Briefing Document & Podcast: Croatia – E-Invoicing, E-Reporting, and E-Transport – Scope and Timeline

See also Mandatory E-Invoice Data Fields (Croatia’s Fiscalization 2.0) – VATupdate

SUMMARY

1. Overview of Fiscalization 2.0

Fiscalization 2.0 represents a significant shift towards a comprehensive digital tax system in Croatia. It aims to increase transparency, improve tax compliance, and combat tax evasion through mandatory electronic invoicing and real-time reporting of all taxable transactions. “Fiscalization 2.0 represents Croatia’s move towards a comprehensive digital tax system encompassing B2C receipt fiscalization, B2B electronic invoicing, and real-time reporting.” The legal basis for this system is the “Law on Fiscalization” (Official Gazette 89/25), effective September 1, 2025.

2. Implementation Timeline

The implementation of Fiscalization 2.0 occurs in phases:

• September 1, 2025: New Fiscalization Act in force (testing phase begins).
• January 1, 2026: Mandatory e-invoicing for all domestic B2B and B2G invoices by VAT-registered businesses. E-reporting expands to cover every B2C sale, regardless of payment method.
• January 1, 2027: Mandatory e-invoicing extends to non-VAT-registered entities for domestic transactions. Paper invoices are phased out for domestic trade. “From this date, paper invoices are phased out for domestic trade.”

3. E-Invoicing

• Definition: The issuance and receipt of invoices in a structured electronic format (XML) that complies with specific standards.
• Scope: Mandatory for domestic B2B and B2G transactions. Optional for B2C transactions, although B2C transactions still require real-time reporting. “Domestic B2B and B2G transactions are subject to mandatory e-invoicing. Cross-border transactions (imports, exports, intra-EU) are excluded from this mandate.”
• Format: Must conform to the European standard EN 16931 using UBL 2.1 XML with a local CIUS (Core Invoice Usage Specifications) extension (HR-FISK 2.0). Each invoice must be digitally signed with a qualified certificate, including the OIB. “Electronic invoices must conform to the European standard EN 16931 format (structured XML). Croatia’s implementation uses UBL 2.1 XML with a local CIUS (Core Invoice Usage Specifications) extension to meet national requirements.”
• Real-time Reporting: Every e-invoice’s full data must be transmitted to the Tax Administration in real-time.

4. E-Reporting

• Definition: Continuous, real-time digital reporting of transaction data to the Tax Administration. “E-Reporting in Croatia refers to the continuous, real-time digital reporting of transaction data to the Tax Administration.”
• Scope: All transaction types (B2B, B2G, and B2C) fall under e-reporting. Includes reporting foreign invoices and deliveries without invoices. “Under Fiscalization 2.0, all transaction types fall under some form of e-reporting.”
• Process: Businesses use the Tax Administration’s online system (via secure web services) to send structured transaction data in XML format to the government’s e-Fiskalizacija service.
• Key Reporting Triggers: New invoice issuance/receipt, payment completion, and invoice rejection.
• Reporting Deadlines: Designed to be real-time or near-real-time, with most data required within 5 working days of the event. “The general rule is that required data should be sent within 5 working days of the event if not immediately.” Invoice rejections can be reported by the 20th of the following month.

5. E-Transport

• Definition: Reporting the transport/delivery of goods when no e-invoice accompanies the shipment at the time of delivery. “E-Transport” in the Croatian context refers to the obligation to report the transport/delivery of goods when no e-invoice accompanies the shipment.”
• Scope: Applicable when goods are delivered without an e-invoice (e.g., invoice to be issued later, buyer’s electronic address unavailable).
• Data and Format: Includes details of the parties involved, description/quantity of goods, date of delivery, and reference to any pending invoice or order. Requires the same data fields as a full invoice, but flagged as “IR” (invoice type)
• Deadline: Within 5 working days of the goods being shipped or delivered.

