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Croatia · Agentic SaaS development

SaaS Development for Croatia: VAT, eRačun and Billing

In Croatia an eRačun has to be a structured invoice that software can process automatically. A PDF does not qualify, and it cannot be sent by e-mail. For a SaaS company registered for VAT there and billing local businesses, invoicing becomes a pipeline with product codes, access points and real-time fiscalization messages. Add a 25% standard VAT rate, a national barcode standard for bank transfers and accessibility rules for consumer services, and the billing layer needs as much design as the product.

Curiosive is a studio in Ankara, Türkiye, that builds subscription products with AI coding agents under senior engineer review. Agents produce the CRUD screens, admin views, migrations and test suites. Engineers design the multi-tenant data model, the billing webhooks and the plan and entitlement logic, because a mistake there leaks data or charges the wrong customer. Clocks there run one hour behind Ankara in summer and two in winter, which leaves most of a working day in common.

24
published portfolio projects
5+
years building for production
12
countries the work runs in
100%
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to hear back, from the engineer

Croatian VAT on SaaS subscriptions, thresholds and OSS

Article 38 of the VAT Act sets a 25% standard rate, reduced rates of 13% and 5%, and a 0% rate. A resident business must register for VAT once its supplies in the previous or current year exceed €60,000. Across the EU, services sold to businesses in another EU country usually fall under the reverse charge, with some important exceptions, and electronic services sold to consumers are taxed in the customer's country, although below a EUR 10,000 threshold they may be taxed where the seller is established. Since 1 July 2021, businesses established outside the EU that supply services to non-taxable persons can use the optional OSS special scheme, according to a Tax Administration page updated 15 May 2026. A billing model that stores customer type, country and VAT number evidence on each subscription computes tax per invoice instead of guessing. Which rate fits your product is worth confirming with an accountant.

eRačun e-invoicing for B2B SaaS billing in Croatia

The Fiskalizacija 2.0 guide treats an eRačun as data, not a document. Goods and services must map to KPD (Klasifikacija proizvoda prema djelatnostima) codes, so each plan, add-on and usage charge in the product needs one. Invoices travel between access points, built in-house or run by information intermediaries, and intermediaries must hold ISO/IEC 27001 certification, pass conformity tests and fall under the Cybersecurity Act. Issuer and recipient each send a fiscalization message, which the Tax Administration cross-checks in real time. For most products that means integrating an intermediary and recording each invoice's fiscalization status, retrying failures without issuing twice. Further out, Council Directive (EU) 2025/516 requires invoices for intra-EU supplies between taxable persons to be electronic invoices to the European standard from 1 July 2030.

Payments in Croatia: online share, SCA and HUB-3 barcodes

The ECB's SPACE 2024 study, the first to include Croatia, found online payments made up 28% of consumers' day-to-day payments by number and 47% by value, among the highest shares in the euro area. It also found 10% of respondents there had technical difficulties entering payment information online, against a 7% euro-area average, which argues for a short checkout with clear error messages. Checkout also has to work with PSD2 strong customer authentication, whose standards let providers skip it for a remote payment of no more than EUR 30 only within a cumulative EUR 100 or five consecutive transactions. For customers who pay by bank transfer, payment slips follow the HUB-3 standard: version 6 of the banking association's specification defines a PDF417 barcode for the HUB 3A payment order, with the header 'HRVHUB30', currency 'EUR', amounts in euro cents and UTF-8 encoding. Agents can write the generator; an engineer checks it against the specification.

Croatia transposed the European Accessibility Act through NN 89/2025, in force since 28 June 2025. The rules cover services to consumers such as e-commerce and consumer banking, so a B2B tool may sit outside them while a consumer subscription sold online may not. Market inspectors of the State Inspectorate check e-commerce services, and micro-enterprises with fewer than ten employees and annual revenue or total assets up to €2 million are exempt. AZOP's cookie guidance, updated 6 August 2024, is specific about the banner: no consent cookie before explicit consent, a first layer with 'Odbijam kolačiće' and 'Prihvaćam kolačiće' designed the same way, a 'Postavke kolačića' option with categories off by default, a settings link in every footer, and no legitimate interest for marketing cookies.

Tenant isolation, billing webhooks and the EU Data Act

The EU Data Act has applied since 12 September 2025, and its recitals place SaaS among data processing services. Switching terms belong in a written contract with a notice period of no more than two months and a transitional period of no more than 30 calendar days, and from 12 January 2027 no switching charges may be imposed. A product mostly custom-built for one customer is exempt from some of these duties, and the provider must say which before the contract is signed. Engineers design for this from the start: tenant isolation in PostgreSQL, a clean per-tenant export, idempotent webhook handlers so a redelivered payment event is not processed twice, and entitlement checks tied to the plan. Comparable work includes Reveal Software (reveal.software), video onboarding built with Hono, Drizzle ORM and PostgreSQL, and PicKey (pickey.ai), a password manager with subscription billing on Stripe.

Questions

The things people ask before starting.

What are the VAT rates in Croatia for a SaaS business?

Croatia's VAT Act sets a 25% standard rate, reduced rates of 13% and 5%, and a 0% rate. Sales to businesses in other EU countries usually fall under the reverse charge, while electronic services sold to consumers are generally taxed in the customer's country.

Can a Croatian SaaS company send invoices to businesses as PDF files?

Not as an eRačun. The Tax Administration's Fiskalizacija 2.0 guide says an eRačun must be a structured, automatically processable invoice, that a PDF does not qualify and that it cannot be sent by e-mail. Domestic B2B billing therefore needs structured invoices with KPD codes, sent through an access point.

How do you add a HUB-3 payment barcode to invoices in Croatia?

Follow version 6 of the HUB-3 specification from the Croatian Banking Association. It defines a PDF417 barcode for the HUB 3A payment order with the header 'HRVHUB30', currency 'EUR', the amount in euro cents and UTF-8 text. The generator belongs in the invoice service, tested against the specification before release.

Is a small SaaS startup in Croatia exempt from accessibility requirements?

Yes, if it is a micro-enterprise providing services. The national act, NN 89/2025, exempts service providers with fewer than ten employees and annual revenue or total assets up to €2 million. Larger companies selling consumer services such as e-commerce must meet the requirements.

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