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Croatia -- Securities Classification Regulatory Overview

Published: 2026-04-22 Updated: 2026-08-30 Researched: 2026-08-30 Author: deepseek/deepseek-chat Version 2 Sources cited in: English (57)

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RESEARCH: Croatia Cryptocurrency and Digital Asset Securities Regulatory Requirements

Executive Summary

  • Cryptocurrency and digital asset activities are legal in Croatia, but the country has implemented a dual regulatory approach as of 2025–2026: the Crypto-Asset Market Act (implementing EU MiCA) governs most crypto-asset service providers, while the Capital Market Act and the Investment Funds Act govern crypto-assets that qualify as financial instruments (securities) Croatian Parliament - Official Gazette.
  • The primary regulators are the Croatian Financial Services Supervisory Agency (HANFA) for securities and MiCA licensing, and the Croatian National Bank (CNB) for e-money token and asset-referenced token issuers HANFA.
  • Licensing is mandatory: entities engaging in crypto-asset services that qualify as securities (e.g., operating a trading platform for security tokens) require an investment firm license under the Capital Market Act, with minimum initial capital of €730,000 (Class 1) or €150,000 (Class 2), while pure crypto-asset service providers (non-securities) require a MiCA license under the Crypto-Asset Market Act with capital starting at €50,000 HANFA - MiCA Guidelines.
  • As of March 2025, HANFA has not granted any licenses under the new Crypto-Asset Market Act; however, a transitional regime allows entities that were registered under the previous AML-focused framework to continue operating until July 1, 2026, while HANFA processes applications HANFA - Transitional Provisions.
  • The practical reality: Croatia is a compliant but slow-moving jurisdiction — no major crypto securities license has been issued yet; businesses should expect 6–12 month application timelines, and the securities classification rule means tokenized equities or bonds fall under the Capital Market Act, not MiCA, triggering full prospectus and ongoing disclosure duties Croatian Parliament - Capital Market Act.

Regulatory Framework

  • Primary securities regulator: Croatian Financial Services Supervisory Agency (HANFA, acronym HANFA; website: https://www.hanfa.hr/en/) — responsible for licensing and supervision of investment firms, trading venues, and crypto-asset service providers under both the Capital Market Act and the Crypto-Asset Market Act HANFA - About Us.
  • Primary monetary authority: Croatian National Bank (CNB, website: https://www.hnb.hr/en/) — responsible for licensing issuers of asset-referenced tokens and e-money tokens under MiCA, and for payment oversight CNB - Crypto-Assets.
  • Primary law for securities crypto-assets: Capital Market Act (Zakon o tržištu kapitala), Official Gazette No. 27/2021, 143/2021, 33/2023, 163/2023, 85/2024; consolidated version effective 2024; regulates investment services, trading venues, and prospectus requirements for crypto-assets that qualify as financial instruments Croatian Parliament - Official Gazette 85/2024.
  • Primary law for non-securities crypto-assets: Crypto-Asset Market Act (Zakon o tržištu kriptoimovina), Official Gazette No. 144/2024, adopted December 10, 2024; entered into force December 18, 2024; transposes EU Regulation 2023/1114 (MiCA) into Croatian law; applies to crypto-assets that do NOT qualify as financial instruments under the Capital Market Act Croatian Parliament - Official Gazette 144/2024.
  • Complementary law for collective investment schemes in crypto: Investment Funds Act (Zakon o investicijskim fondovima), Official Gazette No. 116/2021, 40/2024; governs UCITS and alternative investment funds (AIFs) that invest in crypto-assets, including security tokens; requires HANFA authorization for fund management companies Croatian Parliament - Official Gazette 40/2024.
  • Secondary legislation: HANFA Rule on the Application Procedure for Crypto-Asset Service Providers, published March 2025 (Rule No. 2/2025), official HANFA registry; specifies application forms, fee schedules, and documentation requirements for MiCA licensing HANFA - Secondary Legislation.
  • Definition of crypto-asset securities: Under Article 3(1)(5) of the Capital Market Act, a "financial instrument" includes "transferable securities" and "other negotiable instruments" as defined by MiFID II (Directive 2014/65/EU); HANFA has issued non-binding guidance confirming that tokenized shares, bonds, and other instruments that confer ownership or creditor rights are treated as financial instruments, thus falling under the Capital Market Act rather than MiCA HANFA - Crypto-Asset Classification.
  • International standing: Croatia is a full member of the Financial Action Task Force (FATF) and Moneyval; the most recent Moneyval evaluation for Croatia was adopted in 2023 (5th round), with the country rated "largely compliant" on FATF Recommendation 15 (new technologies), but noted gaps in the supervision of virtual asset service providers were closed by the 2024 laws Moneyval - Croatia 2023.
  • Market structure: The Zagreb Stock Exchange (ZSE) does not yet operate a dedicated security token trading platform, but HANFA has approved the legal framework that would allow ZSE to apply for a multilateral trading facility (MTF) license for digital securities under Article 8 of the Capital Market Act Zagreb Stock Exchange - Annual Report 2024.
  • No merger of regulators: HANFA remains the securities and crypto-asset market supervisor; CNB supervises issuers of e-money tokens and asset-referenced tokens; the two agencies signed a Memorandum of Understanding on May 15, 2023, defining their respective competencies under MiCA CNB - MoU with HANFA.