6. Mandatory E-Invoice Data Fields

Every e-invoice must include standard invoice information as defined by the EU norm EN 16931, plus specific national additions. Key elements include:

• Invoice Identification and Dates: Invoice number (including business premise and issuing device codes), issue date, type code, supply date, payment due date.
• Seller and Buyer Details: Supplier (issuer) name and OIB, Customer (recipient) name and OIB (if applicable).
• Line-Item Details: Description of goods/services, quantity, unit of measure, unit price (net of VAT), KPD 2025 classification code, VAT category and rate.
• Invoice Total Breakdowns: Taxable amounts by rate, VAT amount by rate, total VAT amount, total amount excluding VAT, total amount including VAT, advance payments and amount due.
• Payment Information: Supplier’s bank account number (IBAN) or payment identifier, payment terms.
• References: Original invoice number and date (if amending a previous invoice).
• Digital Signature: Qualified electronic signature with OIB.

7. E-Reporting Data Requirements (Beyond the Invoice):

• Invoice Receipt Confirmation (Fiscalization of Receipt by Buyer): Buyer reports the same invoice data (marked as incoming) within 5 business days.
• Invoice Payment (Collection) Reporting: Issuer reports payment details (date, amount, method – bank transfer “T”, offset “O”, or other “Z”) when payment is received.
• Invoice Rejection Reporting: Recipient reports rejection (reason: “N” Non-tax relevant discrepancy, “U” Tax relevant discrepancy, or “O” Other reason) with rejection date.
• Delivery of Goods without Invoice (E-Transport report): Supplier reports delivery details including a special “IR” invoice type code.

8. Penalties for Non-Compliance

• E-Invoicing: Fines ranging from approximately €2,650 to €66,000 for companies (and about €265 to €6,650 for responsible individuals) for failure to issue or fiscalize invoices.
• E-Reporting: Fines ranging from approximately €1,330 to €13,300 for companies (and about €130 to €1,330 for responsible individuals) for failure to properly report transactions. Manipulating the system can result in fines up to ~€66,000 and business closure.
• E-Transport: Failure to file a required delivery report falls under e-reporting non-compliance fines. “Businesses should ensure any goods delivered without an invoice are promptly reported to avoid these penalties.”

9. Impact and Considerations

Fiscalization 2.0 will significantly impact businesses operating in Croatia. While it offers potential benefits like streamlined VAT compliance in the future, businesses face challenges in implementing the necessary systems and processes to comply with the new regulations. Careful planning, technology adoption, and understanding of the data standards are critical for successful compliance.

10. VAT Returns:

“As of the latest updates, Croatia has not introduced pre-filled periodic VAT returns based on the new e-invoicing and e-reporting data.” However, the Tax Administration intends to leverage the data collected to simplify VAT compliance in the future.

This briefing document provides a comprehensive overview of Croatia’s Fiscalization 2.0. Businesses operating in Croatia should consult the official legal and technical documentation from the Croatian Tax Administration to ensure full compliance.

INDEPTH ANALYSIS

E-Invoicing, E-Reporting, and E-Transport in Croatia – Scope and Timeline

E-Invoicing (Electronic Invoicing)

