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Croatia: fintech & payments regulation

Regulated

Croatia fintech & payments: HANFA oversight under EU PSD2/EMDI framework; no standalone VASP law

Lead regulator:
Croatian Financial Services Supervisory Agency (HANFA)
Key law:
Act on Payment Services (ZPUS-2) and Act on Electronic Money (ZPEP)
Last updated:
2026-07-12

Croatia regulates payment and electronic money services through the transposition of EU Directives PSD2 and EMDI, supervised by HANFA. The jurisdiction does not currently have a standalone licensing regime for Virtual Asset Service Providers (VASPs); crypto-assets are generally treated as property or commodities rather than financial instruments or currency.

Payment institutions and electronic money institutions require authorization from HANFA to operate. General fintech activities such as crowdfunding and leasing are also regulated under specific acts and HANFA guidelines, while pure payment facilitators that do not hold funds may fall outside direct supervision if they do not provide financial services.

The regulatory environment is aligned with EU standards, with HANFA actively issuing guidelines on insurance intermediaries, crowdfunding, and alternative investment funds. There is no explicit ban on crypto-assets, but the lack of a specific VASP licensing framework creates regulatory uncertainty for crypto-native businesses.

Who regulates

  • Croatian Financial Services Supervisory Agency (HANFA)

    Primary supervisor for payment institutions, electronic money institutions, insurance, securities, and pension funds.

    [1][2][3][4][5][6][7][8][9]

  • Croatian National Bank (HNB)

    Supervisor for payment systems and monetary policy; collaborates on payment service oversight.

Core laws & rules

  • Act on Payment Services (ZPUS-2) (2018 (with amendments))

    Transposes PSD2 into national law, regulating payment institutions and payment service providers.

  • Act on Electronic Money (ZPEP) (2014 (with amendments))

    Regulates the issuance of electronic money and the activities of electronic money institutions.

  • Capital Markets Act (2018 (consolidated 2025))

    Regulates investment firms, regulated markets, and securities issuance, transposing MiFID II and other EU directives.

    [2]

  • Factoring Act (2014 (consolidated 2016))

    Regulates factoring contracts and the establishment and supervision of factoring companies.

    [10]

Licensing & registration

  • Payment Institution / Electronic Money Institution

    Authorization required from HANFA to provide payment services or issue electronic money. Compliance with PSD2/EMDI standards is mandatory.

  • Investment Firm / UCITS/AIF Manager

    Licensing required for managing alternative investment funds (UAIFs) or providing investment services under the Capital Markets Act.

    [8][11]

  • Crowdfunding Platform

    Guidelines issued by HANFA establish conditions for mandatory pension funds to invest via crowdfunding platforms; platforms themselves may require authorization if they provide investment services.

    [4]

Restrictions & warnings

  • No specific VASP licensing regime exists; crypto-assets are not recognized as legal tender. Entities facilitating transactions without holding funds may not be supervised as financial service providers.

    [9]

  • Insurance intermediaries and leasing companies are subject to specific authorization and registration requirements under the Insurance Act and HANFA guidelines.

    [1]

Direction of travel

  • Croatia continues to align its financial regulations with EU directives. The absence of a dedicated VASP law remains a key gap, but HANFA's active guidance on fintech-adjacent sectors (crowdfunding, insurance tech) suggests a structured approach to emerging financial services.

Sources

  1. Insurance Intermediaries as Distributors of Units in Investment Funds · 2026-02-05
  2. Capital Markets Act (Official Gazette, Nos. 65/18, 17/20, 83/21, 151/22, 85/24 and 126/25) – Unofficial Consolidated Text · 2025-01-01
  3. Law on Voluntary Pension Funds – Unofficial Consolidated Text (NN, Nos. 19/14, 29/18, 115/18, 156/23 and 52/25) · 2025-01-01
  4. Guidelines on Crowdfunding Platforms · 2024-09-03
  5. Act on Mandatory Pension Funds - Unofficial Consolidated Text (NN, No. 19/14, 93/15, 64/18, 115/18, 58/20 and 156/23) · 2023-01-01
  6. Rulebook on the Conduct of Leasing Business by Leasing Companies from Member States and Third Countries in the Republic of Croatia · 2022-01-01
  7. Rulebook on the Conduct of Factoring Business by Factoring Companies from Other Member States and Third Countries in the Republic of Croatia · 2022-01-01
  8. Regulation on the Issuance of Operating Licenses for UAIFs (Official Gazette Nos. 136/20 and 100/22 – Unofficial Consolidated Text) · 2022-01-01
  9. Official Position Regarding the Application of Article 2(2) of the HAFC Act in Connection with the Establishment of the PlatiMe.hr Digital Platform · 2021-05-06
  10. Factoring Act (Unofficial Consolidated Text - NN, No. 94/14 and 41/16) · 2016-01-01
  11. Regulation on Approval for Establishing and Managing UCITS Funds, and Amending Their Prospectus and Rules - Unofficial Consolidated Text (NN Nos. 3/17 & 41/17) · 2017-01-01

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This guide is compiled automatically from 11 primary-source documents published by Croatia's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.