EUROPAM

European Public Accountability Mechanisms

Croatia

Country score (EU Average*)
  • 86(72) Political Financing
  • 87(57) Financial Disclosure
  • 88(49) Conflict of Interest
  • 81(59) Freedom of Information
  • 61(63) Public Procurement
  • 55(66) Anti Money Laundering
  • 80(71) Asset Recovery

Country Facts

IncomeUpper middle
GNI per capita (2011 PPP $)20797.36
Population, total4170600.00
Urban population (% of total)59.28
Internet users (per 100 people)72.70
Life expectancy at birth (years)77.28
Mean years of schooling (years)11.2
Global Competitiveness Index4.2
Sources: World Bank, UNDP, WEF.

Political Financing

The Political Activity and Election Campaign Financing Act (2011, amended 2016) and the Act on Election of Representatives to the Croatian Parliament 2003 are the main laws regulating the financing of political parties in Croatia.

There are a number of restrictions on the permissible income for political parties. Donations from foreign interests are banned. Corporations are permitted donors except where they are partly owned by the government. Trade unions are banned from donating as are anonymous donors. There are limits in place for the donations received per year and for election cycles.

Public funding is available for political parties. Extensive provisions are provided for the allocation of funding based on the share of votes in the previous election, representation in the elected body and for participating in the election. Public funding may be utilized on the basis of recovering election campaign costs. There is also subsidized media access tax relief available. For each MP representing an underrepresented gender, political parties are entitled to compensation.

For regulations on spending, vote buying is banned and there are limits on election expenditure for each constituency.

Parties are required to public reports on donations every six months on their website. The reports must reveal the identity of donors. The State Election Commission oversees compliance with the law and the State Audit Office performs audits. Sanctions for breaches of the law include fines, the loss of public funding and forfeiture.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Bans and limits on private income92921001009494
Public funding757562627575
Regulations on spending10010010010010075
Reporting, oversight and sanctions100100100100100100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Bans and limits on private income

Is there a ban on donations from foreign interests to political parties? Yes. There shall be no financing of political parties, independent MPs, members of the representative bodies of local and regional self-government units elected from a list of a group of voters, independent lists or lists of a group of voters and candidates by: – foreign states, foreign political parties and foreign legal persons. By way of derogation from paragraph (1)(i) of this Article, the prohibition of financing political parties, independent MPs, members of the representative bodies of local and regional self-government units, independent lists or lists of a group of voters and candidates (by foreign states, foreign political parties and foreign legal persons whose core activity consists of education in the development and promotion of democratic principles) shall not apply to the financing of educational programmes. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016)
Is there a ban on donations from foreign interests to candidates? Yes. There shall be no financing of political parties, independent MPs, members of the representative bodies of local and regional self-government units elected from a list of a group of voters, independent lists or lists of a group of voters and candidates by: – foreign states, foreign political parties and foreign legal persons. By way of derogation from paragraph (1)(i) of this Article, the prohibition of financing political parties, independent MPs, members of the representative bodies of local and regional self-government units, independent lists or lists of a group of voters and candidates (by foreign states, foreign political parties and foreign legal persons whose core activity consists of education in the development and promotion of democratic principles) shall not apply to the financing of educational programmes. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016)
Is there a ban on corporate donations to political parties? No. Natural and legal persons may make donations to political parties, independent MPs and members of representative bodies of local and regional self-government units elected from a list of a group of voters and to independent lists or lists of a group of voters and candidates on a one-off basis or several times during the calendar year (Political Activity and Election Campaign Financing Act, Article 11, 2011, amended 2016)
Is there a ban on corporate donations to candidates? No. Natural and legal persons may make donations to political parties, independent MPs and members of representative bodies of local and regional self-government units elected from a list of a group of voters and to independent lists or lists of a group of voters and candidates on a one-off basis or several times during the calendar year (Political Activity and Election Campaign Financing Act, Article 11, 2011, amended 2016)
Is there a ban on donations from corporations with government contracts to political parties? Yes. Prohibition of income from governmental bodies, public enterprises, legal persons vested with public authority, companies and other legal persons in which the Republic of Croatia or any local and regional governmental unit has any interest or share (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on donations from corporations of partial government ownership to political parties? Yes. Prohibition of income from governmental bodies, public enterprises, legal persons vested with public authority, companies and other legal persons in which the Republic of Croatia or any local and regional governmental unit has any interest or share the law prohibits donations from corporations with partial government ownership to political parties. Article 22 of the Political Activity and Election Campaign Financing Act states that political parties and other political actors may not receive financing from companies and other legal persons in which the Republic of Croatia or any local or regional self-government unit has any interest or shares. This provision explicitly covers corporations in which the state or a local authority holds a stake, even if that ownership is only partial. Therefore, companies with partial government ownership are not allowed to make donations to political parties. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on donations from corporations with government contracts to candidates? Yes. the same rules apply for the donations of the parties that is applicable for the candidates the law establishes a ban on donations from certain corporations connected to the government to candidates. It provides that candidates, along with political parties and other political actors, may not receive financing from government bodies, public companies, legal persons vested with public authority, or companies and other legal persons in which the Republic of Croatia or any local or regional self-government unit has an interest or shares, as well as public institutions owned by these authorities. Consequently, corporations that are publicly owned, controlled, or vested with public authority are prohibited from donating to candidates under this provision. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on donations from corporations of partial government ownership to candidates? Yes. the same rules apply for the donations of the parties that is applicable for the candidates the law prohibits donations from corporations with partial government ownership to candidates. candidates, along with political parties and other political actors, may not receive financing from companies and other legal persons in which the Republic of Croatia or any local or regional self-government unit has any interest or shares. This means that corporations in which the state or a local authority holds any ownership stake, even partial, are barred from making donations to candidates. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on donations from Trade Unions to political parties? Yes. banned sources include labor unions and employer associations The law establishes a clear prohibition on donations from trade unions to political parties and other political actors. It states that political parties, independent MPs, local and regional representatives elected from voter lists, independent lists, and candidates may not receive financing from several ineligible sources, including labour unions or employer associations. Consequently, trade unions are explicitly barred from providing financial contributions to political parties or related political actors under this legal provision. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on donations from Trade Unions to candidates? Yes. the same rules apply for the donations of the parties that is applicable for the candidates the law prohibits donations from trade unions to candidates. The provision states that there shall be no financing of political parties, independent MPs, members of representative bodies of local and regional self-government units elected from voter lists, independent lists, lists of groups of voters, and candidates by several specified sources, including labour unions or employer associations. Therefore, trade unions are explicitly listed among the entities that are not allowed to finance these political actors, which means they are legally barred from making donations to candidates. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on anonymous donations to political parties? Yes. No donations shall be made by unidentified (anonymous) sources. Donations by unidentified (anonymous) sources shall be deemed to include donations made by donors whose details are unknown at the time of their payment or those made by donors who cannot be positively identified without additional action (e.g. donations via text messaging services, telephone answering machines, etc.). the law explicitly prohibits anonymous donations to political parties. It states that no donations shall be made by unidentified (anonymous) sources. The provision further clarifies that anonymous donations include contributions from donors whose identity is unknown at the time of payment or cannot be clearly established without additional action, such as donations made through text messaging services or telephone answering machines. Therefore, political parties and other political actors are not permitted to receive donations from anonymous donors under this law. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on anonymous donations to candidates? Yes. the same rules apply for the donations of the parties that is applicable for the candidates The law prohibits anonymous donations to candidates. It explicitly states that no donations shall be made by unidentified (anonymous) sources, meaning contributions from donors whose identity is unknown at the time of payment or cannot be clearly verified without additional action. This rule applies to all political actors covered by the provision, including political parties, independent MPs, members of local and regional representative bodies, independent lists, lists of groups of voters, and candidates. Therefore, candidates are not allowed to receive donations from anonymous sources. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016 Article 22, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)? Yes. There shall be no funding by government bodies, public companies, legal persons vested with public authority, companies and other legal persons in which the Republic of Croatia or any local and regional self-government unit has any interest or shares, as well as public and other institutions owned by the Republic of Croatia or any local and regional self-government unit; associations, trusts and foundations represented by central government officials, or local or regional officials; (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016)
Is there a ban on any other form of donation? Yes. Other banned sources include religious communities, humanitarian and other non-profit associations and organizations and natural and legal persons subject to any enforcement proceedings related to their outstanding debts due to the budget or their employees. (Political Activity and Election Campaign Financing Act, Art. 22, 2011, amended 2016)
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)? Yes. Within 1 year: HRK 30,000.00 (3,893.72€) by natural persons; HRK 200,000.00 (25,958.15€) by legal persons There is a clear limit on donations even outside of specific election periods. According to the text, the maximum amount a donor can contribute to a political party within a single calendar year depends on their legal status: Natural persons (individuals): May donate up to a total of HRK 30,000.00. Legal persons (entities/companies): May donate up to a total of HRK 200,000.00. Any amount received that exceeds these annual thresholds must be reported to the State Audit Office and the State Election Commission and subsequently paid into the state budget within 8 days of receipt. (Political Activity and Election Campaign Financing Act, Art 11, 2011, amended 2016 Article 11, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included)")
Is there a limit on the amount a donor can contribute to a political party in relation to an election? Yes. The total value of donations made by a legal person within a single calendar year shall not exceed (i) HRK 200,000.00 (two hundred thousand) when such donations are made to a political party or a candidate in elections for the President of the Republic of Croatia; (ii) HRK 100,000.00 (one hundred thousand) when such donations are made to an independent MP, an independent list or a candidate for national minority MP proposed by voters and national minority associations in the elections for members to the Croatian Parliament and the election of members to the European Parliament; and HRK 30,000.00 (thirty thousand) when such donations are made to an independent member of a representative body of a local and regional self government unit elected from a list of a group of voters and to a list of a group of voters or a candidate in elections at the local or regional level. For natural persons: HRK 30,000.00 (thirty thousand) in a single calendar year. | For legal persons: | (i) HRK 200,000.00 (two hundred thousand) when such donations are made to a political party or a candidate in elections for the President of the Republic of Croatia; | (ii) HRK 100,000.00 (one hundred thousand) when such donations are made to an independent MP, an independent list or a candidate for national minority MP proposed by voters and national minority associations in the elections for members to the Croatian Parliament and the election of members to the European Parliament; | and HRK 30,000.00 (thirty thousand) when such donations are made to an independent member of a representative body of a local and regional self-government unit elected from a list of a group of voters and to a list of a group of voters or a candidate in elections at the local or regional level. (Political Activity and Election Campaign Financing Act, Art 11, 2011, amended 2016 Article 11, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included)")
Is there a limit on the amount a donor can contribute to a candidate? Yes. same rules apply for the donations for parties that is applicable for the candidates; Within 1 year: HRK 30,000.00 (3,893.72€) by natural persons; HRK 200,000.00 (25,958.15€) by legal persons the law establishes specific limits on contributions to candidates, but the amount varies depending on whether the donor is an individual or a company, and the type of election involved. For Natural Persons (Individuals) The total value of donations to a candidate cannot exceed HRK 30,000.00 (approximately €3,981) per calendar year. For Legal Persons (Entities) The limits for companies are higher and depend on the office the candidate is seeking: Presidential Elections: Up to HRK 200,000.00 (approx. €26,545). Parliamentary or European Parliament Elections: Up to HRK 100,000.00 (approx. €13,272) for independent candidates or national minority candidates. Local or Regional Elections: Up to HRK 30,000.00 (approx. €3,981) for local-level candidates. Note: Any donation exceeding these amounts must be reported and paid into the state budget within 8 days of receipt. (Political Activity and Election Campaign Financing Act, Art 11, 2011, amended 2016 Article 11, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included)")

