# Fiscalization 2.0 in Croatia for Personal Trainers > In Croatia, bank transfers have been fiscalized since 2026, and from 1 January 2027 flat-rate trainers issue eRačun to businesses. A decision tree for Stripe, the App Store, foreign clients and prepaid packages, plus the fines in NN 89/25. *Author: Trainera Team | Published: 2026-10-28 | Reading time: 8 min* ## What does Fiscalization 2.0 mean for a personal trainer in Croatia in 2026 and 2027? If you train clients through a business registered in Croatia, every invoice to a private client has had to be fiscalized since 1 January 2026, whether the client pays in cash, by card or by bank transfer to your IBAN. As a flat-rate sole trader outside VAT you already have to receive eRačun e-invoices from other businesses and fiscalize their receipt, and from 1 January 2027 you also have to issue them when you bill a gym or any other Croatian company. _Updated 28 October 2026_ This article is about Croatian law only, and it is information, not tax advice. Every date, deadline and fine below is taken from the [Fiscalization Act (Zakon o fiskalizaciji, Narodne novine 89/25)](https://narodne-novine.nn.hr/clanci/sluzbeni/2025%5F06%5F89%5F1233.html) and from the pages of the Croatian Tax Administration (Porezna uprava), with a link to the source next to each claim. We covered the basic dates in [eRačun 2027 in Croatia](/blogs/eracun-2027-personal-trainers-gyms-croatia). This piece focuses on the situations trainers keep running into in practice: Stripe, the App Store, a client abroad and a training package paid in advance. ## Who has to do what: a table for trainers and gyms | Who you are | Invoice to a private client | Receiving eRačun | Issuing eRačun to businesses | | ------------------------------------------------------------------------------------------ | ----------------------------------------------------------- | ----------------------------------------------------------------------- | ---------------------------- | | Flat-rate sole trade (paušalni obrt) or other self-employment outside the VAT system | Fiscalized invoice from 1 Jan 2026 for every payment method | From 1 Jan 2026, receipt fiscalized within 5 working days at the latest | From 1 Jan 2027 | | Sole trade or d.o.o. (limited company) in the VAT system, which is often the case for gyms | Fiscalized invoice from 1 Jan 2026 for every payment method | From 1 Jan 2026 | From 1 Jan 2026 | | Trainer employed by a gym on an employment contract | The gym issues the invoices | The gym's obligation | The gym's obligation | Sources: [Porezna uprava, issuing and receiving eRačun](https://porezna-uprava.gov.hr/hr/izdavanje-i-primanje-eracuna-i-fiskalizacija-eracuna/8047) (last changed 5 June 2026) and [Porezna uprava, invoices to final consumers](https://porezna-uprava.gov.hr/hr/racuni-u-krajnjoj-potrosnji-azurirano-30-1-2026/8034). The Act treats a person paying income tax on self-employment and a company paying profit tax as the parties obliged to fiscalize (Article 2), so an employed trainer who does not bill clients personally has no obligation of their own. Since 1 January 2025 the threshold for entering the VAT system has been 60,000.00 euros ([Porezna uprava, tax changes 2025](https://porezna-uprava.gov.hr/hr/porezne-izmjene-2025/8231)). ## What changed on 1 January 2026 Article 3 of the Act says an obliged party fiscalizes an invoice paid in cash, by card, by bank transfer and by any other means. Before, a trainer who only took bank transfers could get away with sending a PDF made in Word. That no longer works: the invoice must show the time of issue, an operator code, the payment method, the Unique Invoice Identifier (JIR), the Issuer Protection Code (ZKI) and a QR code (Article 7). The second thing trainers often miss: if you send a client an offer or a pro forma invoice with your IBAN before the real invoice, it has to state visibly **OVO NIJE FISKALIZIRANI RAČUN** ("this is not a fiscalized invoice", Article 29). The Act lists forgetting this among the most serious offences. Third: from the same date you must be able to receive an eRačun. If a gym in the VAT system sends you one, you fiscalize its receipt within five working days of receiving it at the latest (Article 48, paragraph 4; also confirmed on the [Porezna uprava page on fiscalizing eRačun](https://porezna-uprava.gov.hr/hr/fiskalizacija-eracuna-azurirano-17-4-2026/8049)). ## What changes on 1 January 2027 * Flat-rate sole traders and other income and profit tax payers outside VAT start **issuing** eRačun for domestic transactions with businesses and the public sector (Article 38). * You fiscalize an issued eRačun at