eBolovanje, an Electronic Sick Leave System, introduces a new method of data exchange concerning employees’ temporary incapacity for work. The term eBolovanje will be used throughout this text.
The Law on the Exchange of Data, Documents and Notifications in Cases of Temporary Incapacity for Work through the Software Solution “e-Bolovanje – Employer” (hereinafter: the Law), applicable as of 1 January 2026, completes the digitalisation of labour-law and healthcare procedures in Serbia.
This Law for the first time systemically regulates the electronic exchange of data relating to employees’ temporary incapacity for work. In doing so, it changes the long-standing practice based on paper certificates, manual delivery of documentation and delays in the exchange of information between healthcare institutions, employees and employers.
For both employers and employees, this Law does not represent merely a technical innovation, but also introduces a new set of rights, obligations and responsibilities.
What Is e-Bolovanje – Employer
The Electronic Sick Leave System (“e-Bolovanje – Employer”) is a software solution that enables employers to access electronically the data relating to employees’ temporary incapacity for work.
Through the system, employers receive information on:
the date sick leave commenced,
the duration of sick leave,
any extensions or termination,
changes relevant for salary compensation calculation and work organisation.
It is important to emphasise that employers do not have access to diagnoses or detailed medical data, thereby ensuring the protection of employee privacy.
Reasons for Adopting the Law
In practice, numerous issues have existed for years in relation to sick leave records and control. Until now, the procedure functioned as follows:
An employee who becomes ill or injured receives a certificate of temporary incapacity for work from their chosen physician and must deliver it to the employer within three days. If the employee is unable to do so personally (due to serious illness or injury), the delivery is performed by a family member. If the employee lives alone, the deadline was three days from the moment they became able to deliver the certificate.
At the end of each period of temporary incapacity for work, or at the end of each month in cases of long-term sick leave, employees had to obtain so-called sick-leave slips (doznake) from their physicians so that employers could correctly calculate salary compensation.
This procedure often resulted in irregular delivery and delays. Additionally, healthcare institutions applied non-uniform practices, and certain certificates were open to interpretation, leading to increased administrative burden for employees and HR departments.
The objectives of the Law are:
- to ensure fast, accurate and secure data exchange;
- to enable employers to organise work more efficiently, as opposed to situations where they had no information for up to three days regarding the reason for an employee’s absence;
- to reduce administrative burdens;
- to improve transparency of the sick-leave system;
- to allow timely actions by employers and the Health Insurance Fund (RFZO).
Absenteeism as an Increasingly Common Phenomenon
Employee absence from work—whether due to sick-leave abuse or failure to report to work without formally terminating employment—is becoming increasingly common and has acquired an established term: absenteeism.
This phenomenon is particularly frequent during summer (July–August) and winter months (December–January). At the same time, employees point to physical exhaustion and stress, especially in manufacturing, public utility services, retail and hospitality.
While sick leave is a fundamental labour right, abuse is often identifiable through recurring patterns, such as absences during periods of increased workload.
Employers are sometimes forced to maintain “reserve” staff, which represents a significant financial burden, while questionable sick leaves may also cause dissatisfaction within work collectives.
One of the purposes of the e-Bolovanje system is to reduce absenteeism. Employers will immediately know whether sick leave has been opened, enabling timely work organisation and accurate compensation calculation. Physicians will also have insight into a patient’s medical and absence history.
Employers Covered by the New System
For the purposes of this Law, an employer includes state authorities, provincial and local self-government bodies, institutions, public notaries, enforcement officers, companies and other legal entities, as well as entrepreneurs employing one or more persons.
Employers are required to register for and access the e-Bolovanje – Employer system by 1 January 2026, except for entrepreneurs employing one or more persons, who must comply by 1 January 2027.
Entrepreneurs who do not employ others may also use the system for their own records.
Employer Obligations Under the New Law
Employers are required to:
- Use the system in accordance with the Law and implementing regulations.
- Act upon received data, which is used for absence records, salary compensation calculation and work organisation.
- Align internal acts and procedures, including work regulations, HR procedures and personal data protection policies.
Rights and Obligations of Employees
For employees, the new system introduces significant changes:
- employees no longer deliver paper certificates to employers;
- employees working for entrepreneurs not yet obliged to use the system must still notify their employer in accordance with employment contracts or work regulations;
- employees retain the right to privacy and protection of health data.
The Law does not reduce employees’ rights to salary compensation during sick leave; it only changes the method of data exchange.
Amendments to the Labour Law
The entry into force of the Law repeals Article 103 and Article 179 paragraph 3 item 2 of the Serbian Labour Law.
By repealing these provisions, employees are no longer required to obtain and deliver paper documentation related to sick leave. However, due to the postponed application for entrepreneurs, their employees will continue to deliver documentation under the previous system until compliance.
Personal Data and Health Data Protection
Sick-leave data constitutes a special category of personal data. Employers process only data necessary for exercising rights and obligations arising from employment relationships and do not have access to diagnoses unless expressly authorised by the employee.
All healthcare data will be stored in the State Data Centre in Kragujevac.
Misdemeanour Penalties
Employers who fail to use the e-Bolovanje system are subject to fines ranging from:
RSD 50,000 to 200,000 for legal entities,
RSD 10,000 to 50,000 for entrepreneurs,
RSD 5,000 to 25,000 for responsible persons.
Conclusion
The new e-Bolovanje system eliminates paper documentation, reduces errors and abuse, and relieves employees of administrative obligations. It represents a significant step towards modernisation and digitalisation of sick-leave administration in Serbia and requires timely compliance by employers as part of lawful and responsible business conduct.
Law Firm Petrović Mojsić & Partners
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