VATupdate
Croatia

Share this post on

FacebookXEmailLinkedInWhatsApp
Croatia

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

4 days ago
1,574 views
26 min read

Update: December 19, 2025

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

SUMMARY

Summary:

Croatia is implementing a comprehensive “Fiscalization 2.0” framework, mandating e-invoicing and real-time e-reporting for domestic transactions. This initiative, based on the Fiscalization Act passed in June 2025 (effective September 1, 2025), requires all VAT-registered businesses to issue and receive invoices electronically and report them in real-time starting January 1, 2026. The mandate will extend to all remaining entities including small businesses not in the VAT system and public bodies by January 1, 2027. This system is designed to align with future EU “VAT in the Digital Age (ViDA)” reforms. Non-compliance will result in substantial fines.

Key Dates and Timeline:

  • June 13, 2025: New Fiscalization Act approved.
  • September 1, 2025: Fiscalization 2.0 system entered into force; voluntary testing period begins.
  • January 1, 2026: Mandatory e-invoicing and real-time reporting for all domestic B2B and B2G invoices for VAT-registered taxpayers. Non-VAT registered businesses and public entities must be able to receive e-invoices.
  • January 1, 2027: Full scope; all remaining entities, including small businesses not in the VAT system and public bodies, must issue e-invoices.

Scope of Transactions:

  • Domestic B2B: Mandatory e-invoicing and e-reporting for all domestic business-to-business sales where both supplier and customer are in Croatia.
    • “Paper invoices will no longer be accepted for these transactions except in limited cases.”
  • B2G (Business-to-Government): Continues through the existing Servis eRačun platform, but now requires real-time reporting to tax authorities.
  • B2C (Business-to-Consumer): E-invoicing is optional, but fiscal e-reporting is mandatory for all sales, regardless of payment method.
    • “Businesses may choose to issue a consumer an e-invoice as well, but it isn’t compulsory by law.”
  • Intra-EU and International: Cross-border invoices are currently out of scope of the domestic mandate.

Exceptions:

  • Specific activities are exempt, including sales of public transport tickets, highway tolls, utility bills measured by meters, and in-flight sales.
  • Paper invoices are allowed as a fallback if an e-invoice cannot be delivered electronically due to the buyer not being registered in the national e-invoice address directory.

Taxable Persons in Scope:

  • Established VAT-Registered Businesses: All businesses established in Croatia that are registered for VAT must issue and receive e-invoices.
  • Public Sector Entities: Required to accept e-invoices and issue e-invoices by 2027.
  • Non-VAT-Registered Businesses: Must be able to receive e-invoices by 2026 and issue them by 2027. The Tax Authority provides a free web application (“Mikro e-Račun”) for these users.
  • Foreign or Non-Established Businesses: It is unclear if foreign companies with only a Croatian VAT registration (but no establishment) are immediately obligated. The requirement is likely aimed at domestic (established) VAT taxpayers.

E-Invoice Format and Data Requirements:

  • Standard Format: Must conform to the European e-Invoicing standard EN 16931 (XML format). Accepted syntaxes include UBL 2.1 or UN/CEFACT CIIs. A PDF alone is not considered an e-invoice.
  • Required Invoice Content: Includes standard VAT invoice information, plus the exact time of issuance, a unique Invoice Identifier, the seller’s Invoice Issuer Code, and a QR code. Key data points include invoice details, party details, transaction details (including six-digit product/service code), tax details, and payment details. Security elements include a digital signature and a “security code.”

E-Reporting Data:

  • The real-time report to the Tax Authority will contain critical invoice fields, but not necessarily full line-item detail.

How Data is Transmitted (E-Invoicing & E-Reporting Process):

  • Decentralized model with a central clearance/reporting system: Suppliers and buyers exchange invoices directly using their chosen method (service provider, EDI network, Peppol).
  • Continuous Transaction Controls (Clearance Reporting): The issuer must send invoice data to the Tax Administration electronically in real-time. Buyers have up to 5 days to report receipt of the e-invoice.
  • Central Address Directory (AMS): A government-run directory is used to identify recipients. Businesses must register their e-invoice receiving address.
  • Transmission Timeline: Outgoing invoices must be reported in real time; incoming invoices within 5 days of receipt.

