Croatian Fiscalization FAQ: Everything You Need to Know
Who must fiscalize in Croatia, what a fiscalized invoice must show, what to do when the connection drops and what the fines are under the Fiscalization Act (NN 89/25) and the rules in force since 2026.
Since 1 September 2025, fiscalization in Croatia has been governed by the new Fiscalization Act (Zakon o fiskalizaciji, NN 89/25). It replaced the Act on Fiscalization in Cash Transactions (Zakon o fiskalizaciji u prometu gotovinom), and from 1 January 2026 it brought two big changes: every invoice issued to a private customer is fiscalized, however the customer pays, and invoices between businesses are moving to eRačun (e-invoices). This FAQ answers the questions tradespeople and service companies ask most, and each answer names the article of the Act or of the Rulebook it comes from.
Key Takeaways
- The Fiscalization Act (NN 89/25) is in force. The Act on Fiscalization in Cash Transactions ceased to apply on 1 September 2025 (Article 79).
- Since 1 January 2026, every invoice to a private customer is fiscalized, whether it is paid in cash, by card, by bank transfer or otherwise (Article 3).
- The invoice must show the time of issue, the operator mark, the payment method, the JIR, the ZKI and a QR code (Article 7). The QR code is mandatory.
- If the Tax Administration cannot be reached, the invoice is issued without a JIR, and its data must be delivered within two working days (Article 21).
- Fines are in euros: up to €66,360 for a company and up to €39,810 for a sole trader, and more for a repeated offence (Articles 71 to 73).
- Since 1 January 2026, every obligor must receive eRačuni, in or out of the VAT system (Article 41), and issues them from 2026 if in VAT, otherwise from 2027 (Article 38).
What Is Fiscalization, and Which Rules Apply?
Fiscalization of invoices to consumers (fiskalizacija računa u krajnjoj potrošnji) is the process of delivering an invoice's data to the Tax Administration's fiscalization system (Article 2(1), point 12). When you issue the invoice, your software signs its data with your certificate and sends it to the Tax Administration (Porezna uprava), which returns the Unique Invoice Identifier (JIR). The JIR is then printed on the invoice (Article 15).
The rules in force today are:
- The Fiscalization Act (Zakon o fiskalizaciji, NN 89/25), in force since 1 September 2025. Its second part (Articles 3 to 32) covers invoices to private customers, and its third part covers eRačun between businesses.
- The Rulebook on fiscalization of invoices to consumers (Pravilnik o fiskalizaciji računa u krajnjoj potrošnji, NN 153/25), in force since 1 January 2026, with the technical rules for certificates, the JIR, the ZKI, the QR code and the bound invoice book.
The old Act on Fiscalization in Cash Transactions and its rulebook no longer apply. Neither do the fines in kuna that can still be found online.
Basic Terms
- JIR (Jedinstveni identifikator računa): a 32-character code the Tax Administration returns to confirm it has received the invoice data (Rulebook, Articles 6 and 7).
- ZKI (Zaštitni kod izdavatelja): a code your software calculates for each invoice, which confirms the link between you and the invoice you issued (Article 2(1), point 35).
- Sales to consumers (promet u krajnjoj potrošnji): invoices issued to citizens or consumers, however they pay (Article 2(1), point 26).
- Who is obliged to fiscalize (obveznik fiskalizacije računa): everyone who pays income tax on self-employment or profit tax (Article 2(1), point 21).
Who Must Fiscalize?
Everyone who pays income tax on self-employment or profit tax and issues invoices to private customers (Article 2(1), points 21 and 26). In practice that means sole traders (obrti), flat-rate ones (paušalisti) included, freelance professions that deal with the public, and companies such as d.o.o. and j.d.o.o.
The obligation used to depend on whether you took cash or cards. Now it depends on whom you invoice. If you are a plumber, an electrician or a service technician and you issue an invoice to a household that pays it by internet banking, that invoice has had to be fiscalized since 1 January 2026 (Articles 3 and 80).
