E-invoicing in Croatia

Comprehensive guide to electronic invoicing in Croatia – Legal basis, obligations and practical implementation

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Overview

Croatia runs three distinct regimes at once. Public procurement has had mandatory e-invoicing since 2019 through the state service operated by FINA. Since 1 January 2026 domestic B2B falls under Fiscalization 2.0 — structured invoices exchanged between access points, with the invoice data reported separately to the Tax Administration. Consumer sales remain a receipt fiscalisation regime, not an e-invoicing mandate.

The architecture is worth understanding precisely, because it is easy to mis-file. This is not a clearance model: the Tax Administration does not approve the invoice before it reaches the buyer and stamps nothing on it. Invoices move directly between access points; a separate fiscalisation message goes to the tax authority in parallel.

All VAT payers

issue, receive and fiscalise; non-VAT businesses receive first

UBL 2.1

EN 16931 with the Croatian CIUS and extensions

11 years

retention period — longer than almost anywhere in the EU

Timeline

The B2B obligation arrived in one step for VAT payers, with a one-year deferral on issuing for businesses outside the VAT system.

Already in force

1 December 2018 – 1 July 2019

B2G becomes mandatory

Public contracting authorities had to accept EN 16931 e-invoices from December 2018; suppliers had to issue them from July 2019. Paper and non-compliant digital invoices are no longer accepted in public procurement.

1 September 2025

The Fiscalization Act enters into force

Act NN 89/25 creates the legal basis for Fiscalization 2.0, defines the eRačun, and sets out the requirements for information intermediaries.

1 January 2026

Domestic B2B e-invoicing begins

VAT-registered businesses must issue, receive and fiscalise e-invoices for domestic transactions. Businesses outside the VAT system must be able to receive and fiscalise them.

Still ahead

1 January 2027

Non-VAT businesses must issue

The issuing obligation extends to taxpayers outside the VAT system. From that point the domestic regime covers everyone.

1 July 2030

ViDA cross-border reporting

EU-wide e-invoicing and Digital Reporting Requirements apply to intra-community B2B transactions. National domestic reporting must align with the EU model by 1 January 2035.

Note the asymmetry in 2026: a business outside the VAT system is not yet obliged to issue, but it is obliged to receive and fiscalise. Companies that assumed the whole obligation was deferred for them are the ones now discovering they are non-compliant on the receiving side.

Fiscalization 2.0

Two things happen for every domestic invoice, and they travel separately. Getting one right and the other wrong is the most common failure mode.

The invoice

A structured eRačun travels from the sender's access point to the recipient's. Addressing runs through the national metadata and routing services. The Tax Administration is not in this path.

The fiscalisation message

Generated automatically from the invoice data and sent to the Tax Administration in its own XML format, separately from the invoice exchange itself.

—The e-invoice carries no visible tax stamp or approval number — there is nothing to check on the document itself

—Beyond the invoice, businesses report rejections and payments to the Tax Administration

—Transport between access points uses AS4; every intermediary must at minimum be able to receive over AS4

—EDI is not prohibited, but it does not exempt anyone from fiscalisation

The right label is decentralised exchange plus central tax reporting — structurally close to a five-corner model, and much closer to Slovakia's design than to Italy's clearance system. If a vendor describes the Croatian regime as "clearance", they have misread it.

Who is in scope

Domestic B2B Mandatory since January 2026 for VAT payers. Non-VAT taxpayers receive and fiscalise from 2026, issue from 2027.

B2G Mandatory since 2019 through the FINA service, on EN 16931. The B2G route and the new B2B regime run alongside each other.

B2C Not an e-invoicing mandate. Consumer transactions stay in the receipt fiscalisation regime, which since 2026 also covers payments into a transaction account.

Cross-border Outside the Croatian mandate. Fiscalization 2.0 applies to domestic transactions. Intra-EU B2B comes under ViDA from July 2030.

For foreign businesses

The mandate targets domestic transactions between Croatian taxpayers. If you supply Croatian customers from abroad, your invoices fall outside it — but your Croatian partners now expect structured documents, and for public procurement the e-invoicing obligation has applied since 2019 regardless of where you are based.

