Mandatory E-Invoicing in Croatia: What Businesses Need to Know

As of January 1, 2026, Croatia has introduced mandatory electronic invoicing for domestic transactions between businesses listed in the Croatian VAT registry.

This requirement is part of Fiskalizacija 2.0, the second generation of Croatia’s fiscalization system. This expands the existing fiscal control system from primarily B2C transactions to include electronic invoices in the B2B and B2G sectors.

As of January 1, 2026, VAT-registered businesses are required to both issue and receive electronic invoices. Businesses and other organizations that are not registered for VAT must, however, be able to receive e-invoices as of that date. For this group, the obligation to issue e-invoices themselves will take effect on January 1, 2027.

What Changes Will Fiskalizacija 2.0 Bring?

With Fiskalizacija 2.0, Croatia is combining two processes that differ in substance:

• the electronic exchange of a structured invoice between supplier and customer;
• the fiscal reporting of data from that invoice to the Croatian tax authority.

An electronic invoice is sent from the supplier’s ERP, accounting, or invoicing system to the recipient via an electronic access point. At the same time, relevant data from the invoice is transmitted to the tax authority for fiscalization.

The recipient also plays a role in tax reporting. The customer’s system extracts data from the received e-invoice and also sends a tax reporting message to the tax authority.

This ensures that the Croatian tax authority has information from both sides of the transaction. The data can then be compared and used for tax audits and to pre-fill tax returns.

What does Croatia consider an e-invoice?

An e-invoice, or eRačun, is an invoice issued, sent, and received in a structured electronic format that enables automatic electronic processing.

A standard PDF sent via email therefore does not meet the new B2B requirement. Although a PDF is digital, it does not contain the structured data required for automatic exchange and tax processing.

The Croatian model complies with the European standard EN 16931. Croatia also uses national implementation rules and extensions that add specific Croatian tax and administrative data to the electronic invoice.

UBL 2.1 is one of the formats used for technical exchange.

How are Croatian e-invoices exchanged?

Croatia does not use a central clearance platform for B2B e-invoicing where every complete invoice must first be approved by the tax authority.

Invoices are exchanged between electronic access points. A company can either have its own access point or use a certified “informacijski posrednik,” an information intermediary that handles the technical exchange and, if necessary, tax reporting.

The invoice flow generally proceeds as follows:

1. The supplier creates the invoice in the ERP or invoicing system.
2. The invoice is converted to the required structured format.
3. The e-invoice is sent from the supplier’s access point to the customer’s access point.
4. The supplier’s system sends the required tax reporting data to the tax authority.
5. The customer receives the electronic invoice.
6. The customer’s system also sends the relevant data from the received invoice to the tax authority.

The tax audit thus runs parallel to the electronic invoice exchange.

How is the recipient identified?

To automatically route electronic invoices to the correct recipient, Croatia uses an infrastructure for electronic addressing and metadata.

Businesses register the electronic address at which they can receive e-invoices. The infrastructure includes, among other things, an Adresar metapodatkovnih servisa (AMS), which can be used to find the correct metadata and access point for a recipient.

The access points communicate using standardized technical protocols. This allows businesses to use different software vendors or information intermediaries while still exchanging invoices with one another.

The model is thus based on interoperability between different service providers, rather than on a single central platform for the entire B2B invoice flow.

What role do information intermediaries play?

Companies can develop their own technical access point, but they can also use an information intermediary recognized by the Croatian tax authority.

Depending on the services provided, such a party can handle various tasks:

• creating and converting e-invoices;
• sending and receiving e-invoices;
• connecting to other access points;
• tax compliance for outgoing and incoming invoices;
• e-reporting;
• metadata and addressing services.

The Croatian tax authority publishes a list of information intermediaries that have completed a compliance procedure. A company that uses an intermediary must also authorize that intermediary for the relevant services.

Fiskalizacija 2.0: E-invoicing and Transactional Reporting

The Croatian system goes beyond mere electronic invoice exchange. With the fiscalization of e-invoices, data from both outgoing and incoming invoices is electronically submitted to the tax authority.

This allows the tax authority to gain near-real-time insight into economic transactions and to compare supplier and customer data.

The tax infrastructure is also used to further automate administrative processes. Through the Croatian FiskAplikacija, businesses can, among other things, view tax-compliant data, manage permissions, check invoice statuses, and use information to prepare a pre-filled VAT return.

Croatia is thus clearly moving toward transactional VAT compliance: the tax authority is relying less and less on periodic returns and increasingly on data from individual transactions for tax audits.

What is eIzvještavanje?

In addition to the fiscalization of the e-invoice itself, Fiskalizacija 2.0 includes supplementary electronic reporting, referred to as eIzvještavanje.

Among other things, the supplier must provide information regarding:

• the payment of an outgoing e-invoice;
• a domestic supply for which no e-invoice was issued when a reporting obligation applies.

The recipient must, among other things, report when a received e-invoice is rejected.

This provides the tax authority with insight not only into when an invoice is issued and received, but also into certain events that occur afterward.

For information regarding the payment of domestic invoices, this more transactional approach to reporting partially replaces older periodic reporting requirements.

The KPD 2025 classification on every invoice line item

A notable additional requirement in Croatia is the use of the Klasifikacija proizvoda po djelatnostima 2025 (KPD 2025).

Goods and services on the electronic invoice must be linked to the correct classification code. To this end, a six-digit KPD code is included on the relevant invoice line.

For businesses, this means that it is not only the technical invoice exchange that must be adapted. Item, product, and service data in the ERP or master data system must also be able to be linked to the correct Croatian classification codes.

For international corporations, this can be a significant part of the implementation process, as existing product classifications from the ERP system do not necessarily correspond one-to-one with KPD 2025.

What happens to businesses that are not subject to VAT?

