Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the HNB decision, including banking and payment rails.
Get a payment license in Croatia.
Croatia joined the euro in 2023 and rewrote its two payment statutes in euros the same year: the Payment System Act and the Electronic Money Act, both amended again in 2024 for DORA and instant payments. The Croatian National Bank authorises payment institutions on EUR 20,000 to 125,000 of capital and e-money institutions on EUR 350,000, registers small payment institutions below EUR 995,000 a month, and the licence passports across the EEA. Ten payment institutions and three EMIs hold it today.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Croatia in brief
Two euro-denominated statutes, one supervisor, and a passport from the newest euro-area member.
Croatia transposed PSD2 in two acts rather than one. The Payment System Act (Zakon o platnom prometu, NN 66/2018) covers payment institutions, and the Electronic Money Act (Zakon o elektroničkom novcu, NN 64/2018) covers issuers of e-money. Both were converted to euro figures in NN 114/2022 when the country adopted the currency, and both were amended in NN 136/2024, in force from 17 January 2025, to carry DORA and the EU instant-payments regulation. Article 82 of the first act sets the payment institution's initial capital at EUR 20,000 for money remittance, EUR 50,000 for payment initiation and EUR 125,000 for the account-based services; Article 14 of the second sets an e-money institution's at EUR 350,000. Below the licence sits a registration: a small payment institution whose average monthly transaction value, agents included, stays under EUR 995,000 may operate in Croatia alone without the full authorisation and without a passport.
The supervisor is the Hrvatska narodna banka, which authorises, keeps the register and inspects. Its register of 9 August 2026 lists ten payment institutions, three e-money institutions and three registered account-information providers - a small crowd, which is part of the appeal. Client funds must be protected by the end of the working day after receipt under the HNB's decision of February 2025: a separate account, low-risk assets or an insurance policy, and since the 2024 amendment an account at the central bank. Instant payments run through EuroNCSInst, operated by FINA, with access to TIPS since June 2023. Tax is 18% on profit, 10% for companies under EUR 1 million of revenue, with 25% VAT and 10% withholding on dividends. The acts print no decision clock of their own, so the file has to be complete on day one; we run it from Prague, and plan on six to nine months.
Two acts, both in euros since 2022: the Payment System Act (PI capital EUR 20,000 / 50,000 / 125,000, Article 82) and the Electronic Money Act (EMI EUR 350,000, Article 14). Small PI registration below EUR 995,000 a month. Funds protected by the next working day under HNB decision NN 13/2025.
Ten PIs and three EMIs on the HNB register (August 2026). EuroNCSInst on TIPS since 2023. 18% tax, 10% under EUR 1M revenue, VAT 25%. Six to nine months realistic. We run it from Prague.
The routes
Payment institution, e-money institution - or the registered small PI.
Three depths under two acts: the full PI authorisation with an EEA passport, the EMI authorisation on EUR 350,000, and a registration for small domestic payment businesses. We fix the route first, then build once.
PI or EMI with an EEA passport - or a registered small PI for Croatia alone.
01 - PAYMENT INSTITUTION
Institucija za platni promet
Authorisation by the HNB under the Payment System Act for any of the PSD2 services - EUR 20,000, 50,000 or 125,000 of initial capital by service under Article 82, own funds by the volume method, safeguarding by the next working day, and a passport into every EEA state.
Authorisation by the HNB under the Payment System Act for any of the PSD2 services - EUR 20,000, 50,000 or 125,000 of initial capital by service under Article 82, own funds by the volume method, safeguarding by the next working day, and a passport into every EEA state.
- ✓All PSD2 payment services, singly or combined
- ✓Capital EUR 20,000 / 50,000 / 125,000 (Article 82)
- ✓Own funds by the HNB's volume method (NN 126/2019)
- ✓Funds protected by the next working day (NN 13/2025)
- ✓EEA passport on notification to the HNB
- ✓Agents and branches entered in the HNB register
02 - E-MONEY INSTITUTION
EMI - EUR 350,000Institucija za elektronički novac
Authorisation under the Electronic Money Act to issue e-money and provide payment services alongside it - EUR 350,000 of initial capital under Article 14, redemption at any time under Article 7, no interest on balances under Article 8, and the same EEA passport.
EMI: EUR 350,000 capital (Article 14); redemption at par, no interest; safeguarding by next working day; EEA passport.
