W System / Blog / Croatia e-invoicing (Fiscalisation 2.0) for software builders

Croatia e-invoicing (Fiscalisation 2.0): what invoicing software must ship for 2026–2027

By Zifeng Wei, W System · Published 27 October 2026 · All articles

In short: Croatia's Fiscalisation 2.0 / eRačun rules are already in force for VAT-registered businesses. Since 1 January 2026 they must issue and receive structured e-invoices for in-scope domestic B2B and fiscalise both sides to the Tax Administration. Non-VAT taxpayers receive (and fiscalise receipts) in 2026 and must issue from 1 January 2027. A PDF by e-mail is not an eRačun. Format: EN 16931 with the Croatian CIUS (UBL), through an access point or listed information intermediary. This page is for invoicing and ERP builders: timeline, scope, format, a checklist and a live route example. Not tax advice.

Timeline

Date	What changes
1 January 2026	VAT-registered businesses established in Croatia must issue and receive structured e-invoices (eRačun) for in-scope domestic B2B, and fiscalise them (Fiscalisation 2.0). Non-VAT taxpayers who are issuers/recipients under the Act must receive and fiscalise receipts; they are not yet obliged to issue.
1 January 2027	Non-VAT taxpayers who are issuers under the Act must also issue e-invoices and fiscalise them. The free Tax Administration app MIKROeRAČUN remains available for non-VAT obligors who only receive in 2026.
Ongoing	Both the issuer's and the recipient's access point (pristupna točka) send a fiscalisation message to the Tax Administration; PDF by e-mail is not an eRačun.

Source: Tax Administration FAQ Izdavatelji i primatelji eRačuna te obveza izdavanja eRačuna, updated 17 April 2026 (questions 6 and 9), and the Tax Administration guide Vodič kroz Fiskalizaciju 2.0 (published 9 December 2025).

Who is in scope

Issuers and recipients under the Act are Croatian-established VAT payers, certain non-VAT income/corporate taxpayers, and listed public bodies. A foreign company with only a Croatian VAT number and no seat, residence or habitual residence in Croatia is not an issuer/recipient (FAQ Q2). Every B2C fiscalisation obligor is not automatically an eRačun party, and the reverse (FAQ Q1). Domestic B2B between in-scope parties is covered; cross-border supplies that are not domestic Croatian VAT transactions are not (FAQ Q12–Q14).

Format, access point and fiscalisation

An eRačun is a structured electronic invoice (EU EN 16931 basic model with the Croatian CIUS, in practice UBL). Each party needs an access point (pristupna točka): own software or a market intermediary published on the Tax Administration list. The issuer's access point extracts the required data set and sends a fiscalisation message; the recipient's access point does the same for receipt. PDF and e-mail are explicitly not eRačun (FAQ Q7–Q10). Non-VAT obligors who only receive in 2026 may use the free MIKROeRAČUN app in ePorezna.

Checklist for invoicing and ERP builders

Emit EN 16931 UBL that matches the Croatian CIUS; validate before send.
Integrate an access point / information intermediary (or document a MIKROeRAČUN hand-off for the smallest non-VAT users in 2026).
Fiscalise issue and receipt with the required data set (dates, parties, quantities, KPD classification, tax bases, rates, bank account, etc. — FAQ Q11).
Support credit notes and other amending documents as eRačun when they change an original invoice (FAQ Q18–Q19).
Store the buyer's OIB / Peppol or AMS receiving address and look it up before the first send.
Do not treat PDF-by-email as compliant for in-scope domestic B2B.
Plan the 1 January 2027 cut-over for non-VAT issuers among your users.

