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Fintech Licensing Hub

Croatia

Croatia regulates crypto under MiCA through the Act implementing Regulation (EU) 2023/1114 (Official Gazette 85/2024), with HANFA as competent authority for CASPs and HNB for asset-referenced and e-money tokens; the full 18-month grandfathering expired on 1 July 2026, and HANFA has begun authorising CASPs (Electrocoin was the first). Payments and e-money run under the Payment System Act (OG 66/2018) and the Electronic Money Act (OG 64/2018), supervised by the HNB, with the Instant Payments Regulation (fully applicable since 9 October 2025) and DORA (since 17 January 2025) in force and PSD3/PSR approaching adoption. Gambling is regulated by the Ministry of Finance (Tax Administration) under the Games of Chance Act, with Hrvatska Lutrija holding the state lottery monopoly and a 2025 reform — in force from early 2026 — tightening advertising, player protection and taxes; Croatia adopted the euro on 1 January 2023.

Available licences

Crypto-Asset Service Provider authorisation (HANFA under MiCAR and the Implementing Act)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require HANFA authorisation under Article 63 MiCAR. HANFA maintains the official registry of authorised crypto-asset service providers and granted Croatia's first CASP authorisation (to Electrocoin) in 2026; an authorisation passports across the EEA.

Asset-Referenced Token (ART) issuer authorisation (HNB)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR, with reserve, custody and disclosure requirements, supervised by the HNB.

E-Money Token (EMT) issuer (credit institution or EMI; HNB)

EMTs may be issued only by an authorised credit institution or e-money institution, with redemption at par; the HNB is the competent authority, consistent with its prudential role over e-money.

Article 60 MiCAR notification route (existing financial institutions)

Credit institutions, investment firms, e-money and payment institutions, UCITS management companies, AIFMs, CSDs and market operators already authorised under EU law may provide specified crypto-asset services by notifying HANFA for the services their existing licence covers.

Payment Institution authorisation (HNB under the Payment System Act)

A licence to provide payment services under the Payment System Act, supervised by the HNB and entered in the HNB register; payment institutions may not take deposits or issue e-money.

E-Money Institution authorisation (HNB under the Electronic Money Act)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital, supervised by the HNB; an authorisation may also cover payment services not linked to e-money.

Small payment / small e-money institution (HNB)

Lighter national regimes for small payment institutions and small e-money institutions (the latter with average outstanding e-money capped at EUR 265,000), able to operate only in Croatia and without EEA passporting.

Account Information and Payment Initiation Services (HNB)

Open-banking providers — account information and payment initiation service providers — fall within the Payment System Act, supervised by the HNB, with strong customer authentication and dedicated-API access under PSD2.

Banking authorisation (HNB / ECB SSM under the Credit Institutions Act)

Deposit-taking and lending require a banking licence under the Credit Institutions Act. The HNB is the national supervisor; with euro-area membership, the ECB decides for significant institutions and oversees less significant ones within the SSM.

Investment firm authorisation (HANFA — MiFID II)

Investment services in financial instruments require authorisation under the Capital Market Act transposing MiFID II, supervised by HANFA.

Casino, betting and online gambling licences (Ministry of Finance under the Games of Chance Act)

The Ministry of Finance licenses casinos, betting (fixed-odds, totalizator and sports betting, retail and online), slot-machine clubs and online gambling. Only companies registered in Croatia may apply; online operators must locate servers in Croatia and integrate with the Tax Administration's monitoring and player-identification systems.

Lottery monopoly (Hrvatska Lutrija)

The right to operate gambling belongs to the Republic of Croatia, which transfers it to the state-owned Hrvatska Lutrija; lottery games are an exclusive Hrvatska Lutrija monopoly, while casino, betting and slot games are open to licensed private operators by Government decision.

Detailed overview

Croatia at a glance

Croatia pairs euro-area membership (since 2023) with an early MiCAR implementation and a state-anchored gambling regime now significantly tightened by a 2025 reform. Crypto is supervised by HANFA (CASPs) and the HNB (ART/EMT issuers) under the Act implementing MiCAR; the transitional regime covered VASPs in HANFA's AML register and expired on 1 July 2026. Payments run under the Payment System Act and the Electronic Money Act with the HNB as supervisor and the Instant Payments Regulation and DORA in force. Gambling is licensed and taxed by the Ministry of Finance through the Tax Administration, with lottery reserved to Hrvatska Lutrija. The euro replaced the kuna on 1 January 2023 (at the fixed rate EUR 1 = HRK 7.53450), and Croatia sits within the euro-area SSM and TARGET infrastructure.