Formats and standards

The basis is the European standard EN 16931-1:2017, applied through a Croatian specification described as "basic use with extensions". In practice the working format for the domestic regime is UBL 2.1; the B2G channel additionally supports CII.

Domestic B2BUBL 2.1 with the Croatian CIUS and extensions

B2GEN 16931 in UBL 2.1 or CII, through the FINA service

Fiscalisation messageThe Tax Administration's own XML format, separate from the invoice

PDFNot an e-invoice — visualisation or attachment only

A national requirement that catches people out

Croatian e-invoices must carry product and service classification data — the KPD code at six-digit level. This is a national field that generic EN 16931 templates do not populate. If your ERP has no KPD mapping, invoices will fail validation, and retrofitting the classification across an article master is not a five-minute job.

Peppol identifiers use the scheme 9934 with the Croatian OIB — for example 9934:<OIB> when addressing a Croatian public buyer.

B2G and FINA

Public sector invoicing runs through Servis eRačun za državu, the central service operated by FINA. It predates Fiscalization 2.0 by several years and continues to operate alongside it.

—Public buyers have had to accept EN 16931 invoices since December 2018

—Suppliers have had to issue them since July 2019 — paper and non-compliant files are not accepted

—FINA operates a Peppol Access Point for cross-border public procurement, which is how foreign suppliers usually reach Croatian public buyers

—Croatian public bodies are addressed as 9934:OIB

For B2G, Peppol is the practical interoperability channel. For domestic B2B it is not: that regime is built on Croatian access points, the national addressing services and AS4 — which is why B2G experience does not automatically translate into B2B readiness.

Information intermediaries

This is where Croatia is stricter than most of its neighbours. Being a certified Peppol Access Point in another EU country is not sufficient to serve Croatian taxpayers under Fiscalization 2.0.

What the law requires of an intermediary

—A Croatian OIB identification number

—Submitted documentation, including security and GDPR measures

—A valid ISO/IEC 27001 certificate

—An undertaking to operate the information system from within the EU and not to transfer data outside it

—Successful conformance testing and a certificate of conformity from the Tax Administration

—Entry in the public register of information intermediaries

A foreign provider can serve the Croatian market — but as a Croatian-compliant intermediary, not simply as a Peppol AP. There is no requirement for a local company or a local representative in the published rules, but the OIB, the digital certificate tied to it and the EU-hosting undertaking are non-negotiable. A business running its own access point purely for itself, without acting for third parties, goes through conformance testing without the full intermediary documentation package.

MIKROeRAČUN

The Tax Administration provides a free application in which it acts as both access point and information intermediary. It is aimed squarely at the smallest businesses.

Receiving e-invoices since January 2026, issuing from January 2027

Fiscalisation of both received and issued e-invoices, plus storage for the statutory retention period

Available only to businesses not registered for VAT and not acting as public procurement buyers

For a small business with a handful of invoices a month this removes the cost argument entirely. For anyone in the VAT system it is not an option — which is worth stating plainly, because the eligibility limit is frequently missed.

Penalties

The fines under the Fiscalization Act are substantial by regional standards, and they are graded by how fundamental the breach is.

€3,980–66,360

Legal entities

For failing to issue, receive or fiscalise e-invoices at all.

€3,980–39,810

Sole traders

The equivalent range for independent activity.

€660–6,630

Responsible individuals

Personal liability for the officer responsible.

—Incorrect or late fiscalisation, software and hardware failures, repeat offences: up to €66,360 for a legal entity and €39,810 for a sole trader

—Lighter breaches — failure to store an e-invoice, late submission of identifiers, late reporting of supplies, rejections or payments: up to €26,540 and €13,270 respectively

Note what sits in the lightest bracket: failing to store an e-invoice, and late reporting of payments or rejections. These are the obligations businesses forget after go-live, because they are not part of sending the invoice.

Retention

Croatia requires eleven years, counted from the beginning of the year in which the invoice was issued. That is longer than almost anywhere else in the EU, where six or ten years is the norm — and it applies to sender and recipient alike.

