Question 1

Is a standard PDF invoice sent by email considered a compliant electronic invoice in Bosnia and Herzegovina?

Accepted Answer

No. An unstructured PDF invoice delivered via email does not satisfy the legal definition of an electronic invoice under the new regulatory frameworks. Under the FBiH Law on Fiscalisation of Transactions (Law No. 9/26) and EU-aligned standards, an electronic invoice must be generated in a structured, machine-readable format (such as UBL 2.1 XML), digitally signed, and registered on the Central Fiscal Platform (CPF) or Electronic Fiscal System (EFS). Standard PDFs remain acceptable purely as human-readable visual copies accompanying the underlying structured XML file.

Question 2

How do tax authorities in Bosnia and Herzegovina manage the division of fiscal powers between the state and the entities?

Accepted Answer

The Indirect Taxation Authority of Bosnia and Herzegovina (UIO BiH) operates at the state level, exercising exclusive authority over Value Added Tax (VAT), customs tariffs, and excise duties. In contrast, the Federation of Bosnia and Herzegovina (FBiH), Republika Srpska (RS), and the Brčko District manage direct taxation (corporate and income taxes) and oversee transaction fiscalisation systems independently. Consequently, businesses must comply simultaneously with state-level VAT reporting (e-KUF and e-KIF) and entity-level transaction fiscalisation (CPF and EFS).

Question 3

What is the difference between an ESET system and a legacy fiscal cash register in the Federation of BiH?

Accepted Answer

A legacy fiscal cash register is an offline, closed physical hardware device fitted with mechanical thermal printers and physical fiscal memory chips. In contrast, an Electronic System for Evidencing Transactions (ESET) is a flexible, software-based solution. It can be hosted on a cloud server, installed on standard personal computers, or embedded in certified POS software. ESET signs invoices digitally and communicates transactions to the tax authority in real time over the internet without requiring specialised mechanical hardware registers.

Question 4

What is the role of an authorised intermediary (ovlašteni posrednik) under the FBiH fiscalisation law?

Accepted Answer

An authorised intermediary is an accredited commercial technology provider licensed by the Tax Administration of FBiH. The intermediary acts as a secure communications bridge for businesses, converting raw invoice data from internal billing engines into compliant XML formats, appending qualified electronic signatures, transmitting transaction feeds to the Central Fiscal Platform (CPF), and routing the cleared electronic invoice to the buyer's system.

Question 5

Are B2C consumer cash transactions subject to the new e-invoicing rules?

Accepted Answer

B2C retail transactions are governed by real-time fiscalisation rules rather than structured B2B electronic invoicing. Retail points of sale must issue digital fiscal receipts containing a system-generated cryptographic verification code and a two-dimensional QR code. Customers can scan the QR code with any smartphone to instantly confirm that the transaction was recorded in real time on the central tax administration server.

Question 6

What happens if a business experiences an internet outage during invoice issuance?

Accepted Answer

The legislation provides an offline fallback procedure. If internet connectivity is interrupted, the certified ESET or electronic fiscal device continues issuing invoices in an approved offline mode, embedding cryptographic security elements generated locally. The system securely queues these transaction records and must automatically transmit them to the central platform (CPF or CFS) within statutory deadlines (typically 48 hours) once connectivity is restored.

Question 7

Are foreign companies without a registered establishment in Bosnia and Herzegovina required to implement ESET software?

Accepted Answer

The application of the Federation's fiscalisation rules to foreign businesses depends on their activities, local business presence and any applicable tax representative arrangements. Article 6 expressly includes business units operating in the Federation whose head offices are located elsewhere, as well as tax representatives for non-residents. Foreign suppliers should therefore assess their local activities and registration status before concluding that ESET requirements do not apply. When foreign businesses export goods or cross-border services to Bosnian buyers, their standard commercial foreign invoices are processed through international customs and reverse-charge VAT mechanisms. The domestic buyer declares these transactions in their state-level e-KUF ledger. However, if a foreign enterprise registers for VAT in Bosnia and Herzegovina and carries out domestic supplies, it must comply fully with local fiscal rules.

Question 8

How does the new entity legislation affect the monthly submission of e-KUF and e-KIF ledgers to UIO BiH?

Accepted Answer

The new entity-level fiscalisation acts do not abolish state-level VAT ledger reporting. The monthly submission of the Electronic Book of Received Invoices (e-KUF) and Electronic Book of Issued Invoices (e-KIF) to UIO BiH remains mandatory under the Law on VAT. However, because new ESET and EFS systems capture transaction data in structured digital formats, enterprises can automate the compilation and reconciliation of these ledgers, eliminating manual data entry and minimising reconciliation errors.

Question 9

What is the statutory timeline for phasing out old fiscal cash registers in FBiH?

Accepted Answer

Following the entry into force of Law No. 9/26 in February 2026, the law stipulates that full operational application begins upon adoption of secondary rulebooks and at the latest 18 months from entry into force (by 12 August 2027). A multi-year transitional window (spanning 3 to 4 years) is provided to allow businesses to phase out their registered hardware fiscal printers gradually and deploy certified software ESET solutions.

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