Public funding 

Eligibility criteria for direct public funding to political parties Yes. The funds required for the regular annual financing of political parties and independent MPs shall be secured in the state budget of the Republic of Croatia, and shall amount to 0.05% of operating expenses incurred as stated in the previously published annual budget execution report. Political parties having their members in the Croatian Parliament and independent MPs elected from independent lists shall be entitled to regular annual financing from the state budget. ( Political Activity and Election Campaign Financing Act, Art. 3 & 4, 2011, amended 2016)
Eligibility criteria for direct public funding to political parties: Share of votes in previous election Yes. There are extensive provisions in Article 18 on the recovery of costs from the state budget on the basis of vote share. They are too extensive to list but one is lilsted for illustrative purposes: The following shall be entitled to recover election campaign costs from the state budget of the Republic of Croatia: – candidates who receive a minimum of 10% of valid votes at elections for President of the Republic of Croatia; ( Political Activity and Election Campaign Financing Act, Art. 18 & 20, 2011, amended 2016)
Eligibility criteria for direct public funding to political parties: Representation in elected body Yes. The funds specified in Article 3 of this Act shall be allocated by setting an equal amount thereof for each MP or each member of the representative body of local and regional selfgovernment units, with each political party being entitled to receive any such funding as may be proportionate to the number of its MPs or members of the representative body at the time of the constitution of the Croatian Parliament or of the representative body of such local and regional self-government unit. The funds required to recover election campaign costs related to the election of members to the Croatian Parliament shall be allocated to political parties, independent lists and candidates for national minority MPs nominated by voters and national minority associations in proportion to the number of seats won in the Croatian Parliament. (Political Activity and Election Campaign Financing Act, Art. 5 & 20, 2011, amended 2016)
Eligibility criteria for direct public funding to political parties: Participation in election Yes. The funds specified in Article 3 of this Act shall be allocated by setting an equal amount thereof for each MP or each member of the representative body of local and regional selfgovernment units, with each political party being entitled to receive any such funding as may be proportionate to the number of its MPs or members of the representative body at the time of the constitution of the Croatian Parliament or of the representative body of such local and regional self-government unit. The funds required to recover election campaign costs related to the election of members to the Croatian Parliament shall be allocated to political parties, independent lists and candidates for national minority MPs nominated by voters and national minority associations in proportion to the number of seats won in the Croatian Parliament. (Political Activity and Election Campaign Financing Act, Art. 18, 2011, amended 2016)
Eligibility criteria for direct public funding to political parties: Number of candidates No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Share of seats in previous election Yes. The funds specified in Article 3 of this Act shall be allocated by setting an equal amount thereof for each MP or each member of the representative body of local and regional selfgovernment units, with each political party being entitled to receive any such funding as may be proportionate to the number of its MPs or members of the representative body at the time of the constitution of the Croatian Parliament or of the representative body of such local and regional self-government unit. The funds required to recover election campaign costs related to the election of members to the Croatian Parliament shall be allocated to political parties, independent lists and candidates for national minority MPs nominated by voters and national minority associations in proportion to the number of seats won in the Croatian Parliament. (Political Activity and Election Campaign Financing Act, Art. 18, 2011, amended 2016)
Eligibility criteria for direct public funding to political parties: Share of votes in next election No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Registration as a political party Yes. The text specifically identifies "political parties" as the primary entities entitled to receive both annual and campaign-related funding. ( Article 4, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Eligibility criteria for direct public funding to political parties: Share of seats in next election No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Number of members No. Absent from legal framework.
Eligibility criteria for direct public funding to political parties: Other Yes. The law includes unique provisions for national minorities, such as a 15% cost recovery for certain candidates who received over 15% of votes but were not elected. (Article 18, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Allocation calculations for direct public funding to political parties Yes. See subindicators
Allocation calculations for direct public funding to political parties: Proportional to votes received Yes. The funds required to recover election campaign costs related to elections for the President of the Republic of Croatia and elections for municipality heads, city mayors, county prefects and the mayor of the City of Zagreb and elections for deputy municipality heads, city mayors, and county prefects elected from among members of national minorities shall be allocated in proportion to votes received. (Political Activity and Election Campaign Financing Act, Art. 20, 2011, amended 2016)
Allocation calculations for direct public funding to political parties: Equal Yes. The funds specified in Article 3 of this Act shall be allocated by setting an equal amount thereof for each MP or each member of the representative body of local and regional selfgovernment units, with each political party being entitled to receive any such funding as may be proportionate to the number of its MPs or members of the representative body at the time of the constitution of the Croatian Parliament or of the representative body of such local and regional self-government unit. ( Political Activity and Election Campaign Financing Act, Art. 5, 2011, amended 2016)
Allocation calculations for direct public funding to political parties: Proportional to seats received Yes. The funds required to recover election campaign costs related to the election of members to the Croatian Parliament shall be allocated to political parties, independent lists and candidates for national minority MPs nominated by voters and national minority associations in proportion to the number of seats won in the Croatian Parliament. (Political Activity and Election Campaign Financing Act, Art. 20, 2011, amended 2016)
Allocation calculations for direct public funding to political parties: Flat rate by votes received No. The text describes calculations as "proportionate" to votes or seats, rather than a fixed "flat rate" per individual vote.
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed Yes. Article 18 (referenced by the context of Article 20) mentions the "recovery of election campaign costs," and Article 20 specifies how these recoverable funds are distributed among eligible parties. (Article 5, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included) Article 20, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Number of members No. Absent from legal framework.
Allocation calculations for direct public funding to political parties: Other Yes. There is a specific provision for national minority candidates who are not elected but receive over 15% of votes, allowing them to recover 15% of the costs normally allocated to an elected MP. (Article 5, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included) Article 20, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Earmarking provisions for direct public funding to political parties Yes. See subindicators
Earmarking provisions for direct public funding to political parties: Campaign spending Yes . election-related funds are paid specifically as a "reimbursement for the campaign," meaning they are earmarked to cover costs incurred during the election. (Article 2, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Earmarking provisions for direct public funding to political parties: Ongoing party activities No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Intra-party institution No. Absent from legal framework.
Earmarking provisions for direct public funding to political parties: Other No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties Yes. See subindicators
Allocation criteria for free or subsidized access to media for political parties: Equal Yes . The text mandates that public broadcasters (Croatian Television and Radio) enable all participants to present their programs. Specifically, for presidential elections, the law requires giving each candidate "equal time" and "equal conditions." (Political Activity and Election Campaign Financing Act, Art. 12, 2011, amended 2016)
Allocation criteria for free or subsidized access to media for political parties: Number of candidates No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Share of seats No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election No. Absent from legal framework.
Allocation criteria for free or subsidized access to media for political parties: Other Yes. There is a distinction between public and private media. While public broadcasters (HRT) have a legal obligation to provide access, private broadcasters "decide independently" whether and to what extent they will follow the campaign. ( Article 29, ACT ON THE ELECTION OF REPRESENTATIVES TO THE CROATIAN PARLIAMENT 2011 (consolidated text), with amendment in 2015)
Are there provisions for free or subsidized access to media for candidates? No. Absent from legal framework.
Are there provisions for any other form of indirect public funding? Yes. See subindicators
Provisions for any other form of indirect public funding: Premises for campaign meetings No. Absent from legal framework.
Provisions for any other form of indirect public funding: Space for campaign materials No. Absent from legal framework.
Provisions for any other form of indirect public funding: Tax relief Yes. With regard to their efforts strictly associated with their political activity, political parties shall not be subject to the payment of profit tax and value-added tax under the provisions of special laws, and may also be entitled to tax benefits under the provisions of a special law. (Political Activity and Election Campaign Financing Act, Art. 9, 2011, amended 2016)
Provisions for any other form of indirect public funding: Free or subsidised transport No. Absent from legal framework.
Provisions for any other form of indirect public funding: Free or subsidised postage cost No. Absent from legal framework.
Provisions for any other form of indirect public funding: Other Yes. The text mentions that parties may be entitled to "tax benefits under the provisions of a special law," which acts as a broad category for other indirect financial advantages not listed in the primary Act. (Article 9, POLITICAL ACTIVITY AND ELECTION CAMPAIGN FINANCING ACT (consolidated text) 2013, (with 2016 amendment included))
Is the provision of direct public funding to political parties related to gender equality among candidates? Yes. For each elected MP or member of the representative body of a local and regional self-government unit who belongs to an under-represented gender, political parties shall also be entitled to a bonus of 10% of the amount allocated for each MP or member of a representative body of such local and regional self-government unit referred to in Article 5(1) of this Act. (Political Activity and Election Campaign Financing Act, Art. 6, 2011, amended 2016)
Are there provisions for other financial advantages to encourage gender equality in political parties? No. Absent from legal framework.

Regulations on spending 

Is there a ban on vote buying? Yes. Whoever, by force, serious threat, bribery or in some other unlawful way, influences a voter to vote for or against a certain candidate in elections, or to vote for or against the recall of a candidate, or to vote for or against a certain proposal in a referendum, or not to vote at all, shall be punished by a fine or by imprisonment not exceeding one year (Criminal Code, Art. 116, No 110/​1997)
Are there bans on state resources being used in favour or against a political party or candidate? Yes. Funds from the state budget or from the budgets of local or regional self-government units which are otherwise used by candidates as officials of the Republic of Croatia or authorized local officials in the performance of their duties shall not be used for the purposes of election campaigns. ( Political Activity and Election Campaign Financing Act, Art. 16, 2011, amended 2016)
Are there limits on the amount a political party can spend? No. Absent from legal framework.
Are there limits on the amount a candidate can spend? Yes. The total amount of election campaign costs per candidate or per list of candidates shall not exceed the following amounts: – HRK 8,000,000.00 (eight million) in the case of elections for President of the Republic of Croatia; – HRK 1,500,000.00 (one million five hundred thousand) within a single constituency in the case of the election of MPs; – HRK 1,500,000.00 (one million five hundred thousand) in the case of the election of members to the European Parliament; – HRK 1,000,000.00 (one million) in the case of elections for the mayor of the City of Zagreb; – HRK 600,000.00 (six hundred thousand) in the case of elections for county prefect and mayor of major cities.– HRK 250,000.00 (two hundred and fifty thousand) in the case of elections for city and municipality head in local self-government units with a population exceeding 10,000; – HRK 100,000.00 (one hundred thousand) in the case of elections for city and municipal chief officials in local self-government units with populations from 3,001 to 10,000; – HRK 50,000.00 (fifty thousand) in the case of elections for mayor and municipality head in local self-government units with a population not exceeding 3,000. (Political Activity and Election Campaign Financing Act, Art. 17, 2011, amended 2016)

Reporting, oversight and sanctions 

Do political parties have to report regularly on their finances? Yes. Reports on donations shall be published by political parties on their website every six months. The control institution - General Audit of the Republic- also keeps public the financial reports of political parties & its own additional control analysis report. (Political Activity and Election Campaign Financing Act, Art. 26, 2011, amended 2016)
Do political parties have to report on their finances in relation to election campaigns? Yes. Political parties and leaders of independent lists or leaders of lists of a group of voters and candidates receiving any funds paid into their special accounts to finance their election campaigns shall, within the time limit specified in paragraph (5) of this Article, submit reports on donations received to finance their election campaigns and reports on their election campaign expenses, including information updated to the day of the submission thereof, to relevant electoral commissions. (Political Activity and Election Campaign Financing Act, Art. 24, 2011, amended 2016)
Do candidates have to report on their campaign finances? Yes. Political parties and leaders of independent lists or leaders of lists of a group of voters and candidates receiving any funds paid into their special accounts to finance their election campaigns shall, within the time limit specified in paragraph (5) of this Article, submit reports on donations received to finance their election campaigns and reports on their election campaign expenses, including information updated to the day of the submission thereof, to relevant electoral commissions. ( Political Activity and Election Campaign Financing Act, Art. 24, 2011, amended 2016)
Is information in reports from political parties and/​or candidates to be made public? Yes. Political parties, leaders of independent lists and leaders of lists of a groups of voters and candidates must publish the reports referred to in paragraph (5) of this Article on their websites, or on the website of the political party that proposed the candidate or in the daily press (for local elections, in the local press) not later than 48 hours following the expiry of the time limit referred to in paragraph (5) of this Article. (Political Activity and Election Campaign Financing Act, Art. 24, 2011, amended 2016)
Must reports from political parties and/​or candidates reveal the identity of donors? Yes. A report on donations shall contain information specifying each donor (personal or corporate name and address), the date when any donation was paid or when any product or service was provided free of charge, the amount of any donations paid or the market value of any donated product or service, specified on an invoice which is not subject to payment, and the type of each donation (Political Activity and Election Campaign Financing Act, Art. 24, 2011, amended 2016)
Institutions receiving financial reports from political parties and/​or candidates
Institutions receiving financial reports from political parties and/​or candidates: Electoral Management Board Yes. The State Election Commission (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institutions receiving financial reports from political parties and/​or candidates: Auditing agency Yes. The State Audit Office as noted above. (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institutions receiving financial reports from political parties and/​or candidates: Ministry No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Special institution No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Court No. Absent from legal framework.
Institutions receiving financial reports from political parties and/​or candidates: Other No. Absent from legal framework.
Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Ministry No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Auditing agency Yes. Election Commission, Audit Office (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body Yes. Election Commission, Audit Office (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose No. Absent from legal framework.
Institution responsible for examining financial reports and/or investigating violations: Other No. Absent from legal framework.
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Ministry No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Auditing agency Yes. Election Commission, Audit Office (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institutions with a formal role in political finance oversight: EMB Yes. Election Commission, Audit Office (Political Activity and Election Campaign Financing Act, Art. 27, 2011, amended 2016)
Institutions with a formal role in political finance oversight: Institution for this purpose No. Absent from legal framework.
Institutions with a formal role in political finance oversight: Other Yes. Croatian Parliament receives a report on supervising the financial operations of political parties entitled to financing from the State Budget. (Political Activity and Election Campaign Financing Act,Art. 32, 2011, amended 2016)
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines Yes. Numerous fines can be imposed for violations of the Political Activity and Election Campaign Financing Act. (Political Activity and Election Campaign Financing Act, Art. 43, 2011, amended 2016)
Sanctions for political finance infractions: Loss of public funding Yes. if political parties, independent MPs and members of representative bodies of local and regional self-government elected from a list of a group of voters fail to submit their annual financial statements, including the required enclosures, to the State Audit Office and the State Election Commission within the specified time limit as stipulated in Article 30 of this Act, the payment of funds for their regular annual financing from the state budget or from the budgets of local and regional self-government units shall be suspended. (Political Activity and Election Campaign Financing Act, Art. 41 and 42, 2011, amended 2016)
Sanctions for political finance infractions: Penal/Criminal No. Absent from legal framework.
Sanctions for political finance infractions: Forfeiture Yes. The administrative sanction of forfeiture of the right to recover election campaign costs shall be imposed on political parties, heads of independent lists or lists of a group of voters and candidates in various cases. (Political Activity and Election Campaign Financing Act, Art. 40, 2011, amended 2016)
Sanctions for political finance infractions: Deregistration of party No. Absent from legal framework.
Sanctions for political finance infractions: Loss of elected office No. Absent from legal framework.
Sanctions for political finance infractions: Suspension of political party No. Absent from legal framework.
Sanctions for political finance infractions: Loss of nomination of candidate No. Absent from legal framework.
Sanctions for political finance infractions: Loss of political rights No. Absent from legal framework.
Sanctions for political finance infractions: Other No. Absent from legal framework.

Legislation

Political Activity and Election Campaign Financing Act, 2011, amended 2016 (Croatian)pdf
Criminal Code, No 110/​1997 (English)pdf

*Last update: 2017

Financial Disclosure

Croatia has encompassing rules in place for financial disclosure, a large part of which are put in place by the Law on Conflicts of Interests (2003, last amended 2015). The Head of State, government Ministers, Members of Parliament, and Senior Civil Servants are subject to the same set of disclosure laws. These foresee a disclosure of real estate, movable assets with a per-item value above HRK 30,000, and all debt. Savings that exceed the annual net income of officials, income from assets and outside employment, and any relationships with the private sector must also be made available. Family members are included in the disclosure.