Additional Monthly E-Reports:

  • Due by the 20th of the following month, businesses must report payments received for invoices, undelivered e-invoices, and invoice rejections.

Penalties for Non-Compliance:

  • Fines for not issuing e-invoices when required, failing to send data to the Tax Authority in real time, refusing to accept e-invoices, or improper use of digital certificates. Fines can range from €1,320 up to €13,270 for companies.

E-Invoice Format for Transmission:

  • The official format aligns to EN 16931 (structured XML). Croatia’s system supports Peppol BIS 3.0 (UBL XML) as a common format.

Transmission Method:

  • Large companies may integrate their ERP systems directly with the Tax Authority.
  • Many will use authorized providers (intermediaries).
  • Small businesses can use the free government web application (FiskAplikacija and Mikro e-Račun).

Data flow: When an invoice is issued, the seller’s system transmits the invoice data (XML) to the central platform. The platform validates and returns a confirmation in real time to the issuer. Only then is the invoice considered fiscally valid. The issuer then sends the actual e-invoice file to the buyer (via direct connection, Peppol, email link, etc., as agreed). The buyer in turn reports back to tax authorities (or simply acknowledges via the platform) within 5 days. Meanwhile, both issuer and recipient will later log periodic reports (monthly) for any required additional info (like payment status). The Tax Authority cross-checks the data from both sides.

Archiving Requirements & Retention Period:

  • All electronic invoices must be archived and retained in a legible, secure form for at least 11 years. Electronic storage is sufficient. The Tax Authority’s Mikro e-Račun app offers a free-of-charge archive for small taxpayers.

Pre-Filled VAT Returns:

  • The system is expected to generate pre-filled VAT returns for taxpayers, reducing administrative workload and errors.

Key Regulatory References and Resources:

  • Fiscalization Act (2025): The primary law enabling B2B/B2C e-invoicing and real-time reporting.
  • Tax Authority Guidance: Porezna uprava website.
  • E-Invoicing in Public Procurement Act (2018): Governing B2G e-invoicing.

Conclusion:

Croatia’s e-invoicing mandate represents a significant shift towards digital tax compliance. Businesses need to prepare to meet the requirements by January 1, 2026, to avoid penalties. While the system doesn’t yet cover cross-border invoices, it positions Croatia for future EU-wide digital reporting.

Disclaimer: This briefing document is based on the provided excerpts and is for informational purposes only. Consult the official sources and legal counsel for definitive guidance. VATupdate.com keeps you ahead of the curve for VAT and customs worldwide.

