Obligation for Employers to Update the Data in the Central Register of Mandatory Social Insurance

Namely, employers i.e. applicants of single application shall be obliged, by 1 January 2021, to update the previously entered information in the single database CROSO, as regards the following:

• Occupation, according to classification of occupations, which is required for employment in certain jobs and/or positions;
• Type and level of qualification e. education that are required for employment in certain jobs and/or positions;
• Type and level of qualifications e. education held by a (employed/self-employed) person.

Adjustment of entered information needs to be done in accordance with the occupation codes and qualification levels established by the Decision.

This obligation applies to those employers who have entered data in the CROSO database in accordance with the old code system.

In relation to the above, it is noteworthy that the Government of the Republic of Serbia has recently adopted the Decision amending the Decision that will start to apply from 25 August 2020 and contains the new single codebook.

Novelties in the single codebook

Adoption of the Decision in 2018 was a great novelty because it ended the practice of classification of education levels according to the degrees of professional practice, which was a result of adoption of the Law on National Framework of Qualifications of the Republic of Serbia (“NOKS“). Previous codebooks became obsolete due to the changes in the labour market and education system, hence it was necessary to adopt regulations so as to adjust occupations and levels and types of qualifications.

The changes, however, are not just terminological. For example, according to the system valid until 2018, the level of education VII – 1 (university education) corresponds to the level 6.2 of the NOKS, which is acquired by completing main academic studies with 240 ECTS.

The Decision amending the Decision contains the new Codebook of occupations, Codebook of levels and types of qualifications, Codebook of states and territories, Codebook of municipalities in the Republic of Serbia and Codebook of populated places in the Republic of Serbia.

Penalties for non-respecting the deadline

If employers fail to update the information in the CROSO system by 1 January 2021, they shall be subject to fines for offence, namely:

• For employer – legal entity, fine shall range from RSD 300,000.00 to 1,500,000.00;
• For employer – entrepreneur, fine shall range from RSD 10,000.00 to 500,000.00;
• For employer – natural person, fine shall range from RSD 5,000.00 to 150,000.00.

Although it may seem there is a lot of time until the expiry of deadline for updating the information, it should be noted that the establishment of occupation equivalents, types and levels of qualifications can be rather extensive, particularly for employers with a large number of employees.

In relation thereto, the Ministry for Labour, Employment, Veteran and Social Affairs prepared a Manual for application of single codebook for entry and codification of information in databases in the field of labour (it should be noted that the manual has not yet been harmonised with the amendments of the Decision from July 2020, but it can be used as general guideline for applying the codebooks).

Also, in case of dilemma during selection of occupation code, NSZ provides assistance upon request that users can submit to e-mail This email address is being protected from spambots. You need JavaScript enabled to view it. (the enquiry needs to specify employer’s business activity and the description of activities within a particular job).

This article is to be considered as exclusively informative, with no intention to provide legal advice.
If you should need additional information, please contact us directly.

By Ivana Ruzicic, Partner, and Natalija Dukic, Associate, PR Legal