Federation of Bosnia and Herzegovina: How Will Migration to the New Fiscalization System Work in Practice?

Retailers in FBiH do not have to replace their current fiscal systems immediately. Migration to the new fiscalization model will be gradual, with different transition periods and special rules allowing certain existing fiscal systems to remain in use.

The practical implementation of the new fiscalization system in the Federation of Bosnia and Herzegovina will be a phased migration rather than a single mandatory switch for all businesses.

Although the new Law on Fiscalization of Transactions formally entered into force in February 2026, retailers were not required to stop using their existing Fiscal Devices at that time. The Law separates three different stages: entry into force, beginning of application, and the actual migration of individual taxpayers.

For retailers and POS providers, the most relevant question is therefore not when the Law entered into force, but when the new system begins to apply and when a particular business must migrate to it.

February 2026 marked the start of the legal implementation process. It did not represent the date on which retailers had to replace their current Fiscal Devices or switch their POS systems to the new fiscalization architecture.

Under Article 90 of the Law, the new fiscalization regime begins to apply only after the necessary secondary legislation has been adopted and the required technical and administrative capacities have been established.

The Law also sets a maximum timeframe for this implementation phase. Application must begin within the statutory period prescribed by the Law, which places the expected outer limit in 2027.

This starting date is essential because the migration periods for businesses are calculated from the beginning of application of the new Law, not from February 2026.

Different businesses will migrate at different times and what does it mean?

Once the new regime begins to apply, businesses will not necessarily migrate on the same date. Article 86 establishes different maximum transition periods depending on the type of transaction. Businesses carrying out B2C transactions must align their operations with the new fiscalization rules within a maximum of two years from the beginning of application. Businesses carrying out B2B and B2G transactions have a maximum period of three years from the beginning of application.

These are maximum statutory periods. They should not be understood as confirmation that every taxpayer can automatically wait until the final day of the two- or three-year period.

The Federal Minister of Finance must prescribe the actual fiscalization dynamics, meaning the timetable according to which different groups of taxpayers will migrate.

In practice, this future rulebook may divide businesses into migration groups according to transaction type, business activity, taxpayer category or another criterion established by the implementing rules.

For this reason, the exact migration date for an individual retailer cannot yet be determined only from the Law.

What happens to existing Fiscal Devices?

Based on the current state of regulations, existing Fiscal Devices do not automatically become unusable once the new fiscalization model starts. The transitional provisions, in their current status, specifically allow certain taxpayers that are already using fiscal systems under the current Law on Fiscal Systems to continue using those systems during the transition.

A qualifying existing fiscal system may remain in use for up to four years from the beginning of application of the new Law, provided that the statutory conditions are met.

Among other conditions, the fiscal system must comply with the technical and functional requirements applicable under the existing regime and must already have been used by the taxpayer before the new Law begins to apply.

The four-year period is therefore a special transitional possibility, rather than the standard migration deadline for every retailer.

A retailer should not assume that the existence of this four-year provision automatically gives it four additional years. Its actual migration date will depend on whether the existing system qualifies for transitional use and on the migration schedule adopted by the Ministry.

Also, migration may involve software changes, not only hardware replacement:

The new fiscalization architecture also changes how businesses should think about system replacement.

The future model is based on the Electronic System for Recording Transactions (ESET). The Law describes ESET as a software application or cloud solution used for recording and processing transactions, generating security information, communicating with the Tax Administration and performing other fiscalization functions.

ESET may operate on different types of equipment, including computers, mobile devices, tablets, cash registers or similar devices.

For retailers, this means that migration should not automatically be interpreted as an obligation to purchase a completely new physical cash register.

The actual technical changes may instead involve a combination of POS software changes, ESET implementation, Security Module integration, communication with the Tax Administration and possible replacement or reuse of existing hardware.

The final technical requirements cannot yet be determined in detail because the implementing technical specifications and approval procedures remain essential for defining what compliant migration will require.

What is the impact on retailers and POS providers?

For retailers, the main practical task is to identify which migration path applies to their current setup. Businesses using existing fiscal systems should determine whether those systems may qualify for transitional use and should avoid planning migration solely on the assumption that the four-year maximum period applies automatically.

For POS providers, migration will require closer attention to the technical framework for ESET, the Security Module, communication with the Tax Administration and any future approval or registration requirements. Current preparatory activity does not itself create a migration obligation for retailers and does not replace the formal technical documentation or migration timetable.

What should businesses do now?

Retailers must continue using and maintaining their currently applicable fiscal systems in accordance with the existing rules until their migration obligation under the new regime becomes effective.

POS providers should prepare for future ESET integration but should avoid implementing assumptions about communication protocols, certification or security requirements until the official technical rules are published.

Both retailers and providers should monitor two important documents in particular: the rulebook governing fiscalization dynamics and the technical and functional specifications for ESET, the Security Module and communication with the Tax Administration. These are not yet available.

What I would point out is that treating the transition as a single replacement date is not correct. The Law instead creates a staged migration model: the new regime first becomes applicable, different taxpayer categories then move according to the prescribed dynamics, and some existing systems may continue temporarily under the transitional provisions.

For implementation planning, the correct question is therefore not when does the old system end for everyone, it is rather when does this specific retailer have to migrate, and can its existing fiscal system remain in use until that date?

The principal legal basis is the Law on Fiscalization of Transactions in the Federation of Bosnia and Herzegovina, Official Gazette FBiH No. 9/2026, particularly the provisions concerning ESET and the transitional rules in Articles 86–90 specifically. Source

Tara Nedeljković, Team Lead of Legal Consultants at Fiscal Solutions

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