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15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the HANFA licence, including banking and payment rails.
Forex license in Croatia: HANFA investment-firm licence.
A forex license in Croatia is an investment-firm licence (odobrenje za rad) from the Croatian Financial Services Supervisory Agency (HANFA) under the Capital Market Act (ZTK). A market maker needs €750,000 of capital and pays HANFA €5,100 for dealing on own account at filing, kept even if the licence is refused. The ZTK's six-month limit runs from a complete file. We build that file in Zagreb.
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Croatia in brief
Forex license in Croatia: a printed fee table and decisions you can read.
Croatia licenses forex and CFD brokers under the Capital Market Act (Zakon o tržištu kapitala, ZTK), Narodne novine (NN) 65/2018, its MiFID II transposition, in force since 27 July 2018 and amended six times to date. HANFA grants the licence by a decision under čl. 38, for the investment services of čl. 5 st. 1. No forex or CFD category exists. A market maker needs service 3, dealing on own account (register code 1-03), normally beside 1-01 reception and transmission, 1-02 execution and the ancillary services 2-01 safekeeping and 2-04 foreign exchange. Initial capital sits in čl. 10, rewritten for the IFD by NN 83/2021 and stated in euro since 1 January 2023: €750,000 for dealing on own account, €150,000 for a firm holding client money, €75,000 for one holding neither. The decision itself says whether the firm may hold client money (čl. 38 st. 4).
HANFA publishes its licence decisions, and the latest own-account grant shows the route in dates. Positive ARB d.o.o. filed on 14 March 2024. Between 3 April and 18 June HANFA sent it five requests for supplements, on subjects that included the business plan, organisation, conflicts of interest, balance-sheet projections and control functions, and on 3 July its board candidates presented their programmes in person. The licence came on 23 July 2024, for dealing on own account only and without the right to hold client money. The fees are printed: €5,100 for dealing on own account under HANFA's rules in NN 157/2025, at most €12,700 for all of a new firm's services, paid at filing and kept on refusal. The register is small. On 23 October 2026 it listed 8 investment firms, and 3 of them were licensed to deal on own account.
An investment-firm licence from HANFA under the Capital Market Act (ZTK, NN 65/2018): capital €75k/€150k/€750k, €5,100 for dealing on own account, six months from a complete file.
HANFA publishes its decisions; the latest own-account licence took four months and nine days in 2024. Eight investment firms on the register, three dealing. Tax 10% up to €1m of revenue.
The two builds
Market maker or agency broker under one HANFA licence.
HANFA licenses one kind of investment firm and prices it service by service. A market maker carries €750,000 of capital and a €5,100 dealing fee; an agency broker carries €150,000 or €75,000, depending on whether its decision lets it hold client money.
Market maker at €750,000 or agency at €75k-€150k, one HANFA licence.
01 - DEALING ON OWN ACCOUNT · 1-03
The market-maker investment firm
A Croatian CFD market maker holds service 1-03 under čl. 5 st. 1 ZTK, normally with 1-01, 1-02 and the ancillary services 2-01 and 2-04, and asks in the same application to hold client money. Capital is €750,000 under čl. 10. HANFA's fees for that set come to €10,400: €5,100 + €1,400 + €2,100 + 2 × €900.
A Croatian CFD market maker holds service 1-03 under čl. 5 st. 1 ZTK, normally with 1-01, 1-02 and the ancillary services 2-01 and 2-04, and asks in the same application to hold client money. Capital is €750,000 under čl. 10. HANFA's fees for that set come to €10,400: €5,100 + €1,400 + €2,100 + 2 × €900.
- ✓1-03 dealing on own account
- ✓€750,000 initial capital, čl. 10 ZTK
- ✓HANFA fees €10,400 for the usual set
- ✓Client money stated in the decision
- ✓Supervisory board, d.o.o. included
- ✓NN 71/2019 retail CFD rules
02 - AGENCY · 1-01 AND 1-02
€75k-€150k · fees from €1,400The agency investment firm
A Croatian agency broker receives, transmits and executes client orders without a dealing book: €150,000 of capital where its decision lets it hold client money, €75,000 where it does not. HANFA charges €1,400 for reception and transmission and €2,100 for execution. A market intermediary (tržišni posrednik, čl. 132) is no shortcut, because it may only transmit orders and advise on transferable securities and fund units.
RTO and execution; €1,400 and €2,100 fees; €75k or €150k capital.
