**Currently (Pre-MiCA full application): Partial.** The primary focus has been on Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) obligations for virtual asset service providers (VASPs). There isn't a comprehensive licensing or prudential supervision framework specifically for crypto-assets outside of AML. Crypto-assets are generally not considered financial instruments or e-money under existing Croatian law, except where they might incidentally fall under such definitions (e.g., security tokens or stablecoins behaving like e-money).

**Future (Post-MiCA full application): Comprehensive.** Once MiCA fully applies, Croatia's regulatory approach will become comprehensive, introducing harmonized rules for the issuance, offering to the public, and admission to trading of crypto-assets, as well as authorization and supervision requirements for crypto-asset service providers (CASPs).

**Hrvatska agencija za nadzor financijskih usluga (HANFA) - Croatian Financial Services Supervisory Agency:**

**Current Role:** Issues warnings to consumers about crypto-asset risks, monitors the financial market for potential impacts. It is expected to be the primary competent authority for the supervision of crypto-asset service providers (CASPs) and issuers under MiCA.

**Hrvatska narodna banka (HNB) - Croatian National Bank:**

**Current Role:** Monitors financial stability, issues warnings regarding crypto-asset risks, and supervises payment institutions and banks. Under MiCA, it will likely play a key role, particularly concerning asset-referenced tokens (ARTs) and e-money tokens (EMTs) if issuers of such tokens are credit institutions or e-money institutions.

**Ministarstvo financija - Ured za sprječavanje pranja novca (Office for the Prevention of Money Laundering, under the Ministry of Finance):**

**Current Role:** Responsible for the implementation of AML/CTF regulations, including the registration and oversight of virtual asset service providers (VASPs) for AML purposes.

**Zakon o sprječavanju pranja novca i financiranja terorizma (Anti-Money Laundering and Terrorist Financing Act):**

**Date:** Latest consolidated text is **Official Gazette 151/22**, which incorporates previous amendments (e.g., 108/17, 39/19).

**Description:** Transposes the EU's 5th and 6th Anti-Money Laundering Directives. It defines virtual assets and virtual asset service providers (VASPs) and subjects them to AML/CTF obligations, including customer due diligence, reporting suspicious transactions, and registration with the Office for the Prevention of Money Laundering.

**Reference:** Available via the official Croatian legal gazette Narodne Novine. A consolidated text can often be found on legal information portals like this (search for "Zakon o sprječavanju pranja novca i financiranja terorizma"): https://narodne-novine.nn.hr/

**Zakon o tržištu kapitala (Capital Market Act):** While not specific to crypto, security tokens that qualify as financial instruments would fall under this act, overseen by HANFA.

**Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA Regulation):**

**Date of Adoption:** 31 May 2023

**Titles III and IV (relating to asset-referenced tokens and e-money tokens):** Applicable from **30 June 2024**.

**Other Titles (relating to authorization of CASPs, issuance of other crypto-assets):** Applicable from **30 December 2024**.

**Description:** This is an EU regulation, directly applicable in all member states, including Croatia, without requiring national transposition. It creates a harmonized regulatory framework for crypto-assets not already covered by existing financial services legislation. It covers:

Transparency and disclosure requirements for the issuance and admission to trading of crypto-assets.

Authorization and supervision requirements for CASPs.

Rules for the operation, organization, and governance of CASPs.

Requirements for protection of crypto-asset holders.

Measures to prevent market abuse.

**National Implementing Legislation (To be enacted):** Croatia will need to enact national legislation to designate competent authorities (likely HANFA), set national fees, and clarify any national specificities permitted by MiCA. This will occur before or around MiCA's full application dates.

**Current Stance (Pre-MiCA full application):**

**Not Banned:** Crypto trading and the operation of crypto exchanges are not banned in Croatia.

**AML Registration Required:** Entities operating as virtual asset service providers (VASPs), which includes crypto exchanges, wallet providers, and other services involving the exchange or transfer of virtual assets, are required to register with the **Office for the Prevention of Money Laundering** under the Ministry of Finance. This registration is for AML/CTF compliance purposes, not for prudential licensing or general operation.

**Unregulated Beyond AML:** Beyond AML/CTF obligations, the crypto market in Croatia is largely unregulated. This means there is no specific regulatory oversight for consumer protection, operational resilience, or financial stability for crypto-asset activities, leading to warnings from HANFA and HNB about inherent risks.

**Future Stance (Post-MiCA full application):**

**Licensed Operation Required:** From **December 30, 2024** (and June 30, 2024 for stablecoin services), any entity wishing to provide crypto-asset services in Croatia (or across the EU) will need to be authorized as a Crypto-Asset Service Provider (CASP) by a competent national authority (likely HANFA in Croatia) in accordance with MiCA.

**Comprehensive Supervision:** Authorized CASPs will be subject to comprehensive prudential, organizational, and conduct of business rules under MiCA, aimed at investor protection, market integrity, and financial stability.

**Passporting:** Once authorized in one EU member state, a CASP can "passport" its services across the entire European Union, including Croatia.