What is Fiscalization 2.0?

• Fiscalization 2.0 refers to electronic fiscalization of invoices (eInvoice) — it is intended for transactions between business entities (B2B) and between entities and public authorities (B2G).
• Unlike the classic fiscalization (1.0), which focuses on invoices issued to final consumers (B2C), in eInvoice the fiscalization process is separated from the invoice issuance itself.
• Not every B2B transaction is required to use eInvoice and fiscalization — the obligations are defined by law and apply only to entities that are legally designated as issuers or recipients of eInvoices in specific cases.

Key Differences: Fiscalization 1.0 vs. Fiscalization 2.0

Fiscalization Obligations for Specific Segments

B2C (Final Consumption)

• Fiscalization of invoices in final consumption covers all payment methods (cash, card, bank transfer, etc.) starting from January 1, 2026.
• When an invoice is issued, the software sends a fiscalization message to the Tax Administration, receives the JIR, and that JIR is printed on the invoice (along with a QR code).
• Fiscalization obligors must ensure:

• an adapted point-of-sale device and software that supports fiscalization,
• an internet connection,
• a digital certificate for signing fiscalization messages,
• an internal rule for invoice number sequencing,
• registration and record of business premises through ePorezna (eTax Administration),
• a visible notice on the obligation to issue/retain invoices in business premises.

• QR code, JIR, and ZKI are mandatory elements of a fiscalized invoice in the B2C segment.
• Exemptions from fiscalization (under Article 4 of the Fiscalization Act) apply only to invoices for final consumption and do not apply to eInvoices.

B2B/B2G (eInvoices)

• In the case of eInvoices, fiscalization is carried out separately from the exchange of the invoice. No fiscal elements (such as JIR or QR code) need to be included within the eInvoice itself.
• Both the issuer and the recipient of the eInvoice send their own fiscalization messages to the Tax Administration and receive confirmations for those messages.
• Not all business transactions are subject to fiscalization — only those that are legally defined as mandatory for specific entities.

Special Cases and Additional Provisions

• Agricultural family farms (OPG – Obiteljska poljoprivredna gospodarstva): Agricultural family farms are not required to fiscalize the sale of their own agricultural products to consumers (e.g., at markets, stands, under the label “own products”) — these exemptions remain valid even after the introduction of the new law.
• Change in payment method / transaction account: When an invoice is paid via a transaction account, fiscalization is required — Fiscalization is carried out regardless of whether the payment will actually be made.
• Tips: If a tip is paid via a transaction account, it must be recorded and fiscalized at the time of posting.
• Book of bound invoices: In the event of a cash register malfunction, the taxpayer may continue issuing invoices but must keep their own bound-invoice book; as of January 1, 2026, the certification of this book can be submitted electronically.
• Customer’s obligation to keep the invoice: The customer must retain the invoice, though not necessarily in paper form — a digital copy (e.g., via an app) is acceptable.
• Software solutions: The same software solution cannot be used for both B2C and B2B fiscalization without adjustments, as the processes and rules differ.
• Digital certificate: A separate certificate is not required for fiscalization and eInvoicing — the same application certificate may be used for both processes.

The law stipulates that entities obligated to issue and receive eInvoices are those that have their registered office, residence, or habitual residence in the Republic of Croatia.

However, the term “registered office” does not include:

• branches of foreign companies registered in the court register,
• permanent business establishments of foreign companies that are not registered (but have a VAT number and a so-called fixed establishment),
• foreign companies that only have a VAT number in Croatia, without a permanent establishment.

These categories are not considered issuers or recipients of eInvoices under the Fiscalization Act on Cash Transactions and the new Fiscalization 2.0 system.

Fiscalization in final consumption remains largely the same, with an extension to include all payment methods — including payments made via transaction accounts as of January 1, 2026. When an invoice is issued, a fiscalization message is sent to the tax system, which generates and returns a JIR (Unique Invoice Identifier). Customers can verify the validity of the invoice using the JIR or QR code.

On the other hand, fiscalization of eInvoices applies to B2B and B2G transactions and is based on structured electronic invoices. It requires appropriate software solutions to enable the automated exchange and fiscalization of invoices.

More information on this topic can be found on the Tax Administration’s official website

Although Grant Thornton is not responsible for implementing Fiscalization 2.0, you can always contact us for advice or assistance in navigating the new obligations. We are here to help make the process easier for you — for more information, please reach out to our local experts