- ✓1-01 reception and transmission
- ✓1-02 execution of orders
- ✓€150,000 with client money
- ✓€75,000 without client money
- ✓€900 per ancillary service
- ✓Market intermediary: no CFDs
Costs and timelines are confirmed for your case before any work begins. HANFA's fees follow NN 157/2025; board approvals at €1,400 per person and the investor-fund contributions are itemised in the quote.
Why Croatia
Printed HANFA costs and a 10% band under €1 million of revenue.
Croatia's case is cost and transparency; the warning is that its retail CFD rules leave the country with you.
✓
Fees printed to the euro
HANFA's 2026 fee rules (NN 157/2025) price each service: €1,400 for reception and transmission, €2,100 for execution, €5,100 for dealing on own account and €900 per ancillary service. A new firm pays at most €12,700 for its services, all of it with the application.€5,100 dealing, €12,700 cap.
✓
Decisions you can read first
HANFA publishes its licence decisions. The 2024 Positive ARB decision gives the dates of five supplement requests and what they covered, from the business plan to the control functions, so a new application can answer those questions before HANFA asks them.Positive ARB's 2024 file, dated.
✓
10% while revenue stays under €1 million
Until revenue passes €1,000,000 in a tax period, a Croatian broker pays 10% corporate tax; past that line the rate is 18%. For a firm in its first licensed years, the 10% band is the one we model first.Revenue up to €1 million.
✓
Capital and fees in euro
Since 1 January 2023 čl. 10 ZTK states initial capital in euro instead of a kuna equivalent, and HANFA's fees and the €20,000 investor cover are euro amounts too. No conversion rate decides whether the capital is enough.Capital and fees in euro since 2023.
✓
One procedure for licence and people
The licence, the management-board approvals and the qualifying-holding approvals can run as one procedure under the general administrative-procedure rules (ZUP čl. 44). There is no appeal against HANFA's decision, only a suit before the Administrative Court in Zagreb (Upravni sud u Zagrebu) within 30 days.Licence and board approvals together.
✓
Retail rules that leave with you
HANFA's CFD decision (NN 71/2019) covers retail clients in Croatia and retail clients abroad served from Croatia. A Croatian licence offers no higher retail leverage offshore: 30:1 on major currency pairs is the ceiling for every retail client it serves.Retail limits follow clients abroad.
How it compares
How Croatia differs from other routes.
Hungary decides in three months and taxes at 9%; Austria charges a market maker €11,875 in licence fees. Cyprus taxes at 15% whatever the revenue, while Croatia's own lines are €10,400 in HANFA fees for the usual market-maker set and a 10% band that ends at €1 million of revenue.
Croatia vs other jurisdictions
| Feature |  Croatia | Other jurisdictions |
|---|---|---|
| Licence fee | €10,400 usual set · €12,700 cap, non-refundable | HUF 2,700,000 Hungary · €11,875 Austria |
| Statutory clock | 6 months from a complete file | 3 months Hungary · 6 months Austria |
| Corporate tax | 10% to €1m revenue · 18% above | 9% Hungary · 23% Austria · 15% Cyprus |
| Retail CFD rules | Bind sales from Croatia abroad | Austria the same: 'in oder aus Österreich' |
Licence fee
Croatia€10,400 usual set · €12,700 cap, non-refundable
Other jurisdictionsHUF 2,700,000 Hungary · €11,875 Austria
Statutory clock
Croatia6 months from a complete file
Other jurisdictions3 months Hungary · 6 months Austria
Corporate tax
Croatia10% to €1m revenue · 18% above
Other jurisdictions9% Hungary · 23% Austria · 15% Cyprus
Retail CFD rules
CroatiaBind sales from Croatia abroad
Other jurisdictionsAustria the same: 'in oder aus Österreich'
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Croatia | HANFA investment firm - ZTK | 10% to €1m revenue · 18% above | IFD €75k-€750k, €5,100 dealing fee, supervisory board |
 Hungary | MNB investment firm | 9% CIT · local tax up to 2% | IFD €75k-€750k, 3-month clock |
 Austria | FMA Wertpapierfirma - § 3 WAG 2018 | 23% CIT · 24% above €1m (2028) | IFD €75k-€750k, €10,000 fee, 2 managers |
 Cyprus | CySEC CIF | 15% CIT (2026) | IFD €75k-€750k, EU passport |
CroatiaLicense typeHANFA investment firm - ZTK
Taxation10% to €1m revenue · 18% above
RequirementsIFD €75k-€750k, €5,100 dealing fee, supervisory board
HungaryLicense typeMNB investment firm
Taxation9% CIT · local tax up to 2%
RequirementsIFD €75k-€750k, 3-month clock
AustriaLicense typeFMA Wertpapierfirma - § 3 WAG 2018
Taxation23% CIT · 24% above €1m (2028)
RequirementsIFD €75k-€750k, €10,000 fee, 2 managers
CyprusLicense typeCySEC CIF
Taxation15% CIT (2026)
RequirementsIFD €75k-€750k, EU passport
European Union
Forex licences in neighbouring jurisdictions
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Before you apply
Forex license requirements in Croatia: what HANFA checks.Croatia forex license requirements.
