The Biggest Challenges of Fiscalization 2.0: KPD Codes and ERP Adaptation

September has ended, marking the first test month of fiscalization 2.0, which realistically signifies a new era for Croatian accounting. This is the first month in which entities that will be subject to the new system could test their solutions, although the actual implementation begins only on January 1, 2026. Nevertheless, September was anticipated as a crucial compliance test.

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According to information we received from the Tax Administration, although the Fiscalization Act came into force on September 1, 2025, the obligation to exchange eInvoices, fiscalize cashless invoices, and eReporting will take effect from January 1, 2026. Accordingly, there are still no taxpayers conducting fiscalization and eReporting activities.

Regarding technical issues during this testing period, the Tax Administration stated that they are available to everyone and directed them to publicly published documentation on the Fiscalization 2.0 portal: ‘Specification of Basic Use of eInvoices with Extensions’ as well as the document ‘Description of Business Processes’ and examples of eInvoices, while the Tax Administration’s eInvoice Fiscalization page also published the most frequently asked questions from users.

– The documentation is publicly available, so we certainly invite all interested parties to find answers, and for open questions, communication is also available through the official web form ‘Contact Us’ – stated the Tax Administration.

– We frequently update the technical documentation published on the Fiscalization 2.0 portal and try to cover as many details and examples as possible to facilitate and support the development of software solutions for a secure and accurate process of fiscalization and eReporting – added the Tax Administration.

It’s Not That Simple

We asked experts from Forvis Mazars, who are also accounting advisors and ERP implementation consultants in finance and accounting, about the most common difficulties entrepreneurs have faced in the past month.

– The biggest challenge is classifying products and services according to KPD codes. In practice, it has proven to be not as simple as it initially seemed. An additional difficulty arises from adapting business processes: in larger systems, the technical implementation of ERP can be organized, but the problem arises because it is necessary to simultaneously change the way a larger number of employees work. The uncertainty is further exacerbated by the fact that a number of questions are still awaiting regulations, which carries the risk of last-minute adjustments – said Benita Rabuzin, the director of the accounting and external services department at Forvis Mazars.

Rabuzin also mentioned that the selection of an intermediary for sending eInvoices is often cited as a challenge since the law prescribes the selection of one intermediary, and the solutions technically differ, meaning that any change of intermediary also entails a new implementation and additional costs.

And now that this testing phase has begun, the real question is whether entrepreneurs, especially small and micro ones, are sufficiently prepared for the new requirements? According to Rabuzin, currently, very few entrepreneurs can say they are fully prepared and have implemented all necessary changes.

– Most rely heavily on the software solutions they use and on accounting services and consultants to obtain clear and reliable instructions. This is yet another in a series of regulatory changes introduced in a short time. Entrepreneurs are somewhat accustomed to such situations, but they are still burdened by uncertainty and a lack of time for thorough preparation – claims Rabuzin.

However, she adds, in the long run, fiscalization 2.0 should bring benefits, simplify the issuance and receipt of invoices, accelerate bookkeeping, and reduce administrative burdens.

– The path to this will not be easy and will require process adjustments, education, and collaboration with experts, but in the end, it should pay off. It may not immediately look like a digital paradise, but the goal is precisely to facilitate everyday business operations – concludes Rabuzin.