Regulatory AlertsCroatia: fintech & payments regulation
RegulatedCroatia: PSD2/PSD3 regime; HANFA supervises payment institutions; no standalone e-money licence
- Lead regulator
- Croatian Financial Services Supervisory Agency (HANFA)
- Also involved
- Croatian National Bank (CBR) · Croatian Financial Intelligence Unit (FIU)
- Core law
- Payment Services Act (ZPUS-1)
- Entry capital
- EUR 20,000 (Payment Institution)
- Approval timeline
- 3-6 months
- Customer assets
- Segregated in dedicated client accounts
- Data protection
- GDPR · Croatian Personal Data Protection Agency (AZOP)
- Sandbox
- No
Croatia implements the EU Payment Services Directive (PSD2) via the Payment Services Act. HANFA supervises Payment Institutions (PIs) and Electronic Money Institutions (EMIs). The regulatory stance is aligned with EU standards, requiring authorization for payment and e-money activities. The market is open to EU passporting and third-country branches.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicencePayment Institution Requires authorization under PSD2 for payment processing services. | EUR 20,000 | 3-6 months | HANFA |
| E-money & wallet issuance | LicenceElectronic Money Institution Requires EMI license for issuing electronic money and wallet services. | EUR 3,500,000 | 3-6 months | HANFA |
| Domestic money transfer | LicencePayment Institution Domestic transfers fall under Payment Institution authorization. | EUR 20,000 | 3-6 months | HANFA |
| Cross-border remittance | LicencePayment Institution Cross-border remittance requires Payment Institution license. | EUR 20,000 | 3-6 months | HANFA |
| Agent network | Registration Agents must be registered with the licensed Payment Institution. | — | — | HANFA |
| Open banking / account information | LicencePayment Institution / AISP/PISP Account Information and Payment Initiation Services require PI license. | EUR 20,000 | 3-6 months | HANFA |
| Foreign-exchange services | LicencePayment Institution Currency exchange for payment services requires PI license. | EUR 20,000 | 3-6 months | HANFA |
Market-entry checklist
- 1Establish Croatian entityIncorporate a d.o.o. or a.d. with registered office in Croatia.
- 2Secure minimum capitalDeposit EUR 20,000 (PI) or EUR 3.5m (EMI) in a blocked account.
- 3Submit HANFA applicationFile business plan, governance structure, and AML policies with HANFA.
- 4Register with CBROpen dedicated client accounts and register with the Central Bank.
- 5Obtain FIU registrationRegister as a reporting entity with the Croatian Financial Intelligence Unit.