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Croatia implements the EU Markets in Crypto-Assets Regulation (MiCA) as directly applicable law. Crypto-asset service providers (CASPs) require authorisation from HANFA (Hrvatska agencija za nadzor financijskih usluga), which is the designated competent authority for MiCA Titles II, V and VI, while the Croatian National Bank (HNB) is designated competent authority for Titles III and IV (asset-referenced tokens and e-money tokens). A national implementing act was expected in H2 2024 to formally split supervisory duties; legacy providers already in Croatia's pre-MiCA register at end-2024 may rely on a transitional/grandfathering period running up to June 2026, after which full HANFA authorisation is mandatory.
Until this cycle, the precise domestic legal footing of HANFA's (and HNB's) competence had rested substantially on the ESMA-notified competent-authority list -- itself a primary administrative source, but one that documents designation rather than the underlying national statute establishing it. That gap has now closed. A Challenger-driven review surfaced and confirmed a Croatian national MiCA Implementing Act, published in Official Gazette No. 85/2024 and enacted by the Sabor (Croatian Parliament) on 12 July 2024, hosted directly on HNB's own website. This act formally codifies the HANFA/HNB competent-authority split at the level of domestic statute, correcting a prior research framing that had characterised national implementing legislation as merely 'expected' during the second half of 2024. The practical effect is to materially strengthen confidence in the underlying institutional-competence claim: the split is not an informal administrative arrangement pending formalisation, but settled national law that has been in force since 19 July 2024.
The second live thread in Croatia's licensing picture concerns the treatment of providers that were operating before MiCA's core provisions became applicable. These legacy, pre-MiCA-registered Croatian crypto-asset service providers were permitted to rely on MiCA's transitional (grandfathering) adjustment period, under which they could continue operating without full MiCA authorisation for a defined window while working toward compliance, whereas any new entrant seeking to commence services after the end of 2024 was required to obtain full HANFA licensing before starting operations. Secondary reporting places the end of that transitional window at approximately mid-2026, with a more precise figure -- 1 July 2026, drawn from an eighteen-month transitional mechanism -- cited in additional secondary reporting but not yet corroborated against a primary source strong enough to displace the retained approximate figure. As of this cycle's retrieval date, that transitional deadline has already passed. No research to date confirms whether previously grandfathered legacy providers have since completed full HANFA authorisation, ceased Croatian operations, or continue operating in an unresolved compliance posture. This is a genuine, live evidentiary gap rather than a settled negative finding, and it is the principal reason this claim's confidence has been downgraded this cycle: a materiality-significant, binding requirement was resting on a single secondary-source citation, now flagged as insufficiently anchored pending stronger primary confirmation of both the precise deadline and post-deadline compliance status.
Taken together, Croatia's licensing regime presents a bifurcated picture: the foundational authorisation requirement and the domestic institutional-competence question are now confirmed and settled at a high confidence level, while the transitional compliance question for legacy operators is live, time-sensitive, and currently unresolved. Both threads sit within the same MiCA architecture and are supervised by the same authority, HANFA, but they carry materially different evidentiary weight and should be read accordingly by anyone assessing licensing risk for a Croatian-facing crypto-asset business.
Outlook
The immediate next step for this module is a targeted check of HANFA's public CASP register to determine whether legacy providers that relied on the transitional grandfathering allowance have completed authorisation now that the transitional window has closed. Absent that confirmation, the licensing regime's traffic-light status is likely to remain amber rather than green: the core EU-level and national-statute foundations are solid, but a materiality-4 compliance question remains open past its own deadline. Any HANFA enforcement action, register update, or Porezna uprava-adjacent guidance addressing legacy-provider status would be the most probable trigger for the next material change to this module.
Crypto Licensing
Croatia's crypto-asset licensing regime completed its transition to full MiCA operation this cycle. The Act Implementing Regulation (EU) 2023/1114 had granted an 18-month national transitional period for legacy virtual asset service providers under MiCA Article 143(3); that period ended on 1 July 2026, confirmed directly from HANFA's own public notice. From that date, all crypto-asset service provision in Croatia requires authorisation from, and registration with, the Croatian Financial Services Supervisory Agency, with consumers separately advised to exercise caution regarding unauthorised providers.
HANFA's licensing activity preceded and has continued past this deadline. Electrocoin d.o.o. became the first company to obtain HANFA's authorisation to operate in accordance with MiCA, with that authorisation confirmed on 9 April 2026, nearly three months ahead of the transitional deadline. This first-mover authorisation indicates that HANFA's licensing process was operative and processing applications well before the hard deadline took effect, rather than the deadline itself being the trigger for the regime's first authorisations.
