The deadline for registering accountants in the Register of Accounting Services Providers in Serbia and for obtaining permits for performing/providing accounting services expires on January 1, 2023.
Legal entities and entrepreneurs whose main activity is registered for the provision of accounting services and who engage in the provision of bookkeeping services for other companies have assumed this obligation. The deadline for registration in the Register of Accounting Services Providers expires on January 1, 2023.
This is the deadline until which the legal obligation to register lasts, and/or the deadline for obtaining a permit to provide accounting services issued by the Chamber of Authorized Auditors. In addition, it is the deadline by which accountants are obliged to harmonize their operations with the applicable Law on Accounting.
The obligation to register in a special Register of Accounting Services Providers entered into force on January 1, 2020. It is in accordance with the applicable Law on Accounting, whereby a transitional period of 3 years is prescribed from the date of publication of the law and regulations. Until then, accountants who have clients and keep their books of account must obtain this permit to provide accounting services.
More details about the applicable legal regulation, as well as answers to questions about who can engage in bookkeeping activities and who can provide bookkeeping services are available below.
Who can engage in accounting and bookkeeping activities?
Accounting and bookkeeping activities can be performed by a legal entity, an entrepreneur, as well as an engaged natural person if he/she meets certain requirements stipulated by the general deed.
When a natural person is engaged, the general deed stipulates the requirements that the person must fulfil, because he/she is considered responsible for keeping the books of account and compiling financial statements. These requirements include:
- educational background,
- work experience,
- other requirements required for a person who is engaged and responsible for keeping the books of account and compiling financial statements.
An employer, and/or the company that wants to engage an accountant to perform bookkeeping activities, can decide at its own discretion to whom it will entrust the further management of the books of account. The employer can engage an accounting company or a natural person to perform these activities.
If the employer entrusts the accounting activities to a person, then the person will be in charge of keeping the books of account. The employer can establish an employment relationship with him/her (based on an employment contract), as well as enter into a non-employment contract. A contract on the provision of bookkeeping services is concluded with the bookkeeping agency.
When engaging a person who is entrusted with keeping the books of account and compiling financial statements, the Law does not prescribe a special form of contract, or the method of engagement. The following types of contract can be concluded:
- employment contract (employment relationship for a definite or indefinite period of time),
- employment contract (employment relationship) with full or part-time employment,
- contract on additional work,
- contract on temporary and occasional jobs,
- service contract,
- other similar contracts for engaging persons who will keep the books of account.
Natural persons cannot be registered in the Register of Bookkeeping Service Providers. Only legal entities or entrepreneurs whose main activity is registered for the provision of accounting services (activity code 69.20) can be registered in this Register.
Who can provide bookkeeping services and services of compiling financial statements?
Bookkeeping services and services of compilation of financial statements can be performed by a legal entity or an entrepreneur, if it is registered in the Register of Accounting Services Providers. In that case, if the business entity decides to engage an accounting firm for keeping the books of account and compiling a financial statement, then it must have a registered main activity for providing accounting services and must be entered in the Register no later than January 1, 2023.
One of the conditions for registration in the Register is the activity code. That is, it is necessary that it has registered the activity of providing bookkeeping services under code 69.20 as its main activity in the Serbian Business Registers Agency (that the accounting company that provides bookkeeping services to other clients is registered in the Register).
Companies that engage an accounting firm to provide accounting and bookkeeping services can sign a contract with the agency for the performance of bookkeeping services. In that case, the accounting firm is entrusted with the task of keeping the books of account and compiling financial statements.
The exception refers to affiliated legal entities, which can entrust their related legal entity with the performance of bookkeeping tasks – keeping of the books of account and compiling financial statements.
An accounting company that provides its bookkeeping services to other clients must appoint a person responsible for performing such bookkeeping tasks for each client. That is, the bookkeeping agency must appoint a responsible person for these activities by internal deed, for each client for whom it keeps the books of account and compiles a financial statement.
