On 12 December 2025, the latest amendments and supplements to the Law on Electronic Delivery Notes entered into force.
The purpose of these amendments is to further clarify the existing provisions of the Law and to tighten the liability of entities that issue electronic delivery notes (for example, with respect to obligations relating to the preparation of electronic delivery notes in paper form).
Bearing in mind the adopted amendments, as well as the accelerated digitalization of business operations and everyday life in general, this presents an excellent opportunity—within a broader analysis of regulations governing digitalization, business modernization, and digital security—to address this area, which is of particular importance for the transport of goods.
Accordingly, the first question that arises is: what is an electronic delivery note?
Pursuant to the statutory definition, an electronic delivery note is a document accompanying goods that are dispatched for the purpose of recording the movement of goods, and which is sent and received through a system in a structured format that enables fully automated electronic data processing.
Simply put, it is an electronic document on the movement of goods, issued, exchanged, and stored in digital form. Such an electronic document enables easier and more accurate real-time tracking of goods movement. All data are recorded automatically and in a fully transparent manner, thereby eliminating the possibility of errors that occurred when delivery notes were issued in paper form.
Now that the nature of this document has been clarified, the most important provisions of the Law will be addressed below in order to better understand the scope of application of electronic delivery notes, their essential elements, and related matters.
Mandatory Use of Electronic Delivery Notes
Electronic delivery notes must be issued by entities from both the private and public sectors that are engaged in the transport of goods or dispose of goods, as well as by carriers acting in the name and on behalf of such entities.
The Law uses the term “any movement of goods,” which in practice means that electronic delivery notes must be issued in the following cases of goods movement:
- sale of goods in any form, including their delivery;
- distribution of goods;
- transport of goods to their destination;
- import and export of goods, including international transport.
The Law also prescribes exceptions to this rule, i.e., areas in which issuing an electronic delivery note is not required. These include:
- transport or distribution of water, electricity, natural gas, heating and cooling energy, as well as the supply of aircraft with fuel and lubricants where the place of dispatch and place of receipt is the same airport;
- retail trade (i.e., goods sold to customers in retail stores);
- delivery of goods in fulfillment of contractual obligations aimed at beneficiaries of funds from international framework agreements (i.e., international aid or cooperation);
- goods intended for procurement, modernization, or overhaul of military and/or security-sensitive equipment;
- goods dispatched within a single public sector entity (for example, where organizational units of such an entity are geographically separated);
- movements of goods where the goods or part thereof are returned using the same means of transport immediately after delivery, provided that the recipient of the electronic delivery note has sent an electronic receipt specifying the goods being returned;
- movements of goods based on an approved clinical trial of a medicinal product or medical device, in accordance with regulations governing medicinal products and medical devices.
It is important to note that the Law will be implemented in phases. The first phase begins on 1 January 2026, introducing the obligation to receive, send, and display electronic delivery notes for public sector entities, as well as for business entities dealing in excise goods. As of that date, the same obligation also applies to business entities engaged in commercial relations with public sector entities.
Electronic Delivery Note System
Electronic delivery notes are issued, received, accepted, rejected, and stored within a dedicated system. The electronic delivery note system is a specialized information system in which fully automated processing is performed and which is managed by the Central Information Intermediary. Through this system, electronic delivery notes and electronic receipts are sent, received, recorded, processed, and stored.
The Central Information Intermediary is the competent organizational unit within the Ministry of Finance responsible for managing the system and ensuring its proper functioning.
In order for the system to function properly and for an electronic receipt to be duly issued, all data relating to the goods must be entered into the system before the goods leave the warehouse, so that tracking and documentation are accurate and precise.
The system must be used by private and public sector entities engaged in the transport of goods as described herein; however, the Law does not prevent other interested parties from accessing the system if they so choose.
Within the system, there is an additional document (the electronic receipt) and an additional action (confirmation of electronic receipt).
An electronic receipt is an electronic document by which the recipient confirms that the goods have been received in the agreed quantity and quality, while confirmation of physical receipt refers to the action by which the recipient confirms that the goods have been delivered to the agreed location.
Through the system, the recipient may also reject or accept the delivery note, depending on whether the data stated therein correspond to the actual situation.
Electronic Delivery Note in Paper Form
In cases where the system fails or where technical issues occur—such as system malfunction or internet outage—the Law allows the electronic delivery note to be printed in paper form, provided that it is marked with a security hologram sticker.
In such cases, users are enabled, through specific system functionalities, to record information on the electronic delivery note in paper form. The consignor of the goods is then required to print three copies of the electronic delivery note and mark them with security hologram stickers bearing the same numbering. One copy is retained by the consignor, while two copies are handed over to the carrier for presentation and for further delivery of one copy to the recipient of the goods.
As this is a temporary situation, the consignor is required to record all missing data in the system no later than the first following business day after the system connection has been restored. Thus, the Law provides a solution even in cases where the system encounters operational difficulties.
As regards the recipient of the electronic delivery note, receipt is confirmed by sending an electronic receipt within the statutory deadline, i.e., on the first following business day after restoration of the system connection, if the recipient was unable to do so within the prescribed period due to a connection outage.
Sending, Receipt, Acceptance, and Rejection
As previously stated, an electronic delivery note must be issued no later than before the goods commence transport.
The recipient of the electronic delivery note is obliged to confirm physical receipt of the goods on the day of taking over the goods or no later than three business days after commencement of receipt, except in cases of system downtime due to technical reasons, in which case this action must be performed on the first following business day after restoration of the system connection.
If confirmation of receipt of the goods to which the electronic delivery note relates is not performed, the electronic delivery note ceases to be valid upon expiry of 30 days from the date on which the movement of goods commenced. In any case, an electronic delivery note is deemed received at the moment it is sent to the recipient through the system.
The consignor may cancel the electronic delivery note before the recipient confirms receipt of the goods, provided that the reasons for cancellation are stated.
The recipient, for their part, is required to verify the electronic delivery note through the system and then accept or reject it, in full or in part, within eight days from the date of confirmation of physical receipt of the goods, by sending an electronic receipt.
If a recipient from the public sector fails to send an electronic receipt within the prescribed deadline, the delivery note is deemed accepted in full. In contrast, if the recipient is a private sector entity, failure to send an electronic receipt within the prescribed deadline results in the electronic delivery note being deemed rejected.
Conclusion
The electronic delivery note system is a natural continuation of the e-invoice system and of the overall digitalization of the economy and transaction recording between entities.
These systems are mutually aligned, as a duly issued and accepted delivery note forms the basis for the subsequent issuance of an e-invoice for payment. In this way, business transparency is increased and transaction records are facilitated.
Although there will undoubtedly be challenges and difficulties in transitioning to this system, it represents an unequivocal benefit, as it reduces administrative burdens, accelerates the flow of goods, facilitates goods tracking, and enables faster system-based communication, thereby contributing to comprehensive digitalization and the acceleration of transport and goods movement procedures.
Naturally, it is incumbent upon state institutions to further strengthen the legal framework through by-laws and to establish a secure, stable, and reliable system that will be of tangible value to its users in their business activities.