A reported enforcement action illustrates, though does not yet confirm, how the regime is being applied to providers outside the authorised perimeter. HANFA is said to have ordered Fima Plus d.o.o., on 29 July 2026, to immediately cease unauthorised crypto-asset custody and execution services and to return client assets, for operating without MiCA authorisation. This account rests on a single secondary press source (FinTelegram) and has not been corroborated against HANFA's own enforcement notice; it is accordingly carried as an uncertain development rather than confirmed fact. If corroborated through a primary HANFA source, this would be the first visible enforcement action under the post-transitional regime, pairing the regulatory deadline with a concrete supervisory consequence for unauthorised activity.
Taken together, the confirmed closure of the transitional period and the confirmed first-mover authorisation establish Croatia's crypto-licensing regime as fully operational and actively processing applications. The uncorroborated enforcement report, while not yet verified, is consistent with an active, maturing supervisory posture by HANFA toward full MiCA implementation, since a regulator that has closed a transitional carve-out and continues to license new entrants would plausibly also act against providers that remain unauthorised.
Outlook
The principal item to watch is whether HANFA publishes its own enforcement notice for the Fima Plus matter, which would convert the current uncertain report into a confirmed enforcement precedent and establish a clearer baseline for how the regime treats unauthorised crypto-asset activity following the transitional deadline. Beyond this, continued processing of CASP authorisation applications by HANFA is the most likely source of further signal in this module, as the regime is now fully in force with no remaining transitional carve-out for legacy providers.
1 earlier distinct update(s)
Crypto Licensing
Croatia's crypto-licensing perimeter underwent its most significant structural change to date on 1 July 2026, when the transitional period under Regulation (EU) 2023/1114 (MiCA) ended nationwide. From that date, crypto-asset services in Croatia may be provided only by entities holding full MiCA Crypto-Asset Service Provider authorisation; the prior route, under which firms could operate subject only to AML/CFT-Act supervision by Hanfa without full MiCA authorisation, has closed. This is confirmed directly by Hanfa's own regulator publication and represents the closure of what had been, until this date, a partial AML-only supervisory arrangement running alongside the harmonised EU licensing framework.
Hanfa has already begun issuing authorisations under the new regime. Croatia's first MiCA CASP licence was granted to Electrocoin, permitting the firm to provide crypto-to-fiat exchange, crypto-to-crypto exchange, custody, and asset-management services. This is reported by Croatian trade press rather than confirmed directly by a Hanfa bulletin, and should be read as probable rather than confirmed pending primary-source corroboration, though the underlying MiCA transitional closure itself is confirmed at the regulator level.
The practical effect of this closure is to eliminate the partial-perimeter AML gap that previously existed for VASPs operating under the AML/CFT Act alone. Firms that have not obtained CASP authorisation by the deadline face an open supervisory question: Hanfa has separately signalled that its powers over such firms are now limited, which sits at the boundary between the licensing and consumer-protection pictures. Whether Hanfa has taken or will take a formal enforcement action against any firm that failed to secure CASP authorisation by 1 July 2026 is not established in the evidence reaching this cycle, and remains an open item.
Supervisory responsibility for the CASP function rests with Hanfa, distinct from the Croatian National Bank's parallel role authorising issuers of Asset-Referenced Tokens and E-Money Tokens, a split that predates this cycle and is unchanged here. A Croatian CASP authorisation, once granted, supports passporting of crypto-asset services across the EU/EEA via MiCA's notification mechanism, meaning an authorisation such as Electrocoin's carries reach well beyond the Croatian domestic market alone.
Outlook
The immediate question for the licensing regime is how many of the firms that previously operated under the AML-only route have since obtained, or failed to obtain, full CASP authorisation, and whether any enforcement action follows for those that did not. Electrocoin's licence is likely to be an early example of a wider wave of authorisations as the market completes its transition; whether Hanfa formalises a public enforcement posture toward unauthorised legacy VASPs, or whether the transition proceeds without contested cases, is the structural variable to watch.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (2)
- T1 · European Securities and Markets Authority (ESMA)European Securities and Markets Authority (ESMA) — Crypto-asset service providers operating in Croatia must obtain authorisation from HANFA, the competent authority designated for MiCA Titles II, V and VI, before providing crypto-asset services.retrieved M5bindingin force
- T3 · CoinDeskCoinDesk — Entities listed in Croatia's national crypto register as at end of 2024 may rely on the MiCA transitional period for adjustment (grandfathering) up to June 2026, by the end of which they must align operations and obtain full MiCA authorisation from HANFA; new entrants after end-2024 must be licensed before commencing services.retrieved M4bindingin force