Fintech & payments regulation in Croatia (2026)
Fintech and digital payments in Croatia: licensing regime.
Croatia operates a comprehensive, fully functional licensing regime for payment institutions and electronic money institutions, with the Croatian National Bank (HNB) as the primary competent authority under the Payment System Act (PSD2 transposition effective July 2018) and the Electronic Money Act. MiCA became fully applicable on 30 December 2024, with HANFA licensing crypto-asset service providers (CASPs) and HNB overseeing asset-referenced and e-money token issuers. Croatia's instant-payment infrastructure (EuroNKSInst via FINA) mandated SEPA Instant receipt from January 2025 and sending from October 2025, while PSD3/PSR and CCD2 (covering BNPL) are incoming EU-level frameworks Croatia will be required to implement.
Legal framework
Payment System Act (transposing PSD2, Directive 2015/2366/EU); Electronic Money Act (transposing EMD2); MiCA Implementation Act (Zakon o provedbi Uredbe (EU) 2023/1114, July 2024); supervised by Croatian National Bank (HNB) and Croatian Financial Services Supervisory Agency (HANFA)
How to get an EMI license in Croatia
To provide electronic-money or payment services in Croatia you need authorisation as an Electronic Money Institution (EMI), supervised by the Croatian National Bank (HNB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Croatian National Bank (HNB)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Croatia covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
Step by step: getting an EMI license in Croatia
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
Deposit and evidence the €350,000 initial capital.
Submit the application to the national competent authority.
The authority has three months from a complete application to grant or refuse.
On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Croatia
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
Ongoing obligations in Croatia
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
Key points: digital payments & fintech in Croatia
Payment Institution & EMI Licensing
Legal persons in Croatia wishing to provide payment services or issue e-money must obtain authorisation from HNB under the Payment System Act (Article 85) and the Electronic Money Act respectively. Full payment institution minimum capital ranges from ~EUR 20,000 to EUR 125,000 depending on services; a separate 'small payment institution' and 'small e-money institution' track exists for limited operators. HNB maintains a public register of all authorised providers.
PSD2 Transposition & Open Banking
The Payment System Act, in force since July 2018, fully transposes PSD2 (Directive 2015/2366/EU) into Croatian law, establishing the regime for account information service providers (AISPs) and payment initiation service providers (PISPs), and requiring banks to provide open-API access to third-party providers. HNB issued guidance on PSD2-compliant qualified certificate formats for TPPs.
Instant Payments & National Rails
Croatia's instant-payment system (EuroNKSInst / NKSInst) is operated by the Croatian Financial Agency (FINA) and is built on the SCT Inst framework using ISO 20022, processing EUR-denominated payments 24/7 with settlement via TARGET. Following EU Instant Payments Regulation requirements, Croatian PSPs must accept SEPA Instant Credit Transfers from 9 January 2025 and send them from 9 October 2025. Individual transactions are capped at EUR 100,000.
MiCA & Crypto-Asset Services
MiCA (Regulation EU 2023/1114) became fully applicable in Croatia on 30 December 2024 following the MiCA Implementation Act (July 2024). HANFA is the competent authority for licensing and supervising CASPs, while HNB supervises issuers of Asset-Referenced Tokens and E-Money Tokens. CASP capital requirements range from EUR 50,000 to EUR 150,000. Electrocoin became Croatia's first MiCA-licensed CASP in April 2026; the 18-month VASPs transition period ends 1 July 2026.
BNPL & Consumer Credit (CCD2)
Buy Now Pay Later services in Croatia will fall under the EU's second Consumer Credit Directive (CCD2, Directive 2023/2225/EU), which EU member states, including Croatia, must transpose by 20 November 2025, with the new obligations applying from 20 November 2026. CCD2 requires creditworthiness assessments, expands coverage to loans up to EUR 100,000, and mandates APR-compliant disclosure. No Croatia-specific BNPL-only licensing track yet exists.
PSD3/PSR, Incoming EU Reform
The EU reached provisional political agreement on PSD3 and the Payment Services Regulation (PSR) on 27 November 2025; publication in the EU Official Journal is anticipated for mid-2026, with application approximately 21 months thereafter (~early 2028). PSD3 must be transposed by member states within 18 months; the PSR will apply directly without national transposition. These reforms will consolidate PSD2 and EMD2, harmonise authorisation regimes, and introduce mandatory IBAN-name verification across all member states including Croatia.
EMI license in Croatia: FAQ
Do you need a license to run an e-money business in Croatia?
Yes. To provide electronic-money or payment services in Croatia you need authorisation as an Electronic Money Institution (EMI), supervised by the Croatian National Bank (HNB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
Which authority issues EMI licenses in Croatia?
