Question 1

Is a PDF invoice sent by email legally valid for domestic B2B transactions in Croatia?

Accepted Answer

No. Standard PDF invoices sent via email or physical paper documents no longer have legal validity for domestic B2B commercial transactions involving VAT-registered taxpayers. Invoices must be issued, exchanged, and archived in structured XML formats compliant with EN 16931 (HR-CIUS) and fiscalised with Porezna uprava.

Question 2

What is the practical difference between ZKI and JIR?

Accepted Answer

The ZKI (Zaštitni kod izdavatelja) is an issuer security code generated by the taxpayer's billing software. The JIR (Jedinstveni identifikator računa) is a unique identifier generated by the Croatian Tax Administration after successful fiscalisation of a consumer transaction invoice. Both identifiers belong to Croatia's consumer transaction fiscalisation framework. Under Fiskalizacija 2.0, structured B2B e-invoices are subject to a separate fiscalisation process in which issuers and recipients submit prescribed invoice data to Porezna uprava. This process does not require JIR and ZKI identifiers on every B2B e-invoice.

Question 3

What is the Address Management System (AMS)?

Accepted Answer

The Address Management System (AMS) is Croatia's national central directory of electronic invoice delivery endpoints. Managed under tax authority oversight, it maps a company's tax number (OIB) to its designated receiving intermediary or Peppol Access Point, ensuring electronic invoices reach the recipient without bilateral network configurations.

Question 4

How does the five-working-day recipient fiscalisation rule work?

Accepted Answer

Under Article 48(4) of the Croatian Fiscalisation Act, recipients must submit the prescribed fiscalisation data from incoming B2B e-invoices to Porezna uprava within five working days of receipt. This obligation is separate from accepting or rejecting an invoice. Under Article 52, recipients must report e-invoices rejected during the previous month by the 20th day of the following month. The rejection report must include the invoice details, rejection date and reason. Reporting an invoice as rejected is deemed to constitute a declaration that the recipient will not exercise the right to deduct input VAT on that invoice.

Question 5

Are cross-border invoices subject to Fiskalizacija 2.0?

Accepted Answer

No. Transactions with foreign trading partners (intra-Community acquisitions, cross-border supplies within the EU, and international trade outside the EU) are currently out of scope for domestic e-Račun fiscalisation. Standard invoicing rules and recapitulative declarations apply until the EU ViDA cross-border framework takes effect on 1 July 2030.

Question 6

Can small and micro-businesses use free government invoicing tools?

Accepted Answer

Yes. The Croatian Tax Administration provides MIKROeRAČUN, a free e-invoicing application for eligible taxpayers outside the VAT system. In 2026, it supports receiving, viewing, searching, rejecting and storing incoming e-invoices, as well as fiscalising their receipt and rejection. The application is being upgraded to support the issuance and fiscalisation of outgoing e-invoices from 1 January 2027. According to the Tax Administration's announcement of 2 September 2026, the enhanced version is scheduled to be available for testing during October 2026. FiskAplikacija serves separate fiscalisation monitoring, authorisation management and e-reporting functions.

Question 7

What happens if the internet connection or tax authority server goes offline?

Accepted Answer

The applicable recovery procedure depends on the type of fiscalisation. Under Article 49 of the Fiscalisation Act, e-invoice fiscalisation must be completed within five working days of a technical failure or internet interruption. For consumer transaction fiscalisation, Article 21 generally requires restoration of the connection and submission of outstanding invoice data within two working days. The JIR and ZKI requirements associated with consumer fiscalisation must not be applied automatically to structured B2B e-invoices.

Question 8

Are non-VAT registered businesses affected in 2026?

Accepted Answer

Yes. Although non-VAT registered entities, small craftsmen (obrtnici), and freelance professionals are not required to issue structured electronic invoices until Phase 2 on 1 January 2027, they have been legally obligated to receive structured electronic invoices via registered AMS addresses since 1 January 2026.

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