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Croatia Updates B2C Fiscalization Rulebook from January 1, 2027

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Summary

Croatia has updated its rules for fiscalization of final-consumption receipts. From January 1, 2027, changes will affect digital certificates, technical requirements, self-service payments and several existing fiscalization procedures.

Content

Croatia has published amendments to the Rulebook on Fiscalization of Final Consumption Invoices in Official Gazette No. 97/2026. The new rules will apply from January 1, 2027.

The amendments do not introduce a new fiscalization system or a new type of Fiscal Receipt. The current B2C fiscalization process remains in place. Instead, the changes update several technical and operational rules that support the existing system.

For retailers and POS providers, the most relevant changes concern digital certificates, the Tax Administration’s Technical Specification and self-service sales.

The Rulebook introduces simpler and more general terminology for certificates used in fiscalization.

Instead of referring to an “application certificate” or “production application certificate”, the Rulebook will generally use the term digital certificate.

Businesses that fiscalize receipts or sales through self-service devices will continue to need a digital certificate containing their Croatian Personal Identification Number (OIB). A DEMO digital certificate containing the OIB will be used for testing.

The terminology for certificate providers is also simplified and aligned under the term trust service provider.

For existing businesses, there is an important transitional rule. Digital certificates issued before January 1, 2027 can continue to be used until they expire.

In practice, this means that businesses do not need to replace a valid certificate simply because the amended Rulebook starts applying in 2027.

Another noticeable change is that some detailed technical requirements will no longer be written directly in the Rulebook.

For example, the current Rulebook specifies a particular method for electronically signing fiscalization messages. From January 1, 2027, the signing method will instead be determined by the Croatian Tax Administration’s Technical Specification for Users.

A similar change applies to the receipt issuer’s security code. The amended Rulebook no longer names a specific cryptographic hash function. It keeps the requirement that the result must contain 32 hexadecimal characters, while the technical implementation is no longer described in the same level of detail in the Rulebook.

The rules for test and production environments are also simplified. Addresses and certificate requirements for these environments will be defined through the Technical Specification.

For POS and fiscalization software providers, this means that checking only the Rulebook will no longer be enough for some technical requirements. The current version of the Tax Administration’s Technical Specification will also need to be followed.

The amendments also update the rules concerning self-service devices.

The existing wording specifically refers to sales without staff participation where payment is made through SMS.

From January 1, 2027, the Rulebook will also expressly mention payments made:

  • by card;
  • through a mobile application; or
  • through other similar payment methods.

This is particularly relevant for vending machines, unattended sales terminals and other self-service solutions.

The basic condition does not change: the sale must take place without a person participating or acting as an intermediary in the sales process.

Therefore, the change does not mean that every card payment becomes a self-service transaction. It simply updates the wording of the Rulebook to reflect payment methods commonly used by modern self-service solutions.

The amendments also make several smaller corrections.

The provision concerning tips is updated so that it refers to the correct article of the Fiscalization Act dealing with the complete failure of an electronic device used to issue receipts.

This is mainly a correction of the legal reference rather than a completely new process for tips.

Another change concerns cash-management rules. The special provision in Article 47(6), which applies to the cash maximum for businesses performing currency-exchange activities, is deleted.

Businesses affected by this provision should therefore review the remaining cash-maximum rules and check whether their internal procedures need to be updated from January 1, 2027.

Several other amendments simply remove outdated wording, correct references or renumber existing paragraphs.

Impact on retailers and POS providers

For most retailers, the everyday process of issuing and fiscalizing a B2C Fiscal Receipt will remain largely the same.

The amendments are more relevant for POS providers, fiscalization software vendors, self-service operators and businesses responsible for maintaining digital certificates.

The main operational change is that more technical information will be managed through the Tax Administration’s Technical Specification rather than being written directly into the Rulebook.

Self-service operators should also note that card and mobile-app payments are now expressly included in the relevant self-service provision.

What should retailers and POS providers do?

Retailers and solution providers should review the changes before January 1, 2027 and determine whether they affect their systems or internal procedures.

In particular, they should:

  • check how digital certificates are managed, while remembering that existing valid certificates can remain in use until expiry;
  • monitor the Tax Administration’s Technical Specification for applicable signing, certificate and communication requirements;
  • review self-service solutions that accept card, mobile-app or similar payments; and
  • review cash-management procedures where the deleted currency-exchange provision is relevant.

From our perspective, the main point is not a change to the basic Croatian fiscalization model, but a change in where businesses and software providers need to look for technical requirements. The Rulebook will continue to define the legal framework, while more implementation details will be contained in the Tax Administration’s Technical Specification.

The official source is the Rulebook on Amendments to the Rulebook on Fiscalization of Final Consumption Invoices, Official Gazette No. 97/2026, which applies from January 1, 2027. Source

 

Filip Kalaba, Junior Legal Consultant at Fiscal Solutions

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