Overview
Croatia has two separate electronic invoicing systems that serve different purposes, and confusing them is one of the most common mistakes among business owners. This guide explains both systems, who is required to use each one, and how they interact.
The two systems at a glance:
- e-Racun (FINA system): A structured electronic invoice sent to public sector buyers (government bodies, public hospitals, schools, municipalities). This is a B2G (Business-to-Government) system based on the European EN 16931 standard.
- Fiscalization (CIS system): Real-time reporting of every invoice to the Croatian Tax Administration ("Porezna uprava"). This is a national tax compliance system covering B2B and B2C transactions. "CIS" stands for "Centralni informacijski sustav" (Central Information System).
These are not the same thing. They run on different technical protocols, serve different regulatory purposes, and are administered by different institutions. Many businesses need to use both.
What is the e-Racun for public procurement?
The e-Racun (e-Invoice) for public procurement is Croatia's implementation of the European Directive 2014/55/EU, which requires all EU member states to accept structured electronic invoices in public procurement. In Croatia, this system is governed by the Law on Electronic Invoicing in Public Procurement (NN 94/2018) and operated by FINA, Croatia's central financial agency.
Key characteristics:
- Mandatory for all suppliers who invoice public sector buyers (state ministries, local government units, public institutions like schools and hospitals, publicly owned utility companies)
- Format: Structured XML documents in UBL 2.1 or UN/CEFACT CII format, complying with the European EN 16931 standard
- Transmission: Through the FINA e-Racun service
- In effect since: December 1, 2018 for public buyers (obligation to receive) and July 1, 2019 for all business suppliers (obligation to send)
Important distinction: An e-Racun is not a PDF sent by email. It is a structured XML document that computer systems can process automatically. A PDF is merely a visual representation of an invoice. The legal requirement is specifically for the machine-readable XML format.
What must an e-Racun contain?
According to the EN 16931 standard, every e-Racun must include:
- Identification data for both seller and buyer (OIB, name, address)
- Invoice number and date of issue
- Line items with descriptions, quantities, and prices
- VAT information (rate, base, amount)
- Total amount payable
- Payment details (IBAN, payment reference)
What is Fiscalization (and Fiscalization 2.0)?
Fiscalization ("fiskalizacija") is Croatia's system for real-time reporting of invoices to the Tax Administration. It has been in place since 2013 for cash transactions and is being significantly expanded under Fiscalization 2.0.
How it works:
- Your invoicing software generates an invoice
- The software creates a ZKI code (a security code calculated from the invoice data using your fiscal certificate)
- The invoice data is sent to the CIS system via SOAP XML protocol
- CIS returns a JIR code (a unique identifier confirming the invoice was registered)
- Both the ZKI and JIR codes must appear on the printed or digital invoice
- All of this must happen within 2 minutes of issuing the invoice
ZKI (Zastitni kod izdavatelja, or Issuer Protection Code) is generated locally using a fiscal certificate obtained from FINA. JIR (Jedinstveni identifikator racuna, or Unique Invoice Identifier) is returned by the Tax Administration's CIS system as confirmation.
What changes with Fiscalization 2.0?
The new Fiscalization Law (NN 89/25) introduces several major changes effective in 2026:
Expanded scope: Fiscalization is no longer limited to cash transactions. It now covers all payment methods including card payments, bank transfers ("virmani"), and cryptocurrency payments.
Introduction of B2B e-invoicing: Structured electronic invoices between businesses (B2B) become possible through the PEPPOL network. For B2G public procurement, PEPPOL becomes the mandatory channel. For B2B, it remains voluntary but encouraged.
Technical requirements: QR codes on every invoice for authenticity verification, digital signatures via fiscal certificates, and integration with the CIS system.
