Croatia's Fiscalisation 2.0: eRačun Issuing, Receiving and Fiscalisation

Croatia already had one of the earliest B2G e-invoicing regimes in the EU and, separately, fiscalisation of retail receipts at the till. Fiscalisation 2.0 joins the two ideas: business-to-business invoices become structured electronic documents, and every one of them is reported to the Tax Administration as it is issued and as it is received. Croatia's place among the other national schemes is set out in mandatory e-invoicing in Europe.

Who issues and who receives

The Tax Administration's guidance lists three groups of issuers and the same three groups of recipients:

1. Taxable persons with seat, residence or habitual residence in Croatia registered for VAT.
2. Income tax payers from independent activity and profit tax payers established in Croatia but not registered for VAT.
3. State administration bodies, local and regional government units and budget users listed in the register of budget users and not registered for VAT.

The obligation is domestic. The issuing and fiscalisation duty in B2B applies to domestic transactions between the taxpayers listed above. Cross-border supplies, and supplies to persons outside the three groups, are invoiced in another permitted form.

Fiscalisation: what it is and when it happens

Fiscalisation of an eRačun is not a stamp on the invoice. The Tax Administration describes it as an automated process that extracts a prescribed set of data from each issued and received eRačun into a fiscalisation message sent to the Tax Administration. It runs separately from the exchange of the invoice, and although the Tax Administration confirms receipt of the message, that confirmation is not visible on the eRačun.

Two consequences are easy to miss. First, the recipient is a reporting party in its own right: a business that receives eRačuni but has not set up fiscalisation of incoming invoices is out of compliance even if it never issues one. Second, the deadline for fiscalising receipt starts at receipt, not at approval — a long internal approval workflow does not extend it. That puts pressure on the receiving process described in accounts payable redesign.

Access points, intermediaries and the AMS

Exchange and fiscalisation run through an access point (pristupna točka): either the taxpayer itself, if it meets all the technical conditions, or an information intermediary (informacijski posrednik) providing the service to others. Status is not automatic. Existing providers had to submit the prescribed documentation, implement the technical specifications and pass conformance testing; those that pass are published on the Tax Administration's list of information intermediaries.

The intermediary is, in practice, the party that communicates with the Tax Administration's AMS — the digital address directory (adresar metapodatkovnih servisa) used to find where a recipient receives eRačun. The guidance's description of self-billing shows the familiar four-corner pattern: the buyer's access point checks the seller in the AMS, retrieves the seller's access point and sends an AS4 message with an SBDH envelope. The model will be recognisable to anyone who has read four-corner versus five-corner models.

Authorisations are given in FiskAplikacija, accessed through ePorezna. The guidance contains a cautionary case: a business authorised its intermediary to receive eRačuni but not to fiscalise them, so received invoices went unreported until the settings were corrected.

MIKROeRAČUN

MIKROeRAČUN is the Tax Administration's free application, in which the Tax Administration itself is the access point. According to the guidance it receives eRačun from 1 January 2026, issues them from 1 January 2027, fiscalises both and keeps them for the retention periods. It is available only to issuers and recipients not registered for VAT and not public contracting authorities — a VAT-registered business cannot use it and needs an intermediary or its own access point.

B2G stays where it was

B2G invoicing continues under the Act on electronic invoicing in public procurement (NN 94/18), which transposed Directive 2014/55/EU, with FINA as the central platform for receiving and exchanging public-sector eRačun. The Tax Administration notes that those eRačuni must still be fiscalised where the issuer and recipient are covered by the Fiscalisation Act.

Penalties

The guidance describes failing to issue an eRačun when there is an obligation to do so as the most serious offence under Article 71 of the Fiscalisation Act, carrying high fines. A recipient whose supplier keeps sending paper or e-mailed invoices is not required to refuse the goods or the invoice, but is directed to report the supplier's failure to the Tax Administration.

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