VP Law Firm • February 13, 2026
New System of Transaction Fiscalization in the Federation of Bosnia and Herzegovina
The regulation of the obligation to issue fiscal receipts, the electronic transaction recording system, supervision in the field of fiscalization, and penalty provisions are governed by the Law on Fiscalization of Transactions in the Federation of Bosnia and Herzegovina (hereinafter: the “Law”), published in the Official Gazette of the Federation of BiH No. 9/26 on 4 February 2026, and which enters into force on the eighth day following its publication.
The purpose of adopting the Law is to combat the grey economy and tax evasion through the introduction of a modern system of real-time electronic transaction recording.
The most significant provisions of the Law relate to:
- the introduction of the obligation to electronically record all transactions through a central fiscalization system;
- the establishment of automatic, real-time transmission of turnover data to the Tax Administration of the Federation of BiH;
- the obligation to issue fiscal receipts for transactions covered by the Law, including electronic forms of receipts in accordance with the technical standards of the system;
- the inclusion, within the scope of fiscalization, of most fee-based service activities, including legal services, with a partial exemption from the obligation to issue fiscal receipts in cases of representation at hearings and certain procedural actions before courts and other authorities, while general fiscalization rules (i.e., issuance of a fiscal receipt or electronic invoice in accordance with the Law) apply to other legal services provided to clients;
- the prescription of technical and security standards for fiscal devices and software solutions used in the fiscalization process;
- the phased implementation of the fiscalization system to enable business entities to adapt to new technological solutions;
- the establishment of a supervision system to ensure proper application of fiscalization by the competent tax authorities;
- the stipulation of misdemeanor liability for legal entities, responsible persons within legal entities, sole proprietors, and other fiscalization taxpayers for failure to issue fiscal receipts, failure to record turnover, and other violations of statutory obligations, with fines for legal entities generally ranging from BAM 5,000 to BAM 30,000, in addition to penalties for responsible persons and the possibility of stricter sanctions in the case of repeated offenses.
By introducing a modern digital fiscalization system, the legislator aims to increase transparency of financial flows, enhance the efficiency of tax supervision, and reduce the scope of the informal economy.
The application of the Law will commence following the adoption of secondary legislation that will further regulate this area, and no later than 18 months from the month in which the Law entered into force. The practical effects of the Law will largely depend on the technical implementation of the system, the readiness of fiscalization taxpayers to adapt to the new solutions, and the consistency of supervisory authorities in its enforcement.
This text was prepared by independent attorney at law Adnan Sarajlić and legal associate Edna Basara
