Three rulebooks published in July 2026 define the forms, supporting evidence and data-exchange procedures for Serbia’s domestic tax on greenhouse-gas emissions and a parallel tax on imported carbon-intensive products. The regulations entered into force on 23 July 2026, after both taxes began on 1 January 2026. Serbia’s Ministry of Finance has also completed an administrative framework intended to apply the new system.
The domestic carbon charge is set at €4 per tonne of CO₂ equivalent, payable in dinars. The framework builds an auditable chain linking physical production, verified emissions, customs documentation, tax returns and investment records. The structure is described as resembling the institutional logic of the EU’s Carbon Border Adjustment Mechanism, while Serbia’s carbon price remains below the cost of EU allowances.
For Serbian manufacturers, the rules make carbon data financially material. For exporters to the European Union, they add a second reporting layer alongside CBAM. Under the new arrangements, emissions data may need to be defended in multiple settings involving Serbian environmental and tax authorities, accredited EU CBAM verification actors and EU importers or authorised CBAM declarants.
Domestic greenhouse-gas emissions tax: scope, calculation and filing
The Serbian domestic emissions tax applies to operators required to hold a greenhouse-gas emissions permit and active in electricity generation, cement, fertilisers and nitrogen compounds, crude iron, steel and ferroalloys, and aluminium production. The tax covers CO₂, nitrous oxide and perfluorocarbons, with non-CO₂ gases converted into tonnes of CO₂ equivalent. The taxable base is based on verified total emissions rather than an assumed installation-wide figure.
The taxable base is calculated as verified total emissions minus a reference quantity linked to the relevant production process or activity. The remaining 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 by the same deadline. For emissions generated during 2026, the first full annual filing is expected by 31 May 2027.
The underlying law also requires an amended tax return within 15 days if an operator later submits a revised emissions report. A new rulebook introduces the PP EGESB tax return and requires attachment of a verified emissions report. Where a competent authority determines emissions itself, an official emissions assessment must be attached instead.
Operators must provide installation-level source data through the PIE form and submit a consolidated calculation for the reporting period through the OUE form. The approach requires building results from individual installation emission sources and reconciling them with the legal entity’s total taxable position. Companies operating multiple sites cannot rely on a single top-down carbon figure without showing how it was assembled.
Credits for emissions-reduction investment and evidence requirements
The rules establish an evidence trail for tax credits tied to emissions-reduction investment. Electricity producers that derive at least 80% of revenue from electricity generation may receive a credit equal to 20% of qualifying expenditure. The credit cannot reduce more than 80% of the calculated carbon-tax liability.
Investment records must be maintained separately for each project or measure. Claimants must submit an analytical schedule of investments through the PK-1 form and calculate the credit through the PK-2 form. Recoverable value-added tax is excluded from eligible investment expenditure.
The framework requires engineering documentation alongside invoices to demonstrate that spending relates to recognised measures capable of reducing emissions. Equipment specifications, baseline energy balances, commissioning records, meter data, acceptance certificates, production volumes and post-investment performance are identified as part of the tax evidence file. Investments such as boiler replacements, waste-heat recovery systems, process electrification projects, renewable-energy installations or efficiency upgrades must be connected to defined emissions sources.
An operator must establish a pre-investment baseline and document measurable change after commissioning rather than treating such spending as capital expenditure with a green label. The rules therefore require links between investments and specific emission sources before credits can be supported by evidence. This includes documenting how performance changes after commissioning for each qualifying measure.
Import tax on embedded emissions: product coverage and thresholds
A 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 a tax period are outside the scope under the current threshold. The import tax base is based on embedded emissions generated during production of imported goods reduced by applicable reference emissions.
Actual embedded emissions may be used where confirmed by an eligible validator. Where actual values cannot be validated, calculations may rely on prescribed default values. This approach ties import liability to product-specific embedded-emissions determinations rather than relying solely on customs values.
The import return is submitted using the PP UUIP form with support from 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.
E-invoicing data exchange with customs and credit claims for foreign carbon payments
The Customs Administration must transmit import data electronically to the Tax Administration by the 10th day of each month for the preceding month. Data fields include tariff code, description, quantity, country of origin, customs value, customs-declaration number and date, importer identity and customs office location details. Monthly exchange supports cross-checking between import declarations held by state systems.
An annual carbon-tax return can be compared with customs declarations already held by Serbia without relying on traditional on-site inspections. Differences in product quantities, tariff classification, origin, supplier identity or reporting period are expected to be detectable through these comparisons. This reduces opportunities for inconsistencies between import reporting and annual returns.
Importers can claim a credit for a carbon price demonstrably paid in the country of origin. Supporting documentation must link payment to relevant product details including production installation information, emissions quantity and reporting period. It must include a verification report plus confirmation from a competent authority that the carbon charge was paid.
If documentation is in a foreign language it must be translated into Serbian by an authorised court interpreter. This requirement applies within credit-support packages submitted alongside import returns under Serbia’s framework. The credit mechanism therefore depends on both validation evidence and administrative confirmation tied to payment.
Ties to EU CBAM: reporting layers and MRV responsibilities
The Serbian measures intersect with EU CBAM but are not identical to it. The EU mechanism entered its definitive phase on 1 January 2026, covering imports in sectors including cement, iron and steel, aluminium, fertiliser, electricity and hydrogen where specified goods apply. EU importers or their indirect customs representatives carry legal obligations to report embedded emissions and surrender CBAM certificates.
If actual embedded emissions are declared under CBAM rules, underlying installation data must be verified by an appropriately accredited CBAM verifier. Serbia’s €4-per-tonne domestic tax does not create automatic exemption from CBAM because EU rules allow account to be taken only when carbon price effectively paid in origin can be evidenced subject to adjustments. Recognition depends on what was actually paid and whether documentation connects that payment to embedded emissions entering the EU.
A Serbian domestic payment receipt alone does not prove how much belongs to a particular shipment or product grade entering EU markets. Exporters need an allocation bridge connecting verified annual Serbian installation emissions with domestic taxable base and carbon payments mapped to specific embedded-emissions assigned to covered products exported to the EU. The bridge also needs to prevent double allocation across different customers or consignments.
Factory monitoring requirements for embedded-emissions calculations
A credible CBAM MRV system begins with defined installation boundaries and an inventory of emission sources at plant level. Operators must identify equipment such as furnaces, kilns, boilers and generators plus other relevant process units; determine which fuels and raw materials enter each process; document measurement instruments and calculation methods; and establish controls over production and inventory data used in calculations.
The system then converts plant data into product-specific embedded emissions using consistent treatment across production routes including intermediate goods, recycled content, process gases and waste streams such as flaring. It also requires handling exported energy flows along with internal transfers and shared utilities where multiple products use common assets like steam or electricity supplies. Allocation methods must be technically justified when several products share production assets.