Before it grants a licence, HANFA tests form, capital, owners, board members and organisation against čl. 8, 10, 20, 21, 28, 29, 38 and 50 ZTK. The ten items below make up a market maker's file.
01
Croatian company - a limited liability company (d.o.o.) or joint-stock company (d.d.) with its seat in Croatia (čl. 8 st. 1 ZTK); the founders, or the management board of a company that already exists, file the application (čl. 40 st. 2).
02
Initial capital - €750,000 for dealing on own account under čl. 10 ZTK, paid in cash in full before entry in the court register (čl. 9 st. 2), with proof of payment to HANFA before the grant.
03
Application file - the content of čl. 40 ZTK and the documents in čl. 4-10 of HANFA's licensing rulebook (NN 96/18 as amended), lodged together with the fees.
04
Management board - each member approved by HANFA in advance for a mandate of at most five years (čl. 29 st. 2), at €1,400 per person, and ready to present the business programme in person (čl. 29 st. 10).
05
Supervisory board - compulsory for every investment firm, d.o.o. included (čl. 34 st. 1), with risk and remuneration committees inside it only once average assets exceed €100,000,000 over four years (čl. 34 st. 2).
06
Qualifying holders - HANFA's prior approval to reach or exceed 10%, 20%, 30% or 50% (čl. 12 st. 1), suitability tested under čl. 21, at €2,600 per approval for a €750,000 firm.
07
Business plan and controls - balance-sheet projections, organisation, conflict-of-interest rules and control functions, the subjects HANFA raised in its supplement requests to Positive ARB in 2024.
08
Investor protection - membership of the investor protection fund (Fond za zaštitu ulagatelja) run by the Središnje klirinško depozitarno društvo (SKDD), a duty under čl. 36, with claims covered to €20,000 per investor (čl. 261).
09
Retail CFD conduct - HANFA's decision in NN 71/2019: initial margin from 3.33% (30:1) to 50% (2:1), close-out at 50% per account, negative balance protection, no benefits, and a firm-specific risk warning recalculated every three months.
10
AML/CFT - risk assessment, customer due diligence, an authorised AML officer with a deputy, staff training and internal audit under the Zakon o sprječavanju pranja novca i financiranja terorizma, with reports to the Ured za sprječavanje pranja novca.
01
A d.o.o. or d.d. seated in Croatia.
02
€750,000 paid in cash.
03
Čl. 40 file, rulebook documents.
04
Board members approved, €1,400 each.
05
Supervisory board in every firm.
06
10% holders approved in advance.
07
Business plan and controls.
08
SKDD fund, €20,000 cover.
09
NN 71/2019 CFD conduct.
10
AML officer and deputy.
Reflects the ZTK (NN 65/2018) with the IFD and euro amendments of NN 83/2021 and NN 151/2022, HANFA's licensing and fee rulebooks and NN 71/2019, as of October 2026. The later amendments (NN 85/2024, NN 126/2025 and NN 45/2026) are checked against the file before it goes in.ZTK + HANFA rulebooks + NN 71/2019; 2024-2026 amendments checked per file.
Verify it yourself
Official sources
Regulator pages, legal texts and public registers the figures on this page are based on.
- LawCapital Market Act (Zakon o tržištu kapitala), NN 65/2018 as first published - Narodne novinenarodne-novine.nn.hr
- RegulatorHANFA - Investment firmshanfa.hr
- RegisterHANFA - Register of firms authorised to provide investment serviceshanfa.hr
- FeesHANFA fee rules (Pravilnik o vrsti i visini naknada, NN 157/2025) - Narodne novinenarodne-novine.nn.hr
- LawHANFA decision restricting CFDs for retail investors (NN 71/2019) - Narodne novinenarodne-novine.nn.hr
How it works
From the d.o.o. to the HANFA decision.