INDEPTH ANALYSIS

Croatia is rolling out a comprehensive Fiscalization 2.0 framework that makes electronic invoicing (e-Invoicing) and continuous e-Reporting mandatory for domestic transactions. The reform is phased: a new Fiscalization Act was passed in June 2025 and took effect on 1 September 2025, with mandatory e-Invoicing and real-time reporting starting 1 January 2026 for all VAT-registered businesses in Croatia. Key aspects of the scope and timeline include: [sovos.com], [kpmg.com]
Implementation Timeline & Grace Period:
    • June 13, 2025: Croatia’s Parliament approved a new Fiscalization Act (Official Gazette 89/2025) that replaces the older cash fiscalization law. [kpmg.com]
    • September 1, 2025: The Fiscalization 2.0 system entered into force, and a production system was opened for testing. Technically prepared businesses and providers could voluntarily test e-invoice exchange, digital signing, and reporting in this period. [sovos.com]
    • January 1, 2026: Mandate begins. All domestic B2B and B2G invoices must be issued and received electronically by VAT-registered taxpayers. Real-time reporting (“fiscalization”) of each invoice to the Tax Administration also becomes compulsory on this date. Non-VAT-registered businesses and public entities must at least be able to accept e-invoices from this date. [marosavat.com], [edicomgroup.com] [kpmg.com], [edicomgroup.com]
    • Grace Period: There is no extended post-implementation grace period for in-scope taxpayers – the mandate is effective from day one of 2026. However, the rollout is phased by taxpayer type (with smaller/non-VAT taxpayers given extra time), and a mandatory testing phase in late 2025 allowed early movers to adapt. In practice, paper invoicing will be “gradually phased out” during 2026, and certain exemptions or fallback scenarios (see below) may apply. [sovos.com] [edicomgroup.com]
    • January 1, 2027: Full scope. The e-invoicing and e-reporting obligations extend to all remaining entities, including small businesses not in the VAT system and public bodies. By this date, even entrepreneurs who are not VAT-registered (e.g. micro-enterprises, sole traders) and government entities must issue e-invoices (not just receive) for domestic transactions. [sovos.com], [marosavat.com] [kpmg.com], [invoice-portal.de]
    • (Looking ahead, Croatia also anticipates aligning with the EU “VAT in the Digital Age (ViDA)” reforms by 2030, which will introduce digital reporting for cross-border EU transactions.) [sovos.com]
Transactions in Scope (Domestic, Intra-EU, Export):
    • Domestic B2B Transactions: Mandatory e-Invoicing and e-Reporting for all domestic business-to-business sales where both supplier and customer are in Croatia. Paper invoices will no longer be accepted for these transactions except in limited cases (see Exceptions below). The e-invoices must be in a structured format and transmitted electronically in compliance with the new system. [marosavat.com], [invoice-portal.de]
    • B2G (Business-to-Government): Already mandatory since 2019 under a separate law for public procurement. Suppliers to public bodies must issue e-invoices via the national platform Servis eRačun managed by FINA, in the European standard format. Under Fiscalization 2.0, B2G invoices continue through the existing system but now additionally must be reported in real-time to the tax authorities just like B2B invoices. (Public entities also have to be able to receive B2B e-invoices from 2026, and issue their own by 2027.) [sovos.com], [ec.europa.eu] [sovos.com], [edicomgroup.com] [edicomgroup.com], [edicomgroup.com]
    • B2C (Business-to-Consumer): Electronic invoicing for B2C remains optional – companies can still issue paper or standard receipts to consumers. However, fiscal e-Reporting is mandatory for all B2C sales regardless of payment method. This means even when a paper receipt is given to a consumer, the sale’s details must be sent electronically to the tax authority (extending the existing “cash fiscalization” system to all payment types, not just cash). From 2026, for example, card and online payments in B2C also need to be reported in real time. Businesses may choose to issue a consumer an e-invoice as well, but it isn’t compulsory by law. [marosavat.com], [invoice-portal.de] [community.sap.com], [edicomgroup.com]
    • Intra-EU and International Transactions: Cross-border invoices (EU or export/import) are currently out of scope of Croatia’s domestic e-invoicing mandate. Companies are not (yet) required to use the Croatian e-invoice system for invoices to foreign business partners. Such invoices can still be issued in paper or other formats by agreement. (The mandatory system applies exclusively to domestic transactions between persons registered in Croatia.) That said, voluntary use of e-invoicing and networks like Peppol is encouraged for cross-border trade. Note: Cross-border invoices still must be reported eventually via VAT returns, but they are not subject to real-time fiscal reporting under Fiscalization 2.0. [marosavat.com], [invoice-portal.de] [invoice-portal.de] [invoice-portal.de], [invoice-portal.de]
