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European Accessibility Act: Croatia
HR- Applies from
- 2025-06-28
- Maximum penalty
- €132,720
- Enforcement authority
- Državni inspektorat (State Inspectorate) — lead authority for general (non-radio) products and e-commerce, and Croatia's single liaison office coordinating market surveillance under EU Regulation 2019/1020; sector regulators handle their own areas: HAKOM (Croatian Regulatory Authority for Network Industries) for radio-equipment products, electronic communications services, e-books and rail passenger transport; Agency for Electronic Media for audiovisual media access services; Croatian Civil Aviation Agency for air transport; Ministry of Maritime Affairs, Transport and Infrastructure inspectors for bus and waterborne transport; Croatian National Bank (HNB) and HANFA for consumer banking services. — https://dirh.gov.hr
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Zakon o zahtjevima za pristupačnost proizvoda i usluga (NN 89/2025)
- File a complaint
- https://dirh.gov.hr/podnosenje-prijava/83
- Notes
- Fines are fixed EUR amounts (not turnover-based), tiered by economic-operator role and by entity type. Legal entities: manufacturers and service providers face €6,630–€132,720 (Art. 32(1) and Art. 36(1)); importers €3,310–€66,360 (Art. 34(1)); distributors €1,990–€13,270 (Art. 35(1)). Each category has separate, lower brackets for 'responsible persons' inside the legal entity and for sole traders/craftspeople (generally €1,320–€6,630). Article 17(7) blocks a 'disproportionate burden' exemption claim for operators receiving external public financing earmarked for accessibility. Article 28 bars any misdemeanor charge at all if the operator cures the defect during inspection or within the deadline set in a corrective order — fines are a backstop for ignored warnings, not a first-resort penalty.
Who is obligated in Croatia
Croatia's Zakon o zahtjevima za pristupačnost proizvoda i usluga transposes the EU-wide EAA product and service list without narrowing it: computers and operating systems, smartphones, e-readers, self-service terminals (ATMs, ticketing and check-in machines), and digital TV equipment on the product side; e-commerce, banking, e-books, electronic communications, audiovisual media access services, and passenger transport information (air, bus, rail, waterborne) on the services side. The law separates duties by economic-operator role — manufacturer, authorised representative, importer, distributor and service provider each carry distinct obligations, from design and technical documentation for manufacturers to ongoing accessible-service delivery for providers. Article 4(2) exempts microenterprises (fewer than 10 staff, turnover or balance sheet under €2 million per Article 5(18)) from the services obligations only — product-side duties apply regardless of company size, matching the EU baseline. A Croatian-specific wrinkle: Article 17(7) blocks any operator that receives external public financing earmarked for accessibility from later claiming a 'disproportionate burden' exemption, even if it would otherwise qualify.
What happens if you don't comply
Enforcement runs through Croatia's ordinary Misdemeanours (prekršaj) framework, but the law builds in a mandatory remediation step first. Under Article 23 (products) and Article 26 (services), an inspector who finds a defect during a check must record it in an inspection report and order corrective measures within a 'primjereni rok' (a deadline proportionate to the violation) — whether the defect is formal (missing CE mark, incomplete documentation) or substantive. Only if the operator ignores that order, or a follow-up check finds the defect persists, does the inspector escalate to a market-withdrawal decision and refer the case for a misdemeanor fine. Article 28 sets a genuine 'opportunity principle': no misdemeanor charge can be filed at all if the operator fixes the problem during the inspection itself or within the deadline in the written order. In practice, the €6,630–€132,720 bracket is a backstop for operators who ignore a documented warning, not a penalty for a first-time finding.
How this differs from the EU baseline
Croatia spreads enforcement across at least seven bodies rather than one regulator, coordinated by the State Inspectorate as the country's single liaison office under EU Regulation 2019/1020: HAKOM covers radio-equipment products, telecoms, e-books and rail transport; the Agency for Electronic Media covers audiovisual access services; the Civil Aviation Agency covers air transport; ministry inspectors cover bus and waterborne transport; and the Croatian National Bank plus HANFA jointly cover consumer banking. Penalty amounts are unusually granular — fixed by economic-operator role (manufacturers and service providers face the highest ceiling, distributors the lowest) and further split for legal entities, 'responsible persons' within them, and sole traders. The built-in 'no fine if cured during inspection' rule (Article 28) is more forgiving toward promptly-fixed first-time defects than the bare Directive requires.
How to complain
Reports of non-compliance go to the relevant sector regulator, but for the largest category — general products and e-commerce — that's the State Inspectorate. Its dedicated reporting page offers an online form requiring the complainant's name, contact details, a description of the issue and choice of regional office, or submission through the national e-Građani e-government login. The page does not advertise an anonymous-complaint option — the form asks for the reporter's identity — and there's no accessibility-specific fast track mentioned. Alternative channels include post (Državni inspektorat, Šubićeva 29, 10000 Zagreb) and email. No published response-time guarantee was found; public service hours are Monday–Friday, 09:00–15:00. Complaints about telecoms, audiovisual, transport or banking accessibility should instead go to the relevant sector regulator.
Frequently asked questions about the EAA in Croatia
- What is the maximum EAA fine in Croatia?
- The maximum penalty is €132,720. Fines are fixed EUR amounts (not turnover-based), tiered by economic-operator role and by entity type.
- Who enforces the European Accessibility Act in Croatia?
- Državni inspektorat (State Inspectorate) — lead authority for general (non-radio) products and e-commerce, and Croatia's single liaison office coordinating market surveillance under EU Regulation 2019/1020; sector regulators handle their own areas: HAKOM (Croatian Regulatory Authority for Network Industries) for radio-equipment products, electronic communications services, e-books and rail passenger transport; Agency for Electronic Media for audiovisual media access services; Croatian Civil Aviation Agency for air transport; Ministry of Maritime Affairs, Transport and Infrastructure inspectors for bus and waterborne transport; Croatian National Bank (HNB) and HANFA for consumer banking services. Details are published at https://dirh.gov.hr.
- Since when does the EAA apply in Croatia?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Croatia by Croatia's national implementing law.
- Are small businesses exempt from the EAA in Croatia?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Croatia that places a covered product on the market still has to make that product accessible.
- How do I report an inaccessible website in Croatia?
- Complaints go to the national complaint route at https://dirh.gov.hr/podnosenje-prijava/83. The enforcement authority above handles market surveillance separately.
Official source: https://narodne-novine.nn.hr/clanci/sluzbeni/2025_06_89_1231.html
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.