The Law on Amendments to the Law on Deadlines for the Settlement of Monetary Obligations in Commercial Transactions (hereinafter: the “Law”) entered into force on 12th of December 2025, while the application of certain provisions has been postponed for 2nd of July 2026.

The Law introduces the following obligations for public sector entities (the sector of the state, as well as public enterprises regardless of whether they fall within the sector of the state):

  • the obligation to enter data on the settlement of monetary obligations into the Treasury Administration’s information system within three working days from the date of settlement of the monetary obligation – for public sector entities that make payments via accounts held with banks; and
  • the obligation to update, by 1st of July 2026, in the Treasury Administration’s information system the status of all undertaken monetary obligations that are recorded in this system as unsettled and for which the payment deadline has expired.

The Law also provides misdemeanor liability of the responsible person in the public sector if the public sector entity that this person manages fails to comply with these newly introduced obligations and monetary fines for these misdemeanors are prescribed in the range from RSD 5,000 to RSD 150,000.

In the explanation of the proposal of the Law it is stated that the main reason for prescribing these obligations is that it has been observed that public sector entities, although they settle their monetary obligations in commercial transactions within the prescribed deadlines, do not keep records of such settlements updated in the Treasury Administration’s information system. As a result, many monetary obligations of these entities that have in fact been settled are recorded in the Treasury Administration’s information system as unsettled, and debt reports prepared based on data from this system show that the indebtedness of public sector entities is higher than it actually is.

An additional reason is that the Treasury Administration does not have insight into transactions on the accounts of users of public funds, who are not included in the consolidated treasury account system, at commercial banks, and therefore has no insight into the settlement of monetary obligations carried out through such accounts (which also has led to debt reports of public sector entities failing to reflect the actual situation).