    • Exceptions: Certain specific activities are exempt from the fiscalization requirements even domestically. For instance, sales of public transport tickets, highway tolls, utility bills measured by meters (electricity, water, etc.), in-flight sales, and similar are carved out from the e-invoice/fiscalization mandate. Moreover, if a domestic e-invoice cannot be delivered electronically because the buyer is not registered in the national e-invoice address directory, the law allows a paper invoice to be issued as a fallback. (In such cases, the issuer must still report the invoice data and note it as undeliverable via e-reporting.) [fintua.com]
Taxable Persons in Scope (Established vs Non-Established):
    • Established VAT-Registered Businesses: From 1 Jan 2026, all businesses established in Croatia that are registered for VAT must issue their outgoing invoices electronically and must be able to receive incoming e-invoices from other domestic taxpayers. This includes companies and sole proprietors subject to corporate or income tax – effectively, the mandate covers all domestic business entities in the VAT system. [marosavat.com], [invoice-portal.de]
    • Public Sector Entities: Government ministries, local authorities, and other public bodies are required to accept e-invoices from suppliers (per the existing B2G law) and, under the new regime, they themselves must issue e-invoices for their own sales of goods/services by 2027. Public entities not in the VAT system are given until 1 Jan 2027 to begin issuing e-invoices, but must be ready to receive them in 2026. [marosavat.com], [edicomgroup.com]
    • Non-VAT-Registered Businesses: Small businesses, entrepreneurs and freelancers not registered in the VAT system are gradually brought into scope. They must be able to receive e-invoices by 2026 (to transact with suppliers who send e-invoices) and will be required to issue e-invoices by 1 Jan 2027. This phase-in allows micro-businesses extra time to adopt e-invoicing. For these users, Croatia’s Tax Authority is providing a free web invoicing application called “Mikro e-Račun” to create, send, and store e-invoices without needing expensive software. [kpmg.com], [invoice-portal.de] [kpmg.com], [marosavat.com]
    • Foreign or Non-Established Businesses: The mandate’s primary focus is on resident taxpayers. All businesses “with a registered office, permanent or usual residence in Croatia” that meet the criteria above are included. It remains somewhat unclear if foreign companies with just a Croatian VAT registration (but no establishment) are immediately obliged to use the system – early guidance suggests the requirement is aimed at domestic (established) VAT taxpayers. (As EU law stands, Croatia cannot force foreign businesses to use a domestic e-invoicing platform for cross-border deals without EU authorization. So non-established entities likely only fall in scope if they are transacting within Croatia, e.g. through a fixed establishment.) [marosavat.com] [ec.europa.eu]
E-Invoice Format and Data Requirements:
    • Standard Format: Croatia’s e-invoices must conform to the European e-Invoicing standard EN 16931. In practice, invoices need to be issued in a structured XML format that adheres to this standard’s data model. The accepted syntaxes include UBL 2.1 or UN/CEFACT CIIs (the same formats used for EU B2G invoices). A PDF alone is not considered an e-invoice – the legally valid invoice is the XML (a PDF copy can be provided for human readability, but the XML is authoritative). The Tax Authority is expected to publish detailed XML schema and format specifications for the national system (including any CIUS extensions) on its website. [kpmg.com] [invoice-portal.de], [invoice-portal.de] [invoice-portal.de]
    • Required Invoice Content: E-invoices must contain all the information normally required on a VAT invoice by law, plus additional fields introduced by Fiscalization 2.0. Notably, as of Sep 2025, invoices need to include the exact time of issuance (hour and minute), a unique Invoice Identifier, the seller’s Invoice Issuer Code, and a QR code, among other security elements. For reporting purposes, key data points that must be transmitted for each invoice include: [fintua.com]
      • Invoice details: Issue date and time, invoice number/series [fintua.com]
      • Party details: Identifiers and addresses of the issuer and recipient [fintua.com]
