Legal regulations applying to e-invoicing in Croatia and legal regulations expected to be implemented

The key legal regulations governing e-invoicing in Croatia are as follows:

• Fiscalization Act (Zakon o fiskalizaciji, NN 89/2025) - sets the legal framework for the issuance, receipt, and fiscalization of e-invoices in B2B transactions.
• Rulebook on the Fiscalization of e-invoices - currently subject to public consultation. 
• Act on Electronic Invoicing in Public Procurement (Zakon o elektroničkom izdavanju računa u javnoj nabavi, NN 94/2018) – regulates mandatory e-invoicing in B2G public procurement.
• Amendments to related tax and accounting legislation, including the General Tax Act, the Croatian Accounting Act, and the VAT Act (with amendments to the VAT Rulebook expected shortly), have been adopted to align the national legislative framework with the new Fiscalization Act and the mandatory e-invoicing regime.

How e-invoicing works in principle in Croatia

In Croatia, an e-invoice is substantively equivalent to a paper invoice, containing all legally required invoice elements, but it is issued and received in a structured electronic format (typically XML) that enables fully automated electronic processing.

E-invoicing is based on the exchange of structured e-invoices via an access point, combined with mandatory fiscalization. In practice, the invoice is generated in the issuer’s accounting or ERP system and automatically transmitted through the intermediary to the recipient’s designated access point, where it is received and processed.

In the Fiscalization 2.0 model, the delivery of the e-invoice between issuer and recipient is distinct from fiscalization/reporting to the Croatian Tax Authorities. Fiscalization is performed by exchanging prescribed fiscalization messages derived from the e-invoice data. In short, the process operates as follows:

1. The issuer generates and issues an e-invoice to the recipient using a compliant software solution.
2. The issuer’s automated software extracts the required data from the e-invoice and submits a fiscalization message to the Croatian Tax Authorities.
3. The recipient’s automated software extracts the relevant data from the received e-invoice and submits a corresponding fiscalization message to the Croatian Tax Authorities.
4. Fiscalization is carried out by both the issuer and the recipient of the e-Invoice, enabling cross-checking of invoice data.

The issuance and fiscalization of e-invoices (Fiscalization 2.0) applies only to domestic transactions carried out between taxpayers and other legal entities (i.e. B2B and B2G transactions within Croatia) that are explicitly defined by the Fiscalization Act as issuers and recipients of e-invoices. The Act does not prescribe the obligation to issue e-invoices for the entire B2B and B2G segment, but only when it comes to parties defined by the Act as recipients and issuers of e-invoices. Consequently, in certain B2B or B2G scenarios, there may be no statutory obligation to issue an e-Invoice. In such cases, the parties may issue invoices in another legally acceptable form (e.g. paper invoices or other agreed formats).

Experience with e-invoicing in Croatia 

Given that the Fiscalization 2.0. e-invoicing regime entered into force on 1 January 2026, practical experience remains limited. It should be noted that Croatia already has several years of experience with B2G e-invoicing in public procurement (mandatory issuance since 1 July 2019). However, Fiscalization 2.0 expands e-invoicing and introduces additional fiscalization/reporting obligations for domestic transactions where both parties fall within the prescribed categories of issuers and recipients of e-invoices.

As is common with the implementation of new systems such as Fiscalization 2.0, certain initial technical challenges are expected, primarily due to the ongoing alignment of IT systems with recent legislative changes. Recent issues have mainly related to communication between different IT intermediaries, including delayed or failed invoice delivery, as well as invoice rejections caused by strict validation rules, where even minor errors may prevent successful processing.

Challenges encountered regarding e-invoicing

One of the biggest challenges relates to the classification of products and services in accordance with CPA (Classification of Products by Activity) codes, as the Tax Administration expects each invoice line item to be linked to at least a six-digit code. This mapping has proven extensive and time-consuming, and more complex than initially anticipated.

Uncertainty is further increased by the fact that several practical and technical questions remain open pending the adoption of the relevant Rulebook of the Fiscalization of e-invoices, creating a risk of additional or unexpected adjustments at a later stage.

Specific aspects about e-invoicing in Croatia businesses should know

Fiscalization 2.0 applies to domestic transactions depending on whether the parties qualify as issuer/recipient of e-invoice under the Fiscalization Act.

Exchange is done via an access point (own solution) or an information intermediary.

Moreover, for the supply of goods and services, taxpayers are subject to a mandatory classification requirement, namely the Classification of Products by Activity (CPA). Taxpayers falling within the scope of the Fiscalization Act are required to link each invoice line item for goods or services in the e-invoice to the appropriate CPA classification code and to report this code in the e-invoice using at least six digits. The issuer of the invoice is responsible for determining the correct CPA code for the product or service supplied, based on the activity for which it is registered.

Small and medium-sized enterprises established in Croatia that are not registered for VAT purposes may, during 2026, use MIKROeRačun, a free application provided by the Croatian Tax Administration, to receive e-invoices from VAT-registered taxpayers. In addition, the option to issue e-invoices trough this application will be available as of 1 January 2027.

For public procurement, Croatia already has an established B2G framework and channels (not related to Fiscalization 2.0.).

SAF-T system implementation status in Croatia

Currently, SAF-T system is not implemented in Croatia. No mandatory SAF-T reporting requirement exists, and none are planned for the time being. Instead, Croatia has adopted a continuous transaction control system integrated into the Fiscalization 2.0 framework.