E-invoices must be kept in their original XML format for the full period

Authenticity of origin, completeness of content and legibility must hold from issuance to the end of the retention period

Storage within the EU is permitted, provided Croatian authorities can access the data online on request

Eleven years of XML is a real infrastructure decision, not a checkbox. Settle early whether retention sits with your intermediary, your own DMS or a specialist archiving service — and confirm that the contract actually covers the full period rather than the length of the subscription.

How we help

As a certified Peppol Access Point we cover the European side of Croatian invoicing and support the transition to the national regime:

Sending and receiving through a certified Peppol Access Point

B2G submission to Croatian public buyers over Peppol, addressed as 9934:OIB

UBL 2.1 and UN/CEFACT CII on the EN 16931 semantic model

Format conversion from ERP, CSV and IDoc data, including national fields such as KPD

Validation against EN 16931 before transmission

Integration via API, SFTP and CSV

Traceable status and error feedback

Frequently asked questions

Can I still send PDF invoices?

Not for domestic transactions in scope. A PDF by email is not an eRačun — the invoice must be structured and exchanged through an access point. A PDF may accompany it as a visualisation or attachment, but it does not satisfy the obligation and it cannot be fiscalised.

We are a certified Peppol Access Point in another EU country. Can we serve Croatian clients?

For B2G over Peppol, yes. For domestic B2B under Fiscalization 2.0, not on that basis alone: you must become a registered information intermediary — Croatian OIB, submitted documentation, ISO/IEC 27001, an EU-hosting undertaking, conformance testing and entry in the public register. Foreign providers are welcome, but on Croatian terms.

Is this a clearance model like Italy's?

No. The Tax Administration does not approve the invoice before delivery and puts no visible confirmation number on it. Invoices move directly between access points, and a separate fiscalisation message goes to the tax authority in parallel. The accurate description is decentralised exchange with a central reporting layer.

Are businesses outside the VAT system exempt in 2026?

Only from issuing. They must still be able to receive and fiscalise e-invoices from January 2026; the issuing obligation follows on 1 January 2027. The free MIKROeRAČUN application from the Tax Administration is designed for exactly this group — it is available only to businesses not registered for VAT and not acting as public procurement buyers.

What is the KPD code and do we need it?

It is the Croatian classification of products and services, required in the invoice data at six-digit level. Standard EN 16931 templates do not carry it, so it has to be mapped from your article master. This is one of the few genuinely national requirements in the Croatian format and a common cause of validation failures.

Does an eRačun affect the right to deduct input VAT?

An eRačun under the Fiscalization Act is a credible accounting document. If the recipient reports a rejection, that is treated as a declaration that no input VAT will be deducted on it. The right to deduct still rests on VAT law generally — but using a PDF where an eRačun was mandatory is not a compliant invoice form and creates both a penalty risk and an argument about the deduction.

How long must invoices be kept?

Eleven years from the beginning of the year of issue, in the original XML format, by both sender and recipient. Storage anywhere in the EU is allowed provided Croatian authorities can access the data online on request. Failing to store an e-invoice is itself a punishable breach.

Summary

Croatia moved from a public-sector-only regime to a full domestic B2B mandate in a single step on 1 January 2026. The model is a sensible one — decentralised exchange over access points, the European standard as the basis, a separate reporting layer to the Tax Administration — and it avoids the bottleneck of a central clearing platform.

What makes Croatia demanding is not the architecture but the detail: a national classification field that generic templates do not fill, an eleven-year retention obligation, obligations to report rejections and payments after the invoice has gone, and an intermediary regime that a foreign Peppol Access Point does not satisfy by default.

If you already invoice Croatian public bodies over Peppol, you have the transport experience but not the domestic compliance. The gaps to close are the KPD mapping, the fiscalisation messages and the choice of a registered information intermediary.

Resources

Tax Administration – Guide to Fiscalization 2.0 The official walkthrough of the new regime (in Croatian) Issuing, receiving and fiscalising eRačun The obligations set out by the Tax Administration, with technical documentation MIKROeRAČUN – the free Tax Administration application Eligibility, functions and timetable for the smallest taxpayers Fiscalisation of eRačun – technical documentation Schemas, AS4 profile, identifier lists and the validator European Commission – eInvoicing in Croatia Country factsheet covering the legal position and operating model OpenPeppol Network, specifications and certified access points

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