All enforcement and oversight falls on the Commission on the Prevention of Conflicts of Interests. An additional depository body exists only in the civil service, where company participation is declared to superiors. The Commission verifies the accuracy of statements, and makes decisions as to possible violations. Submitting disclosure statements is a pre-condition for receiving pay, and fines or administrative sanctions may be stipulated for late filling or non-filling. For Civil Servants, false disclosure may lead to the loss of office. The disclosure statements of high-level public officials are made public on the homepage of the Commission.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Disclosure items776969738986
Filing frequency9494949410088
Sanctions100100100100100100
Monitoring and Oversight88818181100100
Public access to declarations697575817562

Alternative Metric

201220152016201720202024Trend
Head of State929292929394
Ministers929292979394
Members of Parliament929292919394
Civil servants655959639366

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Disclosure items

Spouses and children included in disclosure Yes. The Head of State should declare assets of spouse and children under the age of 18. Officials should disclose business relations between the public body they hold office in and a company their close family member has more than 0.5 shares. (Articles 8.1 and 17.3 of the Law of Prevention of Interests Interest (adopted 2011, amended 2019))
Income and Assets
Real estate Yes. The Head of State should declare their real estate, inherited or acquired, within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Movable assets Yes. The Head of State should declare high value movable assets within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. High value movable assets include: vehicles, vessels, aircraft, working mechines,hunting weapons, art objects, jewellinery,valuable object for personal use,securities,animals/other acquired movables of a per-item value higher than HRK 30,000, with the exception of household objects and clothes. (Articles 8.7 and 8.8 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Cash Yes. The Head of State should declare their savings deposits if they exceed the annual net income of the officials within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Loans and Debts Yes. The Head of State should declare due payments/debts, assumed guarantees and other liabilities within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Article 8.7 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Income from outside employment/assets Yes. The Head of State should declare income from paid employment, income from self-employment, income from property and proprietary rights, income from capital, income fronm insurance and other income within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 9 and 13 (4) of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Incompatibilities
Gifts received as a public official Yes. The Head of State may only hold a symbolic gift of a value of up to HRK 500, any gifts exceeding this value cannot be retained. A gift in cash cannot be retained irrespective of the amount. (Article 11 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Private firm ownership and/or stock holdings Yes. The Head of State should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Shares in a private firm greater than 0.5% should be transferred to a trustee. The Head of State may not carry out any activity, such as regular and permanent occupation for renumeration. (Articles 8.7, 13 and 17 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Ownership of state-owned enterprises (SOEs) Yes. The Head of State should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Members of supervisory boards of companies with state ownership should be proposed to the General Assembly. (Articles 8.7 and 15 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Holding government contracts Yes. The head of state should transfer their voting rights in the private firm they own a share greater than 0.5% to a trustee. If such private firm enters a business relationship with the state, they should notify the Commission for the Resolution of Conflicts of Interest. A company in which the head of state has a share of 0.5% or more cannot enter into a business relationship with a public authority, in which the official holds office. (Article 16, Article 17 and Article 18 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Board member, advisor, or company officer of private firm Yes. The Head of State may not be a member of administrative bodies and supervisory boards of companies, administrative councils of institutions or supervisory boards of extrabudgetary funds, nor perform management affairs in business entities. (Article14 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Post-employment Yes. Within one year after termination of office the Head of State shall not accept the appointment or enter into an employment contract with a legal person with whom they have been in a business relationship during their mandate. (Article 20 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Simultaneously holding policy-making position and policy-executing position Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 13–15 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 13–15)
Participating in official decision-making processes that affect private interests Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 13–15 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5 and 7)
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Head of State shall disclose functions performed professionally or non-professionally prior to taking office, asset and income, as well as any significant changes in the assets during tenure, shares in private companies they own, business relations between public body they hold office in and a company their close family member has more than 0.5% shares in to the Commission within 30 days of taking office. (Article 8.1 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required upon leaving office Yes. The Head of State disclose their income and assets, as well as any significant changes in the assets during tenure to the Commission within 30 days of leaving office. (Article 8.2 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required annually Yes. Law on the Prevention of Conflict of Interest (amended 2021), Article 8 (Law on the Prevention of Conflict of Interest (amended 2021), Article 8)
Ad hoc filing required upon change in assets or conflicts of interest Yes. The Head of State is required to submit a report if during the course of holding office there was a significant change in the state of their assets. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, reprimand, suspension of payment of part of a net monthly salary up to the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Article 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Monitoring and Oversight

Depository body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will keep registers of conflict of interest information. The Commission’s investigative and enforcement powers were expanded, enabling more proactive verification and sanctioning. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Enforcement body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will make decisions regarding violations of the provisions of the Law. The Commission’s investigative and enforcement powers were expanded, enabling more proactive verification and sanctioning. (Articles 28-41 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying submission Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying the submissions. The Commission’s investigative and enforcement powers were expanded, enabling more proactive verification and sanctioning. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying accuracy Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying accuracy. The Commission’s investigative and enforcement powers were expanded, enabling more proactive verification and sanctioning. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Public access to declarations

Public availability Yes. The Commission can publish data on the income and assets of senior civil officials. Public access to declarations was broadened through expanded publication practices and online access. (Article 8.10 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019, amended 2021))
Timing of information release specified Yes. Law on the Prevention of Conflict of Interest (amended 2021), Article 8(10) (Law on the Prevention of Conflict of Interest (amended 2021), Article 8(10))
Location(s) of access specified Yes. Law on the Prevention of Conflict of Interest (amended 2021), Article 8(10) (Law on the Prevention of Conflict of Interest (amended 2021), Article 8(10))
Cost of access specified No. Absent from legal framework.

Ministers

Disclosure items

Spouses and children included in disclosure Yes. Ministers should declare assets of spouse and children under the age of 18. Officials should disclose business relations between the public body they hold office in and a company their close family member has more than 0.5 shares. (Articles 8.1 and 17.3 of the Law of Prevention of Interests Interest (adopted 2011, amended 2019))
Income and Assets
Real estate Yes. Ministers should declare their real estate, inherited or acquired within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Movable assets Yes. Ministers should declare high value movable assets within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. High value movable assets include: vehicles, vessels, aircraft, working mechines,hunting weapons, art objects, jewellinery,valuable object for personal use,securities,animals/other acquired movables of a per-item value higher than HRK 30,000, with the exception of household objects and clothes. (Articles 8.7 and 8.8 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Cash Yes. Ministers should declare their savings deposits if they exceed the annual net income of the officials within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Loans and Debts Yes. Ministers should declare due payments/debts, assumed guarantees and other liabilities within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Article 8.7 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Income from outside employment/assets Yes. Ministers should declare income from paid employment, income from self-employment, income from property and proprietary rights, income from capital, income fronm insurance and other income within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 9 and 13 (4) of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Incompatibilities
Gifts received as a public official Yes. Ministers may only hold a symbolic gift of a value of up to HRK 500, any gifts exceeding this value cannot be retained. A gift in cash cannot be retained irrespective of the amount. (Article 11 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Private firm ownership and/or stock holdings Yes. Ministers should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Shares in a private firm greater than 0.5% should be transferred to a trustee. Ministers may not carry out any activity, such as regular and permanent occupation for renumeration. (Articles 8.7, 13 and 17 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Ownership of state-owned enterprises (SOEs) Yes. Ministers should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Members of supervisory boards of companies with state ownership should be proposed to the General Assembly. (Articles 8.7 and 15 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Holding government contracts Yes. Ministers should transfer their voting rights in the private firm they own a share greater than 0.5% to a trustee. If such private firm enters a business relationship with the state, they should notify the Commission for the Resolution of Conflicts of Interest. A company in which the head of state has a share of 0.5% or more cannot enter into a business relationship with a public authority, in which the official holds office. (Article 16, Article 17 and Article 18 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Board member, advisor, or company officer of private firm Yes. Ministers may not be a members of administrative bodies and supervisory boards of companies, administrative councils of institutions or supervisory boards of extrabudgetary funds, nor perform management affairs in business entities. (Article14 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Post-employment Yes. Within one year after termination of office ministers shall not accept the appointment or enter into an employment contract with a legal person with whom they have been in a business relationship during their mandate. (Article 20 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Simultaneously holding policy-making position and policy-executing position Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41)
Participating in official decision-making processes that affect private interests Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–42)
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Ministers shall disclose functions performed professionally or non-professionally prior to taking office, asset and income, as well as any significant changes in the assets during tenure, shares in private companies they own, business relations between public body they hold office in and a company their close family member has more than 0.5% shares in to the Commission within 30 days of taking office. (Article 8.1 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required upon leaving office Yes. Ministers disclose their income and assets, as well as any significant changes in the assets during tenure to the Commission within 30 days of leaving office. (Article 8.2 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required annually Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41)
Ad hoc filing required upon change in assets or conflicts of interest Yes. Ministers are required to submit a report if during the course of holding office there was a significant change in the state of their assets. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, reprimand, suspension of payment of part of a net monthly salary up to the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Article 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Monitoring and Oversight

Depository body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will keep registers of conflict of interest information. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Enforcement body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will make decisions regarding violations of the provisions of the Law. (Articles 28-41 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying submission Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying the submissions. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying accuracy Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying accuracy. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Public access to declarations

Public availability Yes. The Commission can publish data on the income and assets of senior civil officials. (Article 8.10 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Timing of information release specified Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41)
Location(s) of access specified Yes. Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41 (Law on the Prevention of Conflict of Interest (amended 2021), Articles 5, 7, 8, 13–15, 21–41)
Cost of access specified No. Absent from legal framework.

Members of Parliament

Disclosure items

Spouses and children included in disclosure Yes. Members of Parliament should declare assets of spouse and children under the age of 18. Officials should disclose business relations between the public body they hold office in and a company their close family member has more than 0.5 shares. (Articles 8.1 and 17.3 of the Law of Prevention of Interests Interest (adopted 2011, amended 2019))
Income and Assets
Real estate Yes. Members of Parliament should declare their real estate, inherited or acquired, within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Movable assets Yes. Members of Parliament should declare high value movable assets within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. High value movable assets include: vehicles, vessels, aircraft, working mechines,hunting weapons, art objects, jewellinery,valuable object for personal use,securities,animals/other acquired movables of a per-item value higher than HRK 30,000, with the exception of household objects and clothes. (Articles 8.7 and 8.8 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Cash Yes. Members of Parliament should declare their savings deposits if they exceed the annual net income of the officials within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Loans and Debts Yes. Members of Parliament should declare due payments/debts, assumed guarantees and other liabilities within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Article 8.7 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Income from outside employment/assets Yes. Members of Parliament should declare income from paid employment, income from self-employment, income from property and proprietary rights, income from capital, income fronm insurance and other income within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 8.7 9 and 13.4 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Incompatibilities
Gifts received as a public official Yes. Members of Parliament may only hold a symbolic gift of a value of up to HRK 500, any gifts exceeding this value cannot be retained. A gift in cash cannot be retained irrespective of the amount. (Article 11 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Private firm ownership and/or stock holdings Yes. Members of Parliament should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Shares in a private firm greater than 0.5% should be transferred to a trustee. Members of Parliament may not carry out any activity, such as regular and permanent occupation for renumeration. (Articles 8.7, 13 and 17 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Ownership of state-owned enterprises (SOEs) Yes. Members of Parliament should disclose business relations between public body they hold office in and a company their close family member has more than 0.5 shares. They should also disclose their business shares and stocks in companies. Members of supervisory boards of companies with state ownership should be proposed to the General Assembly. (Articles 8.7 and 15 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Holding government contracts Yes. Members of Parliament should transfer their voting rights in the private firm they own a share greater than 0.5% to a trustee. If such private firm enters a business relationship with the state, they should notify the Commission for the Resolution of Conflicts of Interest. A company in which the head of state has a share of 0.5% or more cannot enter into a business relationship with a public authority, in which the official holds office. (Article 16, Article 17 and Article 18 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Board member, advisor, or company officer of private firm Yes. Memers of Parliament may not be a member of administrative bodies and supervisory boards of companies, administrative councils of institutions or supervisory boards of extrabudgetary funds, nor perform management affairs in business entities. (Article14 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Post-employment Yes. Within one year after termination of office the Members of Parliament shall not accept the appointment or enter into an employment contract with a legal person with whom they have been in a business relationship during their mandate. (Article 20 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Simultaneously holding policy-making position and policy-executing position Yes. Law on the Prevention of Conflict of Interest (amended 2021) (Law on the Prevention of Conflict of Interest (amended 2021))
Participating in official decision-making processes that affect private interests Yes. Law on the Prevention of Conflict of Interest (amended 2021) (Law on the Prevention of Conflict of Interest (amended 2021))
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Members of Parliament shall disclose functions performed professionally or non-professionally prior to taking office, asset and income, as well as any significant changes in the assets during tenure, shares in private companies they own, business relations between public body they hold office in and a company their close family member has more than 0.5% shares in to the Commission within 30 days of taking office. (Article 8.1 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required upon leaving office Yes. Members of Parliament disclose their income and assets, as well as any significant changes in the assets during tenure to the Commission within 30 days of leaving office. (Article 8.2 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required annually Yes. Law on the Prevention of Conflict of Interest (amended 2021) (Law on the Prevention of Conflict of Interest (amended 2021))
Ad hoc filing required upon change in assets or conflicts of interest Yes. Members of Parliament are required to submit a report if during the course of holding office there was a significant change in the state of their assets. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, reprimand, suspension of payment of part of a net monthly salary up to the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. (Article 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Monitoring and Oversight

Depository body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will keep registers of conflict of interest information. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Enforcement body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will make decisions regarding violations of the provisions of the Law. (Articles 28-41 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying submission Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying the submissions. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Some agency assigned responsibility for verifying accuracy Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying accuracy. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))

Public access to declarations

Public availability Yes. The Commission can publish data on the income and assets of senior civil officials. (Article 8.10 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Timing of information release specified Yes. Law on the Prevention of Conflict of Interest (amended 2021) (Law on the Prevention of Conflict of Interest (amended 2021))
Location(s) of access specified Yes. Law on the Prevention of Conflict of Interest (amended 2021) (Law on the Prevention of Conflict of Interest (amended 2021))
Cost of access specified No. Absent from legal framework.

