Croatia’s New Crypto-Asset Regulations
On 19 July 2024 Croatia took a decisive step toward full European harmonisation of the crypto-asset market by publishing the Act on the Implementation of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA) in the Official Gazette (Narodne novine 85/2024). Less than six months later—on 2 January 2025—its financial-services supervisor Hanfa issued a plain-language “Notification for persons intending to trade crypto-assets”. Together these two texts form a practical roadmap for anyone who issues, services or invests in crypto-assets within Croatia.
Although MiCA itself is an EU regulation and therefore directly applicable, each Member State must still designate competent authorities, outline investigative powers and set out a national system of administrative penalties. Croatia’s act does precisely that:
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Hanfa (the Croatian Financial Services Supervisory Agency) is the single contact point for
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ordinary crypto-asset issuers (everything that is not an e-money token or an asset-referenced token),
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crypto-asset service providers (CASPs) such as exchanges, custodians and advisers, and
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market-abuse surveillance.
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Hrvatska narodna banka (the Croatian National Bank) takes the lead whenever a token behaves like money—i.e. e-money tokens and asset-referenced tokens.
Both authorities must cooperate closely with each other and with European supervisors ESMA and the EBA, ensuring that rule-making and enforcement are consistent across the EU.
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Licensing becomes mandatory. From 30 December 2024 any Croatian company that wants to run an exchange, offer custody, execute orders or otherwise provide a “crypto-asset service” must hold a MiCA licence from Hanfa. Authorisation is not a mere formality: applicants must demonstrate robust governance, fit-and-proper management, capital adequacy, IT resilience and detailed procedures for client asset segregation.
Company law is also tweaked. A firm cannot even register a trade name that suggests crypto-asset activity unless a Hanfa licence is in place. Directors who resign or are replaced must be reported to Hanfa within three working days, underscoring the regulator’s emphasis on accountable leadership.
Existing VASPs get a breathing space—but not for long. Operators that were already registered with Hanfa under Croatia’s anti-money-laundering (AML) regime may continue their current services, but only until 1 July 2026. By that date they must either obtain full MiCA authorisation or wind down the crypto-asset side of their business.
MiCA grants retail investors powerful new rights, and the Croatian act turns those rights into enforceable court claims. Anyone who buys a token on the basis of an inaccurate, unclear or misleading white paper can sue not only the issuer but also its directors and any expert who endorsed the document. If the token is an e-money or asset-referenced token, the investor can additionally demand immediate redemption at cost. Claims must be brought within one year of the end of the offer (or of a redemption request) and, in any case, no later than five years after the breach.
The act introduces a tiered system of administrative offences. Serious market-abuse violations—such as insider dealing or manipulation—may attract penalties of up to €5 million or 15 % of annual turnover for companies, and up to €1 million for individuals. Failure to respect core CASP obligations (best execution, order handling, disclosure, governance, etc.) can cost legal persons up to €700 000 and responsible managers up to €25 000, or double any unlawful gain where that is higher. Lesser breaches, like ignoring Hanfa’s instructions or an ESMA guideline, fall into the €1 000–€100 000 bracket. Importantly, challenging a Hanfa decision in court does not suspend its effect—another sign that the supervisor intends to move quickly when it spots misconduct.
Recognising that new rules can be intimidating, Hanfa published a consumer-facing notice immediately after MiCA became applicable. Its key messages are:
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Only firms that appear in Hanfa’s public list are authorised to deal in crypto-assets.
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Pre-MiCA providers may keep operating until July 2026, but they are subject to AML supervision and can be shut down for misconduct.
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Crypto is not covered by the Investor Protection Fund. Losses are yours to bear.
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MiCA makes white papers more reliable, yet they are still marketing documents and cannot eliminate market risk.
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Unrealistic returns, pressure to act fast, and opaque ownership structures remain the classic warning signs of fraud.
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