      • Transaction details: Description of goods/services, including quantity and unit price; the six-digit product or service code according to the national Classification of Products and Activities (KPD); date of delivery or advance payment if applicable. [kpmg.com], [fintua.com] [fintua.com]
      • Tax details: Taxable amount for each VAT rate or exemption, the VAT rate applied, and the VAT amount. [fintua.com]
      • Payment details: Payment due date and the seller’s bank account number (or virtual account for payment) used for the invoice. Also the method of payment (cash, card, transfer, etc.) needs to be indicated. [kpmg.com], [fintua.com] [fintua.com]
      • Linked documents: Reference to any corrected or cancelled invoice (in case of credit notes, etc.). [fintua.com]
      • Security elements: A digital signature or seal based on a qualified certificate tied to the issuer’s tax ID (OIB) must authenticate each invoice. The invoice also includes a “security code” of the liable person for fiscalization (essentially a cryptographic hash to ensure integrity). [kpmg.com] [fintua.com]
    • E-Reporting Data: The real-time report sent to the Tax Authority will contain the critical invoice fields (as above) but not necessarily the full invoice line-item detail. The law specifies certain data elements that must be reported for fiscalization, which cover all the essential identifiers, amounts, and codes listed above. In addition, some information is reported as part of periodic reports (see E-Reporting section below). [fintua.com], [fintua.com]
    • Format of Reports: E-invoice data and related reports are transmitted as structured electronic messages (likely XML as well). The system uses a secure web platform and requires the use of the AS4 protocol for transmitting documents and reports to the government system. In absence of finalized specs, use of Peppol BIS 3.0 (which is based on UBL XML) and standard EDI formats is permitted to ensure compatibility. All transmissions must ensure authenticity and integrity – typically achieved via digital signatures and secure channels. [edicomgroup.com] [invoice-portal.de]
How Data is Transmitted (E-Invoicing & E-Reporting Process):
Croatia has adopted a decentralized model of e-invoice exchange combined with a central clearance/reporting system:
    • Invoice Exchange Between Parties: Suppliers and buyers are expected to exchange the e-invoice directly using their chosen method (via an agreed service provider, EDI network, or the Peppol network) rather than uploading invoices to a single government portal for delivery. Companies can use certified “information intermediaries” (service providers authorized by the Tax Administration) to handle sending and receiving e-invoices. The Tax Authority maintains a directory of approved intermediaries on its website. Many businesses will connect through these providers or through the national Servis e-Račun platform in the case of B2G. Notably, the national platform and Peppol are interconnected, meaning any Access Point (including those abroad) can route invoices into Croatia’s network via FINA’s access point. [sovos.com], [invoice-portal.de] [sovos.com] [ec.europa.eu], [invoice-portal.de]
    • Continuous Transaction Controls (Clearance Reporting): Alongside delivering the invoice to the buyer, the issuer must send the invoice’s fiscal data to the Tax Administration electronically in real time (continuous reporting). In practice, at the moment of issuing an invoice, the seller’s system will transmit an XML with required fields to the tax authority for clearance. The tax system will check the data (validating the digital signature, correctness of fields, etc.) and record it. If any required data is missing or the invoice is not properly signed, it would be rejected – enforcement is effectively at issuance time for sellers. For the buyer, upon receiving an e-invoice, they have up to 5 days to report it to the tax authority (to confirm receipt and enable cross-checking). This incoming invoice report by the recipient ensures the authorities get both sides of the transaction: the seller’s outgoing report and the buyer’s confirmation. [kpmg.com], [edicomgroup.com] [sovos.com]
    • Central Address Directory (AMS): To facilitate this process, a government-run “Address Metadata Service (AMS)” directory is used to identify recipients. Businesses must register their e-invoice receiving address or preferred access point with the Tax Administration. When a supplier is ready to send an invoice, the tax platform can provide the necessary routing info from AMS (e.g., the buyer’s access point or endpoint address). If a buyer hasn’t registered (i.e., not in AMS), the invoice cannot be delivered electronically – that’s the scenario where paper is allowed, and the issuer must report that situation in their monthly e-report (list of undelivered e-invoices). [edicomgroup.com], [edicomgroup.com] [community.sap.com], [fintua.com]
