eArchive - Questions and Answers
From January 1, 2024, the Regulation on Proper Electronic Document Storage is in effect. Below, you can find answers to the most common questions from companies working on compliance.
For any additional questions or assistance, contact us at office@eim.rs.
ARHIVO eArchive Solution – Ensure Your Business Complies with the New Legal Regulations.
1
Is it necessary to store electronic documents in a certified software solution, i.e., does eArchive need to be certified?
No. The information system for storing electronic documents, i.e., eArchive as a software solution, does not need to be certified to comply with the Regulation.
According to the Regulation, electronic documentation must be stored in any information system that meets all its requirements.
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2
Can companies comply with the Regulation without implementing specialized software?
Companies can meet the requirements of the Regulation on their own. It is necessary to obtain a qualified seal or certificate and pay for the timestamp service to a qualified certification body. When signing the document, all certificates must be validated, the timestamp must be attached to the certificate, and then the required metadata must be entered into the internal information system (DMS, ERP...) and two additional PDF documents must be generated and signed — and that's it!
3
In which format is it mandatory to store electronic documents to comply with the Regulation?
According to the Regulation, electronic documents must be stored in either PAdES B-LTA PDF format or XML XAdES B-LTA format.
4
Is it mandatory to maintain an Archive Book for electronic documents, and is it necessary to supplement the physical Archive Book?
According to the Regulation, it is mandatory to maintain an electronic archive book.
It is also required to classify documentary material in accordance with the list of archival categories and determine the retention period for the documentation. Additionally, the section related to electronic documentation must be added to the physical Archive Book.
5
According to the Regulation, can electronic documents be stored on the company's internal infrastructure, or is it necessary to use a certified Cloud server?
You can store the documentation in an application within your internal environment.
The advantages of an in-house solution are that all documentation is kept in your environment and under your control, making integration with your information systems easier. When all documentation subject to the Regulation is within your environment, it is simpler to consolidate and manage other types of documentation (scanned, eDocuments not considered documentary material) in one system.
The advantages of the Cloud are quick implementation and it is ideal for clients with a minimal set of documentation subject to the Regulation, stored as a permanent archive without daily use.
6
Is it necessary to add metadata defined by the Regulation to each document?
Yes. Metadata are mandatory for each document. In order for a document to be stored in compliance with the Regulation, it is required that each electronic document contains a set of metadata defined by the Regulation.
7
Is it mandatory to sign electronic documentation with a qualified electronic certificate?
Yes, with a qualified certificate and an attached timestamp.
According to the Regulation, it is mandatory for the electronic document to be signed with a qualified electronic certificate and validated with a timestamp in order to confirm the authenticity of the original documentary material and the accuracy of the metadata.
8
Is it necessary to generate Confirmations for each electronic document?
Yes. When timestamping the document.
It is necessary to generate two documents: the Metadata Confirmation and the Statement. These documents are generated in PDF format and are qualified with a signature/seal and a timestamp.
9
What is the difference between a qualified electronic signature and a qualified electronic seal?
A qualified electronic signature is associated with an individual, while a seal is associated with a company. Technologically, legally, and securely, they are identical.
10
What is the difference between a qualified electronic signature and a timestamp?
A qualified electronic signature serves as proof of the signer's electronic identity, while an electronic timestamp is the official time attached to the signature in electronic form, confirming that the data existed at that specific moment.
According to the Regulation, it is required that both a qualified electronic signature and a timestamp, obtained from an authorized qualified provider (e.g., Serbian Post), be attached to the electronic document.
11
Do qualified electronic signatures and timestamps last indefinitely, or is it necessary to re-sign or re-seal an electronically signed and timestamped document at some point?
A qualified electronic certificate and timestamp have an expiration period. It is necessary to re-timestamp the document after the certificate expires to ensure the continuous validity of the document.
12
How is electronic documentation separated for destruction after the retention period expires?
After selecting the documentation that is to be stored permanently, a request must be created in electronic form for the destruction of electronic documentation whose retention period has expired. The request is submitted to the competent public archive through the eGovernment portal. Once approval is received, the documentation may be destroyed.
13
What do qualified trust services represent?
Qualified trust services are services for issuing qualified certificates and timestamps (certification bodies) or providing trust services (secure delivery, secure archiving, trusted third-party services).
These services are not a requirement, nor do you need to directly fulfill them to be in compliance with legal regulations.
14
Do businesses have the obligation to store electronic documentation that is already kept by a government authority?
No. Businesses are not obligated to store electronic documentation if it is already stored by a government authority. This means that businesses are not required to store their electronic documents such as electronic invoices (SEF), tax returns (Tax Administration), financial reports (Business Registers Agency), employee registrations and de-registrations (CROSO), etc.