Civil servants

Disclosure items

Spouses and children included in disclosure Yes. Senior civil servants must declare asset of spouse and children under the age of 18. A civil servant shall be obliged to submit a written report to his/her superior on any financial or other interest in which he/she, his/her spouse or partner, and a child may have in the decisions of the State body in which he/she is employed. (Articles 3.3 and 8.1 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019) Article 34 and Article 37 of the Law on Civil Servants (adopted 2000, last amended 2019))
Income and Assets
Real estate No. Senior civil servants should declare their real estate, inherited or acquired, within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 3.3, 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Movable assets No. Senior civil servants should declare high value movable assets within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. High value movable assets include: vehicles, vessels, aircraft, working mechines,hunting weapons, art objects, jewellinery,valuable object for personal use,securities,animals/other acquired movables of a per-item value higher than HRK 30,000, with the exception of household objects and clothes. (Articles 3.3, 8.7, 8.8 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Cash No. Senior civil servants should declare their savings deposits if they exceed the annual net income of the officials within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 3.3, 8.7 and 9 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Loans and Debts No. Senior civil servants should declare due payments/debts, assumed guarantees and other liabilities within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Article 3.3 and 8.7 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Income from outside employment/assets No. Senior civil servants should declare income from paid employment, income from self-employment, income from property and proprietary rights, income from capital, income fronm insurance and other income within 30 days of assuming and leaving office and upon being re-elected or re-appointed in the same office, or if significant change in the assets has occurred while in office or by the end of the year during which the change took place. (Articles 3.3, 8.7, 9 and 13 (4) of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019))
Incompatibilities
Gifts received as a public official Yes. A civil servant is prohibited from claiming and receiving gifts for personal benefit or for the benefit of the their family (Article 17 of the Law on Civil Servants (adopted 2000, last amended 2019))
Private firm ownership and/or stock holdings Yes. A civil servant shall not be permitted to open a trade or establish a company in the field of activity in which they are employed as a civil servant. Outside the normal working hours and upon approval by the appointing institution they may engage in business that does not constitute a conflict of interest or a barrier to the proper performance of regular duties. (Article 32 and 33 of the Law on Civil Servants (adopted 2000, last amended 2019))
Ownership of state-owned enterprises (SOEs) Yes. A civil servant shall not be permitted to open a trade or establish a company in the field of activity in which they are employed as a civil servant. Outside the normal working hours and upon approval by the appointing institution they may engage in business that does not constitute a conflict of interest or a barrier to the proper performance of regular duties. A civil servant may not carry out supervision over a company, in whose work they participate (Article 32, 33 and 35 of the Law on Civil Servants (adopted 2000, last amended 2019))
Holding government contracts No. Senior civil servants should transfer their voting rights in the private firm they own a share greater than 0.5% to a trustee. If such private firm enters a business relationship with the state, they should notify the Commission for the Resolution of Conflicts of Interest. A company in which the head of state has a share of 0.5% or more cannot enter into a business relationship with a public authority, in which the official holds office. (Article 3.3, Article 16, Article 17 and Article 18 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Board member, advisor, or company officer of private firm Yes. A civil servant shall not be a member of the managemnt or supervisory bodies of a company, if as a civil servant he exercises control over it (Article 35 of the Law on Civil Servants (adopted 2000, last amended 2019))
Post-employment Yes. Within one year after termination of office senior civil servants shall not accept the appointment or enter into an employment contract with a legal person with whom they have been in a business relationship during their mandate. Post-employment cooling-off restrictions were clarified and extended to better prevent revolving-door risks. (Article 3.3 and Article 20 of the Law on the Prevention of Conflict of Interest (adopted 2011, amended 2019 + ameded 2021) )
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. A civil servant should not make decision of take part in making decision affecting his financial interest or that of a spouse, partner, child or parent. (Article 37 of the Law on Civil Servants (adopted 2000, last amended 2019))
Concurrent employment of family members in public sector No. Absent from legal framework.

Filing frequency

Filing required upon taking office Yes. Senior civil servants shall disclose functions performed professionally or non-professionally prior to taking office, asset and income, as well as any significant changes in the assets during tenure, shares in private companies they own, business relations between public body they hold office in and a company their close family member has more than 0.5% shares in to the Commission within 30 days of taking office. On the day of commencing employment a civil servant is required to notify his superior in writing whether his spouse or extramarital partner, child, or parent perform the highest duties in a political party, professional association, commercial company, or other legal entity which is in a business relationship with the body in which the civil servant is commencing work, or over which the body exercises supervision. Initial disclosure obligations were strengthened and more clearly defined. (Article 3.3 and 8.1 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019 + ameded 2021) Article 34.4 of the Law on Civil Servants (adopted 2000, last amended 2019) )
Filing required upon leaving office No. Senior civil servants disclose their income and assets, as well as any significant changes in the assets during tenure to the Commission within 30 days of leaving office. (Article 8.2 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Filing required annually No. Absent from legal framework.
Ad hoc filing required upon change in assets or conflicts of interest Yes. The Head of State is required to submit a report if during the course of holding office there was a significant change in the state of their assets. Stronger obligation to report significant changes in assets or interests during tenure. (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019 + amended 2021))

Sanctions

Sanctions stipulated for late filing (fines, administrative, and/or criminal) Yes. A senior civil servant shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, reprimand, suspension of payment of part of a net monthly salary up to the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. The failure to submit on time a declaration of conflict of interest could be considered "failure to execute official obbligations" under Art. 99 of the Law on Civil Servants. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019) Article 99 of the Law on Civil Servants (adopted 2000, amended 2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal) Yes. An official shall not be able to receive a salary until they submit their declaration on assets and incomes to the Commission. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. The failure to submit a declaration of conflict of interest could be considered "failure to execute official obbligations" under Art. 99 of the Law on Civil Servants. (Articles 8, 10 and 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019) Article 99 of the Law on Civil Servants (adopted 2000, amended 2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal) Yes. Sanctions depend on the gravity of the violation of the act and would include proceedings against violators, warning, suspension of payment of part of a net monthly salary upto the amount from HRK 2,000 to 40,000 and for no longer than 12 months; official may be ask to remove the causes of the conflict of interest given the nature of the violation; public announcement can be published by the Commission about non-declaration. False disclosure could be considered "failure an improper execution of official duties" under Article 99 of the Law on Civil Servants (Article 42, 43 and 44 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019) Article 99 of the Law on Civil Servants (adopted 2000, amended 2019))

Monitoring and Oversight

Depository body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will keep registers of conflict of interest information. Civil servants submit their declarations of conflict of interest to their superior officer (Article 8 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019) Article 34 of the Law on Civil Servants (adopted 2000, amended 2019))
Enforcement body explicitly identified Yes. The Commission for Regulating Conflicts of Interest will make decisions regarding violations of the provisions of the Law. The superior officer shall examine the declaration of conflict of interest of the civil servant and report to the head of the public body, if needed. (Articles 28-41 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019) Article 34.5 of the Law on Civil Servants (adopted 2000, amended 2019))
Some agency assigned responsibility for verifying submission Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying the submissions. The Commission’s mandate was expanded to ensure more effective verification of both submission and accuracy. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019 + amended 2021))
Some agency assigned responsibility for verifying accuracy Yes. The Commission for Regulating Conflicts of Interest takes all necessary measures for verifying the submissions. The Commission’s mandate was expanded to ensure more effective verification of both submission and accuracy. (Articles 21-27 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019 + amended 2021))

Public access to declarations

Public availability Yes. The Commission can publish data on the income and assets of senior civil servants. (Article 3.3 and8.10 of the Law on the Prevention of Conflicts of Interest (adopted 2011, amended 2019))
Timing of information release specified No. Absent from legal framework.
Location(s) of access specified No. Absent from legal framework.
Cost of access specified No. Absent from legal framework.

Legislation

Law on Prevention of Conflicts of Interest of 2011_CRO (Croatian)pdf
Law on Civil Servants of 2005_CRO (Croatian)pdf

*Last update: 2017

Conflict of Interest

The Law on the Prevention of Conflicts of Interests (2011, last amended 2015) defines preventing conflicts of interests as being able to impartially put public interests above private interests. Ministers and Members of Parliament may not accept gifts valued above HRK 500 from the same donor, and may not be part of supervisory or managerial bodies of private companies. If they own shares in a private company of 0.5% or more, they must transfer their consequential management rights to another person for the duration of their mandate. The Constitution (1990, last amended 2010) does not allow the President to follow any other professional activity. For one year after the end of their mandate, the President, Ministers, and MPs may not be part of a supervisory or managerial body in companies, and must continue to submit disclosure statements. The Civil Servants Act (2000, last amended 2015) restricts civil servants from owning a private or public firm and holding government contracts. There is no law stating that any officials must abstain from decisions that affect private interests.

In case of violation, the President, Ministers and MPs face fines or administrative sanctions. As in the rules governing conflicts of interests, the monitoring, guidance, and enforcement of these laws fall on the Commission on the Prevention of Conflicts of Interests. Civil servants, instead, can only be subject to administrative sanctions. The Law does not specify any monitoring body, while appointing the chief executive of the State for the enforcement of the law.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Restrictions527777808290
Sanctions674242424275
Monitoring and Oversight50888888100100

Alternative Metric

201220152016201720202024Trend
Head of State496060606389
Ministers628282828689
Members of Parliament527979828689
Civil servants625454546487

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Head of State

Restrictions

General restriction on conflict of interest Yes. In exercising public office, officials shall not place their private interest above the public interest. A conflict of interest exists when the private interests of officials in the public interest, in particular when the private interest of the official affects his/her impartiality in the performance of his/her public duties, or: a) it may reasonably be considered that the private interest of the official affects his/her impartiality in the performance of his/her public duties; or b) the private interest of the official may affect his/her impartiality in the performance of his public duties. "Officials" in the context of the Law also includes the President. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 2 and 3 (1) 1.)
Accepting gifts Yes. A gift in the sense of the Law on Prevention of Conflicts of Interest is considered to be money, things regardless of their value, rights and services given without compensation that bring or can bring an official into a relationship of dependence or create an obligation to the donor. Ordinary gifts between family members, relatives and friends, as well as national and international recognitions, decorations and awards, shall not be considered gifts in the sense of this Act. An official may retain only a gift of symbolic value, up to a maximum of HRK 500.00 from the same donor. An official may not receive the previously referred gift when it is in cash, regardless of the amount, and the security and precious metal. Gifts of a protocol nature exceeding the amount of HRK 500.00 and other gifts that the official does not keep when he is entitled to it, are the property of the Republic of Croatia. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 11 Regulation on Gifts Received by Officials of 2004 (as of 2020), Arts. 2 and 3)
Private firm ownership and/or stock holdings Yes. An official who holds 0.5% or more of shares, ie shares in the ownership (capital of a company), during the performance of public office shall transfer his/her management rights based on the share in the capital of the company to another person, except for persons referred to in Article 4 (5) of the Law on Prevention of Conflicts of Interest of 2011, or a special body. That person, ie a special body (commissioner), shall act with regard to the exercise of membership rights and shares in the company in his own name, and on behalf of the official. While management rights in companies have been transferred to another person or a special body, the official may not give information, instructions, orders or otherwise be related to that person or body and thus affect the exercise of rights and fulfillment obligations arising from membership rights in those societies. The official has the right to be informed once a year about the state of the companies in which he has shares. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 16)
Ownership of state-owned enterprises (SOEs) Yes. The same shareholding restriction applies in 2024 to any company, including an SOE: if an office-holder holds 0.5% or more of shares or capital, they must transfer management rights in that company to another person or a special body while in office. (Zakon o sprječavanju sukoba interesa, Art. 16(1), NN 143/2021, as amended by NN 36/2024.)
Holding government contracts Yes. The rule is not a blanket personal ban on all contracts: a company in which the office-holder holds 0.5% or more may not enter into a business relationship with the public body in which the office-holder serves, and similar limits apply to certain family-held shares. (Zakon o sprječavanju sukoba interesa, Arts. 17(1)-(2) and 18(1)-(2), NN 143/2021, as amended by NN 36/2024.)
Board member, advisor, or company officer of private firm Yes. Officials may not be members of the administrative bodies and supervisory boards of companies, management boards of institutions, ie supervisory boards of extra-budgetary funds, nor perform management tasks in business entities. Exceptionally, officials may be members of up to two administrative councils of institutions, ie supervisory boards of extra-budgetary funds that are of special state interest or are of special interest to a unit of local or regional self-government, unless otherwise provided by a special law. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 14 Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 96)
Post-employment Yes. An official may not, within one year after leaving office, accept an appointment or election or enter into an employment contract with a legal person who was in a business relationship during the official's term, or when at the time of appointment, election or conclusion of the contract, in all circumstances of the case, it is clear that the official intends to enter into a business relationship with the body in which s/he held office. The legal person may not appoint or elect an official or enter into an employment contract with the official within one year from the termination of office. Obligations arising from an official referred to in Arts. 7, 8, 9, 14 and 17 of the Law on Prevention of Conflicts of Interest shall begin on the day of taking office and shall last for twelve months from the day of termination of office. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 20)
Simultaneously holding policy-making position and policy-executing position Yes. The President of the Republic shall not perform any other public or professional duty. (Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 96)
Participating in official decision-making processes that affect private interests Yes. After election or appointment to public office, the official is obliged to regulate his private affairs in order to prevent a foreseeable conflict of interest, and if such a conflict arises, the official is obliged to resolve it so as to protect the public interest. In case of doubt about a possible conflict of interest, the official is obliged to do everything necessary to separate the private from the public interest. Additionally, officials are prohibited from using their position to influence the decision of the legislature, the executive or the judiciary in order to obtain personal gain or the gain of a related person, a privilege or right, enter into a legal transaction or otherwise benefit himself or another related person (family members or friends). (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 6 (4) and 7 (h))
Assisting family or friends in obtaining employment in public sector Yes. Officials are prohibited from promising employment, or some other right in exchange for a gift or promise of a gift, and from influencing the acquisition of jobs or public procurement contracts. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 7 (f) (i))

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. A fine in the amount of HRK 5,000.00 of HRK 50,000.00 shall be imposed on an official who, within one year of leaving office, accepts an appointment or election or enters into a contract by which he enters into employment with a legal person who had a business relationship with the official during the official's term in office. Conversely, a fine in the amount of HRK 50,000.00 to 1,000,000.00 shall be imposed on a legal person who, contrary to the provisions of Article 20 of this Law, appoints or elects an official or enters into an employment contract with him, within one year of leaving office. In addition, a fine in the amount of HRK 50,000.00 to HRK 500,000.00 shall be imposed on a legal person referred to in Article 16 (1) of the Law who fails to notify the Commission of its entry into a business relationship through a public tender or otherwise with state bodies or with units of local or regional self-government or with companies in which the Republic of Croatia or a unit of local or regional self-government has a management share. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 49 and 50)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. For violation of the provisions of the Law on Prevention of Conflicts of Interest of 2011, the Commission may impose the following sanctions on the persons referred to in Article 3: 1. warning; 2. suspension of payment of part of the net monthly salary; 3. public announcement of the decision of the Commission. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 42, 43 and 44)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. The President of the Republic shall enjoy immunity. The President of the Republic shall not be detained nor shall any criminal prosecution be instigated against him/her without prior approval by the Constitutional Court. The President of the Republic may be detained without approval from the Constitutional Court only if he/she has been caught in the perpetration of a criminal offence carrying a sentence of imprisonment exceeding five years. (Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 106)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. For the purpose of implementing the Law, a Commission to decide on conflicts of interest shall be established. The Commission is a permanent, independent and autonomous state body. Any form of influence on the work of the Commission that could jeopardize its autonomy and independence in making decisions within its scope of work is prohibited. Among the Commission's responsibilities are: a) initiating proceedings of conflict of interest and making decisions on whether a certain action or omission of an official constitutes a violation of the provisions of the Law; b) verification of data from the report on the assets of officials; c) development of guidelines and instructions to officials in order to effectively prevent conflicts of interest; d) regular training of officials in matters of conflict of interest and reporting on assets; e) cooperation with the competent body for drafting the law in the field of prevention of conflicts of interest of officials and submission of initiatives to the competent bodies for proposing amendments to the law; f) cooperation with non-governmental organizations and realization of international cooperation in the field of prevention of conflicts of interest. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 28 and 30)
Enforcement body specified (sanctions, hearings) Yes. Among the Commission's responsibilities are: a) initiating proceedings of conflict of interest and making decisions on whether a certain action or omission of an official constitutes a violation of the provisions of the Law; b) verification of data from the report on the assets of officials; c) development of guidelines and instructions to officials in order to effectively prevent conflicts of interest; d) regular training of officials in matters of conflict of interest and reporting on assets; e) cooperation with the competent body for drafting the law in the field of prevention of conflicts of interest of officials and submission of initiatives to the competent bodies for proposing amendments to the law; f) cooperation with non-governmental organizations and realization of international cooperation in the field of prevention of conflicts of interest. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 28 and 30)