01
Services and client money
Which čl. 5 services, which ancillary ones and whether the firm will hold client money: the three answers fix the capital class and the fee before anything is drafted.Capital class and fee fixed.
02
Company and boards
A d.o.o. or d.d. in Croatia with its management board and supervisory board named, and the capital ready to be paid in cash.Both boards, capital ready.
03
Filing with HANFA
The čl. 40 application and the rulebook documents, with the board and qualifying-holding requests joined to it. HANFA's fees are paid on the day of filing.Application, approvals, fees.
04
Supplements and presentation
Supplement requests answered round by round, the board candidates' programmes presented in person, and the ZTK's six-month limit counting from the complete file.Rounds, presentation; 6-month limit.
05
Decision and launch
HANFA's Management Board (Upravno vijeće) decides. The firm enters the register, joins the SKDD fund and notifies its passports; a challenge to a refusal goes to court within 30 days.Register, fund, passports.
Quick facts
RegulatorHANFA
StatuteZTK · NN 65/2018
Own account€750,000
With client money€150,000
HANFA fee - dealing€5,100 · cap €12,700
Statutory limit6 months, complete file
Investor cover€20,000 per investor
Our planning range8-12 months
The six-month limit starts only when HANFA holds a complete file; Positive ARB's licence came four months and nine days after its filing in 2024. We plan for 8-12 months from the first draft to HANFA's decision.
On the ground in Croatia
Run from our Zagreb office.
Prifinance - Croatia
Zagreb · Croatia
Zagreb, Croatia
01
Croatian company formation
A d.o.o. or d.d. with its seat in Croatia, a supervisory board from the first day and the capital paid in cash before the court-register entry.d.o.o. or d.d., supervisory board.
02
The HANFA file
Everything čl. 40 ZTK and the licensing rulebook require, joined in one procedure with the board and qualifying-holding approvals, and the fees paid on the day of filing.One procedure, fees at filing.
03
Board candidates
Management-board candidates prepared for HANFA's approval and for the in-person presentation of the business programme that čl. 29 st. 10 lets HANFA require.Ready for the presentation.
04
Fund, register and passports
Membership of the SKDD-run investor protection fund, the NN 71/2019 conduct pack in the platform, and passport notifications to the other 29 EEA states once the licence is granted.SKDD fund, EEA notifications.
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Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of forex brokers in Croatia.
Corporate tax is 10% or 18% by revenue, dividends paid to foreign companies carry 10% withholding, dealing is VAT-exempt, and HANFA's annual fee runs in per mille.
10% or 18% by revenue
The Zakon o porezu na dobit, as amended to NN 114/23, taxes profit at 10% where revenue (prihodi) in the tax period is at most €1,000,000 and at 18% where it exceeds that figure.Set by revenue, €1m line.
10% on dividends paid abroad
Dividends and profit shares paid to foreign companies carry 10% withholding. Recipients in EU-listed non-cooperative jurisdictions with no tax treaty pay 25%, raised from 20% by the 2023 amendment. Treaty and EU-directive relief is confirmed per structure.25% for listed jurisdictions.
15% on other payments abroad
Croatian withholding tax (porez na dobit po odbitku) on payments to foreign companies has a general rate of 15%, against 10% for dividends. We check each intra-group charge against it before the group structure is fixed.General withholding rate.
VAT-exempt dealing
Transactions in shares, bonds, securities and other financial instruments, negotiation included, are exempt under čl. 40 st. 1 t. f) of the Zakon o PDV-u; management and safekeeping are not.Čl. 40 st. 1 t. f).
Which services the exemption reaches
In a ruling of 21 December 2015 the Tax Administration counted reception and transmission, execution, dealing on own account and placing as exempt, and investment advice, portfolio management and custody as taxable.Not advice or custody.
HANFA's annual fee in per mille
The 2026 fee is computed and paid quarterly: 0.3 per mille of revenue from reception, transmission and execution, and 0.03 per mille of the book value of instruments held for own account. Revenue from dealing on own account sits outside the 0.7 per mille base.Per mille, quarterly.
