Croatia Updates B2C Fiscalization Rules: New Certificate and Self-Service Payment Requirements from 2027

Croatia’s amended B2C fiscalization rulebook takes effect on January 1, 2027, introducing changes to digital certificates, electronic signatures, and self-service payments. Retailers and POS providers should review their fiscalization systems and technical compliance before the deadline.

Croatia has introduced amendments to the Rulebook on the Fiscalization of Invoices in Final Consumption, establishing updated technical and procedural requirements for businesses subject to fiscalization. The amendments were published in Official Gazette No. 97/2026 on September 2, 2026, and will enter into force on January 1, 2027.

The amendments were adopted by the Ministry of Finance on August 27, 2026, under Article 32 of the Fiscalization Act (Official Gazette No. 89/2025). They modify the existing Rulebook (Official Gazette No. 153/2025), particularly regarding digital certificates, electronic signatures, technical specifications, and sales conducted through self-service devices.

The changes were also highlighted in an October 6, 2026 regulatory update, drawing attention to the preparations required before the new rules become applicable.

What Are the Main Changes?

1. Digital certificates can be obtained from a broader range of trust service providers

From January 1, 2027, taxpayers subject to fiscalization must use a digital certificate containing their Croatian Personal Identification Number (OIB).

The certificate must be issued by a trust service provider included in the relevant trusted list under EU Regulation No. 910/2014 (eIDAS) and Regulation (EU) 2024/1183 concerning the European Digital Identity Framework.

The previous wording referred specifically to trust service providers in Croatia. The amended rules remove this national restriction, allowing certificates from eligible providers operating under the applicable EU framework.

Additional requirements include:

• Taxpayers testing fiscalization procedures must obtain a DEMO digital certificate containing their OIB.
• Businesses may independently determine the number of digital certificates required, depending on their fiscalization system's connection model.
• Digital certificates issued before January 1, 2027, may continue to be used until their expiration date.
• Consequently, the amendments do not automatically require every retailer to replace an existing valid certificate when the new rules take effect.

2. Electronic signatures and cryptographic requirements are linked to technical specifications

The amended Rulebook specifies that electronic signing must be performed using a valid digital certificate issued by an eligible trust service provider.

The signing methods must comply with the Technical Specification for Users published by the Croatian Tax Administration.

Additionally, the Rulebook explicitly specifies that the cryptographic hash function produces a 32-character hexadecimal string, consisting of numbers 0–9 and lowercase letters a–f, which must be printed on the fiscal receipt.

The 32-character security-code format already existed within the Croatian fiscalization framework. Therefore, the amendment should be understood as an update and clarification of the applicable technical provisions rather than the introduction of an entirely new receipt identifier.

POS software providers should ensure that their electronic-signature implementation and receipt-generation processes comply with the applicable technical specifications.

3. Self-service fiscalization explicitly covers additional payment methods

An important amendment concerns Article 27, which regulates sales conducted through self-service devices without the participation of a salesperson.

Previously, Article 27(2) specifically addressed transactions where payment was made by sending an SMS message.

The amended provision explicitly extends this treatment to payments made:

• By card;
• Through mobile applications;
• Through other similar payment methods.

This clarification is particularly relevant for automated retail environments, including vending machines and other unattended sales systems.

Businesses operating these devices should assess whether their payment and sales processes fall within the updated self-service fiscalization provisions.

Importantly, the amendment concerns the classification and fiscalization of unattended sales transactions. It does not establish a general new payment-method requirement for all retail transactions.

4. Additional procedural and administrative amendments

Several other provisions have been revised to simplify or clarify the existing regulatory framework.

Article 4, which previously contained provisions concerning the Public Key Infrastructure (PKI) system and taxpayer registration with certificate providers, has been deleted.

Article 5 changes the information maintained by the Croatian Tax Administration. Instead of recording the start of certificate use and the certificate issuer, the amended provision refers to the taxpayer's identification details and the date of the first fiscalized invoice.

Furthermore, Article 23 removes several detailed provisions concerning production and test environments. The applicable environment-related requirements are now expressly linked to the Tax Administration's Technical Specification.

Other amendments include adjustments to technical references and terminology throughout the Rulebook.

Notably, the amendment also deletes Article 47(6), which previously allowed taxpayers conducting foreign-exchange operations to establish a cash maximum of up to EUR 15,000 regardless of certain general business-size provisions. Affected operators should reassess their applicable cash-maximum rules.

Impact on Affected Businesses

The amendments directly concern retailers subject to Croatian B2C fiscalization, operators of self-service machines, POS software providers, and fiscalization technology integrators.

For retailers, the principal consideration is whether their existing digital certificates and fiscalization processes will remain compliant from January 2027. Businesses using valid certificates issued before that date may continue using them until expiration, subject to the applicable requirements.

For POS providers and software developers, the amendments require particular attention to electronic signatures, cryptographic procedures, certificate management, and alignment with official technical specifications.

Operators of automated retail systems should also review their payment configurations, especially where transactions are completed by card or mobile application without staff involvement.

The changes may require technical adjustments depending on the existing implementation, but they do not automatically mean that all businesses must replace their fiscalization hardware or POS software.

What Should Affected Businesses Do Before January 2027?

Retailers and technology providers should prepare for the new requirements by taking the following steps:

• Review existing digital certificates: Verify their validity, OIB information, issuing providers, and expiration dates.
• Check POS technical compliance: Confirm that electronic signatures, cryptographic procedures, and receipt security codes comply with official specifications.
• Assess self-service transactions: Review automated sales and payment methods to determine whether system or procedural changes are necessary.
• Verify testing configurations: Ensure that DEMO certificates and test-environment connections meet the applicable requirements.
• Review cash-management provisions: Foreign-exchange operators should reassess their cash-maximum arrangements following the deletion of the specific exception.
• Monitor official technical documentation: Follow any relevant updates published by the Croatian Tax Administration before implementation.

The amendments are already adopted, with their application beginning on January 1, 2027. Businesses should use the remaining preparation period to identify any necessary compliance adjustments.

The main source confirming these requirements is the amendment published by the Croatian Ministry of Finance in Official Gazette No. 97/2026 and: https://narodne-novine.nn.hr/clanci/sluzbeni/2026_09_97_1181.html   together with the technical documentation maintained by the Croatian Tax Administration.

Filip Kalaba, Junior Legal Consultant at Fiscal Solutions