New “E-Sick Leave – Employer” System: What Employers Need to Know

The new Act on the Exchange of Data, Documents and Notifications in Cases of Temporary Incapacity for Work through the “e-Sick Leave – Employer” Software Solution (“Act”) has been adopted.  As of January 1, 2026, the Act introduces mandatory use of the unified software solution “e-Sick Leave – Employer”.  It aims to achieve full digitalization of the sick leave process, reduce administrative burden, and increase transparency and efficiency.

The Act requires employers to register for and access the “e-Sick Leave-Employer” system no later than January 1, 2026.  Employers who fail to register for and use the system are subject to fines ranging from RSD 50,000 to 200,000 for legal entities, RSD 10,000 to 50,000 for entrepreneurs, and RSD 5,000 to 25,000 for the responsible person within the employer.

The “e-Sick Leave – Employer” system is a digital platform, available as a service within the eGovernment Portal eUprava.  It provides employers a clear and timely insight into information concerning employees who necessitate sick leave.  The system also enables full electronic data exchange between healthcare institutions, employers, and the National Health Insurance Fund (RFZO).

Key Changes Introduced by the New “E-Sickleave – Employer” System 

The “e-Sick Leave-Employer” system introduces a comprehensive modernization of the process of opening and monitoring sick leave.  In practice, this brings a number of significant benefits for both employers and employees, including the following:

1. Elimination of paper documentation and transition to digital data exchange: Doctors will issue electronic certificates confirming the onset of temporary incapacity for work, as well as electronic reports. The Act abolishes the employee’s duty to submit paper certificates or sick leave slips to their employer. Both the electronic certificate and the electronic report will have the legal effect of a public document.

2. Automatic employer notifications: Once the doctor issues an electronic certificate or report, employers will automatically receive it through the “e-Sick Leave – Employer” system and gain immediate access to all electronically issued documents relating to their employees.

3. Electronic access to all sick leave data: The system provides a comprehensive and centralized overview of employees and their sick leaves, including, among other things:

• • a complete overview of all employees sick leaves in one place (full name, personal ID number, reason for sick leave, start/end date, etc.);
  • advanced search capabilities allowing precise filtering by employee, period, type of sick leave, and other parameters;
  • detailed insight into each individual sick leave record, including all relevant information;
  • document download options and data export functionalities.

4. Elimination of certain employee obligations under the Labour Act: As of the date the Act becomes applicable, several obligations previously imposed on employees are abolished. Specifically:

• • the obligation of the employee to submit a medical certificate to the employer within three days of the onset of temporary incapacity for work (Article 103 of the Labour Act);
  • the employer’s right to terminate the employment agreement if the employee fails to submit the medical certificate (Article 179(3)(2) of the Labour Act).

5. New method for submitting requests and appeals to RFZO (applicable as of April 1, 2026):

Through the “e-Sick Leave – Employer” system, employers will be able to:

• • submit electronic requests for calculation and reimbursement of salary compensation,
  • monitor the status of submitted requests directly within the system, and
  • electronically submit appeals.

Employer Obligations and Deadlines

The Act requires all employers to use the “e-Sick Leave – Employer” system. Specifically, employers must:

• • Register the legal entity / complete registration on the eGovernment Portal (eUprava), which may only be performed by the registered legal representative in the Serbian Business Registers Agency (APR), using a qualified electronic certificate (QES) or the ConsentID application (Guide). The Guide notes that all companies registered with APR already have automatically created accounts on the eGovernment Portal. For other subjects (entrepreneurs and foreign company branches), the registration deadline is 1 January 2025.
  • Access the “e-Sick Leave – Employer” system and activate the account, i.e., create the employer profile (Guide). This step is performed upon first accessing the system and includes verifying the automatically retrieved basic company information (company name, registration number, TIN, etc.), as well as entering additional required information (such as the dedicated bank account number and email address for notifications). Deadline: 1 January 2026.
  • Assign authorized users who will be able to manage data within the “e-Sick Leave – Employer” system via the “User Administration” functionality (Guide).

Deadlines Applicable to Employers

• • Registration on the eGovernment Portal eUprava – by January 1, 2026
  • Accessing the “e-Sick Leave – Employer” system and creating the employer profile – by January 1, 2026
  • Electronic issuance, access and exchange of certificates, reports and sick leave information: from January 1, 2026
  • Submission of requests for salary compensation reimbursement and filing of appeals: from January 1, 2026
  • Deadline for registration and system access for entrepreneurs who employ one or more people: by January 1, 2027

The full Act is available here.

Author: Nađa Gogić

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