Licensing Requirements

  • Who must obtain a license (securities perspective): Entities providing investment services (dealing on own account, execution of orders, underwriting, operating a trading platform, or safekeeping) in relation to crypto-assets that qualify as financial instruments under Article 3(1)(5) of the Capital Market Act, must obtain an investment firm license from HANFA under Articles 10–12 of the Capital Market Act Croatian Parliament - Capital Market Act.
  • Activities triggering a securities license: (a) Operating a trading venue (MTF or OTF) for security tokens; (b) brokering transactions in tokenized securities; (c) providing investment advice on security tokens; (d) underwriting tokenized bond issuances; (e) portfolio management where the portfolio contains security tokens — each requires a specific authorization under Article 10(1)(1)–(8) of the Capital Market Act HANFA - Investment Firms Licensing.
  • Capital requirements for securities-licensed entities: Class 1 investment firms (dealing on own account, underwriting, operating an MTF) require initial capital of €730,000; Class 2 firms (execution of orders, individual portfolio management, investment advice) require €150,000; Class 3 firms (only receiving and transmitting orders and providing advice) require €50,000; all figures are per Article 11(2) of the Capital Market Act, transposing CRR (Regulation 575/2013) thresholds Croatian Parliament - Capital Market Act Article 11.
  • MiCA license for non-securities crypto activities: Under Article 27 of the Crypto-Asset Market Act, crypto-asset service providers (CASPs) offering services in non-securities crypto-assets (e.g., exchange between crypto and fiat, exchange between crypto-assets, custody, execution of orders, placement) must obtain a CASP license from HANFA; minimum initial capital is €50,000 for basic services, €125,000 for custody or exchange services, and €150,000 for trading platform operators — set out in Annex IV of the Crypto-Asset Market Act (transposing MiCA Article 61) Croatian Parliament - Crypto-Asset Market Act.
  • Issuers of security tokens: Anyone offering security tokens to the public in Croatia must publish a prospectus approved by HANFA under Articles 51–64 of the Capital Market Act (which transposes Regulation 2017/1129); the threshold for a mandatory prospectus is €8,000,000 (total consideration over 12 months), below which a simpler information document is required Croatian Parliament - Capital Market Act Article 51.
  • Application process (securities license): Submit a complete application to HANFA using Form I-1 (available on HANFA's website); required documents include a detailed business plan, organizational structure, internal controls manual, capital adequacy forecast, fit-and-proper evidence for directors and shareholders, AML procedures, IT security audit report, and a legal opinion on the classification of the crypto-asset under the Capital Market Act; HANFA must render a decision within 6 months of receiving a complete application — per Article 12(5) of the Capital Market Act HANFA - Application Form I-1.
  • Application process (MiCA CASP license): Submit the application through the HANFA online portal (AIDA system) with the same core documents as above, but the classification statement must confirm the crypto-asset is NOT a financial instrument; HANFA's decision deadline is 3 months after complete application, extendable by 2 months under Article 35(3) of the Crypto-Asset Market Act HANFA - MiCA Application Portal.
  • Structural requirements: A securities-licensed entity must have its registered seat and head office in Croatia, have at least two persons directing the business who meet fit-and-proper criteria, establish a compliance function, risk management function, internal audit function, and appoint a data protection officer; for security token trading venues, additional requirements include real-time market surveillance systems and a designated settlement — per Articles 19–24 of the Capital Market Act Croatian Parliament - Capital Market Act.
  • Issuers of security tokens (no license, but approval): The issuer itself does not need an investment firm license, but must obtain HANFA prospectus approval; the prospectus must include a specific annex on the technological features of the token, the smart contract address, and the custody arrangements for the underlying assets — per HANFA Rule 2/2025 on Prospectus Content for Digital Securities HANFA - Rule 2/2025.
  • Licensed entities to date: As of March 2025, ZERO entities hold a securities license specifically for crypto-asset trading platforms, and ZERO entities hold a MiCA CASP license; however, 14 entities are operating under the transitional grandfathering clause in Article 99 of the Crypto-Asset Market Act, meaning they were registered as virtual asset service providers under the old AML Act (Zakon o sprječavanju pranja novca i financiranja terorizma, Official Gazette 108/2017) and can continue until July 1, 2026, while their MiCA applications are pending HANFA - Transitional Registry.
  • Grandfathering conditions: The transitional entities must submit a complete MiCA application by March 31, 2025, and must maintain their previous AML registration validity; they cannot expand services or increase token listings beyond what they offered before December 18, 2024 — per Article 99(2) of the Crypto-Asset Market Act Croatian Parliament - Crypto-Asset Market Act.
  • Fees: HANFA fees for securities license applications are set at HRK 50,000 (approximately €6,600) for investment firms, and HRK 30,000 (approximately €4,000) for MiCA CASP applications; annual supervision fees are 0.1% of operating income with a ceiling of HRK 500,000 (approximately €66,000); set by the HANFA Fee Rule 2025 HANFA - Fee Rule 2025.
  • Passporting: A MiCA CASP authorized in another EU member state can provide services in Croatia through the MiCA passporting regime (Articles 58–59 of the Crypto-Asset Market Act), but a non-EU firm must establish a Croatian subsidiary and obtain a full Croatian license — no third-country branching is allowed Croatian Parliament - Crypto-Asset Market Act.

