E-Invoicing and Fiscalization: Bosnia, Croatia, Serbia

What do trainers and gyms need to know about e-invoicing and fiscalization in Bosnia and Herzegovina, Croatia and Serbia?

In all three countries a training session paid by a private person needs a fiscal receipt; the difference is e-invoicing between businesses. Croatia has required it from VAT payers since 1 January 2026 and requires it from everyone else from 1 January 2027, Serbia requires it from VAT payers through SEF, and in the Federation of Bosnia and Herzegovina the new Law on Fiscalization of Transactions introduces e-invoices for cashless B2B transactions and has to start applying no later than 18 months after it entered into force.

Updated 28 October 2026

This overview covers only Bosnia and Herzegovina, Croatia and Serbia, and it is not tax advice. Every date and obligation below links to the law or the tax administration, and where we could not confirm something in an official source, we say so. For trainers who coach clients online across several of these countries, this is the map: the detailed guides for Croatia and Serbia are linked further down.

The three countries in one table

Sources: Croatia, Fiscalization Act, Narodne novine 89/25 and Porezna uprava on eRačun; Serbia, Law on Electronic Invoicing and Law on Fiscalization; Federation of BiH, Law on Fiscalization of Transactions in the FBiH (adopted text, FBiH Parliament); Republika Srpska, Republika Srpska Tax Administration, fiscalization rules. Brčko District has its own rules and is not covered here.

Federation of BiH: what the new Law on Fiscalization of Transactions brings

Bosnia and Herzegovina has two entities that each regulate fiscalization separately, and this section is about the Federation (FBiH). The law was published in the Official Gazette of the Federation of BiH ("Službene novine Federacije BiH") No. 9/26 on 4 February 2026 and enters into force on the eighth day after publication. It does not apply right away: Article 90 says it starts applying once all implementing regulations are adopted and the technical capacity is in place, and no later than 18 months from the month in which it entered into force. Legal portals such as Paragraf.ba work that out as August 2027. Until then, under Article 89, the old Law on Fiscal Systems ("Službene novine FBiH" No. 81/09) with fiscal cash registers still applies.

Four things in the new text matter to trainers and gyms:

• A card counts as a "cash" payment. Article 11 includes payment cards, coupons and vouchers in cash payments, while cashless means a transfer from account to account. A transaction paid in cash, and so also by card, needs a fiscal receipt (Article 20).
• E-invoices for businesses. For B2B transactions paid cashless or in a combination, an e-invoice must be issued, sent and accepted (Article 15), and invoices to public bodies go out only as e-invoices (Article 16). For clients who are not residents of the Federation, an e-invoice is possible but not mandatory.
• Online sales. If a service is agreed and paid through a mobile app or an online shop, the receipt does not have to be printed and can be sent electronically (Article 20, paragraphs 3 and 4). For online coaching that is the practical route.
• SPe-račun. Self-employed persons who are not VAT payers can issue fiscal receipts through the Tax Administration's free SPe-račun app (Article 47).

The federal finance minister has to adopt the implementing regulations within 180 days of the law entering into force (Article 88). Before you buy a new cash register or software, check on the FBiH Tax Administration website which of those regulations have been published. The fines are set by the law itself, so we do not repeat them from memory here: if you need them, look them up in the penalty provisions of the law or ask your accountant.

Republika Srpska: fiscalization regardless of payment method

The Law on Fiscalization of Republika Srpska ("Službeni glasnik Republike Srpske" No. 15/22) says every person registered to sell goods and services is obliged and must record every single sale "regardless of the method of payment", including advances for future sales. A card counts as a cash payment here too, and the law explicitly requires cashless sales to go through an electronic fiscal device as well. The government can exempt certain activities by decree, so check whether yours is on that list; the rules are listed on the Republika Srpska Tax Administration website.

State level: in the sources we reviewed on 28 October 2026 we found no regulation that, as in Croatia and Serbia, introduces a mandatory e-invoice for all VAT payers in Bosnia and Herzegovina. If you work with companies from both entities, this is a question for your accountant.

Croatia in brief: Fiscalization 2.0

Since 1 January 2026 every invoice to a final consumer is fiscalized, also when the client pays to your IBAN (Porezna uprava, invoices to final consumers). Flat-rate traders outside VAT receive eRačun from that date, and from 1 January 2027 they also issue them to other Croatian businesses. A received eRačun is fiscalized within five working days of receipt at the latest. Fines for sole traders go up to 39,810.00 euros for the most serious offences. The decision tree for Stripe, the App Store, foreign clients and packages paid in advance is in Fiscalization 2.0 in Croatia for personal trainers, and the older basics are in Fiscalization in Croatia for trainers and gyms.

Serbia in brief: SEF and the fiscal receipt

A flat-rate entrepreneur who is not in VAT is not obliged to use SEF, Serbia's state e-invoicing system, because the law ties the e-invoice to a "private sector entity", which means a VAT payer. They have to register before submitting a payment request to the public sector, and voluntary registration binds them for the current and the following calendar year. A fiscal receipt is mandatory for every session and every advance paid by a private person. The full explanation, with the articles of the law and the fines, is in fiscalization and SEF for personal trainers in Serbia.

A trainer with clients in several countries: how to think about it

The rules follow where you are registered, not where the client lives. A trainer from Sarajevo with a client in Zagreb does not issue a Croatian eRačun; they issue an invoice under the rules of the Federation. In practice trainers keep meeting the same situations:

Gyms: what to ask of your membership software

A gym in Croatia now fiscalizes memberships paid by bank transfer, in Serbia every membership a private person pays is a retail sale, and the FBiH is preparing the move from cash registers to software-based recording. So when you choose membership software, the first question is how each payment will get a fiscal receipt, and through which system. The second question is tracking debts, so you can see which membership is paid and which is still waiting for payment and a receipt. More on that in how to track gym member debts and unpaid memberships.

Where Trainera helps and where it does not

Trainera does not issue fiscal receipts or e-invoices in any of the three countries. The agreement a trainer signs to take payments through the platform says the trainer alone is responsible for taxes and fiscal obligations and that Trainera is not their tax representative. The platform keeps track of clients, packages, memberships and payments: cash and bank transfers are recorded with a 0% platform fee, and online payments carry a fee by plan (Free and Starter 8%, Pro 5%, Business 3%, Enterprise 1%). Gyms pay no platform fee.

Trainer plans start at Starter for $19.99 a month, then Pro at $49.99 and Business at $99; gym plans start at Core for $119. Those are the US dollar prices. Prices are fixed per country, so a trainer in Bosnia and Herzegovina pays in KM, in Croatia in euros and in Serbia in dinars; everything is on the pricing page, and for gyms on the gym software page.

Checklist for trainers and gyms in the region

1. Write down where you are registered and whether you are in VAT: that decides every other rule.
2. Croatia: a fiscalized invoice for IBAN payments too, and MIKROeRAČUN or an information intermediary by 1 January 2027.
3. Serbia: a fiscal device that also handles advances; SEF only if you are in VAT, work with the public sector or registered on purpose.
4. Federation of BiH: follow the FBiH Tax Administration's implementing regulations and do not buy a new cash register without checking what the new law requires.
5. Republika Srpska: every sale, cashless too, through the fiscal device.
6. With your accountant, settle advance packages, foreign clients and sales through app stores.

Want clients, packages and memberships in one place while your own fiscal system issues the receipts? See Trainera pricing.