    • Transmission Timeline: Outgoing invoices must be reported in real time, essentially instantly at issuance (the system performs real-time clearance). Incoming invoices (received) should be reported by the buyer within 5 days of receipt. In addition, certain aggregate reports are submitted periodically (see next point). All data are transmitted electronically via the Tax Authority’s systems (either through a web service/API or via the certified intermediaries). The government’s new “Fiskalizacija” portal (FiskAplikacija) will allow taxpayers to log in and view all reported data, invoice statuses, and even download pre-filled returns. Small taxpayers using the Mikro e-Račun app will automatically fulfill their reporting obligations through that tool. [kpmg.com] [sovos.com] [marosavat.com]
    • Additional Monthly E-Reports: Besides the per-invoice real-time transmissions, the law introduces monthly reporting obligations for certain events, due by a set date after month-end. Specifically, by the 20th of the following month, businesses must report:
      • Payments received for invoices (i.e. which invoices have been paid during that month). This is essentially a payment status report for all invoices, enabling the tax authority to know which invoices are settled. [edicomgroup.com]
      • Undelivered e-invoices: Any sales where an e-invoice could not be issued or delivered electronically (typically because the customer wasn’t in the system) must be listed in a report for that period. [community.sap.com]
      • Invoice rejections: If a buyer rejects or fails to accept an invoice (for example, due to a discrepancy), the recipient must report those occurrences. (The buyer’s 5-day window to report inbound invoices presumably includes flagging any rejection).
        These supplemental reports ensure the authorities capture the full picture (any invoice that “fell outside” the normal flow or any invoice not paid). All monthly reports are submitted electronically via the same system, and they complement the real-time invoice data with additional info. [community.sap.com], [marosavat.com]
Penalties for Non-Compliance: Croatia’s law imposes penalties for failures at any stage of this mandate. Businesses may be fined for:
    • Not issuing an e-invoice when required or issuing it outside the mandated system (e.g. giving a paper invoice for a transaction that should be electronic). [kpmg.com]
    • Failing to send the invoice data to the Tax Authority in real time, or a buyer failing to report receipts in time. Missing the 5-day reporting window for received invoices or neglecting the monthly reports (payments, undelivered, rejections) is an offense. [kpmg.com]
    • Refusing to accept an e-invoice (buyers are obligated to receive e-invoices). All taxpayers must be capable of compliance; a buyer insisting on paper when they are required to accept e-invoices could be penalized. [kpmg.com]
    • Improper use of digital certificates or security measures – for example, not using the required qualified electronic signature/seal, or misuse of one (this undermines authenticity). [kpmg.com]
    • General violations of the fiscalization law’s provisions. The law lists fines that range depending on the severity and the size of entity. For instance, under Croatia’s Accounting Act and tax rules, failing to keep or produce proper invoice records can incur fines on the order of €1,320 up to €13,270 for companies. Similar ranges are expected for breaches of the e-invoicing mandate (the exact penalty schedule is defined in the law). In short, substantial fines apply for non-compliance, incentivizing businesses to follow the e-invoicing and e-reporting requirements from the go-live date. There is no indication of a “penalty holiday,” so compliance by deadlines is critical. [finacro.hr]
E-Invoice Format for Transmission:
The official format aligns to EN 16931, meaning it’s a structured XML invoice respecting the EU semantic data model. Croatia’s system supports Peppol BIS 3.0 (UBL XML) as a common format for e-invoices. In fact, the national platform operated by FINA is a Peppol Access Point and can handle UBL 2.1 invoices. Service providers and software will likely implement the required format (either UBL or CII XML) as per the Tax Authority’s schema. E-Reporting messages (for invoice data and monthly reports) will also be in a structured electronic form (likely XML or JSON), ensuring machine-readability. All communications with the tax system use standard web protocols with security (the law mandates AS4, which is an EU-recommended secure web services protocol). [kpmg.com] [invoice-portal.de] [invoice-portal.de], [invoice-portal.de] [edicomgroup.com]
