Grey Book

The Grey Book has, for a full decade, contained the 100 most important recommendations put forward by businesses, local self-government units, and civil society organizations for improving the regulatory framework and reducing and/or eliminating administrative barriers to doing business in Serbia. State institutions have recognized the Grey Book as one of the key documents in the process of public policy development and regulatory reform implementation, as each selected administrative or regulatory barrier is precisely described, thoroughly substantiated, and accompanied by a concrete proposal for its resolution.

Since its first publication in 2008, the Grey Book has gone through 18 editions and has presented nearly 350 new recommendations for improving the business environment. Of these, 93 recommendations (27%) have been fully implemented, while 84 recommendations (25%) have been partially implemented, meaning that state institutions have accepted and implemented more than half of all proposals put forward.

In 2025, three recommendations were fully implemented and five were partially implemented. Key achievements include the introduction of electronic payment for all non-tax charges, the implementation of the e-Sick Leave system, and the establishment of a national carbon pricing mechanism complementary to the European Union’s Carbon Border Adjustment Mechanism (CBAM). Among the partially implemented recommendations, notable progress was made in accelerating and digitalizing the legalization process, establishing an efficient mechanism for determining and registering property rights, reducing excessive and abolishing unnecessary court fees, reforming the environmental impact assessment system for mobile telecommunications base stations, and improving the transparency of bankruptcy proceedings and out-of-court settlements.

The new, 18th edition of the Grey Book contains nine new recommendations for the Government of Serbia, alongside 91 updated and improved proposals carried over from the previous year. As in the previous edition, special emphasis has been placed on obligations arising from Serbia’s European Union accession process. A total of 22 recommendations have been awarded an “EU Badge” in order to highlight reforms whose implementation would contribute to accelerating Serbia’s path toward EU membership.

The 18th edition of the Grey Book identifies ten priority recommendations for the competent institutions. These recommendations focus on the electronic payment of charges, healthcare digitalization, the digitalization and acceleration of administrative procedures, environmental protection and recycling, improvements to the business environment and foreign trade procedures, as well as greater flexibility in the labour market.

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. In the previous five years the tax burden on net wages has been decreased by 2 percentage points (from 63% to 61%).