As of January 1, 2026, all companies based in Croatia and registered in the PDV registry are required to send and receive structured electronic invoices for domestic transactions.
The legal basis is the Croatian Fiscalization Act. The requirement applies to companies with their registered office, domicile, or habitual residence in Croatia and covers domestic B2B and B2G transactions.
With Fiskalizacija 2.0, e-invoicing in Croatia is becoming part of a broader digital audit process. Therefore, it will no longer be sufficient to simply generate invoices in the correct format. Companies must also ensure that the exchange of invoices via an authorized intermediary functions properly, that the data is reported to the tax authority, and that subsequent events – such as receipt, rejection, or payment – are accurately processed in their own systems.
Practical Note: Cross-border invoices between a Croatian company and a foreign company are not automatically subject to the same regulations. However, this does not mean that they are exempt from all digital reporting requirements – certain transaction data may be subject to separate reporting requirements.
An e-invoice is an invoice that is issued, sent, and received in a structured electronic format, allowing it to be processed automatically without manual entry.
Based on the definition provided by the Croatian Tax Administration, we have summarized the most important distinctions for practical implementation:
The legally binding document is the structured file. A human-readable version may be generated from it – but it does not replace the original.
Starting in 2026, this requirement applies to all taxable companies registered in the Croatian PDV registry. Companies outside the PDV system must first be able to receive electronic invoices in 2026. They will be required to issue their own e-invoices starting in 2027.
For smaller businesses without PDV registration, Croatia provides the MIKROeRAČUN application, which can be used to receive and – where applicable – issue e-invoices.
Important for POS operators: B2C must be kept separate. End-customer receipts continue to follow the receipt process, not the structured B2B exchange. However, as of January 1, 2026, this receipt process has been expanded to include all relevant payment methods, including bank transfers. Anyone who maps B2C receipts and B2B e-invoices within a single project is mixing two processes with different rules, formats, and channels, thereby creating requirements that neither process actually demands.
Croatia relies on the European semantic standard EN 16931, which is technically implemented via UBL 2.1 and supplemented by national extensions.
The point that international companies most often underestimate: An invoice may technically comply with the European standard but still fail Croatian validation if required national information is missing.
In addition to the standard fields, the Croatian data set requires, among other things:
Every field that does not originate from the ERP system must have a defined source and a designated person responsible for it. If a service provider populates tax-related fields without validated master data, this creates a reconciliation and audit risk that only becomes apparent during a tax audit.
Both are enshrined in the same law. Structured invoice exchange is one part, and the transmission of invoice data to the tax authority is the other – invoices are issued through the information intermediary and reported to the tax authority.
In our article on Fiscalization 2.0 in Croatia, we have described in detail how fiscalization has developed overall in Croatia, what goals the reform is pursuing, and what changes are in store for point-of-sale systems in the B2C sector.
With Fiskalizacija 2.0, accounts payable becomes a compliance system for the first time: Incoming invoices must not only be received and verified, but also actively reported to the tax authority. Existing practical guidelines specify a deadline of five business days after receipt for this reporting by the recipient. This deadline should be verified on a case-by-case basis against the tax authority’s current technical documentation.
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