EMI license in Croatia: e-money institution (EMI) requirements (2026)

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).

The Croatian National Bank (HNB).

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

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.

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.

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 (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.

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.

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.