends on an activity-based exemption. Retailers, accountants and POS providers supporting such businesses should verify how the existing activity maps from KD 2010 to KD 2025 and avoid assuming that an APR code conversion automatically changes the business’s fiscalization status.

POS providers should also avoid building new exemption logic solely from KD 2025 codes until the Ministry of Finance or Tax Administration confirms how the fiscalization Regulation will be aligned.

What should affected businesses do further?

Businesses must continue applying the currently valid fiscalization rules and exemptions until those rules are formally amended (if such change occurs). KD 2025 itself does not provide a new exemption from using an Electronic Fiscal Device and does not create a new Fiscal Receipt obligation.

Retailers and POS providers should also monitor the Ministry of Finance and Tax Administration for an amendment to the exemption Regulation or guidance explaining how the new classifications will be used from January 2027.

We can say that the main implementation risk is treating an administrative reclassification as if it automatically changed the fiscal obligation. The current Serbian system shows that exemptions can apply only to particular activities within a broader code and only for activities explicitly marked in regulations. The legal basis for the exemption therefore remains more important than the code displayed in the business register.

The principal official source for KD 2025 is the Serbian Statistical Office announcement and its dedicated classification materials including: Serbian Statistical Office – KD 2025 announcement .

The existing fiscalization framework and exemption rules remain available through the Tax Administration and Ministry of Finance, and particularly the Regulation on determining activities in the performance of which there is no obligation to record retail turnover via an electronic fiscal device - Source

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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