Side-by-side comparison
| Feature | e-Racun (FINA) | Fiscalization 2.0 (CIS) |
|---|---|---|
| Purpose | Sending structured invoices to public sector buyers | Reporting all invoices to the Tax Administration |
| Who must use it | Suppliers to public sector entities | All businesses that issue invoices |
| Administering body | FINA | Tax Administration (Porezna uprava) |
| Data format | UBL 2.1 / EN 16931 XML | SOAP XML (CIS protocol) |
| Communication channel | FINA e-Racun service | Central Information System (CIS) |
| Timing requirement | With the invoice (no strict second-level deadline) | Real time (within 2 minutes) |
| Certificate needed | Digital certificate for authentication | Fiscal certificate from FINA (mandatory) |
| Identification codes | None specific | ZKI and JIR on every invoice |
| Standard | EU (EN 16931, Directive 2014/55/EU) | Croatian national system |
| In effect since | July 1, 2019 (for suppliers) | 2013 (cash), 2026 (expanded) |
Critical point: These two systems do not replace each other. If you issue an invoice to a public sector buyer, you must both fiscalize it (send to CIS, get JIR) and send it as a structured e-Racun through FINA. They are parallel obligations.
Who needs which system?
Scenario 1: Restaurant or cafe
Fiscalization: Required. e-Racun: Not required.
Hospitality businesses issue invoices to end consumers. Every invoice must be fiscalized through CIS. Since they do not sell to the public sector, the FINA e-Racun system is not needed.
Scenario 2: IT company with a government contract
Fiscalization: Required. e-Racun: Required.
An IT company developing software for a ministry must fiscalize all invoices and additionally send e-Racuns in EN 16931 format through FINA for its government contracts.
Scenario 3: Online shop selling to consumers and businesses
Fiscalization: Required. e-Racun: Not required.
Under Fiscalization 2.0, all invoices (not just cash) must be reported to CIS. Since the shop does not sell to the public sector, the FINA e-Racun is unnecessary.
Scenario 4: Construction company winning a public tender
Fiscalization: Required. e-Racun: Required.
The company must fiscalize all invoices and send e-Racuns for its public sector contracts.
Scenario 5: Lump-sum sole trader, private clients only
Fiscalization: Required. e-Racun: Not required.
Even lump-sum sole traders must fiscalize their invoices. The e-Racun system is only relevant if they have public sector clients.
Quick test: Do I need the FINA e-Racun?
Ask yourself:
- Do I have a contract with any public sector buyer? (ministry, city, municipality, hospital, school, public utility)
- Do I participate in public procurement tenders?
- Do I supply goods or services to any entity funded by public money?
If the answer to any question is yes, you need both systems. If all answers are no, fiscalization alone is sufficient.
PEPPOL and the future of e-invoicing
PEPPOL (Pan-European Public Procurement OnLine) is a European network for exchanging electronic business documents. In Croatia's evolving regulatory landscape, PEPPOL plays a growing role:
- For public procurement (B2G): PEPPOL is becoming the mandatory channel for sending e-Racuns to public buyers
- For business-to-business (B2B): PEPPOL use is voluntary, but it enables automatic processing of invoices by the recipient, reducing manual data entry
- For consumers (B2C): PEPPOL is not used. Standard fiscalized invoicing applies.
PEPPOL is a network, not a format. Documents sent through PEPPOL use the same EN 16931 standard as the FINA e-Racun. If your software already supports EN 16931, integrating with PEPPOL is the logical next step.
Common misconceptions
"e-Racun and fiscalization are the same thing." They are not. e-Racun sends structured invoices to public sector buyers via FINA. Fiscalization reports transactions to the Tax Administration via CIS. Different systems, different protocols, different purposes.
"If I fiscalize an invoice, I have automatically fulfilled the e-Racun obligation." No. Fiscalization reports the transaction to the Tax Administration (CIS, SOAP XML). The e-Racun sends a structured document to the public sector buyer (FINA, UBL XML). Both steps must be completed separately.
"e-Racun is mandatory for all businesses." No. The FINA e-Racun system is mandatory only for businesses that invoice public sector buyers. If you have no public sector clients, you do not need it. Fiscalization, on the other hand, is mandatory for everyone.
"A PDF sent by email is an e-Racun." No. An e-Racun is a structured XML document in EN 16931 format that can be automatically processed by computer systems. A PDF is a visual document that requires manual processing. Sending a PDF by email does not satisfy the legal requirement.
"Fiscalization 2.0 replaces the e-Racun system." No. Fiscalization 2.0 expands the scope of transaction reporting and introduces B2B e-invoicing capabilities, but it does not replace the FINA e-Racun system for public procurement. The two systems continue to operate in parallel.