- ✓E-money issuance plus payment services
- ✓Capital EUR 350,000 (Article 14 of the E-Money Act)
- ✓Redemption at par at any time · no interest on balances
- ✓Safeguarding of the float by the next working day
- ✓EEA passport · agents and distributors registered
- ✓Small-PI registration as a domestic fallback below EUR 995,000 a month
Costs and timelines are confirmed for your case before any work begins. The HNB's authorisation and supervision fees are not printed in the acts, so the state charges, the safeguarding set-up and substance are itemised in your quote.
Why Croatia
A euro-area passport from a supervisor with ten licensees.
Croatia is the youngest euro-area home state in the EU, with statutes rewritten in 2022 and 2024, an instant rail on TIPS and a register short enough that the supervisor knows every name on it.
✓
Euro and EEA passport
A licence from a euro-area member state since 1 January 2023 - the currency, SEPA and the passport all come with the HNB's decision.Member since 2023; passport included.
✓
PSD2 capital, nothing above it
EUR 20,000, 50,000 or 125,000 for a payment institution and EUR 350,000 for an EMI, printed in Article 82 and Article 14 in euros since NN 114/2022.EUR 20k-125k PI, 350k EMI.
✓
A registered small-PI route
Below EUR 995,000 of average monthly transactions a business registers rather than applies - a domestic first step that keeps the option of the full licence.Registration below EUR 995k a month.
✓
Instant payments on TIPS
EuroNCSInst, run by FINA, has connected Croatian participants to TIPS since 24 June 2023; the 2024 amendment brought the EU instant-payments regulation into the act.EuroNCSInst since June 2023.
✓
Sixteen names on the register
Ten payment institutions, three EMIs and three AISPs as of August 2026 - a supervisor that reads each file itself rather than through a queue.A supervisor that knows every file.
✓
DORA already in the statute
NN 136/2024 wrote ICT-risk governance into the Payment System Act from January 2025, so a file built to DORA now needs no second pass later.In the act since January 2025.
How it compares
How Croatia differs from other EU routes.
Croatia sells the same PSD2 licence as Lithuania or Malta, from a smaller register and a newer euro. The honest comparison is below.
Croatia vs other jurisdictions
| Feature |  Croatia | Other jurisdictions |
|---|---|---|
| Capital | EUR 20,000-125,000 PI · 350,000 EMI | Same PSD2 floors |
| Small regime | Registered PI below EUR 995,000 a month | Waivers vary or are absent |
| Register size | 10 PIs · 3 EMIs (Aug 2026) | Dozens to hundreds |
| Corporate tax | 18% · 10% under EUR 1M revenue | 12.5-25.8% |
Capital
CroatiaEUR 20,000-125,000 PI · 350,000 EMI
Other jurisdictionsSame PSD2 floors
Small regime
CroatiaRegistered PI below EUR 995,000 a month
Other jurisdictionsWaivers vary or are absent
Register size
Croatia10 PIs · 3 EMIs (Aug 2026)
Other jurisdictionsDozens to hundreds
Corporate tax
Croatia18% · 10% under EUR 1M revenue
Other jurisdictions12.5-25.8%
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Croatia | PI / EMI (HNB) | 18% · 10% small | EUR 20k-125k · EMI EUR 350k |
 Slovenia | PI / EMI (Banka Slovenije) | 22% | EUR 20k-125k · EMI EUR 350k · EUR 4,500 fee |
 Hungary | PI / EMI (MNB) | 9% | EUR-equivalent PSD2 floors in HUF |
 Lithuania | EMI & PI (Bank of Lithuania) | 17% · small 7% | EUR 350,000 · CENTROlink |
CroatiaLicense typePI / EMI (HNB)
Taxation18% · 10% small
RequirementsEUR 20k-125k · EMI EUR 350k
SloveniaLicense typePI / EMI (Banka Slovenije)
Taxation22%
RequirementsEUR 20k-125k · EMI EUR 350k · EUR 4,500 fee
HungaryLicense typePI / EMI (MNB)
Taxation9%
RequirementsEUR-equivalent PSD2 floors in HUF
LithuaniaLicense typeEMI & PI (Bank of Lithuania)
Taxation17% · small 7%
RequirementsEUR 350,000 · CENTROlink
Before you apply
Requirements for the HNB authorisation.Requirements for the authorisation.
Article 84 of the Payment System Act lists the conditions and Article 85 the documents; the Electronic Money Act mirrors them in Articles 16 and 17. The checklist below is what a passing file contains.
01
A legal person established in Croatia, with the business conducted from Croatian territory - the E-Money Act says so in Article 16 and the HNB applies the same test to payment institutions.
02
Initial capital at the Article 82 tier - EUR 20,000, 50,000 or 125,000 - or EUR 350,000 for an e-money institution under Article 14, paid in and evidenced.
