From Fiscal Devices to Fiscal Systems

For years, fiscalization in the Federation of Bosnia and Herzegovina has been treated primarily as a hardware obligation: fiscal devices, fiscal memories, and periodic inspections that confirmed compliance only after the fact. The newly adopted Law on Fiscalization fundamentally rewrites that logic. Rather than modernizing the old system, the legislator has replaced it entirely, introducing an IT-centric, real-time fiscal ecosystem that will reshape how retailers, POS vendors, and software providers operate over the next decade.

The law, adopted and expected to enter into force following publication in the Official Gazette, initiates an 18-month transition period. During this time, the current fiscal model remains valid, but the direction is unambiguous: fiscalization in the Federation is moving away from devices and toward systems. This is not merely a technological upgrade; it is a regulatory redesign that places software architecture, data integrity, and continuous connectivity at the core of compliance.

A Software-Driven Compliance Model

At the heart of the reform lies a simple but far-reaching idea: fiscalization should no longer depend on certified hardware installed at the point of sale, but on electronic systems capable of operating across POS environments, webshops, ERP platforms, and cloud infrastructures. In the new model, fiscal compliance is embedded into transactional workflows rather than enforced through standalone devices. For retailers, this promises operational flexibility.

The New Fiscalization Architecture

The architecture defined by the law introduces three central components. The first is the electronic system for transaction recording, commonly referred to as the “ESET” This software-based component is responsible for capturing transaction data, generating fiscal receipts, managing communication with tax authorities, and archiving records. Importantly, the asset is not the POS system itself. The POS remains operationally independent, while the ESET functions as a fiscal intermediary that ensures compliance without dictating retail workflows.

The second component is the security model embedded within the ESET. This module digitally signs transactions, establishes connection between the retailer and the tax authority, and enables secure communication with the central fiscalization platform. Its role is not symbolic. The tax authority retains the power to suspend a security model in the event of violations, effectively halting fiscalization for the affected system. In practical terms, compliance failures can now result in immediate operational consequences rather than delayed penalties.

The third pillar is the central fiscalization platform operated by the tax authority. This platform verifies transaction data in real time, assigns a verification number to each fiscalized receipt, and enables continuous oversight. A transaction that is not authorized through this platform is not fiscally valid. The system shifts supervision from periodic inspection to constant verification, aligning Bosnia and Herzegovina with the most advanced real-time fiscal regimes in Europe.

Connectivity Becomes a Compliance Requirement

One of the most significant implications for retailers is the mandatory requirement for stable internet connectivity. Real-time fiscalization presupposes continuous online communication. While the law allows for temporary offline scenarios, permitting receipts to be issued with a retailer authorization code and reauthorized within 48 hours, this is explicitly framed as an exception, not a standard operating mode. Retailers will need to reassess infrastructure reliability as part of their compliance strategy.

Redefining Transaction Types and Assets

The reform also introduces a clear distinction between transaction types and fiscal assets. Separate ESET are defined for B2C fiscal receipts and for B2B and B2G electronic invoicing, with combined ESET available for entities operating across multiple transaction models. This distinction is particularly relevant for complex retail environments where in-store sales, e-commerce, and invoicing coexist. The law effectively forces businesses to map their transaction flows with greater precision than before.

Registration as a Process, Not a Formality

Equally consequential is the scope of registration required before any transaction can be fiscalized. Retailers must register themselves, their business locations, the ESET they use, and their operators within the central fiscalization platform. These registrations must be completed at least 48 hours before transactions begin. Invoicing workflows add another layer, requiring registration of both issuers and recipients. Fiscal compliance, in this sense, becomes a process discipline rather than a technical checkbox.

The New Fiscal Receipt as a Control Mechanism

Receipts themselves also evolve. Every fiscal receipt must include a retailer authorization code, while only fully fiscalized receipts carry the tax authority’s verification number. A QR code becomes mandatory, enabling consumers to verify the authenticity of transactions. This consumer-facing transparency is not incidental. It embeds public oversight into the fiscal system and reinforces the deterrent effect against non-compliance.

Higher Barriers for POS and Fiscal Software Providers

For POS vendors and software providers, the law introduces stringent conditions for ESET manufacturers. Eligibility requires a registered presence in the Federation for a minimum of five years, specific registered business activities, ISO certifications, and a substantial bank guarantee. These requirements significantly narrow the field of authorized providers and elevate fiscal software from a commodity to a regulated infrastructure component. Unauthorized software use is explicitly prohibited and subject to severe penalties.

Pragmatism Within a Strict Framework

Yet the reform also introduces pragmatic flexibility. ESET rental is permitted for temporary sales locations, fairs, and exhibitions, acknowledging real-world retail scenarios where permanent installations are neither practical nor necessary. This provision, while narrow, reflects a legislator attentive to operational realities rather than theoretical compliance.

The Role of the Webinar in Understanding the Reform

Taken together, the Federation’s fiscalization reform is less about technology and more about governance through systems. It aligns Bosnia and Herzegovina with jurisdictions such as Croatia, while introducing local specificities, particularly around return receipts and transaction separation, that vendors must address explicitly in their implementations.

The value of Fiscal Solutions’ recent webinar lies precisely in this level of clarity. Rather than framing the reform as an abstract legal change, the session translated legislative text into system architecture, operational workflows, and compliance consequences. For POS vendors, it outlined where integration boundaries lie and where responsibility begins and ends. For retailers, it demonstrated that fiscalization is no longer a peripheral obligation but a core component of transaction design.

In an environment where regulatory missteps can halt operations in real time, understanding fiscalization is no longer optional. The Federation’s new law makes one thing clear: compliance will be continuous, software-driven, and unforgiving of ambiguity. Those who treat fiscalization as a strategic system, rather than a device, will adapt smoothly. Those who do not will find that the margin for error has all but disappeared.