Preparing for compliance
If you work only with the private sector
- Ensure your invoicing software supports Fiscalization 2.0 requirements
- Verify it can fiscalize all payment methods (not just cash)
- Check your fiscal certificate's expiration date and renew if needed
- Consider voluntarily adopting B2B e-invoicing for efficiency
If you work with the public sector
- Everything from the private sector list above
- Register for the FINA e-Racun service
- Confirm your software supports EN 16931 format and FINA communication
- Test sending e-Racuns before your first real invoice
- Prepare for PEPPOL integration
If you are just starting a business
When choosing invoicing software, verify it supports both fiscalization (CIS, ZKI/JIR) and e-Racun (EN 16931, FINA). An integrated solution eliminates the need for double data entry and ensures compliance from day one.
Legal timeline
| Obligation | Effective date | Who is affected | Legal basis |
|---|---|---|---|
| Fiscalization of cash transactions | 2013 (in effect) | All businesses with cash transactions | NN 133/12 |
| e-Racun for public procurement (receiving) | December 1, 2018 (in effect) | Public sector buyers | NN 94/2018 |
| e-Racun for public procurement (sending) | July 1, 2019 (in effect) | All suppliers to public sector | NN 94/2018 |
| Fiscalization 2.0 (all payment methods) | 2026 | All businesses | NN 89/25 |
| PEPPOL for B2G | Per FINA schedule | Suppliers to public sector | NN 89/25 |
| B2B e-invoicing (voluntary) | 2026 | All businesses (optional) | NN 89/25 |
Glossary
- B2G (Business-to-Government): Transactions between a business and the public sector
- B2B (Business-to-Business): Transactions between two businesses
- B2C (Business-to-Consumer): Transactions between a business and an end consumer
- CIS: Central Information System of the Tax Administration for fiscalization
- EN 16931: European standard for electronic invoices
- JIR: Unique Invoice Identifier (returned by the Tax Administration to confirm registration)
- ZKI: Issuer Protection Code (generated locally using a fiscal certificate)
- UBL: Universal Business Language, an XML format for business documents
- PEPPOL: Pan-European Public Procurement OnLine, a network for exchanging e-documents
- FINA: Croatian Financial Agency, which operates the e-Racun service and issues fiscal certificates
FAQ
What is the difference between e-Racun and fiscalization? The e-Racun (FINA system) is for sending structured electronic invoices to public sector buyers in EN 16931 format. Fiscalization is for reporting all invoices to the Tax Administration via the CIS system. They are two separate systems with different protocols, formats, and purposes.
Do I need the e-Racun system if I do not work with the government? No. The FINA e-Racun is mandatory only for suppliers to the public sector. If you sell exclusively to private individuals or businesses, fiscalization alone is sufficient.
What happens if I send a PDF instead of an e-Racun to a public buyer? The public buyer has the right to reject an invoice that is not in the required EN 16931 format. This can cause payment delays and administrative complications. Since July 1, 2019, all suppliers to the public sector must send structured e-Racuns.
Can I use the same software for both systems? Yes. Integrated systems can handle both functions. The software must support CIS communication for fiscalization (SOAP XML, ZKI/JIR) and the FINA e-Racun service for B2G invoicing (UBL XML, EN 16931).
Do I need a fiscal certificate for the e-Racun? For fiscalization (CIS), a fiscal certificate is mandatory for generating the ZKI code. For the e-Racun (FINA), a digital certificate is needed for authentication, but it does not have to be the same certificate used for fiscalization.
What is PEPPOL and do I need to use it? PEPPOL is a European network for exchanging electronic business documents. For B2G public procurement, it is becoming the mandatory channel. For B2B, it is voluntary but beneficial as it enables automatic invoice processing by the recipient.
Will B2B e-invoicing become mandatory? Currently it is voluntary. However, the EU trend is moving toward mandatory B2B e-invoicing. Early adoption provides efficiency benefits and positions your business ahead of regulatory changes.
This guide is for informational purposes only and does not constitute legal or tax advice. Tax rules change frequently. Consult a qualified Croatian accountant or tax advisor for your specific situation. Last verified against official sources on the date shown above.