Three rulebooks issued in July 2026 establish the documentation, evidence requirements and data-exchange procedures for Serbia’s domestic tax on greenhouse-gas emissions and a parallel tax covering imports of carbon-intensive products. The regulations entered into force on 23 July 2026, after both taxes began on 1 January 2026.
The domestic carbon charge is set at €4 per tonne of CO2 equivalent, payable in dinars. The framework also creates an auditable chain linking physical production, verified emissions, customs documentation, tax filings and investment records. The structure is described as resembling the institutional logic used for the EU’s Carbon Border Adjustment Mechanism, while Serbia’s carbon price remains below the cost of EU allowances.
Domestic greenhouse-gas emissions tax: scope and calculation base
Serbia’s domestic emissions tax applies to operators that hold a greenhouse-gas emissions permit and operate in electricity generation, cement, fertilisers and nitrogen compounds, crude iron, steel and ferroalloys, and aluminium production. The covered gases include CO2, nitrous oxide and perfluorocarbons, with non-CO2 gases converted into tonnes of CO2 equivalent.
The taxable base is calculated as verified total emissions minus a reference quantity linked to the relevant production process or activity. The taxable emissions are multiplied by €4 per tonne of CO2 or CO2 equivalent. The resulting amount is converted into dinars using the official middle exchange rate of the National Bank of Serbia at the end of the tax period.
The tax period is generally the calendar year. Operators must file electronically with the Serbian Tax Administration by 31 May of the following year, with payment due on the same date. For emissions generated during 2026, the first full annual filing is expected by 31 May 2027. If an operator later submits a revised emissions report, an amended tax return must be filed within 15 days.
Tax return forms and installation-level data requirements
The rulebook introduces the PP EGESB tax return and requires attachment of a verified emissions report. Where the competent authority has determined emissions itself, operators attach an official emissions assessment instead. Installation-level source data must be provided through the PIE form.
A consolidated calculation for the reporting period is submitted through the OUE form. The framework requires that carbon-tax positions be assembled from installation emissions sources rather than relying on a single corporate estimate. For operators with multiple production sites, results must be traceable to how they were constructed from installation-level inputs.
Credits for emissions-reduction investment: eligibility and recordkeeping
The rules establish an evidence trail for tax credits tied to emissions-reduction investment. Electricity producers deriving at least 80% of their revenue from electricity generation may receive a credit equal to 20% of qualifying expenditure on prescribed emissions-reduction measures. The credit cannot reduce more than 80% of the calculated carbon-tax liability.
Investment records must be maintained separately for each project or measure. Companies claiming the credit submit an analytical schedule of investments via PK-1, and calculate the credit through PK-2. Recoverable value-added tax is excluded from eligible investment expenditure.
The evidence requirements extend to engineering documentation supporting that expenditures relate to recognised emissions-reduction measures. Equipment specifications, baseline energy balances, commissioning records, meter data, acceptance certificates, production volumes and post-investment performance are included in the tax evidence file. Projects such as boiler replacement, waste-heat recovery systems, process electrification, renewable-energy installations and efficiency upgrades must be linked to defined emissions sources with documented pre-investment baselines and measurable post-commissioning change.
Import tax on carbon-intensive products: scope, thresholds and embedded emissions
The second part of Serbia’s framework covers imports of carbon-intensive products under specified customs classifications for iron and steel, cement, fertilisers and aluminium. Importers bringing in less than five tonnes of covered products during the tax period are outside the tax under the current threshold.
The import tax base is embedded emissions generated during production of imported goods reduced by applicable reference emissions. Actual emissions may be used when confirmed by an eligible validator; where actual emissions cannot be validated, prescribed default values may be used in calculations.
The import return uses the PP UUIP form supported by the UP form that breaks down imported goods by supplier and customs tariff code. The schedule includes quantity of product, emissions-determination method, emissions per unit, total emissions, reference emissions, taxable emissions and tax liability before credits.
Customs-to-tax data exchange and credits for foreign carbon charges
The Customs Administration must transmit import data electronically to the Tax Administration by the 10th day of each month, covering imports from the preceding month. Data elements include tariff code, description, quantity, country of origin, customs value, customs-declaration number and date, importer identity and customs office.
This monthly exchange supports cross-checking between annual carbon-tax returns and customs declarations already held by state authorities. Differences in product quantities, tariff classification, origin, supplier identity or reporting period can be detected without a traditional on-site inspection approach.
Importers may claim a credit for a carbon price demonstrably paid in the country of origin. The supporting package must link payment to relevant product details including production installation context, emissions quantity and reporting period. It must include a verification report plus confirmation from the competent authority that the carbon charge was paid; foreign-language documents require translation into Serbian by an authorised court interpreter.
Interaction with EU CBAM: reporting parties and MRV inputs
The Serbian measures intersect with EU CBAM but are not treated as identical systems. The EU mechanism entered its definitive phase on 1 January 2026, covering imports of specified goods across cement, iron and steel, aluminium, fertiliser, electricity and hydrogen sectors. Under EU CBAM rules, EU importers or their indirect customs representatives report embedded emissions and surrender CBAM certificates.
If actual embedded emissions are declared under EU CBAM methodology, underlying installation data must be verified by an appropriately accredited CBAM verifier. Serbia’s domestic charge at €4 per tonne does not automatically exempt shipments from CBAM obligations because EU rules allow recognition only when evidence connects payments made in origin countries to embedded emissions entering the EU.
The exporter needs an allocation bridge connecting Serbian installation verified annual emissions and domestic taxable base with carbon payment to specific embedded emissions assigned to each covered product exported to the EU. The allocation method must also prevent double allocation of the same carbon payment across different customers or consignments.
Camb MRV system design: boundaries, measurement controls and allocation methods
A credible CBAM MRV system begins with defined installation boundaries and an inventory of emission sources. Operators identify furnaces, kilns, boilers, generators and process units; determine fuels and raw materials entering each process; document measurement instruments and calculation methods; and establish controls over production and inventory data.
The system then converts plant data into product-specific embedded emissions using consistent treatment across production routes including intermediate goods, recycled content, process gases, waste streams, flaring practices, exported energy flows, internal transfers and shared utilities. Where multiple products use shared steam or electricity assets or other production assets such as heat supplies or utilities allocation methods must be technically justified and applied consistently.
Precursor data risks for steel-related supply chains
For steel-related activities including aluminium production pathways as well as fertilisers and some downstream goods using complex inputs, precursor information is identified as a central risk area for embedded-emissions calculations. Exporters may have reliable direct-emissions information but lack verified data for imported or domestically purchased intermediate materials used in finished products.
A steel processor may know electricity consumption for rolling operations but still depend on emission information for slabs, billets, ferroalloys or direct-reduced iron supplied by other plants. Weaknesses in precursor datasets can contaminate embedded-emissions calculations for finished goods.