Croatia EMI License 2026 — HNB Electronic Money Institution Authorisation

Croatia — The Euro-Area EMI Most Founders Haven't Priced In

Croatia adopted the euro on 1 January 2023, and the Croatian National Bank joined the Eurosystem the same day. For an electronic money institution, that means payments run through TARGET-HR, EuroNCS for SEPA credit transfers and EuroNCSInst for SEPA instant payments — the euro area's own infrastructure, not a national substitute. An EMI licensed outside the euro area needs correspondent arrangements simply to reach euro clearing. A Croatian one does not.

The legal framework is recent. The Electronic Money Act (Official Gazette 64/18, amended by 114/22 and 136/24) was last amended with effect from 17 January 2025, bringing in DORA-aligned ICT requirements and the changes required by the Instant Payments Regulation. The new safeguarding option described below followed on 9 April 2025.

What Croatia is not is the fastest route to a licence with minimal substance. The Act requires an EMI's business to be run from Croatian territory and at least part of its e-money and payment services to be provided in Croatia. Founders looking for a passport shell should read that condition twice. Founders building an operating business will find it costs them little they weren't going to spend anyway.

Direct Clearing Access — What Changed, and What Hasn't

Historically, direct participation in Croatian payment systems was reserved to credit institutions. For the national clearing system, the participants were the central bank, authorised credit institutions established in Croatia and the Croatian Bank for Reconstruction and Development. A payment institution or EMI reached clearing through a bank.

That has changed in law. The November 2024 amendments to the Payment System Act (Official Gazette 136/24), passed together with amendments to the Settlement Finality Act, were drafted expressly to create the precondition for payment institutions and electronic money institutions to become participants in payment systems — the purpose of Articles 3 and 4 of the Instant Payments Regulation, (EU) 2024/886.

Safeguarding at the Central Bank

The same 2024 amendments changed how client money can be protected. Since 9 April 2025, a Croatian EMI may safeguard e-money holders' funds by holding them with the central bank of a member state that, at its discretion, makes that facility available.

That sits alongside the three traditional methods under Article 35 of the Electronic Money Act: a segregated account at a credit institution in Croatia or another member state, investment in secure, liquid, low-risk assets, or an insurance policy or comparable guarantee from an insurer or bank outside the EMI's group. Central bank safeguarding removes exposure to a single commercial bank's credit risk — the weakest point in most EMI safeguarding set-ups. Availability and terms are the central bank's decision, so confirm them before designing the safeguarding model around this option.

Why Croatia for E-Money

HNB and HANFA — Two Regulators, Two Remits

The Croatian National Bank (HNB) authorises and supervises electronic money institutions, small electronic money institutions, payment institutions and small payment institutions. It also supervises the MiCA rules on e-money tokens and asset-referenced tokens for entities within its remit.

The Croatian Financial Services Supervisory Agency (HANFA) authorises and supervises crypto-asset service providers under MiCA, through the Act implementing Regulation (EU) 2023/1114 (Official Gazette 85/24).

For an operator that wants both an EMI and a CASP licence in Croatia, that means two supervisors, two files and two relationships — unlike Latvia, where one regulator covers both. It is manageable, but it should be planned from day one rather than discovered.

The Small EMI — Domestic Only

Croatian law also provides for a small electronic money institution, entered in HNB's register rather than fully authorised, with a lower capital requirement. It cannot issue e-money outside Croatia. It suits a domestic pilot; it does not suit any business plan that depends on EU passporting.