• Implementation Timeline: The mandate for mandatory e-invoicing applies in phases:
  • Sept 1, 2025: New Fiscalization Act in force (testing phase begins). [rtcsuite.com]
  • Jan 1, 2026: All domestic B2B and B2G invoices by VAT-registered businesses must be issued and received as electronic invoices. (B2G e-invoicing was already compulsory since 2019 via the state e-Račun system.) [rtcsuite.com], [kpmg.com] [spaceinvoices.com]
  • Jan 1, 2027: Non–VAT-registered entities (small businesses, freelancers, budget users, etc.) must also issue e-invoices for domestic transactions. From this date, paper invoices are phased out for domestic trade. [rtcsuite.com], [kpmg.com]
• Transactions in Scope: Domestic B2B and B2G transactions are subject to mandatory e-invoicing. Cross-border transactions (imports, exports, intra-EU) are excluded from this mandate. B2C transactions are not required to use e-invoices (consumers can still be given fiscal receipts), and e-invoicing remains optional for B2C sales. [rtcsuite.com] [ey.com]
• Taxable Persons Covered: In 2026, all VAT-registered taxpayers (companies and self-employed persons) established in Croatia must comply, whether acting as invoice issuer or recipient. From 2027, the obligation extends to all other taxpayers (including non-VAT-registered businesses and public entities) for domestic invoicing. Public institutions must be able to receive e-invoices from 2026 and issue them by 2027. [rtcsuite.com] [rtcsuite.com], [kpmg.com] [kpmg.com]
• E-Invoice Format: Electronic invoices must conform to the European standard EN 16931 format (structured XML). Croatia’s implementation uses UBL 2.1 XML with a local CIUS (Core Invoice Usage Specifications) extension to meet national requirements. In practice, this means e-invoices are issued in a standardized XML format (often via the e-Račun platform or PEPPOL network) to ensure interoperability. Each e-invoice must be digitally signed with a qualified certificate linked to the taxpayer’s ID for authenticity and integrity. [rtcsuite.com], [rtcsuite.com] [spaceinvoices.com] [kpmg.com], [rtcsuite.com]
• Data Reporting Requirements: Every e-invoice’s full data must be transmitted to the Tax Administration in real time as part of a continuous transaction control system. Besides standard invoice fields (buyer, seller, amounts, tax details, etc.), Croatia requires additional details to be reported, including the supplier’s bank account number, product or service codes (KPD classification), payment status, and other relevant data. This data is sent to the tax authority at the moment of issuance for verification. Both the issuer and the recipient of an e-invoice have reporting obligations: the issuer reports the invoice data upon issuance, and the recipient must confirm or “fiscalize” receipt of the invoice by reporting certain data (e.g. acceptance or rejection) within 5 working days. (See E-Reporting below for how rejections are handled.) [kpmg.com], [sapeinvoice.com] [sovos.com]
• Deadlines for Sending Invoice Data: For B2B/B2G e-invoices, issuers must transmit the invoice data to the tax authority at issuance (real-time). Invoice recipients must electronically report their receipt/validation of the invoice within 5 business days of receiving it. In practice, this dual reporting “fiscalizes” the invoice on both sides. For B2C invoices (receipts), as of 2026 all sales (including cash, card, bank transfer, etc.) must be reported and authorized by the tax system in real time at the point of sale. (If connectivity is lost, the law allows a short grace period – typically 2 to 5 days – to transmit stored receipts once service is restored.) [kpmg.com] [sovos.com] [rtcsuite.com]
• Penalties for Non-Compliance (E-Invoicing): The Fiscalization Act imposes steep fines for failing to comply with e-invoicing and fiscalization requirements. For example, failure to issue an invoice as required or to fiscalize (report) it to the authorities can incur fines ranging roughly from €2,650 up to €66,000 for companies (and about €265 to €6,650 for responsible individuals). Penalties also apply to not receiving or validating an e-invoice when obligated, misuse of the system or certificates, and missing reporting deadlines. Repeated violations can lead to double fines and even temporary closure of the business in serious cases. In short, businesses must implement the e-invoice process or face significant sanctions. [rtcsuite.com] [kpmg.com]

E-Reporting (Real-Time Electronic Reporting)

