Fiscalization 2.0 and Flat-Rate Hosts in Croatia: Who Actually Has to Fiscalize in 2026?

The announcement of Fiscalization 2.0 has triggered a wave of uncertainty among Croatian hosts. Numerous portals, advisors, and AI-generated articles write as if every host must purchase fiscalization software and a FINA certificate by 1.1.2026. — which is simply incorrect.

The key distinction: Croatian law differentiates between private flat-rate hosts (paušalisti who pay flat-rate income tax via a Tax Administration decision) and flat-rate sole proprietorships or companies engaged in rentals (paušalni obrt). These two categories have completely different obligations.

This article separates those categories under the Croatian Fiscalization Act (OG 89/2025) and Tax Administration clarifications, and helps hosts determine their true status before spending money on software they may not need.

— 01Private Flat-Rate Hosts (Paušalisti): You Are NOT Subject to Fiscalization 2.0

Private hosts who pay flat-rate income tax on rental income, via a Tax Administration decision, are NOT obligors under Fiscalization 2.0. The reason is systemic and follows from the tax classification — a paušalist earns income from property, not income from self-employment. For that same reason, paušalisti were not obligors under Fiscalization 1.0 either, and they do not become obligors under the current expansion.

The reason is systemic. The legal classification of income under the flat-rate system reads "income from property," not "income from self-employment." That's why a paušalist:

• is NOT a VAT taxpayer and is not in the VAT register
• does NOT register a sole proprietorship (obrt) or business activity
• has NO obligation to issue fiscalized invoices with JIR/ZKI codes
• does NOT need a FINA certificate or fiscalization software
• has NO obligation to issue or receive eInvoices (B2B/B2G eInvoice obligation applies only to VAT taxpayers)

How to recognize you're a paušalist in this sense: you have a Porezna uprava decision on flat-rate taxation of rental income, you pay flat-rate per bed/unit annually (typically €19.90–€199 per bed depending on tourist zone, set by the local municipality), and your registration is under your personal OIB (tax ID) as a private individual — not behind a company or sole proprietorship.

— 02When You Become an Obligor: Flat-Rate Sole Proprietorships and Registered Businesses

The fiscalization obligation only exists when you conduct rentals through a registered self-employment activity — typically a paušalni obrt (flat-rate sole proprietorship), a classical obrt, a j.d.o.o. (simple limited company), or a d.o.o. (limited company). In that case you are an entrepreneur, not a private person with income from property.

For flat-rate sole proprietorships engaged in registered rental activity, from 1.1.2026. fiscalization of every invoice issued to end consumers (guests) is mandatory, regardless of the payment method — cash, card, or bank transfer. This is the Fiscalization 1.0 extension (until now only cash payments were fiscalized).

Additionally, during 2026, flat-rate sole proprietorships may still issue paper invoices, but are required to receive eInvoices from VAT-registered suppliers and fiscalize that receipt. From 1.1.2027., sole proprietorships must both issue and receive eInvoices.

— 03Booking.com, Airbnb and Bank Transfers: What This Looks Like If You ARE an Obligor

If you operate a sole proprietorship or company, this section is for you. Private hosts can skip it — these rules do not apply to you.

What changes on 1.1.2026. for obligors (Fiscalization 1.0 extension): until now, only cash transactions were fiscalized. From 2026, every invoice to a guest is fiscalized, regardless of payment method.

Note: this is the opposite of much older advice circulating online. Previously, the rule was "OTA platforms handle this for you" — that was true only under Fiscalization 1.0 (cash transactions). From 2026, the extension means even OTA platform bank transfers carry a fiscalization obligation for obligors.

For VAT-registered taxpayers, on top of that comes the obligation to issue and receive eInvoices in B2B and B2G transactions from 1.1.2026. For small sole proprietorships not yet in the VAT system, eInvoices are an obligation to receive in 2026, and to issue from 2027.

— 04What If You're Not Sure About Your Status?

In practice, the biggest risk isn't your identity — it's assumption. Many hosts forget they once opened then closed a sole proprietorship, or they think flat-rate is the same as a sole proprietorship. Three steps every host should take before the end of 2025:

1. 1 Check your Tax Administration decision: does it say "income from property" (paušalist, exempt) or "self-employment / sole proprietorship" (fiscalization obligor)?
2. 2 Check your OIB in the VAT register: on the Porezna uprava website you can verify if you're in the VAT register. If you are, you're also an eInvoice obligor.
3. 3 Consult an accountant if you rent through a sole proprietorship: they can tell you specifically which software you need and whether it makes sense to remain a flat-rate sole proprietorship or to change tax systems.

A Practical Example: The Horvat Family in Split

The Horvat family rents out two apartments in Split. They have a Tax Administration decision on flat-rate taxation of income from property and pay flat-rate per bed. They do not own a sole proprietorship and are not in the VAT system.

• Status: private flat-rate hosts (paušalisti)
• Fiscalization 2.0 obligation: ❌ none
• Need a FINA certificate: ❌ no
• Need fiscalization software: ❌ no
• What they still must do: register guests in eVisitor within 24h, pay the tourist tax, issue the guest a regular invoice (no JIR/ZKI) if requested as proof of stay, keep annual records of reservations for their flat-rate decision

Compare with Mr. Matković, who in Trogir rents out 3 apartments through a paušalni obrt registered for providing hospitality services. He IS subject to Fiscalization 2.0, must obtain a FINA certificate (around €30–50/year), fiscalization software (around €10–25/month), and be prepared to fiscalize even bank transfers from Booking.com starting 1.1.2026.

One thing often forgotten: if you are a paušalist considering switching to a sole proprietorship for additional services or larger scale, the transition brings a fiscalization obligation. Calculate the cost-benefit — sometimes staying a paušalist (with the limit on the number of units) is financially better than switching to a sole proprietorship due to the additional costs of fiscalization, bookkeeping, and eInvoices.

In conclusion: Fiscalization 2.0 is a real obligation, but not for everyone. If you are a private flat-rate host, set the panic aside — the law doesn't apply to you. If you operate a sole proprietorship or company, prepare seriously: obtain software, a FINA certificate, and accept that every guest transaction (including those from Booking.com) carries a fiscalization obligation.