Detailed overview
Croatia: HANFA MiCA Authorisation under the Croatian Implementation Act
Croatia is a full MiCA jurisdiction. The Croatian MiCA implementation framework is based on Regulation (EU) 2023/1114 and the Croatian Act on the Implementation of Regulation (EU) 2023/1114 on Markets in Crypto-Assets.
The Croatian framework designates two competent authorities. The Croatian Financial Services Supervisory Agency is the main authority for ordinary crypto-asset service providers. The Croatian National Bank is responsible for asset-referenced token and e-money token matters and for the MiCA functions assigned to it under Croatian law.
Regulator
The main regulator for a standard Croatian crypto-asset service provider is HANFA.
HANFA is responsible for MiCA Titles II, V and VI in Croatia. This includes crypto-assets that are not asset-referenced tokens or e-money tokens, CASP authorisation and operating conditions, and market-abuse supervision.
The Croatian National Bank is responsible for MiCA Titles III and IV. This includes Croatian ART issuers, Croatian credit institutions and e-money institutions involved with EMTs, and other matters allocated to HNB under the Croatian implementation law.
A business that combines CASP activity with banking, payment, e-money, ART, EMT or tokenised financial-instrument activity needs a separate competence analysis before filing.
Licensing route
A Croatian home-state CASP applicant must apply to HANFA.
For a Croatian home-state licence, the applicant must be a joint stock company or limited liability company with its seat in Croatia. HANFA decides on the application under the MiCA authorisation procedure if the applicant satisfies MiCA Title V and the Croatian implementation law.
A Croatian company cannot register a trade name that suggests it is a crypto-asset service provider unless it has the required HANFA approval.
Authorised crypto-asset services include custody and administration of crypto-assets for clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of client orders, placing of crypto-assets, reception and transmission of orders, advice on crypto-assets, portfolio management on crypto-assets, and transfer services for clients.
The licence perimeter applies only where the asset is a crypto-asset within MiCA. Tokens that qualify as financial instruments, deposits, fund interests, insurance products, payment instruments, e-money outside the relevant MiCA treatment, or other regulated products require separate analysis.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a route for eligible financial entities that are permitted under MiCA to provide equivalent crypto-asset services.
A regulated financial entity should check whether its existing licence supports the proposed crypto-asset service and whether Croatian HANFA or HNB competence is triggered. A regulated entity that wants to provide non-equivalent crypto-asset services may still need full CASP authorisation.
Application package
A Croatian CASP application is a full regulatory authorisation project.
Applications are submitted using the EU standard form and must include the information required under MiCA, the Croatian implementation law, HANFA’s authorisation rulebook and the applicable EU technical standards.
A credible application should include a complete service map, business plan, governance package, management fit-and-proper materials, qualifying-holder information, prudential analysis, capital or insurance evidence, AML framework, ICT and security materials, business-continuity plan, conflicts procedures, complaints procedures, outsourcing framework, client disclosures, service-specific policies, and proof of fee payment.
Additional service-specific materials are required for custody, holding client crypto-assets or client funds, operating a trading platform, exchange services, order execution, advice, portfolio management and transfer services.
HANFA may request further documents or explanations where necessary to assess whether the authorisation conditions are met.
Language
Croatian-language requirements are important.
Notices, information and documents that supervised entities must submit to Croatian competent authorities or publicly publish under MiCA and the Croatian implementation law are generally submitted and published in Croatian unless an EU delegated or implementing act provides otherwise.
A foreign issuer offering crypto-assets in Croatia may use a whitepaper in Croatian or English where the Croatian Act permits this.
A Croatian CASP application should therefore be prepared with Croatian-language filing capacity.
Transitional position
Croatia’s legacy VASP transition ends on 1 July 2026.
A provider that was entered in Croatia’s former virtual-asset-service-provider register under the AML framework must obtain MiCA CASP authorisation no later than 1 July 2026.
The former AML registration should not be treated as a MiCA licence. A provider that wants to continue Croatia-facing crypto-asset services after the end of the transitional period needs MiCA authorisation, a valid Article 60 route, or a valid MiCA passport from another Member State.
Current register status
HANFA maintains a public MiCA CASP register page.
At the review date, HANFA’s page listed two companies to which HANFA had issued CASP approvals: ELECTROCOIN d.o.o., with approval dated 9 April 2026, and WHITE TECH d.o.o., with approval dated 23 April 2026.
HANFA’s page states that after delivery of the Commercial Court activity-registration notice, the company will be entered in the MiCA CASP register and may begin the authorised activities.
The register should be checked before onboarding, launch, reliance on a Croatian provider, or publication of a list of authorised providers.
Costs
HANFA fees are service-specific.
