What Croatia fiscalization 2.0 brings
Fiscalization 2.0 is the common name for the system introduced by the new Croatian Fiscalization Act (Zakon o fiskalizaciji), adopted in 2025. Until now, fiscalization in Croatia applied mainly to cash transactions, that is invoices to end consumers paid in cash, by card and similar means. The new system also covers invoices between businesses: they are issued as eRačun (a structured electronic invoice), exchanged through information intermediaries and fiscalized, and the Croatian Tax Administration (Porezna uprava) receives data on them almost in real time.
The aim is to narrow the tax gap, speed up VAT checks and encourage fully digital business. For companies this means that an invoice is no longer a document sent as a PDF and re-keyed by the recipient, but a structured data record that travels from the issuer's ERP to the recipient's ERP. The change therefore affects finance, sales, procurement and IT, not just accounting.
The key parts of the new system are:
- eRačun (B2B). Mandatory issuing and receiving of structured e-invoices between businesses in Croatia.
- Fiscalization of e-invoices. Data from the e-invoice is submitted to the Tax Administration on issue and receipt.
- eReporting (eIzvještavanje). The issuer reports on payment, and the recipient on the rejection of an e-invoice.
- Fiscalization of cash receipts (B2C). Continues, with adjustments to the new act.
To see where you stand against these requirements, use the questionnaire on this page.
Who is covered and from when
The deadlines depend above all on whether the company is in the VAT system. The overview below shows the main phases; check exceptions and special cases in the act and the ordinances.
| From | Who | Obligation |
|---|---|---|
| 1 July 2019 | Suppliers to public contracting authorities | Issuing e-invoices in public procurement (B2G) under EN 16931 |
| 1 January 2026 | VAT taxpayers | Issuing, receiving and fiscalizing e-invoices between businesses, eReporting |
| 1 January 2026 | Entities outside the VAT system | Receiving e-invoices |
| 1 January 2027 | Entities outside the VAT system | Issuing and fiscalizing e-invoices |
In October 2026 the obligations for VAT taxpayers are already in force. If your process still includes manual steps, PDF invoices or re-keying of incoming invoices, these are gaps to resolve now, not preparation for the future. Entities outside the VAT system have a few months until the obligation is extended, which is a short time for choosing a solution, connecting and testing.
What this means for a foreign supplier invoicing Croatian customers
Fiscalization 2.0 is aimed primarily at transactions between businesses in Croatia. Whether and how it applies to a company based outside Croatia depends on how the company is set up there, so it is worth looking at your situation, not at the headline deadlines alone. This is a general orientation, not advice for a specific case.
- VAT-registered in Croatia. If you have a Croatian VAT registration, whether through a branch or a fiscal representative, you should expect to be treated much like a domestic VAT taxpayer for invoices to Croatian businesses. That means issuing structured e-invoices, fiscalizing them and reporting through an information intermediary.
- Invoicing from abroad without a Croatian registration. Cross-border invoices are subject to different rules, and the extent to which they fall under the Croatian system should be confirmed with the Tax Administration or a Croatian tax adviser before you rely on any assumption. At EU level, common rules for digital reporting and e-invoicing are being prepared under the ViDA package.
- What your Croatian customers will expect. Croatian VAT taxpayers must be able to receive and process e-invoices, so many of them are likely to prefer suppliers who can send structured invoices rather than PDFs, and may ask you about it in contracts and onboarding.
- Practical preparation. Even before the legal position is settled, it is useful to check whether your invoicing software can produce EN 16931 invoices (UBL 2.1), whether you can add the Croatian specifics such as KPD codes and the customer's OIB (Croatian tax number), and whether an information intermediary is available for your ERP.
The exact scope for non-resident suppliers is a matter for the Croatian tax authority and the act itself, so confirm it there before making decisions.
What an eRačun is, and what it is not
An eRačun is an invoice issued, sent and received in a structured electronic form that allows automatic processing. In Croatia it is based on the European standard EN 16931 and a Croatian specification that prescribes additional data, with UBL 2.1 used as the syntax. For invoice line items, the Croatian specification also requires a code from the Classification of Products by Activities (KPD), so many companies need to complete the master data of their products and services.
An eRačun is not a PDF sent by email, a scanned paper invoice or a file from a program that does not follow the standard. Such documents can remain an attachment to an eRačun, but they cannot replace it.
The role of the information intermediary
eRačuni are exchanged through information intermediaries (informacijski posrednici), service providers that are connected to the Croatian system. An intermediary sends and receives e-invoices on behalf of the issuer or recipient, carries out fiscalization and submits data to the Tax Administration. Recipients are entered in a directory, so the issuer knows from the customer's OIB where an eRačun must be sent. A company can choose its intermediary independently of its business partners.