Which Payment Methods Are Fiscalized?
All of them. Article 3 names cash, cards, bank transfers and other methods. The invoice shows one of four payment methods: banknotes, card, bank transfer or other (Article 7(1), point 3).
If the payment method or the buyer's OIB has to change on an invoice that already has a JIR, you issue an invoice that corrects that detail straight away (Rulebook, Article 11).
Are Invoices to Companies Fiscalized?
Invoices to other businesses in Croatia do not go through fiscalization of invoices to consumers. They are issued as eRačun (e-invoices), which are fiscalized too (the Act's third part):
- businesses in the VAT system have issued eRačuni since 1 January 2026,
- businesses outside the VAT system issue them from 1 January 2027 (Articles 38 and 80).
Invoices to the public sector have had to be eRačuni since 1 July 2019 (Act on Electronic Invoicing in Public Procurement, NN 94/18, Article 7).
The exception is a transaction a business customer pays in cash or by card. It may be exempt from eRačun if you issue a fiscalized invoice for it, and then you also send the buyer's OIB to the Tax Administration (Article 39(1) and Article 15(6)). You cannot then issue an eRačun for the same transaction as well (Article 39(2)).
Receiving. Since 1 January 2026 you must be able to receive eRačuni whether or not you are in the VAT system: everyone who pays income tax on self-employment or profit tax is a recipient of eRačuni (Article 2(1), point 24, and Article 41). You fiscalize every eRačun you receive within five working days of receipt (Article 47 and Article 48(4)). You can do this through an information intermediary or, if you are outside the VAT system, through the Tax Administration's free MIKROeRAČUN application (Articles 55 and 56).
Monthly reports (eIzvještavanje). By the 20th of each month, the issuer of an eRačun reports which eRačuni were paid in the previous month (Article 53), and the recipient reports which ones it rejected (Article 52).
Who Is Exempt?
The exemptions are a closed list of 13 activities in Article 4. They include:
- games of chance, lotteries and betting,
- a family farm (OPG) selling its own produce at the farm, at markets and at stalls,
- public transport tickets and road tolls,
- postal services, banking, insurance and currency exchange,
- consumption measured by meters (electricity, gas, water, public communication services),
- patient co-payments at a chosen primary care doctor, and prescription medicines,
- sales of goods on board aircraft.
If you carry out several activities, only the listed one is exempt (Article 5). Being paid only by bank transfer is not an exemption. Sales through self-service devices are fiscalized too, each sale at the moment of sale (Article 18).
What Must a Fiscalized Invoice Show?
On top of the details an invoice needs under the invoicing rules, such as the VAT Act, a fiscalized invoice must show (Article 7(1)):
- the time of issue (hour and minute),
- the operator mark, that is, the person who issued the invoice,
- the payment method: banknotes, card, bank transfer or other,
- the JIR,
- the ZKI,
- a QR code.
All of these must be correct and complete (Article 7(2)).
Invoice Number
The invoice number has three parts: the sequential number, the business premises mark and the number of the issuing device, for example 15/PP1/1 (Article 9(1)). The sequential number runs without gaps per business premises or per device, and each calendar year it may start from any number (Article 9(2) and (4)). You set the numbering rules, the list of business premises and how devices are numbered in an internal act (Article 9(3)).
Operator Mark
The operator mark is printed on the invoice, and your internal act links it to that person's OIB. You send the operator's OIB to the Tax Administration with the invoice (Article 8(1) to (3)). For activities of natural persons, such as a sole trader, you may send the obligor's own OIB instead of the operator's (Article 8(4)).
QR Code
The QR code is mandatory on every fiscalized invoice. It holds at least the address of the Tax Administration's invoice check page, the JIR or the ZKI, the date and time of issue and the total (Rulebook, Article 17). It must be at least 2 x 2 cm and must not be printed over a picture or a logo (Rulebook, Article 18). The customer can check the invoice within 30 days of its issue (Article 28).
Example Invoice
The labels below are as they appear on a Croatian invoice.