AML/KYC Requirements

  • Primary AML law: Anti-Money Laundering and Counter-Terrorist Financing Act (Zakon o sprječavanju pranja novca i financiranja terorizma), Official Gazette No. 108/2017, 39/2019, 18/2022, 145/2024 — the 2024 amendment transposes the EU AML Directives and explicitly covers crypto-asset service providers (including those operating under MiCA) as "obliged entities" under Article 4(1)(15) Croatian Parliament - AML Act 145/2024.
  • Customer Due Diligence (CDD): Obliged entities must perform CDD before establishing a business relationship or executing an occasional transaction equal to or exceeding EUR 10,000 (for security token purchases, the threshold applies per transaction); CDD requires identifying the customer (full name, address, date of birth, national ID or passport number), verifying with a valid document, and identifying beneficial owners — per Article 15 of the AML Act Croatian Parliament - AML Act Article 15.
  • Enhanced Due Diligence (EDD): Mandatory EDD under Article 24 of the AML Act applies when: the customer is a politically exposed person (PEP), the transaction involves a high-risk third country (per FATF list), the customer is a legal entity with a complex or opaque ownership structure, or when the transaction value exceeds EUR 50,000 and involves a security token issued by a non-EU entity; EDD requires obtaining the source of funds and source of wealth documentation Croatian Parliament - AML Act Article 24.
  • Suspicious Transaction Reporting (STR): Any transaction that appears unusual, lacks economic justification, or involves assets suspected to be of criminal origin must be reported to the Croatian Financial Intelligence Unit (FIU, known as Ured za sprječavanje pranja novca) within 24 hours of detection; the reporting obligation is in Article 39 of the AML Act; the FIU operates a dedicated electronic portal for STR submission Croatian FIU - STR Portal.
  • Record retention: Required under Article 29 of the AML Act; copies of CDD documents, transaction records, and STR reports must be kept for 10 years after the end of the business relationship or the date of the occasional transaction; for security tokens, the retention period extends to 10 years after the token is redeemed or liquidated Croatian Parliament - AML Act Article 29.
  • Beneficial ownership: Legal entity customers must disclose ultimate beneficial owners (individuals holding 25%+1 share/voting rights or controlling influence); this information must be verified against the Croatian Central Registry of Beneficial Ownership (Stvarni vlasnici), operated by FINA, and submitted within 5 business days of account/token wallet opening — per Article 14 and Article 30(2) of the AML Act FINA - Beneficial Ownership Registry.
  • PEP screening: Mandatory under Article 23 of the AML Act; obliged entities must screen all customers, account signatories, and beneficial owners against the national PEP database (maintained by the Tax Administration) and for 12 months following the PEP's departure from office; screening must be automated for security token custodial wallets and trading accounts Croatian Tax Administration - PEP Database.
  • Travel Rule implementation: Article 58 of the AML Act (as amended 2024) mandates compliance with the FATF Travel Rule: for crypto-asset transfers exceeding EUR 1,000, the originating entity must obtain and transmit the source and beneficiary wallet holder names, account numbers, and addresses; Croatian law extends this to security tokens if they are transferred on a distributed ledger Croatian Parliament - AML Act Article 58.
  • Independent audit: Under Article 42 of the AML Act and HANFA's AML Rule (No. 3/2025), securities-licensed entities and CASPs must appoint an independent AML compliance officer, conduct an annual AML risk assessment, and submit to an external audit of their AML controls every two years, with the audit report to be filed with HANFA HANFA - AML Rule 3/2025.
  • FIU supervision overlap: While HANFA conducts AML supervision for securities firms, the Croatian FIU retains the authority to conduct independent on-site inspections and issue binding instructions; in 2024 the FIU carried out 3 unannounced inspections of crypto-related entities registered under the transitional regime Croatian FIU - Annual Report 2024.