the moment of issue, or within five working days of issue if you self-issue (Article 48, paragraph 3). * The free MIKROeRAČUN app may only be used if you are not in the VAT register and are not a public contracting authority. Issuing eRačun through it starts on 1 January 2027 (transitional provisions of the Act). If you do not use MIKROeRAČUN, you authorise an information intermediary through FiskAplikacija. * Every line of an eRačun gets a six-digit KPD classification code (Article 42). Agree the code for "personal training" or "membership" with your accountant once and use it every time. * An exception few people mention: a transaction paid in cash or by card, for which a regular invoice was issued and fiscalized, can be exempt from eRačun (Article 39). ## Decision tree: which document you issue in which situation | Situation | What you issue | What to watch | | --------------------------------------------------------------------------------------- | -------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------- | | A private client pays for training in cash, by card, by IBAN transfer or through Stripe | Fiscalized invoice | Stripe is only a card payment; the invoice obligation stays with you | | A client pays for a 10-session package in advance | Fiscalized invoice when you receive the money | A pro forma with your IBAN carries the line OVO NIJE FISKALIZIRANI RAČUN | | A private client from abroad | Fiscalized invoice | The list of exemptions in Article 4 does not mention foreign buyers; check VAT and place of supply with your accountant | | A foreign company orders online coaching | Regular invoice, not eRačun | eRačun is an obligation for domestic transactions | | You bill a gym or a Croatian d.o.o. | eRačun (outside VAT from 2027, in VAT already now) | The Article 39 exception for cash and card with a fiscalized invoice | | A client buys through the App Store or Google Play | Decide with your accountant | The app store charges the buyer; you receive a payout | ### Why these three cases are different **Package paid in advance.** The Act does not exempt advance payments from fiscalization: when the money lands, you issue an invoice. For eRačun, the Act explicitly counts any advance received before delivery as a domestic transaction (Article 2). How to close the advance once the client finishes the last session is something to agree with your accountant, because it depends on whether you are in VAT. **A client from abroad.** On its [general fiscalization page](https://porezna-uprava.gov.hr/hr/opcenito-8032/8032) the Tax Administration says an eRačun is issued for domestic transactions. So you do not need an eRačun for a company in Germany or Austria. A private person from abroad is a different case: an invoice to a final consumer is fiscalized regardless of how it is paid, and foreign buyers are not on the list of exemptions. **App Store and Google Play.** In [Schedule 2 of its agreement with app developers](https://developer.apple.com/support/downloads/terms/schedules/Schedule-2-and-3-English.pdf), Apple states that it is responsible for collecting all prices from end users. The client then pays the app store, not you, and you get a payout. That is not the same case as a card payment or an IBAN transfer and should not be booked the same way. Before you decide whether to issue a fiscalized invoice for such a sale, ask your accountant. ## Fines: what the Act says, not what blogs say Online you will find ranges of 660 to 66,360 euros and 1,320 to 26,540 euros. Both are correct, but each belongs to a different class of offence and a different type of business. Here is how Articles 71 to 73 of the [Fiscalization Act](https://narodne-novine.nn.hr/clanci/sluzbeni/2025%5F06%5F89%5F1233.html) set it out: | Class | Examples from the Act | Sole trader or self-employed | Legal entity | | ---------------------- | -------------------------------------------------------------------------------------------------------------------- | ---------------------------- | --------------------------- | | Most serious (Art. 71) | Does not issue or receive eRačun, does not fiscalize eRačun, pro forma without the OVO NIJE FISKALIZIRANI RAČUN line | 3,980.00 to 39,810.00 euros | 3,980.00 to 66,360.00 euros | | Serious (Art. 72) | Does not fiscalize invoices for all activities, has no digital certificate, does not fiscalize eRačun on time | 1,320.00 to 39,810.00 euros | 2,650.00 to 66,360.00 euros | | Minor (Art. 73) | Wrong invoice number sequence, no internal rules document, no notice about issuing invoices | 660.00 to 13,270.00 euros | 1,320.00 to 26,540.00 euros | For a repeated serious offence a sole trader