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The era of Fiscalization 2.0 is no longer an “upcoming project” – it is our everyday business reality. Now, with the first months of the new Act’s application behind us, one operational question troubles entrepreneurs the most: invoice number sequencing.
If you use one billing device for all types of transactions, your accounting sequence looks neat (1, 2, 3…), but in the Tax Administration’s systems, the situation looks “fragmented”.
How do you correctly manage B2C transactions (Fiscalization 1.0) combined with e-Invoices and foreign exports, without arousing inspector suspicion due to apparent gaps in the counter?
The new reality of fiscalization 1.0: Not just for cash
The biggest change we felt on January 1st of this year concerns the B2C segment (invoices to citizens).
Until 2026, the rule was: if a citizen pays via bank transfer (to a transaction account), fiscalization is not required. That rule no longer applies.
Today, when you issue an invoice to a natural person (citizen), it automatically enters the Fiscalization 1.0 system, regardless of whether the customer pays with cash at the register or via internet banking from home. Every such invoice must have a JIR (Unique Invoice Identifier) and a QR code at the moment of issuance. Here we come to the main operational challenge: mixing apples and oranges in the same number sequence.
Here we come to the main operational challenge: mixing apples and oranges in the same number sequence.
Anatomy of a “Gap” in the counter: A practical example
Let’s imagine a typical day in a Croatian company that uses a single numerical sequence on one billing device.
- Invoice No. 1
- You issue an invoice to a citizen (B2C). Status: Goes to the Fiscalization 1.0 system. Receives a JIR.
- Invoice No. 2: You issue an invoice to a domestic company (B2B)
- Status: Sent as an e-Invoice (Fiscalization 2.0) via an information intermediary.
- Invoice No. 3: You issue an invoice to a foreign company (Export).
- Status: Doesn’t go anywhere in real-time (stays in your records).
- Invoice No. 4: Another invoice to a citizen (B2C).
- Status: Goes to the Fiscalization 1.0 system.
What does the Tax Administration see when looking only at the Fiscalization 1.0 module (cash traffic)?
It sees Invoice No. 1, and then immediately Invoice No. 4.
4. Numbers 2 and 3 are missing.. This is that infamous “gap” that entrepreneurs fear.
Is it an offense?
No, provided you have proper documentation.
The Tax Administration system is now integrated. Even though module 1.0 sees a gap between 1 and 4, the central system knows that Invoice No. 2 was received through the e-Invoice channel. Invoice No. 3 (export) is visible through your VAT forms and the book of outgoing invoices.
However, to avoid uncomfortable questions and having to prove yourself during an audit, how you set up your Internal Structure is crucial.
How to Elegantly Solve the Problem? (The “Virtual Devices” Model)
Instead of mixing all invoices into one sequence, the best practice that has crystallized in these few months of 2026 is the use of separate billing devices within the same business premise.
Although you physically work on one computer, in the software and Internal Act, you define three device designations:daj
- Device 01 (For citizens/B2C): Here go all invoices requiring a JIR (cash + citizens’ bank transfers). The sequence goes: 1, 2, 3… without interruption.
- Device 02 (For companies/B2B): Only e-Invoices go here. The sequence goes: 1, 2, 3… without interruption.
- Device 03 (Export): Export invoices go here. The sequence goes: 1, 2, 3… without interruption.
Advantages of this approach:
- No gaps: Every channel has its perfect sequence.
- Easier control: You instantly see how many invoices you’ve issued in which regime.
- Clean reports: The Tax Administration knows exactly that Device 01 is only for F1.0 and does not expect to see B2B invoices there.
What if you’ve already started with a single sequence?
If you started the year with a mixed sequence, do not worry. You are not committing an offense, but you must ensure that your Internal Act on Fiscalization (which you are obliged to have in your business premises) clearly describes this logic.
The internal act must contain a sentence like:
All invoices are issued in a single numerical sequence on billing device No. 1, regardless of the customer type. Differences in the sequencing of data delivery to the Tax Administration system stem from different legal protocols for B2C (Fiscalization 1.0), B2B (Fiscalization 2.0), and foreign transactions.
Conclusion: Automation is Key
In 2026, manually thinking about “where which invoice goes” is a risk. Your software must be the one that automatically assigns the correct device number and sends data to the right API (F1.0 for citizens, Intermediary for companies) based on the PIN (OIB) or partner type.
Gaps in the counter are only a problem if you can’t explain them. If they are the result of the lawful application of different tax regimes, and your book of outgoing invoices (KIR) contains all the numbers together – your business is completely safe.
The Vizibit e-Račun application supports issuing invoices in final consumption (B2C, F1.0 fiscalization) and e-Invoices (B2B, F2.0 fiscalization).
he Vizibit e-Račun application supports issuing invoices in final consumption (B2C, F1.0 fiscalization) and e-Invoices (B2B, F2.0 fiscalization).
You can see a short video on how to issue F1 and F2 invoices here.
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