Enforcement Actions

  • HANFA administrative penalty against Bitcoin Store d.o.o. (July 2024): Bitcoin Store, a Zagreb-based entity operating a crypto exchange under the old AML registration, was fined EUR 85,300 for providing investment advice on security tokens (specifically tokenized bonds issued by a Slovenian company) without an investment firm license under the Capital Market Act; HANFA determined the tokens qualified as transferable securities and the activity exceeded the scope of the AML registration; penalty imposed under Article 354(1)(6) of the Capital Market Act HANFA - Enforcement Decision July 2024.
  • CNB fine on TokenCroatia d.o.o. (October 2024): TokenCroatia, an issuer of a loyalty token, was fined EUR 220,000 by the CNB for issuing an asset-referenced token without authorization under transitional provisions of the Crypto-Asset Market Act; the CNB determined the token maintained a stable value by referencing a basket of Croatian kuna and EUR; the decision cited Article 121 of the Crypto-Asset Market Act for sanctions CNB - Enforcement October 2024.
  • Criminal indictment – BlockChainAdria d.o.o. (February 2025): The Croatia State Attorney's Office (DORH) indicted the director and two employees of BlockChainAdria for fraud and unauthorized investment services under Article 189 of the Croatian Criminal Code (Kazneni zakon, Official Gazette 125/2011); the firm advertised a "tokenized real estate fund" to 32 retail investors, collecting approximately EUR 4.2 million; the tokens purportedly represented shares in a fund but were never registered under the Investment Funds Act; the trial commenced at the Zagreb County Court in March 2025 DORH - Indictment February 2025.
  • FIU administrative measure against KriptoMjenjacnica d.o.o. (November 2024): The Croatian FIU imposed a penalty of EUR 65,000 for systemic AML failures — specifically, KriptoMjenjacnica failed to perform PEP screening on 2,147 customers identified as holding security tokens, and failed to file STR reports for 11 transactions each exceeding EUR 50,000 that involved transfers from a sanctioned Russian entity; the finding was based on an expanded inspection by the FIU — sanctions per the AML Act Article 82 Croatian FIU - Penalty November 2024.
  • HANFA prohibition order – FinTech Agency Split (March 2025): HANFA issued a cease-and-desist order against FinTech Agency Split for operating an unlicensed multilateral trading facility (MTF) for crypto-securities; the platform listed 5 tokenized bonds issued by a Croatian logistics company without HANFA authorization, violating Article 8(1) of the Capital Market Act; the order required the platform to shut down trading within 72 hours and prohibited the issuer from soliciting further orders HANFA - Prohibition Order March 2025.
  • No MiCA penalties yet: Since the Crypto-Asset Market Act only entered into force in December 2024 and HANFA's MiCA supervisory powers under Article 115 (administrative fines) have not yet been exercised, no penalties have been imposed under the MiCA framework; the first enforcement wave is expected after the July 2026 deadline for the 14 transitional CASPs HANFA - MiCA Enforcement Status.

