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Obtaining a CASP licence is a mandatory requirement in Croatia to offer services in the EU crypto market. This country is not a particularly strictly regulated jurisdiction, even though it shares a standardised EU-wide legal framework. Local regulatory support helps businesses follow government rules easily, which makes Croatia beneficial for CASPs.
What Is a CASP License in Croatia?
A CASP License in Croatia is required for companies involved in crypto-asset activities within the European Union. The requirement is specified in the Markets in Crypto-Assets Regulation (MiCA). This Regulation (EU) 2023/1114 fully came into force on July 1, 2026. At the national level, MiCA is implemented through the MiCA Implementation Act.
Under this framework, companies must obtain a CASP license in Croatia to provide the following services, listed in Article 3, paragraph 1 of MiCA:
- providing custody and administration of crypto-assets on behalf of clients;
- operation of a trading platform for crypto-assets;
- exchange of crypto-assets for funds;
- exchange of crypto-assets for other crypto-assets;
- execution of orders for crypto-assets on behalf of clients;
- placing of crypto-assets;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets;
- providing portfolio management on crypto-assets;
- providing transfer services for crypto-assets on behalf of clients.
Legacy Croatian VASPs registered before MiCA had to obtain full CASP authorisation by July 1, 2026. Operating without a new license will result in regulatory intervention, including penalties and suspension of business activities.
How Is Cryptocurrency Regulated in Croatia?
In Croatia, the cryptocurrency market is supervised by the Croatian Financial Services Supervisory Agency (HANFA) and the Croatian National Bank (HNB). HANFA oversees CASPs and grants the official authorisation. This regulator handles issues related to services like crypto trading, custody, or portfolio management. Issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs) should apply to the HNB.
What Are the Benefits of Getting a Crypto License in Croatia?
Though obtaining a CASP license in Croatia requires building a real and active business presence in Croatia and deep regulatory reviews, the process is well arranged and structured under MiCA. HANFA doesn’t charge an initial application fee.
What Are the Advantages of a CASP License in Croatia?
A CASP license in Croatia allows service providers to scale across the EU member states. Here, businesses benefit from favorable tax rules and low operational costs. For instance, in Austria, office leasing and administrative maintenance costs are notably higher.
What Are the Requirements for Obtaining a CASP License in Croatia?
Before obtaining a CASP License in Croatia, a service provider must incorporate a Croatian entity, appoint local directors, and create a physical office. Then, he is expected to:
- develop a proper governance structure, ensure that directors have clean records and crypto expertise;
- pay minimum initial capital based on the specific class;
- collect a set of internal documents and submit them with an application.
Core requirements also include detailed risk management frameworks and establishment of robust AML/CFT systems. An entity must be ready to meet taxation obligations.
What Are the Capital and AML/KYC Requirements for CASPs in Croatia?
The minimum capital requirements for CASPs are specified in Article 67(1), point (a) of MiCA. They depend on the type of crypto-asset services in the following way:
- execution of orders on behalf of clients, placing of crypto-assets, providing transfer services for crypto-assets on behalf of clients, reception and transmission of orders for crypto-assets on behalf of clients, providing advice on crypto-assets, and providing portfolio management on crypto-assets — all these services belong to Class 1 and require €50,000.
- providing custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets — these services and Class 1 services fall into Class 2 and require €125,000.
- operation of a trading platform for crypto-assets and Class 2 services are considered Class 3 and require €150,000.
CASPs in Croatia must comply with Croatia’s Anti-Money Laundering and Countering the Financing of Terrorism Act, supervised by HANFA. They must verify the identity of clients, assess the risk of transactions, and monitor suspicious activities.
How Does the CASP Licensing Process Work in Croatia?
Timelines for the CASP licensing process typically cover six months or longer. It involves service and setup costs in addition to the statutory share capital, as it is better to hire lawyers for legal and regulatory advice. Otherwise, it is quite difficult to navigate the Croatian MiCA Implementation Act.
The application and documents are submitted via official regulatory channels or designated electronic methods. The receipt is formally confirmed within 5 working days.