Key Requirements

• •Corporate structure — a company established in Croatia. For a company in formation, the part of share capital equal to the initial capital must be paid in cash.
• •Capital — €350,000 initial capital (Article 14). Own funds must never fall below that figure and must at all times cover at least 2% of average outstanding e-money, plus own funds for any payment services unrelated to e-money, calculated under the payment institution rules (Article 34).
• •Management — management board members must be of good repute with appropriate knowledge and experience in e-money and payment services. HNB obtains Croatian and EU criminal-record data directly.
• •Shareholders — holders of 10% or more of capital or voting rights are assessed for reputation and financial standing.
• •Substance — the business must be run from Croatia, with at least part of the services provided in Croatia, and an organisational, technical and staffing structure capable of stable operation (Article 16).
• •ICT and resilience — ICT risk management, incident reporting and business continuity aligned with DORA, Regulation (EU) 2022/2554, and the EBA Guidelines on ICT and security risk management.
• •Safeguarding — one of the four Article 35 methods described above.
• •AML/CFT — internal controls under Croatia's AML/CFT legislation, including a designated compliance function.
• •Application file — the Article 17 documentation, prepared to EBA Guidelines EBA/GL/2017/09, including a three-year business plan with own-funds projections on HNB's prescribed forms.
• •Distribution — e-money cannot be issued through agents. Distributors may distribute and redeem it. Agents providing payment services must be registered by HNB, which decides within two months of a complete request.
• •Use it or lose it — HNB revokes the authorisation if the EMI has not started issuing e-money within 12 months of receiving it.

Management Relocation — Where Non-EU Founders Get Stuck

Because the Act requires the EMI to be run from Croatia, the people running it usually need to live there. For non-EU nationals, the residence basis matters more than most applicants expect.

• •The digital nomad permit does not work. It covers remote work for employers not registered in Croatia and does not permit work for Croatian employers. A director of a Croatian EMI does not qualify.
• •A non-EU national holding at least 51% of a Croatian company must regularise residence under the self-employment rules: an investment of at least €26,544.56 in establishing the business, at least three Croatian citizens employed full-time on indefinite contracts at no less than the previous year's average gross salary, and the owner's own gross pay at least one and a half times the relevant average gross salary.
• •Non-owner executives may qualify for an EU Blue Card, issued for up to 48 months, with a qualifying employment contract of at least six months, the prescribed salary level, and higher education or, in permitted categories, high-level professional skills.

For an EMI, the three-employee condition is rarely the obstacle it is for a small trading company — the substance requirement means you will be hiring locally regardless. The mistake is sequencing: incorporating and filing before the directors' residence basis is settled.

Croatia's Corporate Tax

Croatia applies corporate income tax at 10% where annual revenue does not exceed €1,000,000 and 18% above it. Both rates apply to taxable profit, not turnover. An EMI that scales will cross the threshold, so the business plan should model the 18% rate from the year revenue passes €1 million rather than assume the lower band indefinitely. Residence, personal tax and company tax are separate questions and should be planned separately.

The Honest Constraints

What to know before choosing Croatia

• •Banking access is harder than the licence. A legislated right to participate in payment systems does not replace operating accounts, card-scheme settlement banks or, unless the central bank facility is used, a safeguarding bank. Plan banking in parallel with the application, not after it. How we approach banking for licensed institutions →
• •Direct access is new in practice. The law is in place; the operational track record for non-bank participants is not yet.
• •Two supervisors for crypto. EMI plus CASP means HNB and HANFA.
• •Substance is a cost line. Local management and staff are a condition of the licence, not an option.

Capital and Statutory Cost Drivers

How Zitadelle AG Assists

• Initial scoping — whether a Croatian EMI, a payment institution or a small EMI fits the business model, benchmarked against Latvia and Lithuania
• Confirming the current operational position on direct payment-system access and central bank safeguarding with the Croatian National Bank
• Company incorporation and substance planning, including the residence route for each non-EU director and shareholder
• Full HNB application — business plan, own-funds projections, safeguarding, ICT and DORA documentation, AML/CFT programme
• Management and shareholder suitability files
• Banking and safeguarding introductions, run in parallel with the application
• EEA passporting notifications
• Coordination with HANFA where a MiCA CASP authorisation is also required

Zitadelle AG works with fintechs and e-money operators building a real presence in Croatia — from scoping and incorporation through the HNB file, banking and passporting. Contact Zitadelle AG for a confidential initial consultation on a Croatian EMI licence.