The Ministry of Finance’s Sector for Accounting and Auditing issued an official opinion (Sluzbeno misljenje) on 28 September 2026 clarifying the scope of internal acts (interni akti) in regulating inventory (popis) procedures. While companies are encouraged to adopt internal rules detailing the organization, methodology, and responsibilities for conducting mandatory annual inventories (per Article 19 of the Law on Accounting), such internal acts cannot extend, shorten, or otherwise modify the statutory deadlines prescribed by the Law on Accounting and the Rulebook on Inventory. The statutory deadline for completing the annual inventory is 31 December of the current year, with results reflected in the financial statements for that year. The opinion emphasizes that any internal act attempting to set a different cutoff date (e.g., 30 November or 15 January) for inventory completion is null and void for legal and audit purposes. External auditors and tax inspectors will disregard internal deadlines that conflict with the law. The opinion also addresses surprise inventories (neplanirani popis), confirming they must follow the same statutory framework. This guidance is effective immediately and applies to all legal entities subject to Serbian accounting law, including foreign branches.
Key Takeaways
- Statutory Deadlines Are Immutable: The legal deadline for annual inventory completion remains 31 December. Internal acts can only prescribe procedural details (counting methods, team composition, documentation templates) but cannot alter this date. Financial statements audited under ISA will be qualified if inventory was not completed by year-end.
- Internal Acts Must Reference Legal Framework: Companies should update their inventory policies to explicitly state that they operate within the statutory timeline. The policy should reference Article 19 of the Law on Accounting and the Rulebook on Inventory (Official Gazette No. 95/2021).
- Surprise Inventories Follow Same Rules: Unannounced inventories ordered by management or supervisors must still adhere to the legal framework; they cannot be used to circumvent year-end procedures. Results of surprise inventories must be documented and reconciled with the annual inventory.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement