E-Invoicing and Fiscalization 2.0: What Companies Must Do in 2026

From 1 January 2026, Croatia requires e-invoices for B2B transactions, and Bosnia and Herzegovina is heading in the same direction with the new Law on Fiscalization of Transactions in FBiH. A paper invoice or a PDF sent by email no longer meets the legal requirements in B2B business. For companies this means concrete obligations: software that supports e-invoicing, a contract with an information intermediary, clean master data and new internal processes. In this guide we walk through what exactly is changing, who is affected and by which deadlines, how high the penalties are and how to prepare step by step.

What is changing: Fiscalization 2.0 in Croatia

The new Fiscalization Act (Official Gazette NN 89/25) entered into force on 1 September 2025, and its key obligations apply from 1 January 2026. The project known as Fiscalization 2.0 brings four major changes:

• Mandatory e-invoicing in B2B transactions. All VAT payers must issue and receive e-invoices for domestic B2B transactions in a structured electronic format (XML compliant with the European standard EN 16931). A PDF, scanned or paper invoice is not considered an e-invoice.
• Fiscalization of e-invoices. Data on every issued e-invoice is reported to the Tax Administration in real time. The recipient is required to fiscalize a received e-invoice within 5 working days of receipt.
• eReporting. A new obligation to report data on rejected e-invoices and on the collection of issued e-invoices, giving the Tax Administration a complete picture of B2B cash flows.
• Extended B2C fiscalization. From 1 January 2026, all invoices issued to end consumers are fiscalized regardless of the payment method, including invoices paid to a bank account, not just cash and card payments.

Another novelty is the obligation to label invoice line items with KPD codes (Classification of Products by Activity). Every line item on an e-invoice must be linked to the corresponding KPD code, which means the product and service catalogue in your software must be mapped in advance.

Bosnia and Herzegovina is heading the same way

In the Federation of BiH, the new Law on Fiscalization of Transactions was published in the Official Gazette of FBiH No. 9/26 and entered into force on 12 February 2026. Full application begins after the adoption of secondary legislation, and no later than 18 months after entry into force. The law introduces ESET (an electronic system for recording transactions) that replaces the classic fiscal cash register, a central fiscalization platform (CPF) through which every invoice passes, and e-invoices in a structured format. A period of three years from the start of application is foreseen for aligning B2B operations. Republika Srpska completed its electronic fiscalization back in 2022 and 2023. Companies operating in both markets need a solution that supports both the Croatian e-invoice and the fiscalization models in BiH from day one.

Deadlines and who must comply

The most important dates for both markets, in chronological order:

In short: if you are a VAT payer in Croatia, the obligation already applies to you. If you are not in the VAT system, you must already be able to receive e-invoices, and from 1 January 2027 you must issue them as well. In FBiH, 2026 is the year for preparation and software selection before full application begins.

What your company specifically needs to do

1. Software that supports e-invoicing and fiscalization

Excel templates, Word invoices and older programs that only generate PDFs are no longer enough. You need a system that creates e-invoices in the prescribed XML format, automatically fiscalizes them with the Tax Administration, receives incoming e-invoices and keeps a record of their status (received, rejected, paid). For the smallest businesses the Tax Administration offers free applications (MIKROeRACUN and FiskAplikacija), but they cover only basic invoicing. Companies with a larger volume of invoices, a warehouse, multiple users or operations in both countries need an ERP system where e-invoicing, fiscalization and accounting are connected in a single flow.

2. Information intermediary and certificates

E-invoices are exchanged through information intermediaries, services that guarantee delivery of the invoice to the recipient and communication with the Tax Administration. Every obligor must have a contract with an intermediary (for example FINA or one of the commercial intermediaries) or use software that covers this role in an integrated way. A valid FINA application certificate is still required for fiscalization, and you should also check the expiry dates of your existing certificates, because an expired certificate means a halt in invoicing.

3. Clean data and internal processes

Technology is only half the job. Before the transition you should verify the master data of customers and suppliers (OIB or ID/VAT number, correct addresses), map products and services to KPD codes, define who in the company approves incoming e-invoices and within what deadline, and align the process with your accounting, whether in-house or an external firm. The 5 working day deadline for fiscalizing a received invoice means incoming invoices must not sit in someone's email inbox.

Penalties: the cost of being unprepared

The new Croatian Fiscalization Act prescribes penalty provisions graded by the severity of the offence. For legal entities, depending on the offence (failure to issue an e-invoice, failure to fiscalize, failure to link line items to KPD codes, failure to report payment data), fines range from EUR 1,320 to EUR 26,540. The responsible person within a legal entity can be fined between EUR 260 and EUR 2,650, while sole traders and self-employed persons face fines from EUR 660 to EUR 13,270. In FBiH the new law also provides for penalty provisions and considerably stricter controls through the central platform, since the Tax Administration sees every transaction in real time. Beyond direct fines, being unprepared also has an operational cost: customers who are obligors can reject an invoice that was not sent as an e-invoice, which means delayed payment.

How to prepare step by step

1. Determine your obligor status. Are you in the VAT system, do you issue B2B and/or B2C invoices, do you operate in Croatia, BiH or both countries. This determines which deadlines apply to you.
2. Check your existing software. Ask your vendor whether it supports issuing and receiving e-invoices, fiscalization under the new law and KPD codes. If the answer is vague, it is time for a replacement.
3. Contract an information intermediary or choose a solution with e-invoice exchange built in, so a separate contract and integration are not an additional project.
4. Clean up your master data. Partner OIBs and identification numbers, addresses, a product catalogue with KPD codes, price lists and tax rates.
5. Define a process for incoming e-invoices. Who receives them, who approves them, within what deadline, and how the invoice ends up in the books. The 5 working day deadline must be built into the process, not left to goodwill.
6. Test before going live. Send test e-invoices to your largest customers and suppliers, and check fiscalization statuses and the validity of the XML.
7. Train your people. A short internal guide for sales, procurement and accounting saves months of improvisation.

Frequently asked questions

Is a PDF invoice sent by email an e-invoice?

No. An e-invoice is exclusively a structured electronic record (XML compliant with the EN 16931 standard) that is exchanged through an information intermediary and can be processed automatically. From 1 January 2026, a PDF, scanned or paper invoice does not fulfil the obligation for B2B transactions between VAT payers in Croatia.

As a flat-rate trade in Croatia, do I already have to issue e-invoices?

If you are not in the VAT system, your obligation to issue e-invoices starts on 1 January 2027. However, from 1 January 2026 you must already be able to receive e-invoices from your suppliers, so you need access to the e-invoicing network now, even if only through the Tax Administration's free application.

What penalties do I face if I do not comply?

In Croatia, fines for legal entities range from EUR 1,320 to EUR 26,540 depending on the offence, for responsible persons from EUR 260 to EUR 2,650, and for sole traders and self-employed persons from EUR 660 to EUR 13,270. On top of the fines, invoices not issued as e-invoices can be rejected, which directly slows down payment collection.

Does the e-invoicing obligation also apply in Bosnia and Herzegovina?

The Federation of BiH adopted the Law on Fiscalization of Transactions, which entered into force on 12 February 2026, with full application no later than 18 months after that. It introduces e-invoices, ESET software solutions instead of classic fiscal cash registers and a central Tax Administration platform. Republika Srpska has been applying electronic fiscalization for some time already. So the obligation is coming to BiH as well, and 2026 is the year to choose software and prepare.

Does Gideon Secure ERP support e-invoicing and fiscalization?

Yes. Gideon Secure ERP issues and receives e-invoices, automatically fiscalizes invoices in line with the applicable regulations in Croatia and BiH, and links invoices with accounting in the same system. Details are on the ERP for business page.