5 Weeks Count Down to Croatia B2B Mandate Go Live

Timing and Approach:

The Croatia B2B Mandate is considered to be a big bang as from 1 January 2026, all VAT‑registered businesses must issue and receive structured e‑invoices for domestic B2B transactions.
A phased element follows as of 1 January 2027, when the obligation will extend to non‑VAT-registered businesses and many public bodies.
Croatia has been live with e-invoicing for public-sector entities since December 2018.

Scope:

VAT: All VAT registered taxpayers must be ready for e-invoicing, real-time reporting and digital signatures on 1^st January 2026
Non VAT: Importantly, non‑VAT entities must be able to receive e-invoices from 2026 but be able to issue them only from 2027.
Small Taxpayers: A free application called MICROeINVOICE will be provided for small taxpayers (especially non-VAT or smaller entities) to issue, receive, and archive e-invoices.
The B2B mandate is only for domestic invoices.

DRR:

Along with e-invoicing, key invoice data must be reported in real-time to the Croatian Tax Administration.
The Croatian government previously requested a derogation from the European Commission to adopt a pre-clearance model, similar to Italy’s SDI system, but this was denied and Croatia is required to implement a model that complies with ViDA (by implementing a post-audit or real-time reporting mechanism).

Format:

E-invoices must conform to EN 16931.
Croatia uses UBL 2.1 XML with a local CIUS extension (HR-FISK 2.0) to reflect national invoice data requirements.

Other details:

For incoming invoices (invoice recipients), there is a requirement to validate or reject them within 5 business days.
Invoices must be digitally signed and include the seller’s tax ID (“OIB”).
Some very detailed data is required, for example:
Bank account details of the supplier
A 6-digit classification code for each line item
E-invoices must be stored electronically for 11 years under the new rules.

Penalties:

There are significant penalties for failing to comply with the e-invoicing rules*.

Failure to issue/fiscalize: €2,650 – €66,000 for companies; €265 – €6,650 for individuals.
Failure to e-report: €1,330 – €13,300 for companies; €130 – €1,330 for individuals.
Tampering with software: Up to €66,000 fine + closure of premises up to 30 days.
Retention breaches: Fines up to €26,500; invoices must be archived for 11 years.