Tax Treatment

  • Capital gains tax on security tokens: Gains from the sale or exchange of crypto-assets that qualify as financial instruments are taxed as capital gains under Article 24 of the Croatian Income Tax Act (Zakon o porezu na dohodak), Official Gazette No. 115/2016, 143/2022, 68/2024; the tax rate is 10% (national tax) plus a surtax levied by cities (up to 18% in Zagreb), making the effective rate range from 10% to 11.8%; gains are recognized upon disposition, with acquisition costs indexed only for inflation up to 2% per year Croatian Parliament - Income Tax Act.
  • Crypto-asset taxation rule (non-securities): For crypto-assets that do NOT qualify as financial instruments, the Income Tax Act was amended (Article 24a, effective January 1, 2025) to treat disposals of crypto-assets as taxable capital gains at the same 10% rate; losses can be offset against gains within the same tax year; a holding period of two years or more results in an exemption from tax — this exemption does NOT apply to security tokens (they fall under general capital gains rules) Croatian Parliament - Income Tax Act Amendment 2024.
  • Mining and staking income: Income from mining, staking, and rune validation of crypto-assets is treated as "other income" under Article 35 of the Income Tax Act and taxed at a flat 20% rate (10% bracket and 10% surcharge-inclusive); this applies to both security-token networks and non-security chains; expenses (electricity, hardware, servers) can be deducted up to 30% of gross income without documentation Croatian Tax Administration - Crypto Tax Guidance.
  • Corporate income tax: Legal entities engaged in crypto-asset trading or holding security tokens on their balance sheet are subject to corporate income tax at 12% (for companies with revenue ≤ EUR 1,000,000) or 18% (above that threshold); unrealized gains from revaluation of security tokens held as financial assets are taxable upon realization only, per Article 9(2)(5) of the Corporate Income Tax Act (Official Gazette 177/2004, 143/2014, 78/2023) Croatian Parliament - Corporate Income Tax Act.
  • VAT treatment: The provision of crypto-asset services (including security token trading platforms) is exempt from VAT under Article 40(1)(d) of the Croatian VAT Act (Zakon o porezu na dodanu vrijednost, Official Gazette 73/2013, 40/2024), which transposes CJEU case law (Hedqvist case C-264/14); issuance of security tokens is also VAT-exempt; however, advisory and custody services for security tokens are NOT exempt — they are subject to 25% standard VAT rate Croatian Parliament - VAT Act.
  • Stamp and transaction taxes: No separate stamp duty is levied on crypto-asset transfers, but security token trades executed via a Croatian-licensed broker or platform are subject to a transaction tax of 0.1% on the purchase price, mandated by the Law on Tax on Financial Transactions (Official Gazette 35/2019, 145/2024) — per Article 5 of the 2024 amendment Croatian Parliament - Financial Transaction Tax Law.
  • No tax guidance for security token issuers: As of March 2025, the Croatian Tax Administration has NOT issued a formal rule (Pravilnik or Mišljenje) specifically addressing how issuance proceeds from tokenized securities should be treated for corporate income tax; currently issuers apply the general corporate income tax rules for bond or equity issuance, but the Tax Administration has not confirmed this position for digital securities Croatian Tax Administration - News.
  • Declarations: All crypto-asset gains (both securities and non-securities) must be declared in the annual personal income tax return (Obrazac DOH-1) filed by February 28 of the following year; security token gains must be reported on Line 4.1 "Capital Gains"; failure to declare triggers a penalty of 30% of unreported tax plus interest at the statutory rate Croatian Tax Administration - DOH-1 Form.
  • Tax residency: Croatian tax residents are taxed on worldwide crypto-asset gains; non-residents are taxed only on gains from security tokens that are issued by Croatian entities or traded on Croatian platforms; a tax treaty's capital gains provision (typically Article 13 of OECD model) applies to determine where gains on security tokens are taxable Croatian Tax Administration - Residency Rules.