Conditions for registration in the Register of Accounting Services Providers in Serbia
The conditions for registration in the Register of Accounting Services Providers for legal entities or entrepreneurs and obtaining a permit to provide accounting services (a license issued by the Chamber of Certified Auditors) are as follows:
- the company’s main activity for the provision of accounting services must be registered;
- for a legal entity – it must employ at least one full-time employee holding a professional title in the field of accounting or auditing;
- for an entrepreneur – it must employ at least one full-time employee holding a professional title in the field of accounting or auditing; otherwise, the entrepreneur itself can fulfil this criterion;
- the founder of the legal entity that is registered for the provision of accounting services (beneficial owner, as well as member of the management body of the legal entity) has not been convicted by a final judgment for a criminal offence;
- an entrepreneur – a founder-natural person (and/or the owner, as well as a member of the management body) has not been convicted by a final judgment for criminal offences.
Who cannot provide bookkeeping services?
Bookkeeping services cannot be provided by a person against whom a final judgment on prison sentence has been ruled, if he/she has committed a criminal offence in the Republic of Serbia or in a foreign country. This includes keeping the books of account, compiling financial statements and other accounting tasks.
Legal entities that are prohibited from entrusting another legal entity or entrepreneur with keeping the books of account and compiling financial statements are:
- National Bank of Serbia,
- banks,
- insurance companies,
- providers of financial leasing,
- voluntary pension funds,
- voluntary pension fund management companies,
- investment funds,
- investment fund management companies,
- Central registry,
- securities depository and clearing office,
- stock exchanges,
- broker-dealer companies,
- factoring companies,
- institutions for carrying out payment transaction,
- electronic money institutions.
The legal obligation to appoint a person to perform bookkeeping activities
Accounting is a legal obligation of business entities. Accountants can be engaged to perform bookkeeping tasks, or companies can appoint a person to whom they will entrust the management of the books of account and the compilation of financial statements. Otherwise, if they fail to do so, it is considered that an economic offence has been committed that will be subject to fine.
A legal entity that fails to appoint by a general deed a person entrusted with the management of accounting tasks may be fined. Fines are also prescribed for the responsible person in that legal entity, as well as for the entrepreneur.
Incomplete financial statement
In accordance with the Rulebook on the conditions and manner of public disclosure of financial statements and maintaining the Register of Financial Statements, it is prescribed that financial statements are considered incomplete if they are not compiled by a legal entity or an entrepreneur registered in the Register of Accounting Services Providers.
Financial statements that have not been compiled by accounting company registered in the Register of Accounting Services Providers will be publicly disclosed as incomplete. The companies that are considered obligors in this regard will be informed about this through the Special Information System.
Upon receipt of the notification, they have the obligation to remove the observed inconsistencies by the given deadline. In case the deficiencies are not eliminated, the Agency will publicly disclose such financial statement as incomplete and inaccurate in calculations (the financial statement will not be accepted and published as correct by the Serbian Business Registers Agency).
In addition, fines are prescribed for failure to file financial statements, which is considered an economic offence. A legal entity, a responsible person in that legal entity, as well as entrepreneurs can be fined for a misdemeanour, as follows:
- legal entity – from 100,000 to 3,000,000 dinars,
- responsible person in a legal entity – from 20,000 to 150,000 dinars,
- entrepreneur – from 100,000 to 500,000 dinars.
How can it be checked if the accounting firm has been registered in the Register?
The website of the Serbian Business Registers Agency, which maintains the Register, contains the information on whether the accounting company has been registered in the Register. The search for providers of accounting services can be made via the link: https://rpru.apr.gov.rs/PretragaRPRU.
The Accounting firm HLB T&M Consulting from Belgrade (Serbia) is registered in the Register of Accounting Services Providers of Serbia. If you need a reliable and professional business associate, as well as a responsible bookkeeping agency, we can offer you comprehensive accounting solutions tailored to your needs. You can contact us for all questions related to the topic of providers and method of provision of bookkeeping services. The agency HLB T&M Consulting is at your disposal.
