Crypto license in Croatia: MiCA CASP requirements (2026)

HANFA's Management Board authorized Zagreb-based Electrocoin d.o.o. as Croatia's first Crypto-Asset Service Provider under MiCA, covering exchange, custody, and asset-management services. Electrocoin became the inaugural entry in HANFA's official Registry of MiCA-Authorised CASPs and a model for the ~20 providers still seeking full authorisation ahead of the July 2026 deadline.

Parliament adopted the domestic implementing law that designates HANFA as the competent authority for CASP licensing and supervision, and HNB (the central bank) for oversight of Asset-Referenced Token and E-Money Token issuers. The act fulfilled Croatia's obligation to establish the national institutional architecture required by MiCA.

All Virtual Asset Service Providers were required to register with HANFA by 4 September 2023 or cease Croatian operations. Post-deadline data showed only a handful had registered while 84+ entities remained unregistered and therefore in breach of AML/CFT obligations — revealing a large compliance gap heading into MiCA.

HANFA's Board enacted the Ordinance on keeping the Register of Virtual Asset Service Providers, setting out the registration procedure, required documentation, and fit-and-proper assessments for owners and managers. Applications opened on 28 June 2023, giving VASPs roughly ten weeks before the binding deadline.

Amendments to Croatia's Anti-Money Laundering and Terrorist Financing Prevention Act introduced enhanced due-diligence obligations keyed to a EUR 1,000 per-transaction threshold and aligned CASP definitions with FATF recommendations and the forthcoming MiCA framework. This was the most significant update to the crypto AML regime before MiCA itself applied.

Croatia's new Money Laundering and Terrorist Financing Prevention Act, passed in April 2019, entered into force on 1 January 2020. Crypto exchange and custodial-wallet providers were required to notify HANFA of their activities by 31 January 2020 — the first time any registration or supervisory obligation applied to crypto businesses in Croatia.

HANFA publicly warned that virtual currencies are not legal tender in Croatia and that neither issuers nor traders are authorised or supervised by any Croatian authority. Consumers were advised they would have no recourse to investor-compensation schemes or regulatory protection if they suffered losses.

HNB formally stated that virtual currencies do not constitute a means of payment under the Payment System Act, are neither foreign currency nor foreign payment instruments, and that trading in them cannot be considered regulated payment services. This declaration established the foundational legal classification that remains in effect today.

Croatia's tax authority opined that cryptocurrency is equivalent to money market instruments (a sub-class of financial assets), making realized crypto-to-fiat capital gains subject to the 12% personal income tax on financial-asset gains. A 2-year holding-period exemption applies; crypto-to-crypto trades remain tax-free. No dedicated crypto-tax statute has since been enacted.