Digital asset regulation and tokenization in Croatia

A digital asset business in Croatia needs to distinguish issuance from services supplied to clients. MiCA contains common European rules, while Croatian law allocates responsibilities to the Croatian Financial Services Supervisory Agency, Hanfa, and Croatian National Bank, HNB.

Actual operations matter: purchasing for clients and holding their positions on another platform can involve execution and custody. This guide explains how to identify those functions, determine permission requirements and document tokenized issuance rights.

Which rules apply after transition

MiCA governs crypto-asset services and issuance within its scope. Croatia's implementing statute allocates domestic responsibilities and develops procedures and liability. Classification depends on product rights and functions: tokenized financial instruments retain securities regulation even when they use the same technology as crypto-assets governed by MiCA.

Hanfa confirmed transition closure in July 2026. Former VASPs lacking entitlement must cease affected services and arrange asset returns. They may subsequently apply for authorisation, but cannot operate while awaiting a decision. Croatian authorised providers must be distinguished from entities in other states entitled to provide cross-border services.

What Hanfa and HNB supervise

Sections 6 to 8 of the domestic statute assign MiCA Titles II, V and VI to Hanfa, and Titles III and IV to Hrvatska narodna banka, HNB. The allocation distinguishes ordinary crypto-assets, services and market abuse from ART and EMT issuance. Product and function determine the relevant supervisor.

Issuer entitlement does not replace intermediary authorisation. An entity issuing tokens while also holding assets or executing customer orders must assess those functions separately. Hanfa guidance requires applicants to connect their business model to each regulated service, including services provided together through a single commercial interface.

How each service is identified and authorised

Hanfa's published procedure includes an optional informal preliminary meeting outside the formal application process. Documentation must be resubmitted with the application. Assessment distinguishes completeness from substantive compliance, covering management, qualifying holdings, resources and controls. Statutory assessment periods are not a promise of authorisation measured from first contact.

July 2026 supervisory action illustrates why actual operations matter: receiving customer money, purchasing on their behalf and holding positions in an entity's own foreign-platform accounts can constitute execution and custody. Using an external technology provider or intermediary does not automatically remove the regulated activity of the customer-facing entity.

What tokenized issuance must establish

Hanfa publishes criteria distinguishing crypto-assets from financial instruments and adopted EU DLT pilot application templates. Instrument classification and infrastructure permission are separate issues. Structures must identify issuer, register operator and rights enforceable against the issuer and intermediaries, rather than infer entitlement solely from control of a token.

The DLT pilot permits defined exemptions for specific infrastructure, not general tokenization authorisation. The PutNaTržište programme, presented in September 2026, provides education and simulation to prepare businesses for capital-market financing. It should not be confused with a licensing waiver for digital asset projects or approval of individual issuances.

Which responsibilities continue after permission

Croatian law develops liability for incorrect, incomplete or misleading white-paper information, distinguishing responsible parties, claim conditions and exclusions. Submission to a supervisor does not guarantee a product. Contracts, marketing and token functions should align without attributing institutional backing or proprietary rights that do not exist.

DORA and the Transfer of Funds Regulation add technology resilience and information requirements within their respective scopes. Segregation, reconciliation and asset recovery must work operationally. Accounts held with another platform require clear entitlement, disposal powers and customer restitution mechanisms alongside technical security.

How to prepare Croatian operations

Preparation should map the complete client money and asset flow: which company receives funds, where purchases occur, whose name positions are held in and how assets are returned. This supports the Hanfa application and helps identify regulated functions involving external providers.

Issuance preparation should define rights, offerees and disclosure and marketing documents. The Hanfa/HNB allocation depends on the asset category. Where securities infrastructure is needed, assess its DLT permission separately; participation in education programmes such as PutNaTržište does not replace that check.

To understand how this framework applies to your project, discuss your case with our team.