Crypto regime under MiCA — HANFA/HNB-split, early implementer, post-transition:

  • MiCA + national implementing law — Regulation (EU) 2023/1114 (MiCAR); the Act implementing Regulation (EU) 2023/1114 (Official Gazette / Narodne novine 85/2024)
  • Competent authorities — HANFA for CASP authorisation and supervision, white papers for crypto-assets other than ARTs/EMTs, and market-abuse and conduct rules; the HNB for issuers of asset-referenced tokens and e-money tokens
  • Grandfathering — closed. Croatia took the full 18-month transitional period; VASPs in HANFA's AML register before 30 December 2024 could continue their existing services (no new services, no passport) until 1 July 2026, or until authorised or refused. That EU-wide backstop has now expired
  • First authorisations — HANFA began issuing CASP authorisations in 2026, with Electrocoin the first company entered in HANFA's registry of authorised crypto-asset service providers
  • Article 60 notifications — credit institutions, investment firms, e-money and payment institutions, UCITS managers, AIFMs, CSDs and market operators may notify HANFA to provide crypto-asset services within their existing authorisation
  • AML/CFT — the Anti-Money Laundering and Terrorist Financing Act applies; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027; the Croatian FIU is the Anti-Money Laundering Office within the Ministry of Finance
  • TFR — Regulation (EU) 2023/1113 (recast Transfer of Funds Regulation) applies the Travel Rule to crypto-asset transfers from 30 December 2024
  • Tax — crypto-to-fiat gains are taxed as capital income at 12% (with a two-year holding exemption, an annual personal allowance and crypto-to-crypto disposals not treated as a taxable event); corporate income tax is 10% for companies below the lower revenue threshold and 18% above it
  • Substance — HANFA expects a genuine Croatian entity, local management and on-site infrastructure, and enforces against unlicensed solicitation, issuing consumer warnings during the transition

Payments and e-money regime (HNB-led):

  • PSD2 — Directive (EU) 2015/2366; transposed by the Payment System Act (OG 66/2018), in force since July 2018, supervised by the HNB
  • Payment Institution licensing — initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services)
  • EMD2 / E-Money Institution — Directive 2009/110/EC; transposed by the Electronic Money Act (OG 64/2018); EUR 350,000 initial capital
  • Small institutions — small payment institutions and small e-money institutions (average outstanding e-money capped at EUR 265,000) may operate only in Croatia, without EEA passporting
  • Instant Payments Regulation (Regulation (EU) 2024/886) — euro instant payments: receiving applicable from 9 January 2025 and sending from 9 October 2025
  • DORA (Regulation (EU) 2022/2554) — applicable from 17 January 2025
  • PSD3 / PSR — Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions, with PSD3 transposed nationally and the PSR directly applicable after a phased timeline
  • Banking — banks are licensed by the HNB under the Credit Institutions Act, with the ECB deciding for significant institutions under the SSM
  • Currency: euro (EUR), adopted 1 January 2023 (replacing the kuna at EUR 1 = HRK 7.53450); no exchange controls

Gambling regime — state-anchored, Ministry-of-Finance-led:

  • Games of Chance Act (Zakon o igrama na sreći, OG 87/2009, as amended) — the framework for lotteries, casinos, betting and slot machines, administered and supervised by the Ministry of Finance through its Tax Administration (Porezna uprava)
  • State monopoly — the right to operate gambling belongs to the Republic of Croatia, transferred to the state-owned Hrvatska Lutrija; lottery games are exclusive to Hrvatska Lutrija, while casino, betting and slot games are open to licensed private operators (the number set by Government decision)
  • Online — only Croatia-registered companies may hold a licence; online operators must host servers in Croatia, integrate with the Tax Administration's centralised monitoring, and verify player age and identity through Tax Administration electronic services
  • 2025 reform (in force from early 2026) — a major overhaul tightened the regime: a progressive tax on winnings (tiers up to 30%, with small lottery wins exempt), sharply increased licence fees, advertising restrictions (no ads on internet/radio/TV between 06:00 and 23:00, bans in print and on billboards, and no celebrity or influencer endorsements), venue location limits, and a mandatory centralised player-identification system and National Self-Exclusion Register
  • Tax — operators pay licence fees and gaming taxes administered by the Tax Administration; the 2025 reform replaced the previous flat winnings tax with a progressive system from 1 January 2026 — confirm the current operator and winnings-tax schedule with the Ministry of Finance
  • Minimum age — 18; operators are AML obliged entities reporting to the Anti-Money Laundering Office
  • No EU passport — gambling is licensed nationally; foreign operators without a Croatian licence are blocked and may face enforcement

Last verified: July 2026. Reference rate: USD 1 ≈ EUR 0.87 (EUR 1 ≈ USD 1.15). Croatia adopted the euro on 1 January 2023, replacing the kuna at the fixed rate EUR 1 = HRK 7.53450.