Tax summary
Corporate tax10% · revenue up to €1m
Above €1m revenue18%
Dividend withholding10% · 25% listed jurisdictions
VAT on dealingExempt · čl. 40 st. 1 t. f)
HANFA annual feePer mille · paid quarterly
*As of 2026 per the Zakon o porezu na dobit as amended to NN 114/23, the Zakon o PDV-u and HANFA's 2026 fee rules (NN 157/2025). Group and founder-level outcomes are modelled per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Croatian company (d.o.o. or d.d.), AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed broker.
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Croatia · HANFA
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Full-service assistance - from the d.o.o. and its supervisory board to the HANFA licence and the first passport notifications - run through our Zagreb office.
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Request a free conclusion →FAQ
HANFA licensing for CFD brokers, answered.
What licence does a forex broker need in Croatia?+
An investment-firm licence (odobrenje za rad) granted by HANFA under čl. 38 ZTK. A CFD market maker needs dealing on own account, register code 1-03, usually with reception and transmission, execution, safekeeping and foreign-exchange services. Croatia has no separate forex or CFD licence.
How much capital does HANFA require?+
€750,000 for dealing on own account, €150,000 for a firm that holds client money and €75,000 for one that holds neither, under čl. 10 ZTK. The capital is paid in cash before the court-register entry, and the IFR then keeps own funds at or above that level at all times.
How long does a forex license in Croatia take?+
Six months from a complete application is the ZTK's limit for HANFA. In 2024 Positive ARB went from filing to licence in four months and nine days, through five supplement rounds and an in-person presentation; we plan for 8-12 months from the first draft.
What does a forex license in Croatia cost?+
HANFA charges €5,100 for dealing on own account, €1,400 for reception and transmission, €2,100 for execution and €900 per ancillary service, capped at €12,700 for a new firm; each board-member approval costs €1,400. Fees are paid at filing and kept on refusal. Capital is €750,000; investor-fund contributions are confirmed in the quote.
Can a d.o.o. hold a HANFA licence?+
Yes: a d.o.o. or a d.d. with its seat in Croatia qualifies under čl. 8 st. 1 ZTK. Every investment firm must still have a supervisory board (čl. 34 st. 1), so a HANFA-licensed d.o.o. has one too.
Do Croatian CFD rules apply to clients abroad?+
Yes. HANFA's CFD decision, published in NN 71/2019 on 26 July 2019, covers retail clients in Croatia and those served from Croatia abroad: 3.33% initial margin on major pairs (30:1), 50% on crypto (2:1), close-out at 50%, negative balance protection and no benefits.
How many investment firms does HANFA supervise?+
Eight, on HANFA's register as at 23 October 2026, beside 11 credit institutions and 3 fund management companies authorised for investment services. Three of the eight may deal on own account, and the newest of them, licensed in July 2024, may not hold client money.
How are forex brokers taxed in Croatia?+
Corporate tax is 10% where revenue stays at or below €1,000,000 and 18% above it. Dividends paid to foreign companies carry 10% withholding, or 25% in EU-listed non-cooperative jurisdictions without a treaty. Dealing is VAT-exempt under čl. 40 st. 1 t. f) of the VAT Act.
Croatia or Cyprus for a retail CFD broker?+
Cyprus, for a brand that needs an ecosystem: the Limassol cluster of platforms, liquidity and compliance staff, and 15% corporate tax at any revenue. Croatia suits a smaller book: 10% while revenue stays under €1,000,000, HANFA fees printed and capped at €12,700, decisions published. We model both.
Why Prifinance for Croatia?+
We run the file from our Zagreb office: the d.o.o. or d.d. with its supervisory board, the čl. 40 application built around the questions HANFA put to Positive ARB in 2024, and board candidates rehearsed for the in-person presentation. The NN 71/2019 conduct pack is in the platform before filing.
What licence?+
HANFA investment firm, čl. 38 ZTK.
Capital?+
€75k/€150k/€750k, čl. 10.
How long?+
6 months statutory; 8-12 planned.
Cost?+
€5,100 dealing; €12,700 cap.
A d.o.o.?+
Yes, with a supervisory board.
Rules abroad?+
Retail limits follow clients abroad.
How many firms?+
Eight; three deal on own account.
Taxes?+
10% to €1m revenue, then 18%.
Vs Cyprus?+
Their cluster; your printed costs.
Why you?+
Zagreb office, presentation-ready board.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Croatian Financial Services Supervisory Agency (HANFA) or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.