Ministers

Restrictions

General restriction on conflict of interest Yes. In exercising public office, officials shall not place their private interest above the public interest. A conflict of interest exists when the private interests of officials in the public interest, in particular when the private interest of the official affects his/her impartiality in the performance of his/her public duties, or: a) it may reasonably be considered that the private interest of the official affects his/her impartiality in the performance of his/her public duties; or b) the private interest of the official may affect his/her impartiality in the performance of his public duties. "Officials" in the context of the Law also includes Ministers in the Government of the Republic of Croatia. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 2 and 3 (1) 4.)
Accepting gifts Yes. A gift in the sense of the Law on Prevention of Conflicts of Interest is considered to be money, things regardless of their value, rights and services given without compensation that bring or can bring an official into a relationship of dependence or create an obligation to the donor. Ordinary gifts between family members, relatives and friends, as well as national and international recognitions, decorations and awards, shall not be considered gifts in the sense of this Act. An official may retain only a gift of symbolic value, up to a maximum of HRK 500.00 from the same donor. An official may not receive the previously referred gift when it is in cash, regardless of the amount, and the security and precious metal. Gifts of a protocol nature exceeding the amount of HRK 500.00 and other gifts that the official does not keep when he is entitled to it, are the property of the Republic of Croatia. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 11 Regulation on Gifts Received by Officials of 2004 (as of 2020), Arts. 2 and 3)
Private firm ownership and/or stock holdings Yes. An official who holds 0.5% or more of shares, ie shares in the ownership (capital of a company), during the performance of public office shall transfer his/her management rights based on the share in the capital of the company to another person, except for persons referred to in Article 4 (5) of the Law on Prevention of Conflicts of Interest of 2011, or a special body. That person, ie a special body (commissioner), shall act with regard to the exercise of membership rights and shares in the company in his own name, and on behalf of the official. While management rights in companies have been transferred to another person or a special body, the official may not give information, instructions, orders or otherwise be related to that person or body and thus affect the exercise of rights and fulfillment obligations arising from membership rights in those societies. The official has the right to be informed once a year about the state of the companies in which he has shares. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 16)
Ownership of state-owned enterprises (SOEs) Yes. If a minister holds 0.5% or more of shares or capital, the minister must transfer management rights in that company to another person or special body while in office. (Zakon o sprječavanju sukoba interesa, Art. 16(1), NN 143/2021, as amended by NN 36/2024)
Holding government contracts Yes. Acompany in which the minister holds 0.5% or more may not enter into a business relationship with the public body in which the minister serves, and similar limits apply to certain family-held shares. (Zakon o sprječavanju sukoba interesa, Arts. 17(1)-(2) and 18(1)-(2), NN 143/2021, as amended by NN 36/2024.)
Board member, advisor, or company officer of private firm Yes. Officials may not be members of the administrative bodies and supervisory boards of companies, management boards of institutions, ie supervisory boards of extra-budgetary funds, nor perform management tasks in business entities. Exceptionally, officials may be members of up to two administrative councils of institutions, ie supervisory boards of extra-budgetary funds that are of special state interest or are of special interest to a unit of local or regional self-government, unless otherwise provided by a special law. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 14 Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 109)
Post-employment Yes. For 18 months after leaving office, a former office-holder may not accept a management post, employment, election, appointment, or contract with a legal entity that had business relations with, or was supervised by, the authority where the office-holder served, unless the Commission consents. GRECO confirmed this 2021-law rule in its 2024 compliance report. (Zakon o sprječavanju sukoba interesa, Art. 23(2), NN 143/2021, as amended by NN 36/2024; GRECO Fifth Round 2nd Compliance Report on Croatia (2024).)
Simultaneously holding policy-making position and policy-executing position Yes. The Prime Minister and the members of the Government may not perform any other public or professional duty without consent of the Government. (Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 109)
Participating in official decision-making processes that affect private interests Yes. After election or appointment to public office, the official is obliged to regulate his private affairs in order to prevent a foreseeable conflict of interest, and if such a conflict arises, the official is obliged to resolve it so as to protect the public interest. In case of doubt about a possible conflict of interest, the official is obliged to do everything necessary to separate the private from the public interest. Additionally, officials are prohibited from using their position to influence the decision of the legislature, the executive or the judiciary in order to obtain personal gain or the gain of a related person, a privilege or right, enter into a legal transaction or otherwise benefit himself or another related person (family members or friends). (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 6 (4) and 7 (h))
Assisting family or friends in obtaining employment in public sector Yes. Officials are prohibited from promising employment, or some other right in exchange for a gift or promise of a gift, and from influencing the acquisition of jobs or public procurement contracts. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 7 (f) (i))

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. A fine in the amount of HRK 5,000.00 of HRK 50,000.00 shall be imposed on an official who, within one year of leaving office, accepts an appointment or election or enters into a contract by which he enters into employment with a legal person who had a business relationship with the official during the official's term in office. Conversely, a fine in the amount of HRK 50,000.00 to 1,000,000.00 shall be imposed on a legal person who, contrary to the provisions of Article 20 of this Law, appoints or elects an official or enters into an employment contract with him, within one year of leaving office. In addition, a fine in the amount of HRK 50,000.00 to HRK 500,000.00 shall be imposed on a legal person referred to in Article 16 (1) of the Law who fails to notify the Commission of its entry into a business relationship through a public tender or otherwise with state bodies or with units of local or regional self-government or with companies in which the Republic of Croatia or a unit of local or regional self-government has a management share. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 49 and 50)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. For violation of the provisions of the Law on Prevention of Conflicts of Interest of 2011, the Commission may impose the following sanctions on the persons referred to in Article 3: 1. warning; 2. suspension of payment of part of the net monthly salary; 3. public announcement of the decision of the Commission. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 42, 43 and 44)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Absent from legal framework.

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The Commission for the Resolution of Conflicts of Interest verifies asset declarations, may require explanations and evidence from officials, and may request information and evidence from competent authorities without delay. GRECO reported these powers as implemented. (Zakon o sprječavanju sukoba interesa, Arts. 12(3)-(4), 28(1), 30, 32, NN 143/2021, as amended by NN 36/2024; GRECO Fifth Round 2nd Compliance Report on Croatia (2024).)
Enforcement body specified (sanctions, hearings) Yes. Among the Commission's responsibilities are: a) initiating proceedings of conflict of interest and making decisions on whether a certain action or omission of an official constitutes a violation of the provisions of the Law; b) verification of data from the report on the assets of officials; c) development of guidelines and instructions to officials in order to effectively prevent conflicts of interest; d) regular training of officials in matters of conflict of interest and reporting on assets; e) cooperation with the competent body for drafting the law in the field of prevention of conflicts of interest of officials and submission of initiatives to the competent bodies for proposing amendments to the law; f) cooperation with non-governmental organizations and realization of international cooperation in the field of prevention of conflicts of interest. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 28 and 30)

Members of Parliament

Restrictions

General restriction on conflict of interest Yes. In exercising public office, officials shall not place their private interest above the public interest. A conflict of interest exists when the private interests of officials in the public interest, in particular when the private interest of the official affects his/her impartiality in the performance of his/her public duties, or: a) it may reasonably be considered that the private interest of the official affects his/her impartiality in the performance of his/her public duties; or b) the private interest of the official may affect his/her impartiality in the performance of his public duties. "Officials" in the context of the Law also includes the President. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 2 and 3 (1) 1.)
Accepting gifts Yes. A gift in the sense of the Law on Prevention of Conflicts of Interest is considered to be money, things regardless of their value, rights and services given without compensation that bring or can bring an official into a relationship of dependence or create an obligation to the donor. Ordinary gifts between family members, relatives and friends, as well as national and international recognitions, decorations and awards, shall not be considered gifts in the sense of this Act. An official may retain only a gift of symbolic value, up to a maximum of HRK 500.00 from the same donor. An official may not receive the previously referred gift when it is in cash, regardless of the amount, and the security and precious metal. Gifts of a protocol nature exceeding the amount of HRK 500.00 and other gifts that the official does not keep when he is entitled to it, are the property of the Republic of Croatia. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 11 Regulation on Gifts Received by Officials of 2004 (as of 2020), Arts. 2 and 3)
Private firm ownership and/or stock holdings Yes. An official who holds 0.5% or more of shares, ie shares in the ownership (capital of a company), during the performance of public office shall transfer his/her management rights based on the share in the capital of the company to another person, except for persons referred to in Article 4 (5) of the Law on Prevention of Conflicts of Interest of 2011, or a special body. That person, ie a special body (commissioner), shall act with regard to the exercise of membership rights and shares in the company in his own name, and on behalf of the official. While management rights in companies have been transferred to another person or a special body, the official may not give information, instructions, orders or otherwise be related to that person or body and thus affect the exercise of rights and fulfillment obligations arising from membership rights in those societies. The official has the right to be informed once a year about the state of the companies in which he has shares. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 16)
Ownership of state-owned enterprises (SOEs) Yes. If an MP holds 0.5% or more of shares or capital, the MP must transfer management rights in that company to another person or special body while in office (Zakon o sprječavanju sukoba interesa, Art. 16(1), NN 143/2021, as amended by NN 36/2024)
Holding government contracts Yes. a company in which the MP holds 0.5% or more may not enter into a business relationship with the public body in which the MP serves, and similar limits apply to certain family-held shares. (Zakon o sprječavanju sukoba interesa, Arts. 17(1)-(2) and 18(1)-(2), NN 143/2021, as amended by NN 36/2024)
Board member, advisor, or company officer of private firm Yes. Officials may not be members of the administrative bodies and supervisory boards of companies, management boards of institutions, ie supervisory boards of extra-budgetary funds, nor perform management tasks in business entities. Exceptionally, officials may be members of up to two administrative councils of institutions, ie supervisory boards of extra-budgetary funds that are of special state interest or are of special interest to a unit of local or regional self-government, unless otherwise provided by a special law. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 14)
Post-employment Yes. An official may not, within one year after leaving office, accept an appointment or election or enter into an employment contract with a legal person who was in a business relationship during the official's term, or when at the time of appointment, election or conclusion of the contract, in all circumstances of the case, it is clear that the official intends to enter into a business relationship with the body in which s/he held office. The legal person may not appoint or elect an official or enter into an employment contract with the official within one year from the termination of office. Obligations arising from an official referred to in Arts. 7, 8, 9, 14 and 17 of the Law on Prevention of Conflicts of Interest shall begin on the day of taking office and shall last for twelve months from the day of termination of office. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 20)
Simultaneously holding policy-making position and policy-executing position Yes. A Member of Parliament may not be a judge of the Constitutional Court of the Republic of Croatia, a judge, an ombudsman, a deputy ombudsman, an ombudsman, a president or deputy prime minister of the Republic of Croatia, a Deputy Minister or another member of the Government of the Republic of Croatia, Deputy Minister, Director of State Administrative Organization, Deputy, Director of State Administrative Organization, Secretary of the Government of the Republic of Croatia, Chief Secretary of the Ministry, Head of Office and Director of the Government of the Republic of Croatia for Council for national security, ambassador, consul general, prefect or deputy prefect, mayor or deputy mayor of the City of Zagreb, active military personnel, officers and employees of the Armed Forces, a member of the management board of a company, institution and extrabudgetary fund predominantly state-owned. (Law on Elections of Representatives to the Croatian National Parliament of 1999, as amended in 2019, Art. 9)
Participating in official decision-making processes that affect private interests Yes. After election or appointment to public office, the official is obliged to regulate his private affairs in order to prevent a foreseeable conflict of interest, and if such a conflict arises, the official is obliged to resolve it so as to protect the public interest. In case of doubt about a possible conflict of interest, the official is obliged to do everything necessary to separate the private from the public interest. Additionally, officials are prohibited from using their position to influence the decision of the legislature, the executive or the judiciary in order to obtain personal gain or the gain of a related person, a privilege or right, enter into a legal transaction or otherwise benefit himself or another related person (family members or friends). (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 6 (4) and 7 (h))
Assisting family or friends in obtaining employment in public sector Yes. Officials are prohibited from promising employment, or some other right in exchange for a gift or promise of a gift, and from influencing the acquisition of jobs or public procurement contracts. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Art. 7 (f) (i))

