The new Proposal for the Fiscalization Act (adopted at the session of the Government of the Republic of Croatia on April 24, 2025) brings significant changes to fiscalization and the issuance of e-Invoices in the Republic of Croatia. These changes will affect how companies issue, receive, and fiscalize invoices.

Key Dates and Obligees:

September 1, 2025:

• The use of digital certificates issued by trust service providers/qualified trust service providers in the Republic of Croatia for the purpose of fiscalizing invoices is enabled.
• The obligation to submit data on business premises via the “Data Registration into the Fiscalization System” form is abolished.
• The option to submit data on checks as a payment method is abolished.
• The fiscalization of accompanying documents is abolished.
• All e-Invoice exchange obligees and information intermediaries will have the opportunity to test the capabilities of their own systems for e-Invoice exchange, e-Invoice fiscalization, and e-reporting to be ready for the implementation of this Act from January 1, 2026.

January 1, 2026:

• The obligation to issue and receive e-Invoices is introduced for VAT taxpayers in the B2B segment.
• The obligation to receive e-Invoices is introduced for companies, sole traders, independent professions – who are not in the VAT system, state administration bodies, local and regional self-government units, and budget and extra-budgetary users of the state budget and local and regional self-government units that are registered in the Register of Budget and Extra-budgetary Users.
• The fiscalization procedure applies to all fiscalization obligees in retail consumption regardless of the payment method (including bank transfer).
• The obligation of fiscalization begins in the sales activity where the predominant part of the turnover value relates to the retail sale of daily newspapers, tobacco and tobacco products, stamps and other postal securities.

January 1, 2027:

• The obligation to issue e-Invoices is introduced for companies, sole traders, independent professions – who are not in the VAT system, state administration bodies, local and regional self-government units, and budget and extra-budgetary users of the state budget and local and regional self-government units that are registered in the Register of Budget and Extra-budgetary Users.

What is an e-Invoice?

An e-Invoice is an invoice that is issued, sent, and received in a structured electronic form, which enables its automatic and electronic processing. It must comply with the EU standard.

Fiscalization of e-Invoices:

The issuer and recipient of an e-Invoice are obliged to carry out the fiscalization of e-Invoices for every issued and received e-Invoice. This procedure includes the submission of prescribed data from the e-Invoice to the Fiscalization System, including:

• invoice issue date
• invoice number
• payment due date
• invoice issuer
• invoice recipient
• quantity, type of goods supplied, or quantity or scope of services performed, including the Classification of Products by Activity (CPA) with at least 6 digits (more details at the link: https://narodne-novine.nn.hr/clanci/sluzbeni/2024_12_151_2491.html (you will need to link the CPA code to your existing item codes)
• date of supply of goods or services performed or date of receipt of advance payment in the advance invoice, if that date can be determined and differs from the invoice issue date
• taxable amount for each tax rate or exemption, unit price without VAT and any discounts or rebates if not included in the unit price
• VAT rate
• amount of VAT to be paid, unless a special procedure within the meaning of VAT regulations applies for which this information is excluded
• number and date of the original invoice, if an invoice, document or notice is issued that amends it, and explicitly and unambiguously refers to it
• bank account number or virtual account number of the e-Invoice issuer or any other identifier that unambiguously identifies the e-invoice issuer for payment.

The issuer of an e-Invoice is obliged to carry out the fiscalization of the issued e-Invoice separately from the e-Invoice exchange procedure at the time of issuing the e-Invoice, and in the case of self-invoicing, no later than 5 working days after the e-Invoice has been issued. The recipient of an e-Invoice is obliged to carry out the fiscalization of the received e-Invoice separately from the e-Invoice exchange procedure no later than 5 working days from the receipt of the e-invoice.

Exemption from the Obligation to Issue e-Invoices:

Exemption from the obligation to issue e-Invoices may apply to transactions paid in cash or by card for which an invoice has been issued and the fiscalization procedure has been carried out in accordance with Article 15 of the Proposal for the Act (issuance of an invoice containing a Unique Invoice Identifier – UAI(JIR), in accordance with the rules previously defined through Fiscalization 1.0). Invoice issuers will have to upgrade the fiscalization message for the invoice with the recipient’s OIB (Personal Identification Number), or, if an invoice is fiscalized, in addition to the data prescribed by Article 7 of the Proposal for the Act, the invoice must also contain the OIB data according to a special regulation. In that case, an e-Invoice cannot be issued and fiscalized (to simplify, if, for example, an invoice is paid in cash/card and fiscalized in a way that it contains a UAI – it cannot be re-issued as an e-Invoice).

Inability to Issue e-Invoices:

The e-Invoice issuer is not liable for non-issuance of an e-Invoice if the e-Invoice cannot be issued to the invoice recipient due to the unavailability of the identifier in the AMS (list of identifiers and corresponding data services of taxpayers that enable e-Invoice exchange). In that case, an invoice can be issued in paper form, and data is submitted to the Fiscalization System through the e-reporting procedure.

MIKROeRAČUN Application:

The Tax Administration will provide a free MIKROeRAČUN application that enables the issuance, receipt, and storage of e-Invoices, as well as the fiscalization of issued and received e-Invoices, provided that users accept the general terms of use. The MIKROeRAČUN application can be used by e-Invoice issuers and recipients who are users of the ePorezna system, and are not registered in the VAT taxpayer register and are not subject to the regulations on electronic invoicing in public procurement as public contracting authorities.

eIZVJEŠTAVANJE System (e-REPORTING):

For the implementation of the e-Reporting procedure, the e-Invoice issuer and e-Invoice recipient can use a web service, the service of an information intermediary, or the FiskAplikacija. The following is reported:

1. deliveries for which it was not possible to issue an e-invoice
2. data on e-invoice rejection
3. data on e-invoice collection

Impact on other tax forms:

The introduction of the obligation to issue e-invoices and submit data on performed transactions will enable the abolition or amendment of several existing tax forms, including:

• Report on Food Donations (DON-H)
• Output Invoice Book (I-RA)
• Special Record of Goods Sold to Customers within Passenger Traffic (PDV-F)
• Report on Domestic Supplies with Reverse Charge (PPO)
• Special Record of Received Invoices (U-RA)
• Statistical Form (RAD 1G) for small and medium-sized enterprises

The introduction of the obligation to issue e-Invoices and submit data on performed transactions will enable the alignment of the deadline for submitting the VAT return (Form PDV) with the deadline for submitting data to the fiscalization system, i.e., by the last day of the month following the tax period.

We recommend that you prepare your systems and processes for these important changes to ensure a smooth transition.

Author, Admin