What Are the Steps to Apply for a CASP License in Croatia?
To apply for a CASP license in Croatia, a service provider should take the following steps:
- Define a business model and types of services to determine the class under MiCA and develop a business plan, security protocols, and internal policies.
- Submit a license application with company registration details, proof of minimum share capital deposit, and internal documents.
- Wait until the regulator assesses the business perspectives, internal policies, and financial sustainability.
- Receive the CASP license if all the requirements are met, which allows an entity to immediately provide services.
CASPs regularly send financial reports to the regulator, adhere to AML/KYC standards, and continue to comply with MiCA.
How Is a CASP Company Incorporated in Croatia?
A CASP can choose any business structure depending on growth plans. The most typical choice is a limited liability company (d.o.o.). To open it, a service provider should opt for a unique company name. Business activities should be thoughtfully defined, as they impact the license class and licensing requirements. The next step is the preparation of founding papers. When everything is ready, the share capital is paid, and the above documents are submitted to the Court Register. As a result, a CASP obtains a personal identification number, registers tax obligations, and starts operating.
How Does the Application Submission to HANFA Work?
A CASP can submit an application with the accompanying documents to HANFA both online (signed with a qualified electronic signature) and by post (to Croatian Financial Services Supervision Agency, Franje Račkoga 6, 10000 Zagreb). Hand-delivery is not the primary designated channel.
How Does the HANFA Review Process Work?
Upon application submission, HANFA checks the completeness of filings within 25 working days. Then, a qualitative review of the business model and security setup is performed within 40 working days. If everything complies with the requirements, a deep review process continues and usually takes about 4 months.
What Happens After CASP License Approval in Croatia?
The license approval is sent to a CASP online or by mail. In addition to an official written decision, the status is published in public registries. Upon this, a company can provide its services across EU member states.
What Is the Tax Regime for Crypto Businesses in Croatia?
The tax regime for crypto businesses in Croatia includes an ordinary corporate income tax, which is quite low compared with other EU states, such as Malta. The rates depend on annual revenues:
- up to €1,000,000 are taxed at 10%;
- exceeding €1,000,000 are taxed at 18%.
Also, there is a 2-year tax rule. Under it, individual investors do not pay capital gains tax on cryptocurrency if they hold it for more than two years before selling it for fiat currency like Euros. If sold within two years, a capital gains tax applies.
When applicable, a standard 25% VAT can be paid. However, VAT obligations in this crypto market are not frequent. Core cryptocurrency exchange transactions are exempt from a value-added tax.
What Should You Know Before Applying for a CASP License in Croatia?
Before applying for a CASP license in Croatia, you should know that application failure is possible. The most frequent reasons are weak corporate governance and insufficient AML policies. The SBSB team of fintech lawyers assists in obtaining a MiCA license across various European jurisdictions, including Croatia, Germany, Netherlands, etc. We provide regulatory consulting, help with policy drafting, and support license applications. If you want to navigate MiCA requirements with confidence, reach out to us!
FAQ About CASP License in Croatia
Who regulates CASP licenses in Croatia?
The main regulator for CASP licenses in Croatia is the Croatian Financial Services Supervisory Agency (HANFA). The Croatian National Bank may also be involved for services overlapping with payment or e-money activities.
How long does it take to obtain a CASP license in Croatia?
For a well-prepared application, the standard review period is usually around three months, although the exact timeline can vary depending on the complexity of the business and the quality of the documentation submitted to HANFA.
Which crypto services require a CASP license in Croatia?
Under MiCA, services such as operating a crypto-asset trading platform, exchanging crypto-assets for funds or other crypto-assets, providing custody and administration of crypto-assets, and executing orders on behalf of clients typically require CASP authorisation.
Can an existing VASP registration be converted into a CASP license?
Yes, Croatia provides a transitional regime that allows existing VASP-registered providers to migrate to full CASP authorisation, subject to meeting MiCA requirements and HANFA’s additional national rules before the transition deadlines.
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