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. A fine in the amount of HRK 5,000.00 of HRK 50,000.00 shall be imposed on an official who, within one year of leaving office, accepts an appointment or election or enters into a contract by which he enters into employment with a legal person who had a business relationship with the official during the official's term in office. Conversely, a fine in the amount of HRK 50,000.00 to 1,000,000.00 shall be imposed on a legal person who, contrary to the provisions of Article 20 of this Law, appoints or elects an official or enters into an employment contract with him, within one year of leaving office. In addition, a fine in the amount of HRK 50,000.00 to HRK 500,000.00 shall be imposed on a legal person referred to in Article 16 (1) of the Law who fails to notify the Commission of its entry into a business relationship through a public tender or otherwise with state bodies or with units of local or regional self-government or with companies in which the Republic of Croatia or a unit of local or regional self-government has a management share. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 49 and 50)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. For violation of the provisions of the Law on Prevention of Conflicts of Interest of 2011, the Commission may impose the following sanctions on the persons referred to in Article 3: 1. warning; 2. suspension of payment of part of the net monthly salary; 3. public announcement of the decision of the Commission. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 42, 43 and 44)
Penal sanctions are stipulated for violations of COI regulations restricting behavior No. Deputies in the Croatian Parliament shall enjoy immunity. No deputy shall be held criminally liable, detained or sentenced for an opinion expressed or a vote cast in the Croatian Parliament. No deputy shall be detained nor shall any criminal proceeding be instigated against him/her without approval by the Croatian Parliament. A deputy may be detained without approval from the Croatian Parliament only if he/she has been caught in the perpetration of a criminal offence carrying a sentence of imprisonment exceeding five years. In such a case, the Speaker of the Croatian Parliament shall be notified thereof. If the Croatian Parliament is not in session, approval for the detention of its deputy or the continuation of criminal prosecution against him/her shall be given and the decision on his/her right to immunity shall be made by the Credentials and Privileges Commission, subject to its subsequent confirmation by the Croatian Parliament. (Constitution of the Republic of Croatia of 1990 (as of 2020), Art. 76)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. For the purpose of implementing the Law, a Commission to decide on conflicts of interest shall be established. The Commission is a permanent, independent and autonomous state body. Any form of influence on the work of the Commission that could jeopardize its autonomy and independence in making decisions within its scope of work is prohibited. Among the Commission's responsibilities are: a) initiating proceedings of conflict of interest and making decisions on whether a certain action or omission of an official constitutes a violation of the provisions of the Law; b) verification of data from the report on the assets of officials; c) development of guidelines and instructions to officials in order to effectively prevent conflicts of interest; d) regular training of officials in matters of conflict of interest and reporting on assets; e) cooperation with the competent body for drafting the law in the field of prevention of conflicts of interest of officials and submission of initiatives to the competent bodies for proposing amendments to the law; f) cooperation with non-governmental organizations and realization of international cooperation in the field of prevention of conflicts of interest. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 28 and 30)
Enforcement body specified (sanctions, hearings) Yes. Among the Commission's responsibilities are: a) initiating proceedings of conflict of interest and making decisions on whether a certain action or omission of an official constitutes a violation of the provisions of the Law; b) verification of data from the report on the assets of officials; c) development of guidelines and instructions to officials in order to effectively prevent conflicts of interest; d) regular training of officials in matters of conflict of interest and reporting on assets; e) cooperation with the competent body for drafting the law in the field of prevention of conflicts of interest of officials and submission of initiatives to the competent bodies for proposing amendments to the law; f) cooperation with non-governmental organizations and realization of international cooperation in the field of prevention of conflicts of interest. (Law on Prevention of Conflicts of Interest of 2011 (as of 2020), Arts. 28 and 30)

Civil servants

Restrictions

General restriction on conflict of interest Yes. In the performance of their civil service duties, civil servants shall not abuse their authority and position in order to acquire any financial or other gains for themselves or any other natural or legal person. Civil servants shall not use any official information concerning the activities and operations of the governmental bodies where they are employed for unauthorized purposes, nor shall they disclose any official secrets that may come to their knowledge during the performance of their duties. Civil servants shall not exploit their position to influence any decision of the legislature, executive or judiciary, or the adoption of any political decision. (Code of Ethics for Civil Servants of 2011 (as of 2020), Art. 9)
Accepting gifts Yes. A civil servant is prohibited from requesting or receiving gifts for personal gain, the benefit of a family or an organization, for the purpose of a favorable settlement of the subject of administrative or other proceedings. A civil servant may not offer or give gifts or other benefits to another civil servant, his relative or a spouse or extramarital partner, for the purpose of achieving his own benefit. (Law on Civil Servants of 2005, as amended in 2019, Arts. 17 and 18)
Private firm ownership and/or stock holdings Yes. A civil servant is not allowed to open a trade or establish a company or other legal entity in the field of activity in which s/he is employed as a civil servant, or in the field of activity related to activities within the scope of the body in which s/he is employed. A civil servant may not be a member of the administrative or supervisory body of a company, if the body in which s/he is employed supervises the company. Within the performance of official duties, a civil servant may not exercise supervision over a company or other legal entity in whose work s/he participates. A civil servant shall be obliged to inform the superior official in writing about the ownership of shares and bonds or financial and other interests in companies according to which the body in which he works performs administrative tasks, which could be a cause of conflict of interest. (Law on Civil Servants of 2005, as amended in 2019, Arts. 32, 34 (3) and 35)
Ownership of state-owned enterprises (SOEs) No. Absent from legal framework.
Holding government contracts No. No specific provision concerning the possibility of holding a government contract (public contract/procurement) applies. The only relevant provision merely stipulates that a civil servant may, outside regular working hours, with the previously obtained approval of the head of a state body, perform tasks or provide services to a legal or natural person, only if the state body in which the natural or legal person is located does not perform supervision or if such work is not prohibited by a special law, and does not represent a conflict of interest or an obstacle to the proper performance of regular tasks or damage the reputation of the civil service. (Law on Civil Servants of 2005, as amended in 2019, Art. 33)
Board member, advisor, or company officer of private firm Yes. A civil servant is not allowed to open a trade or establish a company or other legal entity in the field of activity in which s/he is employed as a civil servant, or in the field of activity related to activities within the scope of the body in which s/he is employed. A civil servant may not be a member of the administrative or supervisory body of a company, if the body in which s/he is employed supervises the company. Within the performance of official duties, a civil servant may not exercise supervision over a company or other legal entity in whose work s/he participates. A civil servant shall be obliged to inform the superior official in writing about the ownership of shares and bonds or financial and other interests in companies according to which the body in which he works performs administrative tasks, which could be a cause of conflict of interest. (Law on Civil Servants of 2005, as amended in 2019, Arts. 32, 34 (3) and 35)
Post-employment No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position No. Absent from legal framework.
Participating in official decision-making processes that affect private interests Yes. A civil servant may not make decisions or participate in decision-making that affect the financial or other interest of: a) his/her spouse or common-law partner, child or parent; b) natural or legal persons with whom s/he has or has had official or business contacts in the last two years; c) natural or legal persons who have financed his/her election campaign in the last five years; d) the company, institution or other legal entity in which the civil servant intends to be employed; e) an association or legal entity in which s/he is a manager or a member of the board of directors; f) natural or legal persons whose representative, legal representative or bankruptcy trustee is; or g) natural or legal persons with whom the civil servant, his/her spouse, child or parent is in dispute or is their debtor. (Law on Civil Servants of 2005, as amended in 2019, Art. 37)
Assisting family or friends in obtaining employment in public sector Yes. A civil servant may not make decisions or participate in decision-making that affect the financial or other interest of: a) his/her spouse or common-law partner, child or parent; b) natural or legal persons with whom s/he has or has had official or business contacts in the last two years; c) natural or legal persons who have financed his/her election campaign in the last five years; d) the company, institution or other legal entity in which the civil servant intends to be employed; e) an association or legal entity in which s/he is a manager or a member of the board of directors; f) natural or legal persons whose representative, legal representative or bankruptcy trustee is; or g) natural or legal persons with whom the civil servant, his/her spouse, child or parent is in dispute or is their debtor. (Law on Civil Servants of 2005, as amended in 2019, Art. 37)

Sanctions

Fines are stipulated for violations of COI regulations restricting behavior Yes. The following penalties may be imposed for minor breaches of official duty: a) verbal reprimand; b) written warning; c) a written reprimand with entry in the personal register of the civil servant; d) a fine in the amount of up to 10% of the employee's salary paid in the month when the fine was imposed. The following penalties may be imposed for serious breaches of official duty: a) a fine for a period of one to six months, in the monthly amount of 10 to 20% of the total salary paid to the official in the month in which the penalty was imposed; b) transfer to another job of lower complexity of jobs of the same level of education; c) termination of civil service. The sum of fines imposed in one month for minor and serious breaches of official duty may not exceed 30% of the total salary paid to the official in that month. While the conduct of a civil servant contrary to the Code of Ethics of Civil Servants, which does not harm the reputation of the service, is considered a minor breach of official duty, the same conduct which causes harm to the reputation of the service is consided a serious breach of duty. Other serious breaches of duty include: 1. providing inaccurate information that influences the decision-making of the competent authorities or thereby creates other harmful consequences; 2. abuse of position or exceeding authority in the service; 3. abuse of the obligation of a civil servant to report a justified suspicion of corruption; and 4. violation of the right to protection of anonymity of a civil servant who reports a justified suspicion of corruption. (Law on Civil Servants of 2005, as amended in 2019, Arts. 98 8., 99 and 110 (1) (2) (6))
Administrative sanctions are stipulated for violations of COI regulations restricting behavior Yes. The following penalties may be imposed for minor breaches of official duty: a) verbal reprimand; b) written warning; c) a written reprimand with entry in the personal register of the civil servant; d) a fine in the amount of up to 10% of the employee's salary paid in the month when the fine was imposed. The following penalties may be imposed for serious breaches of official duty: a) a fine for a period of one to six months, in the monthly amount of 10 to 20% of the total salary paid to the official in the month in which the penalty was imposed; b) transfer to another job of lower complexity of jobs of the same level of education; c) termination of civil service. The sum of fines imposed in one month for minor and serious breaches of official duty may not exceed 30% of the total salary paid to the official in that month. While the conduct of a civil servant contrary to the Code of Ethics of Civil Servants, which does not harm the reputation of the service, is considered a minor breach of official duty, the same conduct which causes harm to the reputation of the service is consided a serious breach of duty. Other serious breaches of duty include: 1. providing inaccurate information that influences the decision-making of the competent authorities or thereby creates other harmful consequences; 2. abuse of position or exceeding authority in the service; 3. abuse of the obligation of a civil servant to report a justified suspicion of corruption; and 4. violation of the right to protection of anonymity of a civil servant who reports a justified suspicion of corruption. (Law on Civil Servants of 2005, as amended in 2019, Arts. 98 8., 99 and 110 (1) (2) (6))
Penal sanctions are stipulated for violations of COI regulations restricting behavior Yes. By a decision of the head of the body, an official may be removed from office if criminal proceedings have been instituted against him/her for a serious breach of official duty, and the violation is of such a nature that remaining in office while such proceedings could harm the interests of the service. The head of the body shall be obliged to remove from the service a civil servant against whom criminal proceedings have been instituted or proceedings for a serious breach of official duty due to an act with characteristics of corruption. (Law on Civil Servants of 2005, as amended in 2019, Art. 112)

Monitoring and Oversight

Monitoring body specified (guidance, training, data tracking) Yes. The central state administration body responsible for civil service relations is responsible for the implementation and supervision of the implementation of the Law on Civil Servants of 2005, as well as for monitoring the situation and proposing measures for the development of the civil service. (Law on Civil Servants of 2005, as amended in 2019, Art. 38)
Enforcement body specified (sanctions, hearings) Yes. The head of the body shall decide on minor violations of official duty, unless otherwise determined by a special law for the employees of individual state bodies. Serious breaches of official duty shall be decided in the first instance by the civil service court, and in the second instance by a higher civil service court, unless otherwise determined by a special law for employees of certain state bodies. (Law on Civil Servants of 2005, as amended in 2019, Art. 100)

Legislation

Constitution of the Republic of Croatia of 1990 (consolidated in 2010) (Croatian)pdf
Code of Ethics for Civil Servants of 2011 (Croatian)pdf
Law on Civil Servants of 2005 (consolidated in 2012) (Croatian)pdf
Law on Prevention of Conflicts of Interest of 2011 (consolidated in 2013) (Croatian)pdf
Regulation on Gifts Received by Officials of 2004 (Croatian)pdf
Law on Elections of Representatives to the Croatian National Parliament of 1999 (Croatian)pdf

*Last update: 2017

Freedom of Information

The legal framework governing Croatia's freedom of information regime is grounded in its 1990 Constitution. The Law on Access to Information (2013, amended 2015) applies to state administration bodies, bodies of self-government, organizations fully financed from the state budget, as well as companies in which the government has majority ownership.

Specific exemptions to disclosure are outlined in the aforementioned FOI law, the Data Secrecy Act (2007, amended 2012), and the Act on Personal Data Protection (2003, amended 2011). However, there is a public interest test whereby exemptions to disclosure may be overridden in cases where the public interest outweighs the prohibition on disclosure.

The 2013 FOI law establishes an Information Commissioner with the mandate to hear appeals, issue binding decisions, apply sanctions (fines), conduct public awareness, and oversee implementation of the law. Appeals may also be submitted to public authorities in the first instance, and with the courts as a last resort.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope and Coverage939393939387
Information access and release100100100100100100
Exceptions and Overrides6767676767100
Sanctions for non-compliance676767676733
Monitoring and Oversight505050505083

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope and Coverage

Scope of disclosure

Existence of legal right to access Yes. The right to access to information held by any public authority shall be guaranteed. Restrictions on the right to access to information must be proportionate to the nature of the need for such restriction in each individual case and necessary in a free and democratic society, as stipulated by law. (Article 38, Constitution of Croatia, 1990)
"Information" or "Documents" is defined Yes. Information is any information held by the public authority in the form of a document, record, dossier, register or in any other form, regardless of the manner of representation (written, drawn, printed, recorded, magnetic, optical, electronic or any other record), which the public body has created alone or in cooperation with other bodies or received from other persons, and was created within the scope of competences or in regards to organization and work of the public body. (Article 5 of the Law on Access to Information, 2013, amended 2015)
Proactive disclosure is specified Yes. Public authorities are obliged to publish a range of information on their websites in an easily searchable manner. (Article 10 of the Law on Access to Information, 2013, amended 2015)

Coverage of public and private sectors

Executive branch Yes. "Public authorities" within the meaning of this Act, the state administration bodies, other state bodies, bodies of local and territorial (regional) selfgovernment, legal persons with public authority and other persons to whom public powers, the legal entity whose the founder of the Republic of Croatia or local and regional (regional) governments, legal persons and other persons who perform public service, legal persons that are fully financed from the state budget or the budget of local and regional (regional) governments, as well as companies in which the Republic of Croatia and local and regional (regional) governments have separately or together majority ownership; (Article 1 and 5 of the Law on Access to Information, 2013, amended 2015)
Legislative branch Yes. "Public authorities" within the meaning of this Act, the state administration bodies, other state bodies, bodies of local and territorial (regional) selfgovernment, legal persons with public authority and other persons to whom public powers, the legal entity whose the founder of the Republic of Croatia or local and regional (regional) governments, legal persons and other persons who perform public service, legal persons that are fully financed from the state budget or the budget of local and regional (regional) governments, as well as companies in which the Republic of Croatia and local and regional (regional) governments have separately or together majority ownership; (Article 1 and 5 of the Law on Access to Information, 2013, amended 2015)
Judicial branch No. The provisions of this Act shall not apply to the parties in judicial, administrative and other procedures based on the law, which is the availability of information from these procedures established by regulation. (Article 1 and 5 of the Law on Access to Information, 2013, amended 2015)
Other public bodies Yes. "Public authorities" within the meaning of this Act, the state administration bodies, other state bodies, bodies of local and territorial (regional) selfgovernment, legal persons with public authority and other persons to whom public powers, the legal entity whose the founder of the Republic of Croatia or local and regional (regional) governments, legal persons and other persons who perform public service, legal persons that are fully financed from the state budget or the budget of local and regional (regional) governments, as well as companies in which the Republic of Croatia and local and regional (regional) governments have separately or together majority ownership; (Article 1 and 5 of the Law on Access to Information, 2013, amended 2015)
Private sector No. Absent from legal framework.

