Once you have picked an ESIR, one question is left, and it is the more important one: which fiscal receipt processor you work with. It decides what equipment sits on the premises, what you pay for, and what happens on a Saturday night when the internet drops. If you sell from business premises, the law, as we understand it, already gives part of the answer, so we start there.
Article 2 of the Law on Fiscalization defines a fiscal receipt processor as an element whose use has been approved by the Tax Administration and which exchanges data with an ESIR. The two variants come from article 6 paragraph 3: a device with its own processor, which issues receipts "even in the event of a temporary or permanent interruption of the internet connection" (an L-PFR), and a device that uses the processor in the Tax Administration's fiscalization management system and issues receipts "exclusively through a permanent internet connection in real time" (a V-PFR). Article 6 paragraph 4 adds, as we understand it, that a taxpayer who uses a V-PFR must also ensure the unobstructed operation of at least one L-PFR device in every business premises that has been given a unique premises identifier. The only exceptions are taxpayers whose retail sales are made exclusively over the internet, or who only sell their own used movable assets at retail. The Tax Administration says the same in its answers to frequently asked questions: in a retail outlet a V-PFR may be used "with the obligation to have at least one L-PFR per outlet".
V-PFR: the processor sits at the Tax Administration
A virtual fiscal receipt processor runs on Tax Administration infrastructure. Your ESIR sends receipt data to it over the internet, the V-PFR processes and signs it, and returns a signed journal.
What you need:
- A digital certificate as a file (.pfx or .p12), which you get from the Tax Administration. That is your security element.
- The PAC, a six character code (letters and digits) that you choose yourself when you request the certificate file. Without it the V-PFR rejects the request.
- A stable internet connection. This is not a recommendation, it is a precondition.
What the V-PFR itself does not need: a card reader, a computer that has to stay on for the processor, a local network for somebody to maintain. But note: if you sell from business premises, article 6 paragraph 4, as we understand it, still requires at least one L-PFR device to be running in those premises alongside the V-PFR. A V-PFR with no equipment on site is enough only for a taxpayer whose retail sales are made exclusively over the internet, or who only sells their own used movable assets at retail.
The defining property of a V-PFR. When the line drops, a receipt cannot be signed through the V-PFR, because the signature is created by the processor on the Tax Administration's side and the only way to it is over the internet. That is exactly why, as we read article 6 paragraph 4, the law requires an L-PFR alongside a V-PFR in business premises.
L-PFR: the processor sits with you
A local fiscal receipt processor runs on your own equipment, on the premises or on the local network. Its security element is, as a rule, a smart card in a reader standing right there next to the register.
Because both the processor and the card are physically on site, signing does not depend on the internet. The L-PFR signs the receipt immediately and sends the data to the Tax Administration later, when there is a connection.
There is one limit, though: the Tax Administration sets a ceiling on the smart card, the largest total amount of receipts the card will sign without an audit. Once that amount is reached, the card stops signing until the data reaches the Tax Administration.
Article 8 paragraph 2 of the Law provides for this explicitly: when the internet connection is interrupted or not available at the place of sale, the data is delivered "immediately upon restoration of the internet connection, and within five days of the day the individual fiscal receipt was issued at the latest".
What you need:
- A smart card from the Tax Administration and a card reader.
- A device to run the L-PFR on. That can be a dedicated appliance or a computer on the premises.
- A local network over which the ESIR talks to the L-PFR.
From which follows something that is often missed: if your ESIR is a web application in the cloud and you want an L-PFR, the ESIR has to be installed locally. A server on the internet cannot reach a device on your local network. You can combine a web register with an L-PFR, but only by installing the register on the premises.
The comparison in one table
| L-PFR | V-PFR | |
|---|---|---|
| Where the receipt is signed | on the premises | on a Tax Administration server |
| Security element | smart card in a reader | a .pfx or .p12 file |
| Issuing receipts without internet | works | does not work |
| Deadline for sending data to the Tax Administration | real time; without a connection, as soon as it returns and within 5 days of the day each receipt was issued at the latest | real time |
| Equipment on site | reader, device, a local network if needed | nothing for the processor itself; in business premises an L-PFR must still run alongside it (article 6 paragraph 4), save for the exceptions in that paragraph |
| Maintenance | yours or your service company's | the processor is run by the Tax Administration; you remain responsible for the proper working of the device as a whole (article 6 paragraph 5) |
| Cloud ESIR | no, a local installation is required | yes |
| Several sales points | as a rule one processor per location | a separate certificate for each business premises, and an L-PFR in each of them as well |
The decision rule, in one question
If you sell exclusively over the internet, the question is: what does an hour without issuing receipts cost you. If you sell from business premises, you need an L-PFR in any case, as we read article 6 paragraph 4, and the only question is whether you also want a V-PFR alongside it.
