One of the most frequent questions around Croatia's Fiscalisation 2.0 framework is whether the recipient of an e-invoice may attach a remark to an already received document — a dispute note, an internal classification, or a delivery reservation. Short answer: yes, but the Tax Authority's rules clearly separate an internal remark from a change to the fiscal content.
This article walks through the legal frame, what is allowed in practice and what instead requires a formal credit note and a new invoice — and how the REDOK e-archive carries the audit trail for both.
What the law and the technical spec actually say
The Fiscalisation Act and its technical specification separate two data layers: fiscal content (amounts, issuer tax ID, date, JIR, ZKI codes) and business metadata (internal label, processing status, accountant note). Fiscal content cannot be modified — any change triggers a reversal and a new invoice. Business metadata can be added and amended by the recipient inside their own records as many times as needed.
The grey zone is remarks that affect VAT — e.g. "20 % of delivery returned". That is no longer just an internal note; it is information that, in the next step, requires either a credit note or a discount document because it changes the deductible VAT amount.
What you may add after the fact
- Internal classification and cost codes (cost centre, project, purchase order) — pure internal bookkeeping.
- Processing status (received / verified / posted / paid) — workflow notes that do not touch the fiscal amount.
- Accountant or approver comments — e.g. "awaiting procurement sign-off" or "verify article code 4711".
- Links to related documents — the purchase order, the contract, the dispatch note that led to this invoice.
What is NOT allowed without a reversal
Changing the amount, VAT rate, issuer or recipient tax ID, or issue date — any of those means the original invoice must be reversed (with its own JIR) and a new invoice issued. Quietly „editing“ those fields in the archive is, as a rule, an offence and is easy to detect at audit time by broken JIR/ZKI chains.
How the REDOK e-archive handles this
The REDOK e-archive keeps the original fiscal document untouched (digitally signed and timestamped under eIDAS), and stores any later recipient remarks in a separate metadata layer. Each remark carries an author, timestamp and version — which gives a clean audit trail for tax audits or internal review.
The result is the best of both worlds: legal integrity for the original document and operational flexibility for downstream bookkeeping.
Summary
Adding remarks after the fact is a normal part of daily e-invoice work — as long as they stay separate from the fiscal content and are stored in a dedicated archive layer. If amount, parties or date need to change, the only correct path is a reversal plus a new invoice.
If you want a deep dive into how the REDOK e-archive splits those layers technically, or a compliance review of your current archive, reach out through the contact form and we will share an architecture brief.