Access to specific documents (subject to reactive and/or proactive disclosure)

Draft legal instruments Yes. Available through both requests for information and proactive disclosure. (Articles 10, 11, 12 of the Law on Access to Information, 2013, amended 2015)
Enacted legal instruments Yes. Available through both requests for information and proactive disclosure. (Articles 10, 11, 12 of the Law on Access to Information, 2013, amended 2015)
Annual budgets Yes. Available through both requests for information and proactive disclosure. (Articles 10, 11, 12 of the Law on Access to Information, 2013, amended 2015)
Annual chart of accounts (actual expenditures) Yes. Available through both requests for information and proactive disclosure. (Articles 10, 11, 12 of the Law on Access to Information, 2013, amended 2015)
Annual reports of public entities and programs Yes. Available through both requests for information and proactive disclosure. (Articles 10, 11, 12 of the Law on Access to Information, 2013, amended 2015)

Information access and release

Procedural access

Universal access (agencies, citizens and non-citizens) Yes. Information is available to every domestic or foreign natural and legal persons in accordance with the conditions and restrictions of this law. (Article 6 of the Law on Access to Information, 2013, amended 2015)
Type of request is specified (written, electronic, oral) Yes. The user is entitled to access to information by submitting an oral or written request to the competent authority. (Articles 17 and 18 of the Law on Access to Information, 2013, amended 2015)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.) Yes. Public authorities are obliged to appoint information officers in their agencies, who provide essential help for applicants in relation to the exercise of the rights set forth in this Act. In the case of an incomplete or incomprehensible request, the public authority body shall without delay request the submitter to make corrections within 5 days from the date of receipt of the request for corrections. If the submitter fails to correct the request in the appropriate manner, and it can not be clearly ascertained which information are requested from the original request, the public authority body shall reject the request by issuing a decision. (Articles 13 and 20 of the Law on Access to Information, 2013, amended 2015)
Cost of access is specified (free, request fees, photocopying costs, other administrative costs) Yes. (1) Access to information in procedures before the public authority bodies does not require the payment of administrative and court fees. (2) The public authority body is entitled to request the beneficiaries to cover the actual material expenses incurred by providing information, under Article 17 of this Act, and to cover the expenses of delivery of the requested information. Upon the request submitted by the beneficiary, the public authority body is obliged to provide the calculation of expenses. (3) The criteria for setting the amount of fees and the manner of covering the expenses as referred to in paragraph 2 of this Article, shall be prescribed by the Commissioner. (4) Revenue from fees collected pursuant to paragraph 2 of this Article shall be considered the revenue of the public authority body. (Article 19 of the Law on Access to Information, 2013, amended 2015)

Deadlines for release of information

20-day response deadline Yes. (1) Pursuant to request for access to information, the public authority body shall issue its decision within 15 days from the date of submission of an orderly request. (Article 20 of the Law on Access to Information, 2013, amended 2015)
Agency granted right to extend response time Yes. (1) The deadlines for exercising the right of access to information may be extended by 15 days from the date the public authority body was expected to decide on the request for access to information: 1) if the information must be sought outside the seat of the public authority body, 2) if the request pertains to numerous different information, 3) if this is necessary to ensure the accuracy and integrity of the requested information, 4) if the situation requires conducting the Proportionality Test and the Public Interest Test, in accordance with the provisions of this Act. (Article 22 of the Law on Access to Information, 2013, amended 2015)
Maximum total response time of no more than 40 days Yes. Pursuant to request for access to information, the public authority body shall issue its decision within 15 days from the date of submission of an orderly request. The deadlines for exercising the right of access to information may be extended by 15 days from the date the public authority body was expected to decide on the request for access to information (Articles 20 and 22 of the Law on Access to Information, 2013, amended 2015)

Exceptions and Overrides

Exemptions to disclosure

Existence of secrecy/states secrets law Yes. Data Secrecy Act, 2007, last amended 2012 (Data Secrecy Act, 2007, last amended 2012)
Existence of personal privacy/data law Yes. Law on the Implementation of the General Regulation on Data Protection (Law on the Implementation of the General Regulation on Data Protection, 2018)
Specific exemptions to disclosure Yes. There are specific exemptions for the disclosure of information. (Article 15 of the Law on Access to Information, 2013, amended 2015)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

Appeals

Appeals allowed within public entities Yes. (1) If the beneficiary considers the information provided on the basis of request to be inaccurate or incomplete, they may request its correction, i.e. amendment of the respective information, within 15 days of the date of receipt of the information. (2) The public authority body shall be obliged to decide on the request for amendment or correction of the information, within 15 days of the date of receipt of the request, pursuant to Article 23 of this Act. (Article 24 of the Law on Access to Information, 2013, amended 2015)
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding. Yes. The submitter may file a Complaint to the Commissioner against the Decision issued by the public authority body within 15 days of the date of delivery of the Decision. A Complaint may also be filed if the public authority body fails to issue a Decision on the Submitter’s request within the legal deadline. The Commissioner: – conducts the tasks of the second instance body in resolving complaints relating to exercising the right of access to information and the right to re-use information; (Articles 25 and 35 of the Law on Access to Information, 2013, amended 2015)
Judicial appeals mechanism Yes. (1) No complaint may be filed against the Decision issued by the Commissioner, though an administrative dispute may be initiated before the High Administrative Court of the Republic of Croatia. The High Administrative Court of the Republic of Croatia must issue a decision on Complaint within 90 days. The Complaint shall delay the execution of the Decision granting access to information. (Article 26 of the Law on Access to Information, 2013, amended 2015)

Sanctions for non-compliance

Administrative sanctions are specified for violations of disclosure requirements No. Absent from legal framework.
Fines are specified for violations of disclosure requirements Yes. Specific fines and violations are listed in Articles 61-62 of the FOI law. (Articles 61-62 of the Law on Access to Information, 2013, amended 2015)
Criminal sanctions are specified for violations of disclosure requirements No. Absent from legal framework.

Monitoring and Oversight

Information officers must be appointed in public agencies Yes. Public authorities are obliged to appoint information officers in their agencies, who perform the following duties: 1) performs regular publication of information, in accordance with the internal organization of the public authorities, as well as dealing with individual requests for access to information and reuse of information, 2) improve the manner of processing, classification, storage and publication of information contained in official documents relating to the work of public authorities, 3) provide essential help for applicants in relation to the exercise of the rights set forth in this Act. (Article 13 of the Law on Access to Information, 2013, amended 2015)
Public body that is responsible for applying sanctions Yes. (3) The Commissioner: – files an indictment proposal and issues a misdemeanour order for any identified misdemeanour. (1) The head of the public authority body is obliged to implement the ordered measure within the deadline set in the record. (Articles 35 and 56 of the Law on Access to Information, 2013, amended 2015)
Public body that is responsible for public outreach (raising public awareness) Yes. (3) The Commissioner: – informs the public on exercising the beneficiary rights of access to information and re-use of information; (Article 35 of the Law on Access to Information, 2013, amended 2015)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman. Yes. (3) The Commissioner: – conducts supervision and performs inspection supervision over the implementation of this Act; – monitors the implementation of this Act and the regulations governing the right of access to information and the re-use of information, and informs the public of the implementation thereof; – issues proposals to the public authority bodies with regard to measures to improve the right of access to information and the re-use of information, as governed by this Act; – proposes measures for the professional development of Information Officers within public authority bodies, and familiarization with their duties with regard to the implementation of this Act; – initiates the issuance or amendment of regulations for the purpose of implementation and improvement of the right of access to information and the re-use of information; – submits a report to the Croatian Parliament on the implementation of this Act and other reports when considered necessary; (Articles 35, 42-51 of the Law on Access to Information, 2013, amended 2015)
Ombudsman involvement in implementation is specified by law No. Absent from legal framework.
Reporting of data and/or implementation is required Yes. Public body authority is obliged to maintain an official record of requests, proceedings and decisions on requests for information and re-use of information, in accordance with provisions of this law. (Article 14 of the Law on Access to Information, 2013, amended 2015)

Legislation

Constitution of Croatia of 1990_CRO (Croatian)pdf
Constitutional Court Decision of 2014_CRO, interpreting Constitution of Croatia of 1990 (Croatian)pdf
Law on the Right to Access Information of 2013_CRO (Croatian)pdf
Data Secrecy Act of 2007_CRO (Croatian)pdf
Law on the Implementation of the General Regulation on Data Protection of 2018_CRO (Croatian)pdf

*Last update: 2017

Public Procurement

The Croatian public procurement system is regulated by the Public Procurement Act (2011), and other laws such as the Public Private Partnership Act (2011) and the Concessions Act (2008), along with secondary legislation such as the the Regulation on public procurement notices and records (2012). The public procurement body is the Directorate for the Public Procurement System that is located under the Ministry of Economics.

The lowest minimum threshold for conducting a public procurement tender is:

▪         HRK 200,000 (ca. 27,000 EUR) for goods

▪         HRK 500,000 (ca. 67,000 EUR) for works

▪         HRK 200,000 (ca. 27,000 EUR) for services

The minimum number of bidders is 5 for restricted procedures and 3 for negotiated procedures. The minimum submission period is 35 days for open procedures, 30 days for restricted procedures and 30 for negotiated procedures from dispatch date. However, this can be shorter for low value tenders. The final beneficial owners do not have to be disclosed when placing a bid.

There is no preferential treatment, but there are several options for bid exclusion: conviction for certain criminal acts, outstanding tax liabilities, false information at bid submission, and abnormally low bid prices.

In the bid evaluation phase, there are conflict of interest restrictions on the composition of the evaluation committee. However, no form of independence of  the contracting authority is mandated for the evaluation committee.

There is a payable fee in case of an arbitration procedure proportioned to the size of the claim (between HRK 5,000 and 100,000 – ca. EUR 600-15,00). Decisions are published online at the State Commission’s website.

Quantitative Data

Primary Metric

201220152016201720202024Trend
Scope7675398899
Information availability8585979742
Evaluation10094948875
Open competition8383757256
Institutional arrangements2929293636

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Scope

Threshold - lowest PP

What is the minimum contract value above which the public procurement law is applied? (Product type GOODS) EUR 26,540. Regulated procurement for supplies applies at EUR 26,540 and above. Below this, unregulated purchasing permitted, but inclusion in procurement plans/contract registers from EUR 2,654 up is required for transparency. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12(1), 15(1), 28(5))
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS) EUR 66,360. Any works contract with estimated value EUR 66,360 or more requires full PPA procedure (open, restricted, negotiated, etc); lesser values are outside formal regulation but require basic documentation. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12(1), 15(1), 28(5))
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES) EUR 26,540. The PPA applies to contracts for services worth EUR 26,540 or more. Services below this value can be procured directly, but require inclusion in procurement planning and contract data registers from EUR 2,654. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12(1), 15(1), 28(5))

Threshold - by PP type

What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR) EUR 26,540. The law mandates open/restricted/negotiated procedures for all public sector procurements above EUR 26,540 (goods/services) or EUR 66,360 (works); below, less formal processes govern. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12, 15)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES) EUR 26,540. Utilities are included in the same regime: EUR 26,540 threshold for supplies/services, EUR 66,360 for works; procurement below these limits is not formally regulated but must meet good governance/contract register requirements. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 1, 7, 12, 15, 335)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE) EUR 26,540. For defence and security procurement, the same threshold applies: EUR 26,540 for supply/service contracts and EUR 66,360 for works. Additional rules from the Decree No. 19/2018 apply to classified contracts. (Decree No. 19/2018, Art. 1; PPA 2016 (as of Dec. 2024), Arts. 12(1), 40)

Threshold - by product type

What are the minimum application thresholds for the procurement type? (Product type GOODS) EUR 26,540. Goods contracts above EUR 26,540 require regulated procedures/publication; those above EUR 2,654 must be declared in contract registers/procurement plans. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12, 15, 28(5))
What are the minimum application thresholds for the procurement type? (Product type WORKS) EUR 66,360. Works contracts are regulated by PPA from EUR 66,360 on; required registration starts at EUR 2,654 in terms of planning/transparency. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12, 15, 28(5))
What are the minimum application thresholds for the procurement type? (Product type SERVICES) EUR 26,540. Service contracts from EUR 26,540 require full compliance; those above EUR 2,654 included in registers and procurement plans for oversight. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 12, 15, 28(5))

Information availability

Publishing and record keeping

Is there a requirement that tender documents must published in full? Yes. Simultaneous publication of contract notice and all tender documents is mandatory; the internet address for docs must be in the notice. Interested suppliers must register on EOJN RH but access is free. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 68(1)4, 200(5))
Are any of these documents published online at a central place? Yes. All procurement notices and major tender documentation must be centrally and electronically published on EOJN RH, Croatia’s official system. Where above EU threshold, simultaneous publication in TED/OJEU is required. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 67, 68, 69, 70, 71, 72, 73, 200(5))
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system) Yes. Contracting authorities must create and maintain extensive files (calls, questions, bids, communications, evaluations, contracts, amendments, appeals, settlements) for every procurement, kept at least four years; EOJN RH retains digital documents six years for audit and transparency. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 333(2), 334)
Are contracts awarded within a framework agreement published (ie mini contracts)? Yes. All contracts under framework agreements are recorded and published by the authority; quarterly grouped award notices for “mini-contracts”/concluded awards under any individual framework must be published within 30 days after each quarter. Registers and changes published online. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 28(2)(4), 248(2), Annex V Part D)