03
A three-year business plan with projections, and the own-funds forms (IPK-RK or IEN-RK) showing the volume-method calculation the HNB's decision NN 126/2019 prescribes.
04
A safeguarding description that meets the HNB's decision NN 13/2025: separate account, low-risk assets or insurance, funds protected by the end of the next working day.
05
Governance, internal control and risk-management arrangements proportionate to the services, with the outsourcing rules of Article 107 applied to any provider.
06
ICT documentation built to DORA, which NN 136/2024 wrote into the act from 17 January 2025 - governance, incident reporting, testing and third-party risk.
07
Professional indemnity insurance for payment-initiation or account-information services under Article 101, sized to the EBA criteria.
08
Managers of good repute with the knowledge and experience to run the institution, and qualifying shareholders assessed for suitability.
09
AML/CFT policies and procedures under Croatia's anti-money-laundering act, with a compliance function that reports to the authority.
10
A plan to start at least one licensed service within twelve months of the decision - the act withdraws an unused authorisation after that period.
01
Legal person established and run in Croatia.
02
Capital EUR 20k / 50k / 125k or EMI EUR 350k.
03
Three-year plan and own-funds forms.
04
Safeguarding per HNB decision NN 13/2025.
05
Governance, controls, outsourcing (Art. 107).
06
ICT documentation to DORA.
07
PII for PIS/AIS (Art. 101).
08
Managers and shareholders assessed.
09
AML/CFT policies and compliance function.
10
First service within 12 months of decision.
Reflects the Payment System Act (NN 66/2018, 114/2022, 136/2024), the Electronic Money Act (NN 64/2018, 114/2022, 136/2024), the HNB decisions NN 126/2019 and NN 13/2025, as of 2026.Payment System Act NN 66/2018, 114/2022, 136/2024; E-Money Act NN 64/2018; HNB decisions NN 126/2019, NN 13/2025.
How it works
From first call to the HNB register.
01
Route and strategy
PI, EMI or registered small PI; service list and capital tier; passport plan - the route and budget fixed in writing.PI, EMI or small PI - in writing.
02
Company and capital
Croatian company formed, capital paid to the Article 82 or Article 14 figure, managers and shareholders documented.Formed, paid, documented.
03
The application file
Business plan, own-funds forms, safeguarding, DORA and AML documentation under Articles 85 and 17 - complete before filing.Plan, forms, safeguarding, DORA, AML.
04
HNB review
Question rounds answered, opinions of other authorities awaited where the HNB asks for them - plan on six to nine months.6-9 months realistic.
05
Decision and launch
Rješenje issued, register entry made, safeguarding live, first service started inside the twelve-month window.Register entry; first service in 12 months.
Quick facts
RegulatorHrvatska narodna banka
LawPayment System Act · E-Money Act
LicencePI · EMI · registered small PI
CapitalEUR 20k / 50k / 125k · EMI EUR 350k
Client fundsProtected by next working day
PassportEEA
Timeline6-9 months realistic
Corporate tax18% · VAT 25%
The acts print no decision period, which puts the weight on the first filing. A complete file is what keeps the review inside a year, and our job.
Your Croatia desk
Run from our Central Europe desk.
Prifinance - Central Europe desk
Prague · coordinating Croatian mandates
Vlkova 532/8, Žižkov, Prague
01
Croatian company formation
A d.o.o. or d.d. with the capital tier the service list requires, the corporate layer the HNB expects and the business conducted from Croatia from day one.d.o.o., capital tier, corporate layer.
02
The HNB file
Business plan, own-funds forms, safeguarding, DORA documentation and AML policies to the acts' articles - drafted by us and defended through the question rounds.Articles 85 and 17 answered in order.
03
Safeguarding and rails
The safeguarding account or policy under NN 13/2025 opened before launch, and EuroNCSInst and SEPA access planned with the licence.NN 13/2025 account; EuroNCSInst.
04
Substance in Croatia
Managers who pass the HNB's assessment, a compliance function and premises in Zagreb - the presence the register entry is built on.Zagreb managers, compliance, premises.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Croatia.
An 18% corporate rate that drops to 10% under EUR 1 million of revenue, 25% VAT, and 10% withholding on dividends - the euro-area member with the simplest tax card in the region.
Corporate tax 18%
The standard rate on profit. Companies with revenue up to EUR 1,000,000 pay 10% - a real advantage in a licensee's first years.10% under EUR 1M revenue.