Croatia is phasing in the requirement for non-VAT-registered businesses.

As of January 1, 2026, businesses, self-employed individuals, and certain public organizations that are not listed in the VAT registry must be able to receive electronic invoices.

Starting January 1, 2027, this group will also be required to issue electronic invoices themselves.

For smaller businesses, the tax authority is making the MIKROeRAČUN application available. In 2026, this application can be used, among other things, to receive e-invoices. Starting in 2027, the application will also support the issuance of e-invoices.

International Transactions and Foreign Companies

The general B2B e-invoicing requirement effective in 2026 primarily applies to domestic Croatian transactions between taxpayers subject to Croatian regulations.

For a Dutch corporate group with a separate Croatian subsidiary, this means that, in principle, that local entity is subject to the Croatian requirements if it is registered for VAT in Croatia and conducts domestic transactions.

A foreign company that does business exclusively with Croatian customers without a relevant Croatian establishment or local tax status is not automatically subject to the same B2B e-invoicing requirement. For international transactions, therefore, one must consider the entity’s place of establishment, VAT registration, and the location of the relevant supply of goods or services.

Furthermore, existing VAT reporting obligations will continue to apply to cross-border EU transactions until the European ViDA model is fully implemented starting in 2030.

E-invoicing to the Croatian government

Croatia had already mandated electronic invoicing to the public sector well before Fiskalizacija 2.0.

Since December 1, 2018, public contracting authorities have been required to be able to receive structured electronic invoices. Since July 1, 2019, suppliers have been required to actually issue a structured e-invoice for transactions subject to public procurement rules.

These invoices must comply with the European standard EN 16931 and are exchanged via the national central infrastructure Servis eRačun za državu, which is managed by FINA.

Furthermore, the Croatian B2G requirement extends beyond just procurements above the European thresholds and also covers various forms of smaller-scale public procurement.

The existing B2G infrastructure will continue to operate alongside the new Fiskalizacija 2.0 regulations.

What role does Peppol play in Croatia?

For the new domestic B2B requirement, Croatia uses its own interoperable eDelivery infrastructure with access points, metadata services, and AS4 communication.

That model shares technical similarities with international four-corner models such as Peppol, but the Croatian tax requirement should not simply be equated with a Peppol mandate.

For compliance, it is essential that the access points, messages, validation rules, and tax processing procedures used meet the Croatian technical specifications.

An international e-invoicing solution that already supports Peppol therefore requires additional Croatian functionality for, among other things, fiscalization, eIzvještavanje, local validation rules, and KPD classification.

B2C fiscalization is different from B2B e-invoicing

Croatia has long required fiscal registration of transactions with consumers. Starting January 1, 2026, this fiscalization of B2C invoices will also be extended to all payment methods, including payments via a bank account.

This fiscalization in final consumption must be distinguished from the new B2B e-invoicing.

In the B2C context, a structured electronic invoice does not necessarily need to be exchanged between two financial systems. The company reports the relevant data from the consumer invoice electronically to the tax authority.

In B2B and B2G, however, the combination of structured e-invoice exchange and tax reporting is central.

What does ViDA have to do with Croatia?

Fiskalizacija 2.0 is a national Croatian initiative. The mandatory domestic B2B e-invoicing set to take effect in 2026 is therefore not the European e-invoicing requirement under “VAT in the Digital Age.”

However, the Croatian model does fit within the same broader trend. Structured electronic invoices are used as a source for increasingly faster and more detailed tax reporting.

Starting July 1, 2030, ViDA will introduce harmonized Digital Reporting Requirements for relevant cross-border B2B transactions within the European Union. There, too, structured e-invoicing forms the basis for tax reporting.

For Croatia, this means that, in addition to the national model for domestic transactions, a harmonized European model for cross-border transactions will also be established. National digital reporting systems must align with European technical and semantic standards.

The Croatian Roadmap for E-Invoicing

The key steps are:

• December 1, 2018: Croatian public organizations must be able to receive structured electronic invoices for public procurement.
• July 1, 2019: Suppliers to public organizations will be required to issue structured B2G e-invoices.
• June 17, 2025: The new Fiscalization Act is published, laying the legal foundation for Fiskalizacija 2.0.
• September 1, 2025: The new Tax Invoicing Act takes effect, and the preparatory and testing phase for the new B2B infrastructure begins.
• January 1, 2026: VAT-registered businesses must issue and receive e-invoices for relevant domestic B2B transactions.
• January 1, 2026: Non-VAT-registered businesses and various other organizations must be able to receive e-invoices.
• January 1, 2026: Taxation of B2C invoices is extended to all payment methods.
• January 1, 2026: Tax reporting for B2B e-invoices and additional e-reporting via Fiskalizacija 2.0 will become operational.
• January 1, 2027: The requirement to issue e-invoices will be extended to relevant businesses and organizations that are not listed in the VAT registry.
• July 1, 2030: ViDA’s European Digital Reporting Requirements will apply to relevant cross-border B2B transactions.

What does this mean for organizations?

For organizations with a Croatian entity, e-invoicing has been part of both the financial process and daily VAT compliance since 2026.

The technical infrastructure must not only be capable of generating and receiving structured invoices. It must also support local validation, KPD classification, electronic addressing, communication via access points, tax processing of incoming and outgoing invoices, and additional e-reporting.

Croatia thus demonstrates once again just how different national e-invoicing models can be within Europe. Belgium uses Peppol, France works with accredited platforms, Poland with KSeF, Italy with SdI, Romania with RO e-Factura, and Croatia combines an interoperable eDelivery network with two-way tax reporting via Fiskalizacija 2.0.

For international organizations, this requires an e-invoicing infrastructure capable of translating the same financial data into different national formats, exchange networks, and tax reporting requirements.