faces 2,000.00 to 45,000.00 euros. The responsible person in a legal entity is fined separately, on top of the company. ## If you run a gym in Croatia For a gym, the biggest 2026 change is memberships paid by bank transfer. A monthly membership a member pays by payment order is now fiscalized just like one paid by card at reception. If your membership system does not issue fiscalized invoices, you need another program that does it for every payment, not only for cash. So that no payment is left without an invoice, it helps to see debts and payments in one place; more on that in [how to track gym member debts and unpaid memberships](/blogs/how-to-track-gym-member-debts-unpaid-memberships), and the older basics are in [Fiscalization in Croatia for trainers and gyms](/blogs/fiscalization-croatia-personal-trainers-gyms). * A gym in the VAT system has been issuing eRačun to companies (corporate memberships) since 1 January 2026, through an information intermediary. * Freelance trainers who bill the gym for their sessions send eRačun from 2027, and the gym has to receive and fiscalize them within five working days. * Payment instructions you send new members before their first payment need the Article 29 line. ## Where Trainera helps and where it does not Trainera does not issue fiscalized invoices or eRačun. 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. What the platform does is keep the records: cash and bank transfers are recorded with a 0% platform fee, and online payments carry a fee that depends on the 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, with Pro at $49.99 and Business at $99; gym plans start at Core for $119 a month. Those are the US dollar prices. Prices are fixed per country, so a trainer or gym based in Croatia sees euro prices; check yours on the [pricing page](/pricing?utm%5Fsource=blog&utm%5Fmedium=blog%5Finline&utm%5Fcampaign=fiskalizacija-hr). For gyms there is also an [overview of the gym software](/for-gyms?utm%5Fsource=blog&utm%5Fmedium=blog%5Finline&utm%5Fcampaign=fiskalizacija-hr). ## Checklist before 1 January 2027 1. Check whether you are in the VAT register, because both your deadline and your right to use MIKROeRAČUN depend on it. If you are only opening your business, read [Paušalni obrt for personal trainers in Croatia](/blogs/personal-trainer-business-croatia-pausal). 2. Make sure your fiscalization software issues invoices for IBAN transfers and for card payments through Stripe. 3. Add the line OVO NIJE FISKALIZIRANI RAČUN to every pro forma and every set of payment instructions. 4. Choose MIKROeRAČUN or an information intermediary, and check that the eRačun documents businesses already send you are arriving. 5. Settle three open questions with your accountant: packages paid in advance, private clients from abroad and sales through app stores. Do you also work with clients in Serbia? The rules for SEF and fiscal receipts are different there; we explain them in [fiscalization and SEF for personal trainers in Serbia](/blogs/serbia-fiscalization-sef-personal-trainers-gyms). A comparison of Croatia, Serbia and Bosnia and Herzegovina in one place is in our [regional overview of e-invoicing and fiscalization](/blogs/e-invoicing-fiscalization-trainers-bosnia-croatia-serbia). _Want client payments and memberships tracked in one place while your own fiscalization software issues the invoices? See [Trainera pricing](/pricing?utm%5Fsource=blog&utm%5Fmedium=blog%5Finline&utm%5Fcampaign=fiskalizacija-hr) and pick a plan._ ## FAQ ### Does a flat-rate sole trader in Croatia have to issue eRačun in 2026? No. In 2026 a flat-rate trader outside VAT must receive eRačun and fiscalize their receipt, and issuing eRačun to businesses starts on 1 January 2027. ### Is a bank transfer fiscalized in Croatia? Yes. Since 1 January 2026 an invoice paid in cash, by card, by bank transfer or any other way is fiscalized (Article 3 of the Fiscalization Act). ### How long do I have to fiscalize a received eRačun? Five working days from receipt at the latest, under Article 48 of the Croatian Fiscalization Act. ### Do I need an eRačun for a client from Germany? Not for a German company, because eRačun is an obligation for domestic transactions. A private person gets a fiscalized invoice; check VAT and place of supply with your accountant. ### What is the fine in Croatia for not fiscalizing an invoice? A sole trader who does not fiscalize invoices for all activities faces 1,320.00 to 39,810.00 euros (Article 72). For a repeated offence the range is 2,000.00 to 45,000.00 euros. --- Source: https://trainera.fit/blogs/fiscalization-2-0-croatia-personal-trainers-decision-tree