Regulatory updates - Croatia

As part of Pagero and Thomson Reuters’ commitment to customers, we have a solution ready to support this upcoming decentralized CTC model, where both issuers and recipients of e-invoices will be required to report these transactions to the Fiscalization System.

As a reminder, buyers must also report rejections of e-invoices to the Fiscalization System, while sellers are required to report payments to the same system. The upcoming e-invoicing and reporting mandate must be complied with by taxpayers established in Croatia.

Timelines

• January 1, 2026: VAT registered entities must issue and receive e-invoices, plus report issued and received e-invoices
• January 1, 2026: Non-VAT registered entities must receive e-invoices plus report received e-invoices
• January 1, 2027: Non-VAT registered entities must issue e-invoices plus report issued e-invoices

Taxpayers must prepare for the upcoming changes affecting not only B2B transactions but also B2G and B2C transactions, all of which are within the scope of the newly approved law. 

B2B & B2G transactions 

One of the most significant developments in the new law is that both B2B and B2G transactions – whether the taxpayer is the issuer or the recipient – will now fall within the scope of mandatory reporting to the Croatian fiscalization system, i.e., using a decentralized CTC exchange model. Furthermore, only e-invoices will be permitted for these transactions. 

Transactions with Croatian public entities (B2G) are already being conducted through e-invoices. However, under the new law, taxpayers will soon be required to start reporting these transactions to the fiscalization system. 

Lastly, issuers of e-invoices will be required to report such payments through a dedicated service called “e-Reporting.” This service will also allow buyers to reject received e-invoices. 

B2C transactions  

Since 2013, businesses have been required to report transactions to the fiscalization system when cash, credit card, or check payments are made. However, under the new law, online payments, such as bank transfers, Google Pay, PayPal, and similar methods, will also fall within the scope of mandatory reporting, all through the same pre-clearance model as before. 

Timelines 

• September 1, 2025 – it will be possible to start testing the e-invoicing environment for B2B & B2G transactions;  

• January 1, 2026 – online payments for B2C transactions will now be in the scope of reporting to the fiscalization system. This means that all B2C transactions will be in the scope of reporting, regardless of the payment method;  

• January 1, 2026 – All VAT taxpayers must issue and receive e-invoices for B2B & B2G transactions. Issuers and recipients must report such transactions to the fiscalization system;  

• January 1, 2026 – Businesses not registered in the VAT system – including income and profit taxpayers, as well as budgetary and non-budgetary users – must have capabilities to receive e-invoices and report them; 

• January 1, 2027 – Businesses not registered in the VAT system – including income and profit taxpayers, as well as budgetary and non-budgetary users – must issue only e-invoices and report them. 

According to the draft law, issuers and recipients of e-invoices will be required to report, in real-time, invoice data (Croatia’s fiscalization procedure) to the tax administration’s system (fiscalization system).

The fiscalization system checks that all mandatory elements of the reporting have been submitted and whether they have been signed with a valid digital certificate, a practice to be performed for all transaction types (B2B, B2G, and B2C).

The draft also specifies which taxpayers are exempt from reporting data to the fiscalization system in Article 4. 

E-invoice exchange

The draft mentions that the e-invoice exchange can be performed via service providers or other technologies such as the Peppol Network, EDI, or API solutions, among many different options.

Timelines

The draft proposes the following dates:

• From September 1, 2025, taxpayers can start testing systems for e-invoice exchange and reporting;
• From January 1, 2026
  • VAT-registered businesses (B2B) must begin issuing e-invoices exclusively. Issued and received e-invoices must be reported.
  • Taxpayers issuing invoices on final consumption (B2C) must report each transaction.
• From January 1, 2027, taxpayers outside the VAT system (not registered in the VAT register), such as taxpayers under income or profit tax, as well as budgetary and extra-budgetary users, must start issuing only e-invoices and reporting them.

The public consultation will be open for public feedback until March 28, 2025.