Croatia is a euro-area venue that moved early on MiCAR: crypto runs under the national Implementing Act with HANFA (CASPs) and the HNB (ART/EMT issuers), payments sit under the Payment System Act and the Electronic Money Act with the HNB as supervisor, and gambling is licensed and taxed by the Ministry of Finance under the Games of Chance Act — with lottery reserved to Hrvatska Lutrija and a 2025 reform tightening advertising, player protection and taxes.

Is there a crypto licence in Croatia?

Yes. Croatia applies MiCAR through its national Implementing Act, with HANFA authorising and supervising CASPs and the HNB supervising ART and EMT issuers. The full 18-month transitional window expired on 1 July 2026, so operating now requires a HANFA authorisation, a valid MiCA passport, or an Article 60 notification.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) — the directly applicable EU framework for offerings, admission and crypto-asset services
  • Act implementing Regulation (EU) 2023/1114 (OG 85/2024) — designates HANFA and the HNB, sets procedures and enforcement
  • Anti-Money Laundering and Terrorist Financing Act — AML/CFT obligations for CASPs
  • Regulation (EU) 2023/1113 — Travel Rule for crypto-asset transfers

Structure:

  • A Croatian legal entity with local management and genuine on-site infrastructure; letterbox structures are not acceptable
  • MiCAR own-funds floors by class — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) — with the prudential requirement set as the higher of the own-funds floor or a fixed-overheads measure
  • Fit-and-proper management and qualifying shareholders, AML officers, a white paper for in-scope offerings, and custody, conflicts, complaints and market-abuse arrangements

Operational reality:

  • HANFA is an accessible regulator that encourages pre-application meetings and has begun issuing authorisations; it does not charge an initial CASP authorisation fee but levies ongoing supervisory fees
  • Croatia's competitive tax regime (12% capital-income tax on crypto disposals with a two-year exemption, and a 10% corporate rate below the revenue threshold) makes it an attractive euro-area base for licensed CASPs
  • New Croatia-facing activity should be structured through a HANFA authorisation, a valid passport or an Article 60 notification — not the closed transitional regime

Official CASP roadmap: HANFA does not publish a separate step-by-step roadmap, but it provides official MiCA guidance, maintains the registry of authorised crypto-asset service providers, and encourages pre-application meetings before an Article 62/63 submission. See HANFA's notification for persons intending to trade crypto-assets and its crypto-asset registers on the HANFA website.

Payments & E-money (HNB — PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and open-banking operators that want a euro-area base supervised by the Croatian National Bank.

What it is: Authorisation as a payment institution under the Payment System Act or as an e-money institution under the Electronic Money Act, both supervised by the HNB and passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers seeking a euro-area foothold; smaller entrants may use the small institution tracks.

Covers: The payment services under the Payment System Act — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Croatian entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management.

Headline figures

  • Primary instruments: Payment System Act (OG 66/2018, PSD2); Electronic Money Act (OG 64/2018, EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
  • Regulators: HNB (authorisation and supervision); ECB (SSM, for significant banks)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000
  • Light regime: small payment institutions and small e-money institutions (average outstanding e-money capped at EUR 265,000), domestic only, no passport
  • Instant payments: euro instant payments — receiving from 9 January 2025, sending from 9 October 2025
  • Reform pipeline: PSD3 / PSR — political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
  • Currency: EUR (adopted 1 January 2023); no exchange controls

Is there a gambling licence in Croatia?

Yes. The Ministry of Finance licenses casinos, betting, slot-machine clubs and online gambling under the Games of Chance Act, while lottery is reserved to the state-owned Hrvatska Lutrija. Only Croatia-registered companies may apply, and a 2025 reform has significantly tightened the regime.