If the answer is "nothing dramatic, we will wait" and you sell only online, the V-PFR is the obvious choice. Less equipment, fewer things that break, nothing maintained on site.
If the answer is "a queue of twenty people on a Saturday night", you see the value of an L-PFR in practice too: it keeps issuing receipts when the line drops. A bakery at peak, a cafe during a match, a stand at a fair or a shop in a place where the line can be down for half a day are all business premises, so, as we understand the law, they need an L-PFR anyway.
A useful addition that gets forgotten is two internet connections: a mobile router as a backup. With a V-PFR it cuts down outages, but it does not replace the L-PFR that the law, as we understand it, requires in business premises. It does not solve a power cut and it does not solve an outage at the operator itself, but it solves a cut cable.
What an L-PFR does not solve. The five days in article 8 are a deadline for delivering data, counted from the day each receipt was issued, not permission to run for five days cut off from the world. If there is still no connection after that, the data has to be delivered another way: the Rulebook on the manner and procedure of delivering data on issued fiscal receipts (article 3 paragraph 2 and article 7) provides for a local audit of the L-PFR onto a USB stick or memory card and upload through the Tax Administration portal, within the same five days. Missing that deadline is, as we understand article 16 of the Law, an offence, even if every receipt comes out of the printer exactly as it should.
Can the decision be changed later
It can, but not for free. Moving from a V-PFR to an L-PFR means a new security element in a different form, buying a reader and a device, and as a rule a local installation of the ESIR. Moving the other way is easier, because you are removing equipment instead of adding it.
In practice the security element takes the most time, because the Tax Administration issues it: under the Rulebook on the conditions and procedure for issuing and using the security element (article 6 paragraph 3) it generates the element within seven days of the application, and by its own account a card can usually be collected at a Tax Administration office the next day. If you are considering a move, start with that step, not with the last one.
How this looks in Otkucaj
Otkucaj supports both modes and a third, demo, for trials and training. The mode is chosen in settings, and the connection status is shown live, so you know straight away whether the processor is reachable.
- V-PFR: you enter the processor address, the certificate file with its password, and the PAC. Nothing is installed.
- L-PFR: you enter the address of the local processor on the shop network; as explained above, the ESIR then has to run on the premises, not from a server on the internet. Otkucaj never touches the card and must not touch it, because the L-PFR is what signs with it.
- Demo: a built in simulator. Every receipt is marked DEMO, has no fiscal validity, and exists so cashiers can be trained before the real processor is ready.
Otkucaj is an ESIR approved by the Serbian Tax Administration, record number 1667, classification 3. A new account starts in the test environment, where receipts are not fiscal; production requires your own security element and PAC.
Sources
- Law on Fiscalization („Службени гласник РС“ no. 153/2020, 96/2021, 138/2022 and 80/2026), articles 2, 6, 8 and 16.
- Rulebook on the manner and procedure of delivering data on issued fiscal receipts to the Tax Administration („Службени гласник РС“ no. 31/2021 and 99/2021), articles 3 and 7.
- Rulebook on the conditions and procedure for issuing and using the security element („Службени гласник РС“ no. 31/2021 and 96/2021), article 6.
- Tax Administration of the Republic of Serbia, eFiscalization help (tap.suf.purs.gov.rs/help): "Digital certificate PAC", "Security element limit", "Local audit"; and answers to frequently asked questions.
- Tax Administration of the Republic of Serbia, eFiscalization: the security element, the heart of the new fiscalization system, 17 October 2022.
- Tax Administration of the Republic of Serbia, Technical guide for the administrative and technical review of ESIR or L-PFR functionality.
- Tax Administration of the Republic of Serbia, Register of approved elements of an electronic fiscal device.