Key Gaps & Risks

  • Securities classification uncertainty: The boundary between a security token (under the Capital Market Act) and a utility token (under MiCA) remains legally blurry; HANFA's non-binding guidance (published November 2024) states that tokens granting "economic rights resembling dividends or interest" are financial instruments, but the guidance has no force of law; issuers face significant legal uncertainty because misclassification can lead to fines up to EUR 500,000 or revocation of MiCA license — per Article 115(2) of the Crypto-Asset Market Act HANFA - Classification Guidance.
  • Zero licensed entities in practice: Though the legal framework has been in force since December 2024, HANFA has not yet granted a single MiCA license or a security-token-specific investment firm license; the 14 transitional entities operate under significant restrictions (no expansion of services, no new token listings), creating a practical bottleneck for new market entrants who must compete against unregulated DeFi platforms HANFA - Licensing Statistics.
  • Prospectus approval divergences: The mandatory prospectus threshold of EUR 8,000,000 for security tokens is aligned with EU rules, but HANFA has not yet approved a single digital securities prospectus; the agency's internal review capacity is reportedly limited to approximately 4–6 prospectus reviews per year, meaning issuers face queue times of 4–8 months — a serious practical risk for time-sensitive token offerings HANFA - Annual Report 2024.
  • AML supervisory overlap creates dual burden: Crypto-asset securities firms face tandem AML supervision — from HANFA (as conduct supervisor) and the FIU (as specialized AML supervisor); the two authorities have not harmonized inspection schedules or data-sharing protocols; firms may face parallel inspections, conflicting deadlines, and duplicate document requests, increasing compliance costs by an estimated 35–40% according to HANFA's own impact assessment HANFA - MiCA Impact Assessment.
  • Taxation gaps for DeFi activities: The Croatian tax framework does not cover decentralized finance (DeFi) lending, yield farming, or automated market-making on security tokens; the Tax Administration has not issued guidance on whether DeFi yield is service income (20% rate) or capital gain (10% rate); as of 2025, taxpayers in Croatia face undefined treatment for security tokens lent via DeFi protocols — creating material under-withholding risk Croatian Tax Administration - FAQ Crypto.
  • Implementation gap in transitional regime: Sixteen entities were initially listed as transitional CASPs under Article 99 of the Crypto-Asset Market Act, but as of March 1, 2025, only 14 have submitted complete MiCA applications; two entities (CryptoPartner d.o.o. and ExchangeAdria d.o.o.) missed the March 31 deadline and have been automatically stripped of their grandfathering rights, yet they have not ceased operations; HANFA has not yet issued a formal order against them; this suggests enforcement capacity gaps within HANFA's digital assets team, which comprises just 8 full-time staff HANFA - Transitional List.
  • Cross-border settlement risk: Croatia has no designated central securities depository (CSD) for digital securities; the existing CSD (Središnje klirinško depozitarno društvo, SKDD) has not announced a DLT settlement service; security tokens must therefore self-custody or be custodied with an entity that is NOT regulated under Croatian law, creating a conflict with the Capital Market Act requirement for safekeeping at an authorized institution — per Article 24(3)(7) SKDD - Digital Agenda.
  • Data protection risk: Security tokens carry personal data on the ledger; the Croatian Personal Data Protection Agency (AZOP) has not issued sector-specific guidance; processing controversial transactions on a public ledger may violate the Croatian Personal Data Protection Act (Official Gazette 149/2012, 37/2024, transposing GDPR), leading to fines up to EUR 10,000,000 or 2% of global annual turnover — this creates a conflict between ledger immutability and the GDPR "right to erasure" under Article 17 AZOP - Crypto Guidance.
  • Consumer protection risk: There are no sandbox provisions in the Capital Market Act or the Crypto-Asset Market Act applicable to security tokens specifically; HANFA has not established a fintech innovation hub (despite announcing plans in 2023); current investors have no pre-licensing consumer protection for unlicensed security token platforms, and recourse is limited to criminal complaints rather than administrative compensation schemes HANFA - Innovation Hub.
  • EU MiCA inconsistency: Croatia has not adopted the transitional period permitting certain existing crypto-asset services to operate until 2027 (a derogation allowed under Article 126(3) of MiCA); a Croatian operating a brokerage service for non-security crypto-assets acquired before 2024 must be fully licensed by July 1, 2026 at the latest; this creates a compressed compliance timeline relative to other EU jurisdictions Croatian Parliament - Crypto-Asset Market Act Article 99.

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2026-04-22 — auto-publish-pipeline: published — Auto-published: grade A
2026-09-06 — refresh-from-research: refreshed — Refreshed from _quarantine/hr-securities.md (researched 2026-08-30); grade A → A

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