Grey Book

The Grey Book contains 100 most significant recommendations by businesses, local government and civil society organizations for eliminating the administrative obstacles to doing business in Serbia, and it represents one of the key documents used by the state institutions as guidelines in planning and implementing the regulatory reforms.

Since it was first published in 2008, the Grey Book has seen 13 editions and presented 281 recommendations for improving the business environment. Out of this number, 75 have been fully resolved (27%), and 68 partially resolved (24%), meaning that more than half of recommendations have reached the policy makers. 

In 2021, 12 recommendations were implemented - three fully and nine partially, which represents continuation of the slower reform tempo from 2020, largely due to the economic crises caused by coronavirus pandemic. However, this result is slightly better than the average for the past 12 years. 

The new edition of the Grey Book for the first time brings 21 new recommendations for the Government of Serbia and repeats unrealized 79 recommendations from the previous year. Last year we highlighted 15 recommendations marked with a "COVID-19 badge", while this year the focus is on the country's commitments in the process of accession to the European Union. We had choosed the 22 recommendations awarded with the "EU badge" in order to point out the Grey Book's contribution to getting closer to our European family and meeting the standards that we see not as a goal but as a means to create better living and working conditions in our country.

As in the previos years, the Grey book 14 marked ten priority recommendations for the responsible institutions. These recommendations mostly focus on procedures digitalization, property and planning issues, flexible forms of work engagement, higher transparency of non-tax levies and criteria of the environment protection. 

The first steps

The Grey Book came into existence in 2008 as a result of NALED’s desire to assemble all segments of society and encourage them to engage and contribute to the common goal – building a better business environment by eliminating redundant and obsolete administrative procedures. No initiative before or after the Grey Book had dealt systematically with the administrative and practical problems faced by businesses on a daily basis, which led to Grey Book being accepted by institutions as a strategic document in planning policy reforms.

Late in May 2008 the public was introduced to the „Out of the Maze“ campaign NALED initiated together with USAID and B92 TV station. Citizens and businesses were invited to nominate complicated procedures and propose models of improvement. During June, NALED received as much as 245 justified proposals, 55 of which earned their place in the first issue of the Grey Book. Three citizens were prized for their proposals for improving the procedures of TIN assignment, construction permitting and tax filling.

Key Results

The Grey Book is responsible for elimination of some of the proverbial bureaucratic barriers. Based on NALED’s initiative, to name a few examples, the wage tax and social security contributions are now paid to a single account instead of 12 different accounts, the institutions no longer require that an excerpt from public records is not older than six months, the employment booklets are no longer used, the health insurance card are verified automatically, and the construction permitting procedures have been significantly improved. New businesses obtain a tax identification number (TIN) in BRA in a much easier fashion and if they are micro or small enterprises they are exempted from the signage fee. Pregnant women and new mothers no longer need to collect dozens of different original documents and certified copies to exercise the right to allowance during pregnancy and maternity leave, new employees are now registered electronically via online portal of the central registry of compulsory social insurance (CRCSI) and businesses do not need to provide a seal to open a bank account and conduct a payments. A unique place for the registration of property in the cadastre through the eCounter was established, which decreased the number of institutions that buyers need to go, while the procedure of property tax claim for citizens and businesses has been simplified. The implementation of the new Law on Fiscalization and the Law on Electronic Invoicing (the two long-standing recommendations of the Grey Book) will have a positive effect on reducing the grey economy, but also on the work of businesses. The whole procedure of buying and selling the used motor vehicles among the citizens has been relieved and simplified for the calculation and payments of the tax on the transfer of absolute rights, electronic payments of fees and levies for the services provided by the Ministry of Interior, without providing a proof of payments was enabled, the Central Register of Real Owners in food manufacturing has been digitalized, all of which represents the realization of the initiatives and policy reforms proposed by NALED in the previous years.