For smaller entities, especially those outside the VAT system, the Tax Administration offers the free MIKROeRAČUN application for receiving and issuing e-invoices without their own software. For companies that issue invoices from an ERP or have a larger number of invoices, integration with an intermediary is usually more suitable, because it removes manual work on both sides.
How your processes change
Fiscalization 2.0 affects the whole flow from order to payment. The table shows the most common changes by process.
| Process | Before | With Fiscalization 2.0 |
|---|---|---|
| Issuing invoices | PDF or paper, sent by email or post | A structured eRačun from the ERP through an intermediary, with fiscalization |
| Incoming invoices | Manual re-keying or scanning | Automatic import into the ERP, matching with the order and goods receipt, electronic approval |
| Payment | Clearing of open items for internal purposes only | Reporting payment to the Tax Administration within the prescribed deadlines |
| Rejecting invoices | By phone or email | Formal rejection of the eRačun and reporting |
| Master data | Internal item codes | Additional prescribed data, for example KPD codes |
| Archiving | Printouts or PDF files | Original XML in an electronic archive for the prescribed period |
eReporting on payment and rejection
A novelty that companies often underestimate is eReporting (eIzvještavanje). The issuer of an eRačun submits to the Tax Administration data on when and in what amount the invoice was paid, and the recipient reports on the e-invoices it has rejected. Payment data usually already exists in the ERP, in the clearing of open items based on bank statements, but it has to be reliably linked to the right eRačun and submitted within the prescribed deadline. Partial payments, set-offs and assignments need clear rules, so include them in your test scenarios.
For invoices to end consumers, fiscalization of cash transactions still applies. Companies that sell to both businesses and consumers, for example through an online shop and wholesale, therefore run two flows at the same time: fiscalization of receipts to consumers and the exchange of e-invoices with business customers.
ERP, online shop and integrations
Most of the work is usually not in the eRačun format itself but in connecting systems. Typical situations:
- A single ERP with vendor support. The vendor offers an e-invoice module and a connection to an intermediary. Check whether it also covers eReporting on payment, invoice rejection, KPD codes and automatic import of incoming invoices.
- An international ERP. Global solutions often cover the Croatian specification with a local add-on or a partner connector. Check who maintains it and how it keeps up with changes to the technical specifications.
- Several systems that issue invoices. An online shop, a service billing system and the ERP often issue invoices separately. Each of them must meet the same requirements, so it is often simpler to route all invoices through a single outlet to the intermediary.
- Groups of companies. If several related companies use a shared system, align master data, numbering and access rights across all of them.
Rollout also reveals data quality: incomplete customer OIBs, inconsistent item codes and manually entered discounts cause rejected e-invoices. Cleaning and migrating master data should therefore be part of the project from the start. If you are also thinking about replacing an old system, see the ERP selection checklist.
A six-step preparation plan
- Inventory. List all systems and processes in which invoices are created or received, including the online shop, cash registers and manual exceptions.
- Vendor check. For each system, establish whether it supports EN 16931 and the Croatian specification, fiscalization of e-invoices and eReporting, and by when.
- Choosing an intermediary. Compare intermediaries by price, API, support for your ERP, availability and exit terms. Smaller entities should consider MIKROeRAČUN.
- Master data. Add KPD codes, check customer and supplier data and align item codes.
- Integration and testing. Connect the systems and test issuing, receiving, rejection and payment reporting with real scenarios.
- Archive and responsibilities. Set up an archive of original XML files, assign responsible persons and follow changes to the rules.
The most common mistakes
- A project for accounting only. Without IT, sales and procurement, the solution covers the format but not the real processes.
- Forgotten systems. The online shop, service billing or manually issued invoices stay outside the new flow.
- Incoming invoices as PDFs. The company receives e-invoices but still re-keys them, losing the biggest benefit of automation.
- Testing too late. Rejected e-invoices and reporting errors are found only in production, when customers are already waiting for invoices.
For information only, status as of October 2026; check current rules with the Croatian Tax Administration (Porezna uprava). The text does not replace tax or legal advice. Check exact obligations, deadlines and technical specifications on the Tax Administration website and in the Fiscalization Act published in the Official Gazette (Narodne novine).
Humanfrog helps companies integrate ERP systems, online shops and invoicing software with information intermediaries, migrate and clean master data and automate the processing of incoming invoices. If you want to check your environment, talk to us.