VAT 25%
The standard rate is high, but payment and e-money services are VAT-exempt under the EU directive; technology fees may not be, so the product mix is mapped early.Payment services exempt.
Dividends 10%
Withholding on profit shares to foreign owners is 10%, cut by treaties and by the parent-subsidiary rules inside the EU.Treaties and EU rules cut it.
Other withholding 15%
The general withholding rate on services and royalties paid abroad is 15%, rising to 25% for payees in listed non-cooperative jurisdictions.25% to listed jurisdictions.
Payroll
Income tax and social contributions on Zagreb salaries - the operating budget prices them in with the compliance and management hires.Income tax + contributions.
Treaties and the EU
Croatia's treaty network and EU directives on dividends and interest - outbound flows to the parent are structured with the licence, not after it.Wide; EU directives apply.
Tax summary
Corporate tax18% · 10% under EUR 1M revenue
VAT25% · payment services exempt
Dividend withholding10%
Other withholding15% · 25% to listed jurisdictions
PayrollIncome tax + contributions
Tax treatiesWide · EU directives apply
*Figures as of 2026 per Porezna uprava. Treaty and regime positions are assessed 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 d.o.o., 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 institution.
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Croatia · HNB
Launch your payment project in Croatia with expert support.
Full-service assistance - from company formation to the HNB authorisation, safeguarding, rails and ongoing compliance.
Get a consultation →Free legal opinion
Is Croatia the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Croatian payment licence, answered.
What licence does a payment business need in Croatia?+
Authorisation by the Hrvatska narodna banka as a payment institution under the Payment System Act, or as an e-money institution under the Electronic Money Act if you issue stored value. A domestic business with average monthly transactions under EUR 995,000 may register as a small payment institution instead, without a passport.
How much capital is required?+
Article 82 of the Payment System Act: EUR 20,000 for money remittance, EUR 50,000 for payment initiation, EUR 125,000 for the account-based services. Article 14 of the Electronic Money Act: EUR 350,000 for an EMI. The figures have been in euros since NN 114/2022.
How are client funds protected?+
By the end of the working day after receipt, under the HNB's decision NN 13/2025 - on a separate account, in low-risk liquid assets, or through an insurance policy or comparable guarantee. Since the 2024 amendment the funds may also be held at the central bank.
How long does the HNB take?+
The acts do not print a decision period of their own, and the HNB may ask other authorities for opinions before deciding. With a complete file, plan on six to nine months. An authorisation lapses if no licensed service starts within twelve months.
Does the licence passport?+
Yes - a Croatian PI or EMI provides services in any EEA state through a branch, an agent or cross-border after notifying the HNB. The registered small payment institution does not passport.
Are there rules on e-money balances?+
The Electronic Money Act requires redemption at par at any time (Article 7) and prohibits interest or any other benefit tied to the holding period (Article 8). The act sets no balance cap.
How are payment companies taxed?+
Corporate tax at 18%, or 10% while revenue stays under EUR 1 million; VAT at 25% with the EU exemption for payment services; 10% withholding on dividends and 15% on other outbound payments.
What substance does the HNB expect?+
A company established in Croatia and run from it: managers with the repute and experience the acts require, a compliance function, premises, and ICT governance to DORA. Outsourcing is allowed under Article 107 with the HNB informed.
What changed in 2024 and 2025?+
NN 136/2024 brought DORA and the EU instant-payments regulation into both acts from 17 January 2025, added an access route to payment systems for PIs and EMIs, and the HNB issued a new safeguarding decision in force from 4 February 2025.
Why Croatia rather than Slovenia or Lithuania?+
Croatia has the smallest register of the three and a 10% rate for small companies; Slovenia prints its fees and a three-month decision clock; Lithuania has CENTROlink and the deepest e-money desk in the EU. Groups choosing a euro-area base with a quiet supervisor start here.
Which licence?+
HNB PI or EMI; small PI registration below EUR 995k a month.
Capital?+
EUR 20k / 50k / 125k; EMI EUR 350k.
Client funds?+
Protected by next working day (NN 13/2025).
How long?+
No printed clock; 6-9 months realistic.
Passport?+
Yes - EEA; not for small PIs.
E-money rules?+
Redemption at par; no interest; no cap.
Taxes?+
18% (10% small), VAT 25%, dividends 10%.
Substance?+
Run from Croatia; managers, compliance, DORA.
Recent changes?+
DORA and instant payments from Jan 2025.
vs Slovenia / Lithuania?+
Smallest register; 10% small-company rate.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
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Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.Free legal opinion: which Croatian route fits your project and what it will cost.
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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 Hrvatska narodna banka or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.