Croatia: MIKROeRAČUN Upgrade Will Add Free e-Invoice Issuance for Non-VAT Taxpayers in 2027

From January 1, 2027, certain Croatian taxpayers outside the VAT register will also have to issue e-Invoices for domestic transactions. The Tax Administration is upgrading MIKROeRAČUN so eligible users can issue, receive, fiscalize and store eInvoices without purchasing an additional solution.

The Croatian Tax Authority announced that it is upgrading its MIKROeRAČUN application to support the next phase of Croatia’s e-Invoicing and Fiscalization 2.0 rules. The change is not a new legal obligation created by the September announcement. The obligation already follows from the Fiscalization Act, while the announcement explains how eligible smaller taxpayers will be able to meet it through the Tax Administration’s free application.

From January 1, 2027, the e-Invoice issuance obligation expands to certain taxpayers that are not registered for VAT. Article 38 of the Fiscalization Act covers, among others, income-tax taxpayers carrying out independent activities and corporate-income-tax taxpayers that are not in the VAT register and have their seat, residence or usual residence in Croatia. The Act applies the e-Invoice requirement to domestic transactions falling within its scope.

During 2026, MIKROeRAČUN already allows eligible users to receive, review, search, reject and store e-Invoices through the e-Porezna system. It also supports fiscalization of received e-Invoices and their rejection. The Tax Authority is now adding the functionality needed for outgoing e-Invoices.

Once the upgrade becomes applicable, MIKROeRAČUN will support the issuance and fiscalization of outgoing e-Invoices as well. The Fiscalization Act defines the application as a tool for issuing, receiving and storing e-Invoices and for fiscalizing issued and received e-Invoices. Its use is free of charge. The part of the legislation concerning e-Invoice issuance through MIKROeRAČUN becomes applicable on January 1, 2027.

However, MIKROeRAČUN is not a general free e-Invoicing platform for every Croatian business. Under Article 55, the right to use it is limited to e-Porezna users who are not registered for VAT and are not public contracting authorities subject to the rules on electronic invoicing in public procurement. The Tax Authority’s terms further identify the intended users as relevant income-tax and corporate-income-tax taxpayers outside the VAT register.

The upgraded version is scheduled to become available for testing during October 2026. The Tax Administration has also stated that educational materials, user instructions and other information will be published so users can become familiar with the new issuance functions before the January 2027 obligation starts.

For retailers, an important distinction is between e-Invoice obligations and fiscalization of final-consumer sales. The 2027 extension does not mean that every transaction processed through a retail POS must be converted into an e-Invoice.

A small retailer outside the VAT register may therefore have two different processes. A standard final-consumer sale may continue through the applicable retail fiscalization process, while an in-scope domestic business transaction may require an e-Invoice. MIKROeRAČUN can provide the e-Invoice route for eligible businesses without requiring them to purchase a separate e-invoicing application.

The upgrade therefore has a more direct impact on invoicing, accounting and back-office processes than on the POS itself.

Impact on affected businesses and solution providers

For eligible non-VAT businesses, the practical benefit is that the Tax Authority is providing a no-fee route for managing the e-Invoice lifecycle. This may reduce the need to acquire an additional commercial solution solely to handle the new issuance requirement.

ERP, accounting and POS providers should nevertheless identify which customer workflows will use MIKROeRAČUN and which will continue through other systems. Businesses with mixed B2C and B2B activity may need clear internal procedures so employees know when the retail fiscalization process applies and when an eInvoice must be handled.

The October testing period is therefore relevant even for businesses planning to rely entirely on the free application. It allows users to understand the issuance workflow, check their access through e-Porezna and determine how MIKROeRAČUN will fit into their existing invoicing and accounting procedures before January 2027.

What should affected businesses prepare for?

Eligible businesses intending to use MIKROeRAČUN should use the October 2026 testing period to become familiar with the new issuance functionality and review the Tax Authority’s updated instructions as they are published. They should also confirm that they meet the conditions for using the application and map which transactions will require an eInvoice from January 1, 2027.

Retailers should pay particular attention to the separation between B2C fiscalized sales and B2B e-Invoice flows. Software providers should avoid assuming that the MIKROeRAČUN upgrade itself creates a POS integration requirement; any system changes should be based on the retailer’s actual invoicing process and the applicable technical guidance.

From a retail compliance perspective, the main implementation risk is not the availability of a free tool but correctly determining which transaction belongs to which fiscal process. Businesses that combine final-consumer sales with invoiced domestic B2B transactions will need procedures that prevent duplicate or incorrect document treatment. The testing period should therefore be used not only to learn the application but also to validate the surrounding business process.

The official source for this article is the Tax Authority announcement confirming the application upgrade and the October 2026 testing period: Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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