Croatia Clarifies eInvoicing Business Process Codes with New Official Guidance

Croatia’s Tax Administration published updated guidance on October 20, 2026, explaining how to match eInvoice document types with business-process codes P1–P12 and P99. Process codes are mandatory, but the suggested document-code combinations are recommendations, not new legal requirements.

Croatia’s Tax Administration published an updated document titled Description of Business Processes (Opis poslovnih procesa), announced on October 20, 2026. The document explains how businesses should select the appropriate business-process identifier and associate it with the corresponding document type when issuing, exchanging, and fiscalizing electronic invoices (eRačuni).
The guidance provides practical examples covering advance payments, ordinary sales, periodic invoicing, credit notes, invoice corrections, and self-billing.
Importantly, this publication does not introduce new legal obligations or implementation deadlines. Instead, it clarifies how businesses should apply the existing technical requirements under Croatia’s Fiscalization 2.0 framework.
What does the new guidance clarify?
Under Croatia’s Specification for the Basic Use of eInvoices with Extensions, every eInvoice must contain a business-process identifier describing the circumstances of the transaction.
This information is also included in the corresponding fiscalization message, allowing the transaction to be identified consistently throughout the invoicing and fiscalization process. The business-process field, identified as BT-23 in the eInvoice specification, is mandatory. The updated guidance explains which codes correspond to particular commercial activities and recommends appropriate document-type codes for each process.
The distinction is important: including a valid business-process identifier is mandatory, while the combinations of business-process and document-type codes presented in the new guidance are recommendations. Businesses should therefore use the document to improve their invoicing configurations without interpreting every suggested combination as a newly introduced legal requirement.
Which business processes are covered?
The guidance describes 13 business-process identifiers covering different invoicing scenarios.
Standard sales and payment processes include P1 for deliveries under existing contracts and purchase orders, P2 for periodic contractual invoicing, and P3 for individual orders without a previously established contractual relationship.
P4 covers advance payments, P5 refers to payment at the point of sale, and P6 applies when an invoice is issued against a purchase order and paid before delivery.
Delivery-related processes include P7 for invoices referencing dispatch notes and P8 for invoices referencing both dispatch notes and goods-receipt confirmations.
Adjustments and special invoicing processes include P9 for credit notes or negative invoices, including returns of packaging, and P10 for correcting or cancelling previously issued invoices.
P11 covers partial and final invoices, P12 applies to self-billing arrangements, and P99 allows a buyer-defined business process where the standard categories do not adequately describe the transaction. Each category is explained through practical business situations, together with recommended document-type codes.
What are the most important differences between the processes?
Several distinctions are particularly relevant for retailers, invoicing software providers and businesses managing different transaction types.
Advance payments versus payment before delivery (P4 and P6)
P4 applies when a customer makes an advance payment before delivery. The guidance describes issuing an advance invoice, subsequently cancelling it and issuing the invoice for the completed supply.
P6 concerns an invoice issued for a specific purchase order before delivery, which the customer pays before receiving the goods or services. Unlike P4, this does not involve an advance invoice subsequently replaced by a final invoice.
Credit notes versus invoice corrections (P9 and P10)
P9 applies when a subsequent commercial event justifies reducing an amount previously invoiced, such as returned goods, returned packaging or an additional discount.
P10 concerns correcting an error in the original invoice, including incorrect prices, quantities, VAT rates or discounts.
For example, a newly granted discount belongs under P9, while correcting a discount that should already have appeared on the original invoice belongs under P10. The guidance also explains that corrective documents should reference the original invoice.
Payment at the point of sale (P5)
One particularly relevant clarification concerns transactions paid immediately by cash or card.
Where the specified conditions are satisfied, the issuer may use the existing Fiscalization 1.0 (F1.0) procedure, including submitting the recipient's OIB (Croatian identification number).
However, when this option is used, the issuer cannot also issue and fiscalize an eInvoice for the same transaction. The choice of procedure belongs to the invoice issuer. This distinction matters for businesses operating POS systems alongside B2B e-invoicing solutions.
How should document types be matched with business processes?
The document provides recommended document-type codes for each business process.
For example, process P4 includes document code 386 for advance invoices and code 380 for commercial invoices.
For P9, the guidance recommends codes 213 and 381, while P10 includes codes 83, 213, 381, and 384 for different correction-related documents.
For self-billing under P12, the recommended codes include 261, 389, and 527.
These examples help businesses and software developers establish consistent mappings between commercial transactions, document types, and business-process identifiers. For users of the Croatian Tax Administration’s MIKROeRAČUN application, the selection is simplified because document types and corresponding business processes are already linked within the application.
Impact on affected businesses
The guidance is relevant to businesses issuing and receiving Croatian eInvoices, including retailers, retail chains, e-commerce businesses, accounting departments, ERP providers, and eInvoicing software developers.
For retailers, the main consideration is correctly identifying the transaction and selecting the corresponding business process, particularly when handling advance payments, returns, corrections, and B2B sales paid at the checkout.
For POS providers and software developers, the document offers practical support for configuring business-process identifiers, document-type mappings, and invoice-generation workflows.
Existing systems may require a configuration review, but the publication itself does not establish a general obligation to replace software or introduce new fiscalization functionality.
What should businesses do?
Affected businesses should review how their systems assign business-process identifiers and match them with document types, particularly for advance payments, credit notes, invoice corrections, and POS transactions.
They should also verify whether existing configurations follow the Tax Administration’s recommended mappings and ensure that users understand the distinction between mandatory technical requirements and recommended practices.
The guidance can be used immediately to improve existing invoicing workflows. No new implementation deadline has been established by this publication.

The main source confirming the updated business-process guidance is the published official announcement published by the Croatian Tax Administration on October 20, 2026. 

Filip Kalaba, Junior Legal Consultant at Fiscal Solutions