The Croatian National Bank (HNB).
How much does an EMI license cost in Croatia?
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
How long does it take to get an EMI license in Croatia?
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
What documents do you need for an EMI license in Croatia?
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
What is the application process for an EMI license in Croatia?
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Does an Croatia EMI license work in other EU/EEA countries?
Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Timeline of decisions
- Law · officialMiCA (EU Regulation 2023/1114) Becomes Fully Applicable in Croatia
Markets in Crypto-Assets Regulation became fully applicable across all EU member states on 30 December 2024. HANFA is designated as the competent authority for licensing and supervising CASPs, while HNB oversees issuers of asset-referenced tokens and e-money tokens, establishing a split-supervisory model for crypto-assets.
HANFA
- Decision · officialCroatia Adopts the Euro, Joining the Eurozone as Its 20th Member
The kuna was replaced by the euro on 1 January 2023 (Croatia also joined Schengen the same day), granting Croatian payment institutions and fintechs direct access to Eurosystem payment infrastructure including TARGET2 and TIPS for instant payments, eliminating intra-EU currency-conversion costs and qualifying Croatia for the earlier eurozone deadlines under the Instant Payments Regulation.
European Central Bank — Economic Bulletin
- Guidance · officialHNB Launches Fintech Innovation Hub (Inovacijski hub)
The Croatian National Bank established its Innovation Hub to provide non-binding, informal regulatory guidance to firms developing innovative banking or payment products. The Hub became the primary pre-application channel for payment institutions and e-money institutions navigating HNB's authorisation process under the 2018 Payment System Act.
HNB Fintech Innovation Hub
- Law · officialPayment System Act (Narodne Novine 66/2018) Enters into Force — Full PSD2 Transposition
Croatia enacted the Zakon o platnom prometu (NN 66/2018), fully transposing PSD2 (Directive 2015/2366/EU). The Act established HNB as the competent authority for licensing payment institutions and electronic money institutions, introduced open-banking access obligations for account-servicing banks toward AISPs and PISPs, and mandated strong customer authentication, forming the cornerstone of today's Croatian fintech licensing regime.
HNB — Payment System Act (Official English Text)
- Guidance · officialHNB Establishes Cross-Disciplinary FinTech Task Force
The Croatian National Bank formed an internal FinTech Task Force drawing on legal, payment services, IT-risk, supervision, and financial stability experts to monitor innovation and prepare regulatory responses. The task force directly informed Croatia's PSD2 transposition strategy and the subsequent Innovation Hub, marking the beginning of proactive fintech engagement by the regulator.
HNB
- Law · officialCroatia Accedes to the EU — Full EU Payment Services Acquis Takes Effect
Upon joining the European Union, Croatia became bound by PSD1 (Directive 2007/64/EC) and the Electronic Money Directive 2 (2009/110/EC), triggering the formal licensing of payment institutions and e-money institutions under HNB supervision and integrating Croatia into the Single Euro Payments Area (SEPA). This established the foundational legal architecture that all subsequent fintech regulation has built upon.
HNB — About the Payment System
Sources
- hnb.hr/en/core-functions/payment-system/licensing
- hnb.hr/en/core-functions/payment-system/licensing/payment-institutions
- hnb.hr/en/core-functions/payment-system/licensing/electronic-money-instituti
- hnb.hr/en/core-functions/payment-system/licensing/small-payment-institutions
- hnb.hr/en/core-functions/payment-system/licensing/small-electronic-money-ins
- hnb.hr/en/core-functions/payment-system/registers-and-records/register-of-pa
- hnb.hr/en/-/nks
- hnb.hr/en/-/obavijest-o-pocetku-rada-nksinst-platnog-sustava
- fina.hr/en/national-clearing-system
- hanfa.hr/consumers/consumer-news/notification-for-persons-intending-to-trade-c
- croatiaweek.com/croatia-first-mica-crypto-licence-electrocoin/
- europarl.europa.eu/legislative-train/theme-an-economy-that-works-for-people/file-revisio
- hoganlovells.com/en/publications/eu-second-consumer-credit-directive-scope-and-impact-
- thedubrovniktimes.com/news/croatia/item/17373-revolutionizing-payments-in-croatia-sepa-inst
- hnb.hr/en/-/notification-to-qualified-trust-service-providers-qualified-cert
- copla.com/blog/compliance-regulations/mica-regulation-in-croatia-licensing-impl
- oliverwyman.com/our-expertise/insights/2025/feb/impact-of-ccd2-on-buy-now-pay-later-s
- nortonrosefulbright.com/en/knowledge/publications/cedd39c6/psd3-and-psr-from-provisional-agre
- dlapiper.com/en/insights/publications/2026/03/psd3-and-psr
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026