The Law on the Exchange of Data, Documents, and Information in the Event of Temporary Incapacity for Work through the Software Solution “e-SickLeave – Employer” (“Official Gazette of RS” no. 109/2025 – hereinafter: the “Law”) has been adopted by the Serbian Parliament.

The Law stipulates the mandatory use of the software solution “e-SickLeave – Employer”, which will serve as the system for exchanging documents and status updates related to employee sick leave, simplifying communication between employers, chosen primary care physicians, and the Health Insurance Fund.

Employers will be required to register with and access the “e-SickLeave – Employer” software solution (hereinafter: “e-SickLeave”) by 1 January 2026 (entrepreneurs employing one or more employees have an additional year). Employers will use the “e-SickLeave” platform to receive, review, and submit data and documents relevant to temporary incapacity for work, and to monitor wage compensation calculations, payments, and the status of objections and requests. Key functionalities include:

• receipt of certificates and reports on temporary incapacity for work (delivered automatically when the chosen primary care physician determines temporary incapacity);
• submission of requests for calculation of wage compensation during temporary incapacity for work, as well as receipt of calculations from the competent authority;
• submission of objections or requests, and receipt of notifications in procedures conducted before the first-instance and second-instance medical commissions.

Non-compliance with the obligation to register with and use the “e-SickLeave” platform may result in fines ranging from RSD 50,000 to 200,000 (c. EUR 420 to 1,700) for employers, RSD 10,000 to 50,000 (c. EUR 85 to 420) for entrepreneurs, and RSD 5,000 to 25,000 (c. EUR 42 to 212) for responsible persons within the employer.

Automatic delivery of the certificate and report on temporary incapacity for work will eliminate the current Labor Law requirement for employees to submit such confirmation to the employer within three days. Consequently, failure to submit this confirmation will no longer be grounds for termination of the employment contract.

Details on the use of “e-SickLeave” platform, its connection to other information systems, and the content of relevant forms should be regulated by a bylaw by 1 January 2026.

The Law enters into force on 12 December 2025, and will apply from 1 January 2026, except for provisions on employer registration and access to the “e-SickLeave” platform, which apply upon entry into force. Some functionalities of the “e-SickLeave” platform will become operational somewhat later – from 1 April 2026.

Procedures initiated before the Law starts to apply will be concluded under previously applicable regulations.