Transmission Method:
In practice, companies have a few options to connect:
    • Large companies may integrate their ERP or billing systems directly with the Tax Authority’s servers (or via an intermediary) to send the required data automatically at invoice issuance. They will either connect through an API/web service provided by the Tax Administration or through a certified e-invoicing platform.
    • Many will use authorized providers (intermediaries) who handle connectivity, formatting, and compliance. Croatia’s Tax Administration is certifying such providers (e.g., EDICOM, SAP, etc. are becoming certified nodes). These providers can, for example, register clients in the AMS directory and submit invoices on their behalf. [edicomgroup.com] [edicomgroup.com], [edicomgroup.com]
    • Small businesses not using a provider can use the free government web application (FiskAplikacija and Mikro e-Račun). Through this portal, they can manually create invoices or upload them, and the system will automatically send the data to the authorities and deliver the e-invoice to customers (or at least make it available). This ensures even micro-businesses comply without needing custom IT development. [marosavat.com]
    • Data flow: When an invoice is issued, the seller’s system transmits the invoice data (XML) to the central platform. The platform validates and returns a confirmation (fiscalization confirmation code) in real time to the issuer. Only then is the invoice considered fiscally valid. The issuer then sends the actual e-invoice file to the buyer (via direct connection, Peppol, email link, etc., as agreed). The buyer in turn reports back to tax authorities (or simply acknowledges via the platform) within 5 days. Meanwhile, both issuer and recipient will later log periodic reports (monthly) for any required additional info (like payment status). The Tax Authority cross-checks the data from both sides. This clearance-style model means the tax authority effectively monitors each invoice shortly after issuance, rather than waiting for periodic VAT returns. [edicomgroup.com], [edicomgroup.com]
Archiving Requirements & Retention Period:
All electronic invoices must be archived and retained in a legible, secure form for at least 11 years (counted from the end of the year in which the invoice was issued). This mirrors Croatia’s general accounting record retention rules, which require 11-year retention for accounting documents like invoices and ledgers. Key points about archiving: [invoice-portal.de]
    • Integrity and Accessibility: The e-invoices must be stored in a way that guarantees their integrity (no alteration) and authenticity over the entire retention period. During a tax audit, the business must be able to retrieve and present the invoices in a readable format, and the digital signatures or security codes should verify that the content is untampered. [invoice-portal.de]
    • Electronic Storage: Electronic archiving is sufficient and is actually the norm – printing out e-invoices is not required or recommended. Companies should use an audit-proof electronic archiving system, possibly a document management system, with regular backups and safeguards against data loss. [invoice-portal.de]
    • Access for Authorities: The archive should be organized such that the Tax Administration can be granted access or provided data on request. Businesses can keep their electronic archives on servers outside Croatia (within the EU) if needed, but they remain responsible for compliance and access provision to Croatian authorities on demand. [finacro.hr]
    • Free Archiving Solution: The Tax Authority’s Mikro e-Račun app offers a free-of-charge archive for small taxpayers, storing their invoices for the legally required period in the government system. This lowers compliance burden for micro firms. Larger companies may use their own IT or third-party archiving solutions, but must meet the same retention and security criteria. [marosavat.com]
    • Retention Limit: The minimum 11-year retention is primarily for VAT/tax purposes. After that, invoices can be disposed of if no longer required, although companies often keep records for a bit longer as a precaution. Some records (like salary or financial statements) have different retention spans, but for invoices 11 years is the key requirement in Croatia. Failing to keep invoices for the full period or compromising their integrity can lead to penalties under the Accounting and tax laws. [finacro.hr]
Pre-Filled VAT Returns:
