Fiscalization 2.0 for restaurants: e-invoices from 2026 and what to do.

Fiscalization 2.0 is the name for the changes brought by Croatia's new Fiscalization Act ("Zakon o fiskalizaciji", NN 89/2025). Three of them matter for hospitality businesses:

• From 1 January 2026, a VAT-registered hospitality business issues and receives e-invoices (eRačun) when it deals with other companies and sole traders.
• A hospitality business that is not registered for VAT receives e-invoices from 1 January 2026 and issues them from 1 January 2027.
• Every issued and every received e-invoice is fiscalized (Article 47).

What an e-invoice is

An e-invoice is an invoice in a structured electronic format that software can process automatically (Article 2). A PDF invoice sent by email is not an e-invoice. The Tax Administration says the same.

Your POS still issues and fiscalizes the guest's receipt. It carries the JIR, the ZKI and a QR code (Article 7).

From 1 January 2026, receipts are fiscalized whatever the payment method, including when the guest pays by bank transfer. The Tax Administration says so in its questions on receipts to end consumers.

A company that pays you in cash or by card can get a regular fiscalized receipt from your POS instead of an e-invoice (Article 39). The POS then also sends the company's tax number (OIB) to the Tax Administration (Article 15). As the issuer, you decide which one to issue.

From 1 January 2026, VAT-registered hospitality businesses must receive e-invoices, and so must companies and sole traders that are not registered for VAT, including lump-sum sole traders (paušalisti) (Articles 2 and 41). The steps are:

1. Choose an information intermediary, that is, a solution for receiving e-invoices.
2. In FiskAplikacija on the ePorezna portal, confirm the address for receiving e-invoices. The Tax Administration set 31 December 2025 as the deadline for this.
3. In FiskAplikacija, authorize whoever fiscalizes on your behalf, for example the intermediary.
4. Every received e-invoice must be fiscalized within five working days of receipt (Article 48(4)).
5. If you reject an e-invoice, the rejection is reported to the Tax Administration by the 20th of the following month (Article 52).

The POS and e-invoicing are two separate solutions

The POS issues receipts to guests. Suppliers' e-invoices come in through a separate solution. A business that only issues POS receipts to guests but receives e-invoices from suppliers needs both. The Tax Administration says so in its questions and answers on e-invoices.

An information intermediary (informacijski posrednik) is a company that sends, receives and fiscalizes e-invoices on your behalf (Article 2). You sign a contract with it.

The Tax Administration publishes the list of information intermediaries that hold a certificate of conformity. The list dated 16 October 2026 has 37 intermediaries. They include Fina, ePoslovanje by Pondi d.o.o. and the mer solution by Elektronički računi d.o.o., with the moj-eracun.hr portal.

Before you choose, check:

• whether the intermediary is on the Tax Administration's list
• the price per received and sent e-invoice and the monthly fee
• whether it fiscalizes received e-invoices and handles e-reporting (eIzvještavanje)
• whether your bookkeeper can collect e-invoices from it

Restaurant software is not an intermediary

Restaurant or accounting software is not an information intermediary unless it is on the list itself. The Tax Administration states that a contract with such software alone, without a contract with an intermediary, does not comply with the law.

During 2026, a sole trader not registered for VAT, including a lump-sum sole trader, receives and fiscalizes e-invoices. They issue their own invoices as before.

From 1 January 2027, they must also issue e-invoices when the buyer is a company or a sole trader, however many invoices they issue (Articles 38 and 80).

For taxpayers not registered for VAT, the Tax Administration offers the free MIKROeRAČUN app (Articles 54 to 56). It receives e-invoices from 2026, and since 21 October 2026 it can issue them too. MIKROeRAČUN does not issue receipts to guests. A sole trader who does not want to use it chooses a commercial intermediary.

For a company that does not receive e-invoices or does not fiscalize them, the law sets a fine of 3,980 to 66,360 EUR. For a sole trader, the fine is 3,980 to 39,810 EUR (Article 71).

The Tax Administration has announced that it will not bring misdemeanour proceedings for errors in the initial phase of applying the law.

Patrono does not create or send invoices. Your POS issues and fiscalizes guest receipts. Patrono is not an information intermediary either.

If you receive e-invoices through ePoslovanje, Patrono pulls them in as soon as they arrive. Supplier, amount, due date and line items land in Finance without retyping. Receiving e-invoices costs you nothing extra.

Croatia's Fiscalization Act ("Zakon o fiskalizaciji"), NN 89/2025. The e-invoice provisions apply from 1 January 2026, and the duty to issue e-invoices for those not registered for VAT from 1 January 2027 (Article 80).

Tax Administration ("Porezna uprava"): eRačun, questions and answers on e-invoices, receipts to end consumers and the list of information intermediaries, all in Croatian, read on 21 October 2026.