• What It Is: E-Reporting in Croatia refers to the continuous, real-time digital reporting of transaction data to the Tax Administration. It is a complement to e-invoicing, ensuring that every taxable transaction (B2B, B2G, and B2C) is reported electronically, even in scenarios where an e-invoice is not exchanged. The new system creates an electronic audit trail for all sales and invoice life-cycle events, enabling tax authorities to verify transactions promptly. [sapeinvoice.com], [comarch.com]
• Scope of Transactions: Under Fiscalization 2.0, all transaction types fall under some form of e-reporting:
  • B2B and B2G: As noted, each e-invoice issued or received must be reported by both parties. This dual reporting of B2B/B2G invoices is part of e-reporting (often termed a decentralized continuous transaction control system). [sovos.com]
  • B2C: All B2C retail transactions (final consumer sales) have long been subject to fiscal cash register reporting in Croatia. From Jan 1, 2026, this obligation expands to cover every B2C sale regardless of payment method (not just cash sales). In practice, whether the customer pays by cash, card, bank transfer, or other electronic means, the sale must be recorded and sent to the tax authority’s system for a unique invoice ID in real time, just as was done for cash receipts since 2013. The result is that all invoices/receipts to consumers are electronically verified by the tax authority at sale time (with a unique code, JIR, and QR code embedded on the receipt). [comarch.com] [comarch.com], [rtcsuite.com] [rtcsuite.com], [rtcsuite.com]
  • Cross-Border and Exceptions: Transactions outside the domestic e-invoice scope (e.g. a Croatian company’s imports or foreign-supplied invoices, or certain exceptional cases) must be reported via the e-reporting system as well. For instance, if a Croatian taxpayer receives an invoice from an EU supplier (which isn’t a domestic e-invoice through the national platform), those foreign invoices need to be reported digitally to the tax authority by the Croatian buyer. This ensures the tax authority still gets visibility of VAT on inbound transactions even when the invoice wasn’t issued through the local system. [rtcsuite.com], [sapeinvoice.com] [rtcsuite.com], [rtcsuite.com]
• How E-Reporting Works: Businesses will use the Tax Administration’s online system (via secure web services) to send structured transaction data. No specific document format like an invoice is required for e-reporting events; instead, businesses transmit the required data fields through an API in XML format to the government’s e-Fiskalizacija service. Key reporting triggers include: [fiscal-req…ements.com]
  • New Invoice Issued/Received: Whenever an invoice is issued or received, the invoice data (all details mentioned above) is immediately transmitted to the tax authority for validation. The tax system checks the data and logs the sale. (For B2C, the system returns a unique JIR code to be printed on the receipt in real time.) [sapeinvoice.com] [rtcsuite.com]
  • Payment Completion: When an invoice is paid by the customer (for B2B, this could be after issuance), the payment details (date, amount, method) must be reported as well. This links payments to invoices in the tax system, helping the tax authority track settlement of invoices. [sapeinvoice.com]
  • Invoice Rejection: If a B2B invoice recipient rejects or refuses an e-invoice (for example, due to a discrepancy), this rejection must be reported electronically, including the reason for rejection. (The system thus knows the invoice was not accepted by the buyer, which is important for audit trail and obligations.) [sapeinvoice.com]
  • Goods Delivery without Invoice: (Covered under E-Transport below.)
• Reporting Deadlines: E-reporting is designed to be real-time or near-real-time. The general rule is that required data should be sent within 5 working days of the event if not immediately. In practice: [rtcsuite.com]
  • B2B/B2G invoice issuers report instantly at issuance; recipients have up to 5 business days to report their side (acceptance/fiscalization). [sovos.com]
  • B2C receipts are reported instantly at sale (any delay beyond a very short window violates fiscal rules). [rtcsuite.com]
  • Exceptions: The only longer grace period is for invoice rejections – a buyer rejecting an invoice can report the rejection by the 20th of the following month at the latest. (This allows businesses to consolidate or handle rejections in their monthly compliance workflow.) All other out-of-band reports, such as reporting a foreign invoice or a delivery made without an invoice, must be submitted within 5 working days of the transaction/event. [rtcsuite.com]
• Penalties for Non-Compliance (E-Reporting): Failing to properly report transactions through the e-reporting system when required also carries penalties. For instance, failure to submit required reports (such as neglecting to report a foreign invoice, a payment, or a rejection in time) can result in fines roughly ranging from €1,330 up to €13,300 for companies (and about €130 to €1,330 for individuals responsible). These fines are separate from the e-invoice issuance fines – a company could incur both if they neither issue an e-invoice nor report the transaction. Additionally, manipulating or bypassing the system (such as using unapproved invoicing software or altering data) is taken very seriously – penalties can include up to ~€66,000 fine and a business premise closure for up to 30 days in severe cases. All these measures underscore that real-time reporting is mandatory and enforced. [rtcsuite.com]