The current fee rulebook lists the following CASP authorisation and extension fees:
Custody and administration: EUR 900.
Operation of a crypto-asset trading platform: EUR 10,200.
Exchange of crypto-assets for funds: EUR 2,500.
Exchange of crypto-assets for other crypto-assets: EUR 2,500.
Execution of client orders: EUR 2,000.
Placing of crypto-assets: EUR 2,000.
Reception and transmission of orders: EUR 1,500.
Advice on crypto-assets: EUR 2,700.
Portfolio management on crypto-assets: EUR 3,500.
Transfer services for clients: EUR 2,000.
The fee for management board consent is EUR 1,400. The fee for certain Article 60 financial-entity notifications is EUR 2,000. For issuing authorisation to a new CASP, the authorisation fee is capped at EUR 12,700.
Ongoing HANFA supervisory fees also apply. For 2026, non-platform CASPs pay 0.7 per mille of realised revenue from crypto-asset services, excluding revenue from operating a crypto-asset trading platform. A trading-platform operator pays 0.003 per mille of total annual turnover in crypto-assets achieved on the platform.
Fees should be checked before filing because HANFA fee rulebooks may be amended and supervisory-fee rules are annual.
Ongoing obligations
Croatian CASPs must comply with MiCA, the Croatian implementation law and HANFA rulebooks.
Core obligations include governance, management suitability, qualifying-holder controls, prudential protection, regulatory capital or insurance, internal controls, AML controls, conflicts management, complaints handling, business continuity, ICT and security controls, outsourcing oversight, client disclosures, recordkeeping, service-specific conduct rules, and supervisory reporting.
CASPs authorised by HANFA must maintain MiCA prudential protection at all times. The amount must be at least the greater of the permanent minimum capital requirement for the services provided or one quarter of fixed general expenses for the previous year. Prudential protection may take the form of regulatory capital, an insurance policy, a comparable guarantee, or a permitted combination.
Croatian CASPs must also comply with client-asset protection rules. Client crypto-assets and client funds received, held, paid out or delivered in connection with crypto-asset services must be treated as client assets. CASPs must maintain records that distinguish each client’s assets from those of other clients and from the CASP’s own assets, and must maintain organisational controls to reduce misuse, fraud, poor administration, poor recordkeeping and negligence risk.
Marketing and client information
Information provided to clients or potential clients, including promotional communication, must be fair, clear and not misleading. Promotional communication must be clearly identifiable as such.
Risk disclosures must be accurate and prominent. The Croatian Act requires risk wording to use a font size at least equal to the predominant font size used for the information.
A CASP must not use HANFA’s name or another competent authority’s name in a way that suggests the authority endorses or approves the CASP’s products or services.
Advice and portfolio-management models require appropriately qualified persons. Persons giving crypto-asset advice or making investment decisions within crypto-asset portfolio management must have knowledge and capabilities comparable to the standard required for investment advisers under Croatian capital-markets rules.
Enforcement risk
Croatia is not a light-touch jurisdiction.
HANFA may prohibit unauthorised crypto-asset services, order a person to stop conduct that breaches MiCA or Croatian law, request judicial assistance, seek asset freezing, and require temporary activity bans where unauthorised activity or market-abuse concerns arise.
For CASP breaches, including unauthorised provision of crypto-asset services in Croatia, a legal person may be fined up to EUR 5,000,000. The fine cannot be lower than 1 percent or higher than 5 percent of total net revenue for the relevant business year. If the breach generated a benefit or avoided loss that can be quantified, the fine may be increased to twice that amount if higher.
Responsible persons in a legal person may be fined from EUR 7,000 to EUR 25,000 for CASP breaches.
Market-abuse breaches carry higher exposure. Legal persons may be fined up to EUR 5,000,000, with a 7 percent to 15 percent net-revenue range, and the fine may be increased to three times the benefit or avoided loss where quantifiable. Natural persons and responsible persons may be fined up to EUR 1,000,000.
A competent-authority decision under the Croatian MiCA implementation framework cannot be appealed administratively, but an administrative dispute may be initiated. A lawsuit against a HANFA decision does not suspend the decision’s effect.
Practical assessment
Croatia is suitable for firms seeking a MiCA authorisation in an EU jurisdiction with a clear statutory framework, active HANFA licensing practice and detailed implementing rulebooks.
It is not suitable for firms looking for a paper registration, a long-term VASP transition, or an informal market-entry route.
The main execution risks are incorrect service classification, using the former VASP regime as if it were a MiCA licence, missing the 1 July 2026 transition deadline, underestimating Croatian-language documentation, failing to prepare management and qualifying-holder materials, and filing before AML, prudential, ICT, client-asset, complaints, conflicts and service-specific controls are ready.