Grey book 17

Dear members and partners,

We present to you the new, 17th edition of Grey Book, which traditionally includes 100 concrete proposals for reducing unnecessary bureaucracy and
improving the predictability and transparency of business conditions in Serbia. Since the previous edition, institutions have managed to partially resolve only
two recommendations, which is one of the weakest results since the first Grey Book was published in 2008. This indicates a signicant slowdown in the pace of
reforms, which in previous years reached as many as 12 fully or partially implemented recommendations.

In 2024, partial progress was made on the recommendations for reducing administrative and financial obligations for beekeepers, and for the digitalization and
centralization of procedures related to connecting prosumers to the electricity distribution grid, including the introduction of the concept of the "active customer"
- a step toward alignment with the EU. Considering the complexity of some reforms, which require more than a year to be fully implemented (the time frame of
a single Grey Book edition), we began tracking ongoing reforms last year, with 11 featured in this edition.

For example, a long-standing Grey Book recommendation to regulate non-tax charges became relevant again in 2024, with the aim of ensuring full transparency
through electronic payments of all fees and charges. This will enable further systemic improvements in this area and the elimination of parafiscal levies. The
importance of this recommendation for citizens, the economy, and Serbia’s EU integration has been recognized by both the Government of Serbia and the EU
Delegation, and the reform of non-tax and parascal charges has found its place in the ofcial Reform Agenda of Serbia.

Digitalization continues to be a catalyst for change, through ongoing reforms such as the introduction of eBills of lading for transported goods, eSick Leave
certificates, and a unied electronic health record and resource database. Accordingly, digitAIization was particularly highlighted last year as a strategic focus of
NALED’s activities.

Grey Book 17 contains 9 new and 91 previous recommendations, of which 21 were revised and improved. This year, we continue the practice of tagging certain
recommendations with the “EU Badge” - 23 in total - to emphasize their contribution to Serbia’s faster EU integration. Additionally, 11 recommendations retain
the “Cashless Payments” label due to their importance for countering the shadow economy and further developing eGovernment and eBusiness. Furthermore,
we have highlighted 35 recommendations focused on digitalization.

Over the past 17 years, our regulatory Bible has presented nearly 330 unique recommendations, more than half of which have been partially or fully implemented.
Behind each proposal and successfully implemented reform lies dialogue and cooperation between the private, public, and civil sectors - embedded in NALED’s
very DNA. Therefore, I would like to thank all NALED members and fellow Executive Board members for their trust and contributions, our international
partners - especially the Government of the Kingdom of Sweden for its valuable support - and our expert team who push the boundaries every year in preparing
this important publication.

I also invite competent institutions to stay on the reform path and, in cooperation with NALED, achieve better results in implementing Grey Book recommendations
for the benet of all who live, work, and invest in Serbia. Because only together can we make a difference.