Starting January 1, 2026, the method of issuing invoices in Croatia primarily depends on who the customer is and whether the transaction falls under domestic fiscalization. Sales to citizens go through Fiscalization 1.0. Domestic invoices to business and public entities within scope go as e-invoices through Fiscalization 2.0. Taxpayers outside the VAT system covered by the Law receive e-invoices during 2026, and starting January 1, 2027, they will also begin issuing them.
Applies to: sole proprietorships (obrtsi), limited liability companies (d.o.o. and j.d.o.o.), associations, property renters, and other businesses registered in Croatia. Specific obligations depend on the tax status, customer, and transaction.
Publication date: 27 July 2026
Author: Tin Dizdarević
First question: who are you issuing the invoice to?
The easiest way to choose the right invoice is not to start with the payment method, but with the customer.
The customer is a citizen
When selling to an end consumer, it is a B2C invoice. Starting January 1, 2026, Fiscalization 1.0 covers invoices in retail consumption regardless of the payment method. This means cash, cards, and transaction accounts are no longer sufficient reason for different handling of B2C fiscalization.
In BillKO, such an invoice can be created manually, in the Android app, through the POS process, or from eCommerce sales. When fiscalization applies, BillKO sends the necessary data and returns the invoice status.
The customer is a domestic company, sole proprietorship, or other business entity
When issuing an invoice to another domestic business entity, it is generally a B2B invoice. For transactions within the scope of Fiscalization 2.0, a structured e-invoice is exchanged rather than just a PDF sent by email.
BillKO enables sending and receiving e-invoices, tracks their status, and connects e-invoices with other invoices and reports in the system.
The customer is a public contracting authority
For B2G invoices, the customer is a public sector body. The e-invoice is sent in the prescribed structured format. BillKO manages B2G invoices alongside other outgoing invoices, so the user does not need to maintain a separate list just because the customer is a public entity.
The customer is from another EU member state or a third country
Invoices to customers from the EU and outside the EU do not automatically turn into a domestic e-invoice just because the customer is a business entity. For such transactions, an invoice is issued according to applicable rules, and domestic Fiscalization 2.0 does not apply in the same way as in domestic B2B exchange.
You can use BillKO for invoices to foreign customers and for invoices that are not fiscalized. The correct tax treatment and customer data must be set on the invoice according to the specific business case; for individual tax interpretations, consult your accountant or tax advisor.
Second question: are you in the VAT system?
Tax status is particularly important for the transition to issuing e-invoices.
Period | VAT-registered Taxpayers | Non-VAT Registered Taxpayers Covered by the Law |
|---|---|---|
From January 1, 2026 | Issue and receive domestic e-Invoices within the scope of Fiscalization 2.0. | Receive e-Invoices. |
From January 1, 2027 | Continue issuing and receiving e-Invoices. | Begin issuing e-Invoices for covered transactions. |
This schedule means that a lump-sum sole proprietor or another non-VAT taxpayer covered by the Law must be ready to receive an eInvoice during 2026, even though the obligation to issue them begins on January 1, 2027.
Fiscalization 1.0 and Fiscalization 2.0 are not the same thing
The names sound like two versions of the same procedure, but they address different types of invoices.
Fiscalization 1.0
Fiscalization 1.0 refers to retail consumption invoices—B2C. The focus is on the fiscalization of invoices issued to citizens. BillKO includes it in manual issuing, POS, mobile, and eCommerce sales when applicable.
Fiscalization 2.0
Fiscalization 2.0 covers domestic business e-invoices, their exchange, and related reporting. An e-invoice is not a PDF attachment, but a structured electronic document that passes through an information intermediary.
A single business can use both systems on the same day. A salon can fiscalize a B2C invoice after a citizen's visit, and then send an e-invoice to a company for a contracted service. A webshop can issue a B2C invoice to a private customer, while an agency sends a B2B e-invoice to a domestic client.
What does an information intermediary do?
An information intermediary technically exchanges structured e-invoices between the sender and recipient. KUPUJ ONLINE d.o.o., the provider of BillKO, is on the official list of information intermediaries maintained by the Tax Administration.
With the BillKO e-invoice service, you do not contract another information intermediary and have no separate fee for another intermediary. You still contract payment services with your chosen payment partner when using them.
Three examples
Lump-sum sole property outsite the VAT system
During 2026, a lump-sum sole proprietor can:
fiscalize B2C invoices to citizens through Fiscalization 1.0;
receive supplier eInvoices;
issue other invoices according to the rules that apply to the specific customer;
prepare to issue domestic e-invoices within scope starting January 1, 2027.
In BillKO, alongside invoices, they can maintain KPR and PO-SD records, use POS, the Android app, or eCommerce when needed.
d.o.o. in VAT system
A company in the VAT system sends and receives domestic e-invoices for transactions within scope starting January 1, 2026. If it simultaneously sells to citizens, it also uses Fiscalization 1.0. For EU or export invoices, the appropriate international tax treatment applies.
BillKO keeps B2C, B2B, and B2G invoices in the same system, complete with statuses, payments, and reports.
Association or non-profit organizations
An association's obligations are not determined solely by the name of its legal form. Economic activity, tax status, customer, and transaction type are what matter. An association may need B2C fiscalization, e-invoice reception, e-invoice issuance, or an invoice that is not fiscalized—depending on the specific case.
That is why a website does not replace accounting advice. BillKO provides the tools for the appropriate invoice flow, while an expert confirms how the rules apply to the association.
Checklist for 2026 and 2027
Write down whether you issue invoices to citizens, business entities, the public sector, or foreign customers.
Check if you are in the VAT system.
Determine whether you need Fiscalization 1.0, e-invoice reception, e-invoice issuance, or a combination.
Choose an information intermediary and verify what is included in the service.
Align your POS, eCommerce, mobile sales, and manual invoicing.
Agree with your accountant on the tax treatment for exports, EU invoices, and special transactions.
Test the entire process before your first mandatory production transaction.
How BillKO helps
BillKO connects invoices, quotes, and advance invoices, Fiscalization 1.0, Fiscalization 2.0, sending and receiving e-invoices, POS, eCommerce, payments, and reports. You can start with the obligation that is current today, without maintaining a separate system for each type of invoice.
In a presentation, we can go through concrete examples for your business: an invoice to a citizen, a domestic e-invoice, an invoice for an EU customer, or an e-invoice for a non-VAT taxpayer.
