The Parliament of the Federation of Bosnia and Herzegovina (BiH) enacted the Law on Fiscalization of Transactions, which entered into force on February 12, 2026. The Federal Minister of Finance must enact all implementing bylaws within 180 days of that date. The law will begin to apply once all necessary implementing bylaws have been enacted and the required technical and administrative infrastructure has been established. This must occur no later than 18 months from the month of entry into force.
The law introduces mandatory invoice issuance, an Electronic Transaction Recording System (Elektronski sistem za evidentiranje transakcija, ETRS), supervision mechanisms, and penalties to curb tax evasion through real-time reporting. It replaces device-based compliance with a software-driven fiscal system and applies to B2G, B2B, and B2C transactions. The law also supports partial harmonization with European directives and modernization of the tax system.
Taxpayers in scope
The law applies to all fiscalization taxpayers operating in the territory of the Federation of BiH, including:
- Companies, sole proprietors, and organizations (such as associations and foundations) with registered offices in the Federation;
- Business units of companies, sole proprietors, or organizations with registered offices outside the Federation that operate within the Federation;
- Tax representatives for non-resident persons; and
- Administrative bodies and organizations carrying out transactions subject to fiscalization.
Certain entities are fully or partially exempt, including public administration bodies, certain health and social work activities where no fee is charged, and specific regulated entities (such as banks and insurance companies), but only for transactions within the scope of their regulated activities.
E-invoicing framework
The law introduces several key elements:
Electronic Transaction Recording System (ETRS): a software application or cloud solution that enables the input of all required invoice elements, as well as invoice preparation, signing, issuance, and acceptance of electronic invoices (e-invoices). It also supports communication with the Tax Administration and archiving. The ETRS may be installed on any device, such as a computer, mobile phone, or cash register.
Providers of ETRS must be established in the Federation, obtain registered manufacturer or representative status, and receive Ministry approval before offering software or cloud solutions.
Central Fiscalization Platform (Centralna platforma za fiskalizaciju, CFP): a dedicated platform managed by the Tax Administration of the Federation through which transaction data are recorded and exchanged in real time. The CFP verifies transaction data in real time, assigns an Invoice Verification Number to each fiscalized receipt, and enables continuous oversight.
Detailed technical and functional rules for the ETRS and its communication with the Tax Administration’s platform will be established by a future bylaw.
Invoice types: The law distinguishes between two types of invoices:
- E-invoices: issued and received in a structured electronic format compliant with European standard EN 16931, primarily for B2G transactions and B2B transactions paid by non-cash or combined payment methods; and
- Fiscal receipts: issued for B2C transactions, in paper or electronic form.
All e-invoices must be signed electronically and include a QR code or link that enables clients to verify whether the invoice has been reported to the Tax Administration. Invoices relating to defense and security contracts fall outside the scope of e-invoicing.
SPE-invoice application (Aplikacija SPe-račun): a free application will be provided for certain categories of taxpayers, such as sole proprietors who are not VAT taxpayers.
Penalties
The law establishes a tiered monetary penalty regime applicable to legal entities, responsible persons, and natural persons carrying out business activity. Penalties vary depending on the severity of the offense and the offender:
- Serious offenses, such as failure to issue invoices or to use an approved ETRS: 3,000 BAM (approx. 1,530 EUR) to 30,000 BAM (approx. 15,300 EUR); and
- Minor offenses, such as incorrect invoice content: 3,000 BAM (approx. 1,530 EUR) to 18,000 BAM (approx. 9,200 EUR).
All fines increase by 50% in the event of a repeated offense within one year. Additionally, taxpayers may be prohibited from carrying out business activities for up to 120 days.
Timelines
The law sets a phased implementation schedule:
- B2B and B2G transactions: the e-invoicing and reporting regime must be completed within three years from the commencement of application of the law;
- B2C transactions: the transaction recording regime must be completed no later than two years from the commencement of application of the law.
A three-year transitional period applies, during which taxpayers may continue using existing fiscal systems under the previous Rulebook. In some cases, taxpayers already using such systems may continue to do so for up to four years after the law's application begins.