OBRT ZA VODOINSTALATERSKE RADOVE PRIMJER, vl. Ivan Horvat
Ulica Primjer 1, 10000 Zagreb
OIB: [the business's OIB]
RAČUN br. 15/PP1/1
Datum i vrijeme izdavanja: 14.10.2026. 10:30
Operater: IH
Kupac: Marko Marić, Ulica Klijenta 5, 10000 Zagreb
Opis Količina Cijena Iznos
Popravak slavine 1 40,00 EUR 40,00 EUR
Zamjena sifona 1 15,00 EUR 15,00 EUR
Osnovica (PDV 25 %): 55,00 EUR
PDV 25 %: 13,75 EUR
Ukupno: 68,75 EUR
Način plaćanja: transakcijski račun
ZKI: [32 characters calculated by the software]
JIR: [identifier returned by the Tax Administration]
[QR code, at least 2 x 2 cm]
What Do I Need Before My First Fiscalized Invoice?
- A certificate. Get a production application certificate carrying the obligor's OIB from a trust service provider in Croatia, such as FINA (Article 10; Rulebook, Article 2).
- Business premises. Report every business premises where you issue invoices in the ePorezna system before the first invoice (Article 16(1), (7) and (9)). Premises are reported only through ePorezna. For field work you decide yourself whether you need a separate mobile business premises (Article 2(1), point 27).
- Software details. In the same way, submit the OIB of the producer or maintainer of the software you issue invoices with (Article 17).
- An internal act. It sets the numbering rules, the list of business premises, the device numbers and the link between operator marks and their OIBs (Article 8(2) and Article 9(3)).
- A notice for customers. In closed business premises, display a notice about the obligation to issue an invoice and the customer's obligation to take and keep it (Article 25).
If you already fiscalized under the old Act, you do not need to report your business premises again or adopt a new internal act unless the details have changed, and you may keep your existing customer notice (Article 75).
The software you issue invoices with must not allow the lines of an issued invoice to be changed, and you and the software's producer or maintainer are responsible for it working correctly (Article 14(2) and (3)).
What If the Internet Drops or the Tax Administration Does Not Answer?
- You issue the invoice without a JIR, with all the other details from Article 7. Issuing the invoice to the customer must not stop because of a sending error (Article 21(1); Rulebook, Article 9).
- You deliver the data of every such invoice within two working days, counted from the day the connection broke. If you do so in time, the invoice counts as properly fiscalized (Article 21(2) and (3)). The 48-hour deadline found in older texts no longer applies.
- If the issuing device stops working entirely, you issue invoices from a bound invoice book, which you have certified through ePorezna before first use. You must get the device working again within five working days and then deliver all the invoices, writing the JIR you receive onto the copies (Article 22).
- If you work in an area with no connection, you issue invoices from a bound invoice book and prove the lack of connection with a certificate from HAKOM, the Croatian regulator for network industries, valid for one year (Article 23).
Cancellations (Storno) and Refunds
A cancellation (storno) invoice and an invoice for returned goods or services follow the same rules as any other invoice: it is fiscalized and carries every required detail (Article 24(1)). When you refund money to the customer, the invoice may be fiscalized with negative amounts (Article 24(2)).
Quotes and Pro Forma Invoices: "OVO NIJE FISKALIZIRANI RAČUN"
If you issue any document with payment details before the invoice, such as a pro forma invoice (predračun), it must say "OVO NIJE FISKALIZIRANI RAČUN" ("this is not a fiscalized invoice", Article 29). Leaving it out is among the most heavily fined offences: €3,980 to €66,360 for a company (Article 71(1), point 2).
Cash Between Businesses and the Cash-Holding Limit
- You may pay another obligor in cash up to €700 per invoice (Article 30(3)).
- Cash above your cash-holding limit goes to the bank the same day, or the next working day at the latest (Article 30(6)).
- You set the cash-holding limit (blagajnički maksimum) in your internal act, at most €2,000 for micro entities and natural persons, €7,000 for small, €12,000 for medium-sized and €15,000 for larger entities (Rulebook, Article 47).