E-Transport (Reporting of Goods Transport)

• Scope: Whenever goods are delivered without an e-invoice at the time of delivery – for example, if an invoice will be issued later or the buyer’s electronic address is not available – the delivery must be electronically reported to the tax authorities as a special event. This situation can occur for certain industries or cross-border scenarios (e.g., consignments, or where a final invoice is issued days after delivery). The report ensures the Tax Administration is aware of the movement of taxable goods even if the actual invoice flows through a different process or later date. [sapeinvoice.com], [rtcsuite.com]
• Data and Format: The delivering taxpayer must provide details of the delivery via the e-reporting system. This “invoice delivery report” would typically include data such as the parties involved, description/quantity of goods, date of delivery, and reference to any pending invoice or order, etc. (The exact data fields are defined by the Tax Administration.) The report is submitted digitally (likely via the same XML web service for e-reporting) – there is no paper form. In essence, the format is an electronic message to the tax authority indicating a goods dispatch without an invoice. [sapeinvoice.com]
• Deadline: Such delivery without invoice must be reported within 5 working days of the goods being shipped or delivered (the law imposes the same 5-day window for these e-transport reports as for other non-invoice reporting events). Early reporting (closer to real-time) is encouraged to maintain transparency. [rtcsuite.com]
• Integration with System: Once the invoice is eventually issued (if it is issued later or by a foreign supplier), that invoice will either be fiscalized normally (if domestic) or also reported (if foreign). The initial transport report helps tax authorities match a later invoice to a prior delivery. It’s effectively a stop-gap measure to prevent unreported shipments, thereby combating tax evasion on goods in transit. [sapeinvoice.com], [sapeinvoice.com]
• Penalties: There is no separate penalty category called “e-Transport,” but failing to file a required delivery report would fall under the e-reporting non-compliance fines (up to €13,300 for companies). Businesses should ensure any goods delivered without an invoice are promptly reported to avoid these penalties. [rtcsuite.com]

Pre-Filled VAT Returns

References and Official Resources

• Legal Basis: Law on Fiscalization (“Zakon o fiskalizaciji”), Official Gazette 89/25, published June 13, 2025, effective Sept 1, 2025. This law and its bylaws detail the e-invoicing, e-reporting, and related obligations. (Available in Croatian; an official English summary is provided by the Ministry of Finance in public consultations.) [pointer.hr]
• Tax Authority Guidance: The Croatian Tax Administration (Porezna uprava) will publish technical documentation including the e-invoicing schema, data format, and communication procedures. Taxpayers can refer to the Tax Administration’s website and the ePorezna portal for guidelines on using the new e-invoice exchange system and the free “MIKRO e-RAČUN” application provided for small taxpayers. [kpmg.com]
• EU and Government Portals: For further details, see the European Commission’s eInvoicing Country Sheet: Croatia 2025 and the Ministry of Finance announcements (e.g., the February 2025 public consultation on mandatory e-invoicing). Also, FINA (the Croatian Financial Agency) operates the central B2G e-invoicing platform “Servis e-Račun za Državu,” which will integrate with the new system.
• News and Analysis: Recent tax newsletters and analyses by firms such as KPMG, Sovos, EY, and others provide overviews of the Croatian mandate. These external sources confirm the timeline and requirements outlined above and can be consulted for more context and any updates on implementation. All businesses in Croatia should review the official law and guidance to ensure full compliance by the stated deadlines. [kpmg.com] [sovos.com] [ey.com]

• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Collection of E-Invoicing Guides – Worldwide – VATupdate
  • Briefing / Comprehensive Guides (incl. podcasts)

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE