Independent Activities: Problems and Solutions Facing Freelancers of All Kinds

Craftsmen, artists, journalists, lawyers, healthcare workers, notaries, auditors, engineers, architects, translators, writers, family farms, in other words, all those who perform independent activities will be subject to fiscalization 2.0 starting January 1 of next year, which means that in transactions with other taxpayers they will have to issue e-invoices and fiscalize them. Those who are not in the VAT system will have to start receiving e-invoices from January 1, 2026, and from January 1, 2027, they will also have to issue and fiscalize them. The new Fiscalization Law came into effect on September 1, 2025, and there is a transitional period until the beginning of next year. Compared to fiscalization 1.0, which included citizens and cash or card payments, the new law regulates business transactions among entrepreneurs (B2B) and with the state (B2G) and introduces mandatory application of e-invoices.

Fiscalization 2.0 will enable the Tax Administration (the state) to monitor the purchase of goods and services, their prices, and further sales in real-time. Penalties for non-compliance with deadlines, i.e., failure to provide data on the rejection or collection of e-invoices for legal entities, range from 1,320 to 26,540 euros, and for responsible persons from 260 to 2,650 euros. Invoices must be stored in their original XML format, and those who do not comply will face a fine of 66,360 euros. A mitigating circumstance for those engaged in independent activities is MIKROeRAČUN, a free tool from the Tax Administration for micro-entrepreneurs who are not in the VAT system. This is a free application within the eTax system, a unique portal of the Tax Administration, available at any time from anywhere.

For Whom It Is Free

MIKROeRAČUN replaces the need to maintain a series of tax records and reports, reduces business costs, accelerates operations by saving time and reducing the need for human labor, and the data is secure. If freelancers decide to use the mentioned application by the end of the year, from the beginning of next year they will not have to seek or contract another information intermediary. If a user becomes a VAT payer during this time, they will not have the right to use the MIKROeRAČUN application and will have to choose another information intermediary.

As simple as it may seem at first glance, accountants believe that not everything is ready, they will have more work than before, and they expect problems in implementation. According to Dubravka Kopun, a certified auditor from the Kopun Group, a company that provides accounting services, auditing, tax and legal consulting, and identifying business difficulties, and is a member of Nexia International, a global network of independent accounting and consulting firms, the idea of e-invoices is not new – it has been discussed in accounting circles for over twenty years. The first e-invoices in the world emerged more than two decades ago, with Chile introducing them back in 2003, followed by Brazil and Mexico. In the European Union, this story is fifteen years old, culminating in March 2025 with the VAT in Digital Age package (ViDa), which anticipates the introduction of e-invoices. By July 1, 2030, electronic exchange of invoices and electronic reporting on invoices issued between two EU member states should be introduced, and by January 1, 2035, e-exchange of invoices and e-reporting on invoices issued between all EU member states. Croatia is one of four EU members introducing electronic invoices nine years ahead of the deadline.

Expensive Mistakes Due to Classification

The European Commission published the state of the legislative framework within member states related to the ViDa project last summer, according to which Croatia, Poland, Belgium, and Denmark will introduce e-invoices starting in 2026.

– In this context, there are four key pieces of information that everyone must understand: the first is that within fiscalization at the (B2B) level, every line of the invoice is exchanged with the Tax Administration – every product, every service, and data about them, such as the usual name, unit price, quantity, total value, must be submitted to the Tax Administration. The second is that every product/service must be linked to the Classification of Products by Activities (KPD); this is a fairly detailed classification at the six-digit level. Operationally, there are still many questions regarding this classification. A special e-address has been provided by the State Bureau of Statistics to which all questions can be directed, but we hear from clients that there are situations where there are no answers to their questions or the questions are redirected to the Tax Administration. To make matters worse, if you choose the wrong classification, it is considered a minor offense under the provisions of the Fiscalization Law, for which a fine of 1,320 to 26,450 euros is prescribed – explains Kopun.

Programmers Becoming Intermediaries

According to her, there is also a problem with information intermediaries for exchanging this data between ERP systems and the Tax Administration. The problem at this stage is that the exchange of data between the Tax Administration and information intermediaries is defined by the Tax Administration, but the modality of information exchange between the information intermediary and individual ERPs is not defined.

– The result is that each information intermediary has its own processes and procedures, which makes it time-consuming to align data exchange with the information intermediary. For the software package we use, it took them three months to align data exchange with each information intermediary. So far, they have done this with two intermediaries. Because of this, the decision about the information intermediary is not made by the end user, but by the programmers whose ERP is used. Some programmers are already considering becoming information intermediaries because it is simpler for them to program the data exchange with the Tax Administration once, for which there are defined rules, than with different information intermediaries – explains Kopun.

Additional Records and Revisions for All

She adds that the Ministry of Finance is announcing in the media that the introduction of e-invoices will significantly relieve the economy, but little is said and written about the additional records being introduced, which will require additional engagement from accountants.

– Two new records are being introduced, along with data on rejected e-invoices. For each invoice that will not be liquidated, which the recipient rejects, it is stipulated that the Tax Administration must be notified by the twentieth of the month for the previous month. By that date, the Tax Administration must also report on all collected e-invoices from the previous month. A new feature is the FiskAplikacija, which will be used to control fiscalized invoices, rejected and collected invoices, which will need to be monitored additionally – says Kopun.

And that’s not all. She adds that at this stage, what is most concerning is that the legal provisions stipulate that the Minister of Finance must adopt an implementing regulation within ninety days from the date the law comes into force, i.e., by the beginning of December.

– Although the provisions of the Law stipulated that by September 1 of this year, the Minister of Finance would create a list of information intermediaries available on the Tax Administration’s website, this is still not the case. Almost every week, the Tax Administration is revising the technical documentation. For example, on September 10, 2025, it announced that a new version of the retail fiscalization service (F1) would be available by early November 2025, leaving programmers and users two months to adjust their fiscalization processes by the beginning of 2026. At the end of September, the instructions related to data exchange in fiscalization F2 (data exchange between the information intermediary and the Tax Administration, note) were revised. Our clients have questions about this, and we are also wondering how it will work in live mode starting January 1 of next year – concludes Kopun.