What Are the Fines?
The Tax Administration and the Customs Administration supervise fiscalization (Article 65). Fines are set in euros:
- Most serious offences (Article 71), for example a document with payment details without "OVO NIJE FISKALIZIRANI RAČUN", or an eRačun you did not issue, receive or fiscalize (Article 71(1), points 2 and 3): a company €3,980 to €66,360, its responsible person €660 to €6,630, a sole trader or other self-employed person €3,980 to €39,810.
- Serious offences (Article 72), for example an invoice that is not fiscalized, lacks the required details or the JIR, no certificate, or cash not deposited in the bank: a company €2,650 to €66,360, its responsible person €390 to €6,630, a sole trader €1,320 to €39,810. For a repeated offence: a company €3,500 to €80,000, its responsible person €500 to €8,000, a sole trader €2,000 to €45,000.
- Lesser offences (Article 73), for example the operator's OIB not sent, wrong numbering, unreported business premises, late delivery after an outage, a storno issued against the rules, or no customer notice: a company €1,320 to €26,540, its responsible person €260 to €2,650, a sole trader €660 to €13,270 (for the offences listed in Article 73(3)). For a repeated offence: a company €2,500 to €35,000, its responsible person €500 to €4,000, a sole trader €1,000 to €20,000. A company and its responsible person are also fined under Article 73 for a missing or late report of rejected or paid eRačuni (Article 73(1), points 23 and 24).
- A customer who does not keep the invoice or show it on request pays €30 to €260 (Article 73(5)).
If an inspection finds that you do not fiscalize invoices, the Tax Administration can temporarily ban the activity by sealing the premises, for up to eight days (Article 66).
How It Works in Operitivo
- When you issue an invoice to a private customer, Operitivo signs its data with your certificate, sends it to the Tax Administration and stores the JIR and the ZKI.
- It sends the Tax Administration the OIB of the user who issued the invoice, so every user who issues invoices needs their own OIB entered.
- The invoice PDF shows the JIR, the ZKI, the QR code, the time of issue and the payment method.
- Draft invoices and quotes carry "OVO NIJE FISKALIZIRANI RAČUN".
Quick Questions
Must I fiscalize an invoice a private customer pays by bank transfer?
Yes, since 1 January 2026 (Articles 3 and 80).
I am a flat-rate sole trader (paušalist). Does this apply to me?
Yes. A paušalist pays income tax on self-employment, so they are obliged to fiscalize invoices (Article 2(1), point 21). Since 1 January 2026 you must also be able to receive eRačuni and fiscalize the ones you receive, for example with the free MIKROeRAČUN application (Articles 41, 47 and 55). If you are not in the VAT system, you must issue eRačuni to companies from 1 January 2027 (Articles 38 and 80).
Must I report my business premises again and adopt a new internal act?
No, unless the details have changed (Article 75(1) and (2)).
Can I issue an invoice without a JIR?
Yes, and then you must, in three cases: when the connection is down or the Tax Administration returns an error, delivering the data within two working days (Article 21; Rulebook, Articles 9 and 10); from a certified bound invoice book when the device stops working entirely, getting it working again and delivering the invoices within five working days (Article 22); and from a bound invoice book in an area with no possible connection, with a HAKOM certificate (Article 23).
How does a customer check an invoice?
By scanning the QR code or entering the invoice details on the Tax Administration's website, within 30 days of issue (Article 28; Rulebook, Article 45).
Sources
- Fiscalization Act (Zakon o fiskalizaciji), NN 89/25
- Rulebook on fiscalization of invoices to consumers (Pravilnik o fiskalizaciji računa u krajnjoj potrošnji), NN 153/25
- Act on Electronic Invoicing in Public Procurement (Zakon o elektroničkom izdavanju računa u javnoj nabavi), NN 94/18
- Croatian Tax Administration (Porezna uprava)
This guide is not legal advice. For your own situation, check with your accountant or the Tax Administration.
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