Croatia: crypto & digital assets regulation

Who regulates

• Croatian Financial Services Supervisory Agency (HANFA)

  Primary national supervisor for Crypto-Asset Service Providers (CASPs) and other authorized entities, responsible for issuing instructions and guidelines for MiCA implementation.

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• European Securities and Markets Authority (ESMA)

  Issues guidelines to ensure consistent application of the MiCA Regulation across the EU, which HANFA implements or refers to in its national directives.

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• European Banking Authority (EBA)

  Jointly issues guidelines with ESMA, specifically concerning the assessment of fit and proper management body members for asset-referenced token issuers and CASPs.

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Core laws & rules

• Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation - MiCA) (2023)

  Establishes a comprehensive regulatory framework for crypto-assets and crypto-asset service providers across the European Union, which Croatia is actively implementing through national guidelines and instructions.

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Licensing & registration

• Crypto-Asset Service Providers (CASPs)

  CASPs are required to comply with organizational, reporting, and conduct-of-business requirements under MiCA, including robust internal controls, risk management, investor protection policies, and suitability requirements for services like portfolio management. Timeline: The documents indicate active implementation of MiCA, with guidelines issued between 2024 and 2026, aligning with MiCA's phased application.

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• Issuers of Asset-Referenced Tokens (ARTs)

  Issuers of ARTs are subject to specific guidelines regarding the assessment of fit and proper members of their management body.

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Restrictions & warnings

• Third-country entities are restricted from soliciting clients established or located in the EU, with supervisory practices in place to detect and prevent circumvention of the reverse solicitation exemption under MiCA.

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• CASPs must adhere to strict organizational requirements, including robust internal control systems, distinct risk management, and comprehensive investor protection policies for services like crypto-asset transfers and portfolio management.

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Direction of travel

• Croatia is actively implementing the EU's MiCA Regulation through national instructions and guidelines, indicating a clear direction towards a comprehensive and harmonized regulatory environment for crypto-assets and service providers.

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Sources

1. Instruction on the Preparation and Submission of Reports by Crypto-Asset Service Providers · 2026-03-27
2. Guidelines on Organizational Requirements for Crypto-Asset Service Providers · 2025-12-23
3. Guidelines on certain aspects of suitability requirements and the format of periodic reports for portfolio management activities under the Markets in Crypto-Assets Regulation (MiCA) · 2025-03-26
4. Guidelines on templates for explanations and legal opinions and the standardized test for crypto-assets under Article 97(1) of Regulation (EU) 2023/1114 · 2025-03-10
5. Guidelines on procedures and policies, including client rights, in the context of crypto-asset transfer services under the Markets in Crypto-Assets Regulation (MiCA) regarding investor protection · 2025-02-26
6. Guidelines on procedures and policies, including client rights, in the context of crypto-asset transfer services under the Markets in Crypto-Assets Regulation (MiCA) regarding investor protection (ESMA35-1872330276-2032) · 2025-02-26
7. Guidelines on situations where a third-country entity is deemed to be soliciting clients established or located in the EU and supervisory practices to detect and prevent circumvention of the reverse solicitation exemption under the Markets in Crypto-Assets Regulation (MiCA) · 2025-02-26
8. EBA and ESMA Joint Guidelines on the Assessment of Fit and Proper Members of the Management Body of Asset-Referenced Token Issuers and Crypto-Asset Service Providers · 2024-12-04