One of the anticipated benefits of the new e-invoicing and e-reporting system is the generation of pre-filled VAT returns for taxpayers. Because the Tax Administration will receive detailed data on sales and purchases in real time, they can auto-calculate each taxpayer’s VAT input and output. Taxpayers will have access to pre-populated VAT return drafts via the Fiskalizacija portal. Both invoice issuers and recipients will see their VAT reporting data pre-filled based on the invoices declared (including any corrections for credits or rejections). This is expected to reduce administrative workload and errors, as businesses can simply verify the pre-filled amounts instead of compiling returns from scratch. It also means the tax authority can detect discrepancies (if, say, a counterparty’s reporting doesn’t match) early. While the system is new, the introduction of pre-filled returns is explicitly part of the reform’s goals – Croatia is leveraging the e-invoicing data to streamline compliance. Taxpayers will still need to review and formally submit these returns, but the heavy lifting of preparation is done by the system. (At this stage Croatia is implementing this for domestic VAT; there is no mention of pre-filled EU sales lists or similar, as those cross-border transactions aren’t in the system yet.) [marosavat.com], [marosavat.com] [marosavat.com]
Key Regulatory References and Resources:
The e-invoicing mandate in Croatia is grounded in legislative and official sources:
    • Fiscalization Act (2025): The primary law enabling B2B/B2C e-invoicing and real-time reporting. Passed June 2025 (published in Narodne Novine Official Gazette no. 89/25), this act (“Zakon o fiskalizaciji u prometu bezgotovinskih računa”) came into force Sep 2025 and defines obligations for e-invoices, reporting, use of certificates, etc. (Available in Croatian; the Tax Administration has summaries online.) [fintua.com] [community.sap.com]
    • Tax Authority Guidance: The Croatian Tax Administration (Porezna uprava) provides technical guidelines and updates on its website. It maintains an official list of certified e-invoicing service providers and the “AMS” directory for addresses. (See Porezna Uprava’s page on “Fiskalizacija bezgotovinskih računa” for details, in Croatian). Technical documentation including the XML schema and interface specifications are to be published by the Tax Authority ahead of the 2026 mandate. [sovos.com] [community.sap.com] [kpmg.com]
    • E-Invoicing in Public Procurement Act (2018): The existing law governing B2G e-invoicing (Official Gazette 94/2018) remains in force for public sector transactions. It transposes EU Directive 2014/55/EU, requiring public bodies to accept e-invoices and vendors to send them via the national platform (FINA’s e-Račun). This infrastructure is now being augmented to interface with the new fiscal reporting. [ec.europa.eu]
    • EU Legislation Context: Croatia’s move is in line with EU initiatives. It required special permission under the EU VAT Directive to mandate electronic invoicing for B2B (since normally buyers must agree to e-invoices). The European Commission’s expected “VAT in the Digital Age” rules will likely make such systems common by 2028–2030, but Croatia is an early adopter. Relevant EU laws include the VAT Directive (2006/112/EC) and eIDAS Regulation (for digital signatures). [vatupdate.com], [vatupdate.com]
    • Recent Articles and Government Announcements: For detailed explanations, see sources like the KPMG TaxNewsFlash on Croatia (June 17, 2025), the Ministry of Finance’s public consultation document from Feb 2025, and official news releases on the Recovery and Resilience Plan (which funded this digitalization). The Croatian government’s Official Gazette website publishes the full legal texts (e.g., the Fiscalization Act and its amendments). [kpmg.com], [kpmg.com] [ec.europa.eu] [community.sap.com]
In summary, from 2026 Croatia will require domestic invoices to be electronic and reported in real-time to tax authorities, covering B2B and B2G initially, with B2C reporting enforced and full coverage by 2027. Businesses must adapt their systems to issue EN16931-compliant e-invoices, transmit invoice data immediately to the Tax Administration, and comply with periodic reporting of payments and exceptions. The system does not (yet) cover cross-border invoices, but positions Croatia for future EU-wide digital reporting. There is little leniency in timing – affected businesses should be ready by January 1, 2026 to avoid penalties. The new framework promises benefits like reduced fraud, greater efficiency, and automated VAT return prep, but it also imposes strict requirements on data content, transmission, and record-keeping. All these changes are backed by law and detailed in official resources, ensuring that Croatia’s e-invoicing rollout is grounded in clear regulations and guidance. [marosavat.com], [invoice-portal.de] [fintua.com], [community.sap.com]
  • Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE

 

Latest Posts in "Croatia"

Sponsors:

Advertisements:

  • Exchange Summit