The legal foundation:

  • Games of Chance Act (OG 87/2009, as amended) — the framework for all gambling
  • Ministry of Finance / Tax Administration — licensing, supervision, technical certification and gaming taxation
  • 2025 reform (in force from early 2026) — progressive winnings tax, higher fees, advertising limits, location rules and mandatory player-identification and self-exclusion systems
  • Anti-Money Laundering and Terrorist Financing Act — AML obligations for operators

Structure:

  • Lottery is an exclusive Hrvatska Lutrija monopoly; casino, betting and slot licences are open to Croatia-registered private operators, with the number set by Government decision
  • Online operators must host servers in Croatia and integrate with the Tax Administration's monitoring and player-identification systems
  • Minimum share capital and financial guarantees apply by licence type, with player age and identity verified through Tax Administration electronic services

Gambling — Online licence (Ministry of Finance)

Best for established operators able to incorporate in Croatia and meet server-localisation and player-protection requirements; not for offshore operators relying on a foreign licence.

What it is: A Ministry-of-Finance licence for online gambling (online casino, betting and other games of chance) under the Games of Chance Act, with a Croatian entity and certified technical systems.

Who it suits: B2C operators with a Croatian company prepared to meet capital, certification, localisation and responsible-gambling requirements.

Covers: Online casino games and betting within the licence scope; lottery is excluded as a Hrvatska Lutrija monopoly.

Operational requirement: A Croatia-registered company, minimum share capital and guarantees, Croatia-based servers, integration with the Tax Administration's monitoring and self-exclusion systems, AML/CFT and player-protection tools.

Headline figures

  • Primary instruments: Games of Chance Act (OG 87/2009, as amended) and implementing ordinances; the 2025 reform legislation
  • Regulators: Ministry of Finance / Tax Administration (licensing, supervision, taxation)
  • Costs: minimum share capital and financial guarantees by licence type; one-off and annual licence fees increased sharply by the 2025 reform — confirm current figures with the Ministry of Finance
  • Tax/duty: operator licence fees and gaming taxes administered by the Tax Administration; a progressive winnings tax (up to 30%) from 1 January 2026
  • Online: Croatia-based servers, centralised monitoring, mandatory player identification and National Self-Exclusion Register
  • Player protection: minimum age 18; restricted advertising; AML obligations

Costs and timelines at a glance

  • Crypto: MiCAR via the national Implementing Act, HANFA for CASPs and HNB for ART/EMT issuers; own-funds floors EUR 50,000 / 125,000 / 150,000 by class; Article 63 timeline of a 25-working-day completeness check plus a 40-working-day decision; transitional regime closed 1 July 2026; no initial HANFA CASP fee
  • Payments primary instruments: Payment System Act (OG 66/2018, PSD2); Electronic Money Act (OG 64/2018, EMD2); Instant Payments Regulation (EU) 2024/886; DORA
  • Payments regulators: HNB (authorisation and supervision); ECB (SSM, banks)
  • Banking entry: authorisation under the Credit Institutions Act; HNB national supervisor, ECB for significant institutions under the SSM
  • Reform pipeline: PSD3 / PSR — agreement November 2025, compromise texts April 2026, adoption expected during 2026
  • Gambling: Ministry-of-Finance regime under the Games of Chance Act; lottery reserved to Hrvatska Lutrija; 2025 reform tightened advertising, player protection and taxes (progressive winnings tax up to 30% from 1 January 2026); server-localisation required
  • Currency: EUR (adopted 1 January 2023); no exchange controls
  • FX: USD 1 ≈ EUR 0.87 (EUR 1 ≈ USD 1.15)

Who Croatia suits and who it does not

Suitable for

  • Crypto exchanges, custodians and token issuers wanting a MiCAR CASP authorisation from an accessible regulator in a euro-area state, with EEA passporting and a competitive tax regime
  • Already-licensed banks, investment firms, payment and e-money institutions that can add crypto-asset services through the Article 60 notification route
  • Payment, remittance, acquiring, wallet and open-banking operators seeking a euro-area base under HNB supervision, with instant-payments readiness
  • Smaller payment or e-money entrants that fit the small institution tracks and do not need an EEA passport
  • Gambling operators willing to incorporate in Croatia and meet capital, server-localisation, certification and player-protection requirements

Not suitable for

  • Firms seeking a bespoke or light-touch national crypto regime — Croatia applies MiCAR in full, with HANFA/HNB supervision and a local-substance expectation
  • Providers relying on a former VASP registration — the transitional window closed on 1 July 2026
  • Payment or e-money firms expecting to avoid EU prudential, safeguarding, DORA or AML obligations
  • Offshore gambling operators relying on a foreign licence — Croatia licenses gambling nationally, requires Croatian incorporation and server localisation, and blocks unlicensed sites
  • Operators seeking to offer lottery products — these are reserved to the state-owned Hrvatska Lutrija

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