Example: route a Croatian company

Disclosure: W System, which publishes this page, makes the e-invoice API used below. GET https://api.wsystem.dev/einvoice/route?id=HR28921978587 checks the VAT number (OIB) in VIES, looks for the company on Peppol under scheme 9934, and returns the dated Croatian mandate row. The example is HEP d.d. (OIB published on hep.hr). W System is not a Croatian access point and does not fiscalise. Not tax advice.

curl "https://api.wsystem.dev/einvoice/route?id=HR28921978587"

Real response from the live API on 27 October 2026 (shortened):

{
 "query": "HR28921978587",
 "vat": {
  "vat": "HR28921978587",
  "status": "valid",
  "valid": true,
  "name": "HEP d.d.",
  "address": "ULICA GRADA VUKOVARA 37, ZAGREB, 10000 Zagreb"
 },
 "peppol": {
  "registered": false,
  "ids_checked": [
   "iso6523-actorid-upis::9934:hr28921978587"
  ],
  "note": "Checked in the public Peppol Directory (business cards) and, if not found there, in the Peppol SML/SMP (the DNS + SMP lookup Access Points use before sending). 'false' means none of the ids in ids_checked is registered on Peppol; the company may still use another identifier, so ask for its Peppol participant id."
 },
 "mandate": {
  "b2b_mandatory": true,
  "since": "2026-01-01",
  "scope": "Domestic B2B for VAT-registered businesses (Fiscalisation 2.0); non-VAT taxpayers issue from 2027-01-01.",
  "format": "EN 16931 (HR CIUS, UBL)",
  "channel": "Fiscalisation 2.0 / information intermediaries",
  "source": "https://www.porezna-uprava.hr/",
  "country": "HR",
  "as_of": "2026-10-26"
 },
 "recommendation": {
  "format": "en16931",
  "channel": "Fiscalisation 2.0 / information intermediaries",
  "create_with": "POST /einvoice/create {\"format\":\"en16931\"}",
  "why": "EN 16931 UBL is the EU standard; check with the buyer which channel they accept."
 }
}

To check invoices you produce, post them to /einvoice/validate or drop a file into the free e-invoice validator; /einvoice/create builds EN 16931 UBL from JSON. Free for 20 calls a day per IP; details on the e-invoice API page.

Questions and answers

Who must issue and receive eRačun in Croatia?

Under the Fiscalisation Act, issuers and recipients are: (1) a tax payer established, resident or habitually resident in Croatia and registered for VAT; (2) income-from-self-employment or corporate-income taxpayers not in the VAT register who are established/resident there; (3) state bodies, local self-government and budget users listed in the relevant register. Foreign companies with only a Croatian VAT number and no establishment are not issuers/recipients under the Act (Tax Administration FAQ Q2, updated 17 April 2026).

When do non-VAT businesses have to issue?

In 2026 they must receive and fiscalise incoming e-invoices when the issuer is in scope, but they may still issue paper or other invoices. From 1 January 2027 they must also issue e-invoices and fiscalise them toward recipients under the Act (FAQ Q6, Q9).

Is a PDF by e-mail an e-invoice?

No. An eRačun is issued, sent and received in a structured electronic form that allows automatic processing. PDF and e-mail are not eRačun and are not a permitted exchange channel (FAQ Q7, Q8).

What format and channel?

The technical basis is the EU EN 16931 model with the Croatian CIUS (UBL), exchanged through an access point (own software or an information intermediary on the Tax Administration list). Both sides fiscalise. Non-VAT obligors who only receive in 2026 may use the free MIKROeRAČUN app inside ePorezna.

Does the mandate cover cross-border supplies?

The Act applies when both parties are issuers/recipients under the Act and the supply is a domestic transaction taxed under Croatian VAT rules. Intra-EU or third-country supplies are outside that domestic eRačun duty (FAQ Q12–Q14).

Can W System be my Croatian access point?

No. W System validates and builds EN 16931 invoices and looks up Peppol routing; it is not a Croatian information intermediary and does not fiscalise to the Tax Administration. Use a listed intermediary or MIKROeRAČUN for the access-point role.

Sources

Checked against the Tax Administration FAQ (updated 17 April 2026), the Vodič kroz Fiskalizaciju 2.0 and the MIKROeRAČUN pages on 27 October 2026. Not tax advice.

Facts checked 2026-10-27. W System is the maker of this product. Not affiliated with the European Commission. Not legal or tax advice.