Sub-contracting

Is it mandatory to publish information on subcontractors (ie names) in some cases? No. There is no general obligation to publish the identity of subcontractors for every contract. Where appropriate, contract award notices must indicate the value/proportion expected to be subcontracted, and for utilities, must specify if works have been or may be subcontracted. Publishing actual names is not required except where specifically requested by EU rules or by contracting authority in notice. (PPA 2016 (as of Dec. 2024), Art. 248(1), Annex V Part D)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column. There is no numeric threshold: disclosure is only required if deemed appropriate, not as a function of value or percentage of contract. (PPA 2016 (as of Dec. 2024), Art. 248(1), Annex V Part D)

Evaluation

Preferential treatment

Is there a ban on mentioning specific companies or brands in tender specification/call for tender? Yes. Technical specifications must avoid reference to brand, make, process, origin or specific products, except when necessary for technical precision; in all such cases "or equivalent" must be included. Unjustified restrictions are prohibited. (PPA 2016 (as of Dec. 2024), Art. 210)
Is there a preferential treatment for small-to-medium enterprises (SMEs)? Yes. Authorities may divide contracts into lots (by objective criteria: type, purpose, place, time) and set up bid design to facilitate SME participation. Such division is encouraged but not compulsory; monitoring is in place to support SME access. (PPA 2016 (as of Dec. 2024), Arts. 204(1), 370(1))
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies) No. Law prohibits any discrimination based on nationality or local establishment; all principles of EU internal market and GPA are affirmed and codified. (PPA 2016 (as of Dec. 2024), Arts. 4(1), 84)
Is there a specific set of rules for green/sustainable procurement? Yes. Authorities may require bidders to provide certified environmental management standards (EMAS, ISO or equivalents) and can specify environmental/social requirements in technical or award criteria. Valid conformity assessment is required by law, compatible with EU/HR standards. (PPA 2016 (as of Dec. 2024), Arts. 206–211, 218, 271, 284–288)

Bid evaluation

Are there restrictions on allowable grounds for tenderer exclusion? Yes. Mandatory exclusions: criminal convictions (for terrorism, corruption, organized crime, etc), unpaid taxes/social contributions, as well as management members being convicted/liable. Discretionary exclusions include breach of social/environmental/labour law, bankruptcy, professional misconduct, grave business error. (PPA 2016 (as of Dec. 2024), Arts. 251, 252, 254)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc. No. Abnormally low bids must trigger a request for written justification; only if explanations are insufficient may exclusion occur (rejection must be reasoned and documented). (PPA 2016 (as of Dec. 2024), Art. 289)
Is scoring criteria published? Yes. All award criteria and relative weighting or priority must be specified in the tender documents; only in purely price-based contracts is weighting allowed to be omitted. (PPA 2016 (as of Dec. 2024), Arts. 285(3), 286, Annex V Part D)
Are decisions always made by a committee? Yes. Examination and evaluation of tenders is performed by an "expert committee," whose members (not required to be authority staff) must include at least one with a certified public procurement qualification. (PPA 2016 (as of Dec. 2024), Arts. 197, 290)
Are there regulations on evaluation committee composition to prevent conflict of interest? Yes. General conflict of interest regulation applies to all actors, including evaluation committees. Members must declare and recuse in case of direct or indirect conflict with bidders. (PPA 2016 (as of Dec. 2024), Arts. 75–83)
Is some part of evaluation committee mandatorily independent of contracting authority? No. While at least one member must be qualified, the law does not require a committee to be outside the contracting authority; non-employees may be included but not mandatory. (PPA 2016 (as of Dec. 2024), Art. 197)
Are scoring results publicly available? No. Only the highest score/awarded bid must be notified and published; full scoring is not required to be disclosed except on bidder request or in a formal review. (PPA 2016 (as of Dec. 2024), Arts. 248, 302, Annex V Part D)
Does the law specify under which conditions the tender can be cancelled? Yes. Law provides a closed list of situations allowing (or requiring) cancellation: no or invalid bids, changed circumstances, breach of rules, loss of finance, errors in notices or documentation, etc. (PPA 2016 (as of Dec. 2024), Art. 298)

Open competition

CFT publication

Does the law specify the location for publicizing open calls for tenders? Yes. Same as above: EOJN RH, TED and customer profiles serve as official publication channels for restricted procedures. (PPA 2016 (as of Dec. 2024), Arts. 66, 244, 250)
Does the law specify the location for publicizing restricted calls for tenders? Yes. Publication line identical (EOJN RH, TED, etc.) for any negotiated calls, including multi-stage and innovation partnership. (PPA 2016 (as of Dec. 2024), Arts. 66, 244, 250)
Does the law specify the location for publicizing negotiated calls for tenders? Yes. Electronic Public Procurement Classifieds of the Republic of Croatia ("EOJN RH"), TED. The contracting authority may also publish a customer profile on the website. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 66, 244 and 250)

Minimum # of bidders

What is the minimum number of bidders for restricted procedures? 5. Restricted procedures require at least five invited bidders; if fewer are eligible after preselection, the procedure continues with those available. (PPA 2016 (as of Dec. 2024), Art. 143(3))
What is the minimum number of bidders for negotiated procedures? 3. Negotiated and competitive dialogue require a legal minimum of three bidders to be invited, unless fewer eligible. (PPA 2016 (as of Dec. 2024), Art. 143(3))
What is the minimum number of bidders for competitive dialogue procedures? 3. Minimum of three bidders for competitive dialogue is the universal base. (PPA 2016 (as of Dec. 2024), Art. 143(3))

Bidding period length

What are the minimum number of days for open procedures? 20. Minimum for open procedures is 20 days for contracts below the EU threshold and 35 days for high-value/EU contracts. (PPA 2016 (as of Dec. 2024), Arts. 228, 236)
What are the minimum number of days for restricted procedures? 20. Restricted and negotiated procedures must allow at least 20 days (30 for higher-value procedures). (PPA 2016 (as of Dec. 2024), Arts. 229, 236)
What are the minimum number of days  for competitive negotiated procedures? Yes. Permitted types: open, restricted, competitive with negotiation, competitive dialogue, innovation partnership, negotiated without prior publication; all defined, with sectoral and procedural details. (PPA 2016 (as of Dec. 2024), Art. 85)

Institutional arrangements

Institutions and regulations

Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations? Yes. Explicit legal exemptions: international/organization rules, international projects with third countries, intra-governmental contracts, real estate (acquisition/rent), certain public-service and defense/security contracts, etc. (PPA 2016 (as of Dec. 2024), Arts. 29–38)
Does the law specify the main types of institutions that must apply the public procurement law? Yes. The law defines the contracting authorities and the contracting entities that have to apply the procurement law. Indicatively, contracting authorities are the following: the state bodies, local and regional self-government units, associations established by state, local or regional bodies, legal persons established for the purpose of meeting needs in the general interet without having a commercial interest and interlinked with the state by one of three conditions, etc. (Public Procurement Act 2016 (as of Dec. 2024), Arts. 5, 6 and 7)
Does the law specify the main procedure types or procurement methods permitted? Yes. Open, restricted, competitive procedure with negotiation, competitive dialogue, innovation partnership and negotiated procedure without prior publication (Public Procurement Act 2016 (as of Dec. 2024), Art. 85)
Is there a procurement arbitration court dedicated to public procurement cases? Yes. Filing of an admissible appeal automatically suspends contract signing/award until DKOM issues a decision, except as otherwise provided (emergencies or express legal exceptions). (PPA 2016 (as of Dec. 2024), Art. 422)
Is there a procurement regulatory body dedicated to public procurement? No. Systematic oversight and policy staff are in the Directorate for the Public Procurement System at the Ministry of Economy, not an independent regulatory agency. The integrated portal (javnanabava.hr) is managed by this directorate. (PPA 2016 (as of Dec. 2024), Art. 436)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)? Yes. All arbitration/review decisions of DKOM are published on its official website in a timely and systematic manner as required by law. (PPA 2016 (as of Dec. 2024), Arts. 432(5), 432(7))
Is disclosure of final, beneficial owners required for placing a bid? No. See above; no regulatory or procedural requirement. (—)

Complaints

Is there a fee for arbitration procedure? Yes. See Q55: appeal fee is always due; special rates for challenge to documentation (EUR 5,000 fixed fee). (PPA 2016 (as of Dec. 2024), Art. 430)
Is there a ban on contract signature until arbitration court decision (first instance court)? Yes. See Q56: appeal blocks contract until DKOM rules, with minor exceptions. (PPA 2016 (as of Dec. 2024), Art. 422)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts? Yes. All DKOM decisions on procurement must be published online for public access; publication is compulsory and timely. (PPA 2016 (as of Dec. 2024), Arts. 432(5), 432(7))
Is there a requirement to publicly release arbitration court decisions ? Yes. Regulatory and judicial/appeal body decisions are all made public via the official platform; access is unrestricted and in full. (PPA 2016 (as of Dec. 2024), Arts. 432(5), 432(7))

Legislation

Ordinance on Procurement Documentation and Tenders in Public Procurement Procedures (Croatian)pdf
Public Procurement Act (Official Gazette No. 120/2016) (Croatian)pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data

Primary Metric

201220152016201720202024Trend
Risk-based approach100
Sanctions for natural persons71
Sanctions for legal persons50
Pecuniary sanctions for obliged entities60
Beneficial ownership of legal persons and legal arrangements24
Supervision of obliged entities100
Financial Intelligence Units (FIUs)100
Mutual legal assistance (MLA) and International Cooperation100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Risk-based approach

Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it. Yes. Croatia is legally required to conduct a national ML/TF risk assessment to identify, assess, understand and mitigate risks. The assessment must be updated every four years and earlier if needed. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 5(1))
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years. Yes. The national ML/TF risk assessment must be regularly updated every four years from the previous assessment, and earlier where needed. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 5(1))
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks. Yes. The Office for the Prevention of Money Laundering coordinates the inter-institutional working group in carrying out and regularly updating the national ML/TF risk assessment. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 110(2)(2))

Sanctions for natural persons

The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action; Yes. Croatian criminal law punishes conversion, transfer, exchange, takeover or investment of criminal proceeds for the purpose of concealing their unlawful origin. (Kazneni zakon, Art. 265(1))
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity; Yes. Croatian criminal law punishes concealing or disguising the true nature, origin, location, disposal, transfer, rights over, or ownership of criminal proceeds. (Kazneni zakon, Art. 265(2))
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity. Yes. Croatian criminal law punishes acquiring, possessing or using property obtained by another person through criminal activity. (Kazneni zakon, Art. 265(3))
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence. Yes. Attempt, incitement and aiding are punishable under the general rules of the Criminal Code and apply to money-laundering offences. (Kazneni zakon, Arts. 34, 37, 38)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years. Yes. Aggravated money laundering is punishable by imprisonment from one to eight years, exceeding the four-year threshold. (Kazneni zakon, Art. 265(4))
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences No. The offence definition does not expressly state that a prior or simultaneous conviction for the predicate offence is not required. (Kazneni zakon, Art. 265)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator; No. Croatian law criminalises laundering of property derived from criminal activity, but no explicit provision states that conviction is possible without establishing all factual elements or the identity of the predicate offender. (Kazneni zakon, Art. 265)

Sanctions for legal persons

Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person. No. Absent from legal framework
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority. No. Corporate liability is tied to offences committed by a responsible person, not expressly to a lack of supervision or control enabling a subordinate to commit a money-laundering offence for the legal person’s benefit. (Zakon o odgovornosti pravnih osoba za kaznena djela, Arts. 3-5)
Legal persons held liable are punishable by criminal or non-criminal fines. Yes. Legal persons held liable may be punished by monetary fines. (Zakon o odgovornosti pravnih osoba za kaznena djela, Arts. 8-10; Zakon o izmjenama i dopuni Zakona o odgovornosti pravnih osoba za kaznena djela (2023), Art. 3)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence. Yes. Legal persons may face dissolution, bans on activities, bans on permits, concessions or subsidies, bans on dealing with public-budget users, confiscation and publication of the judgment. (Zakon o odgovornosti pravnih osoba za kaznena djela, Arts. 12, 15-21)

Pecuniary sanctions for obliged entities

In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach. Yes. Croatian law imposes pecuniary sanctions on legal persons and responsible natural persons for breaches of the national AML law implementing the EU AML framework, and supervisors may also apply administrative measures. Under the stated methodology, sanctions for breach of the national implementing law are sufficient. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 83, 150-154, 96)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention). Yes. Croatian law provides pecuniary sanctions for serious AML compliance failures under the national AML law, including core internal controls, CDD, reporting and record-keeping obligations. Under the stated methodology, sanctions for breach of the national AML law implementing the EU rules are sufficient. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 150)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed. Yes. Supervisors may apply administrative measures where they find breaches of the AML law, its implementing acts, or Regulation (EU) 2015/847, including warnings, remedial orders and temporary prohibitions. Substantively this satisfies the indicator, since the national AML framework enables administrative measures for AML-rule breaches and related control weaknesses. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 83)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures. No. Absent from legal framework
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments. No. Publication is required only for final misdemeanor sanctions. The law does not clearly require publication of all administrative measures or periodic penalty payments described in the indicator. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 96)

Beneficial ownership of legal persons and legal arrangements

Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered. Yes. Croatia has a central electronic beneficial ownership register for listed Croatian legal entities and for trusts or equivalent foreign-law arrangements that have a Croatian OIB. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 32(1)-(2))
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation. Yes. The Croatian framework substantively empowers the register system to obtain supporting material needed to identify and verify beneficial owners. The Tax Administration may require documentation establishing the ownership and control structure and enabling collection of beneficial-owner data, while the Financial Agency verifies register entries. This is sufficient in substance even if the request power sits with the supervisory authority rather than being framed only for the register operator itself. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 32(3)(5), 36(1), 36(4))
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number No. Croatian rules provide fallback registration of persons authorised to represent certain entity types where no natural person can be identified, but not a general rule for all legal entities and legal arrangements together with the required statement and justification. (Pravilnik o Registru stvarnih vlasnika, Arts. 4(3), 6(3))
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date. Yes. The framework substantively requires verification of beneficial-ownership information on submission and thereafter. The Financial Agency verifies register data, the Tax Administration supervises whether entities hold and have entered accurate and complete data, and changes must be updated within 30 days. Under the stated methodology, these concrete verification and updating rules satisfy the timing requirement. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 32(3)(5), 33(1), 36(1), 36(3)-(4); Pravilnik o Registru stvarnih vlasnika, Arts. 15, 18-19)
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them. No. Absent from legal framework
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register. Yes. Entities and trustees must update previously entered beneficial ownership information in the register within 30 days of any change. (Pravilnik o Registru stvarnih vlasnika, Art. 15(1))
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date. No. Croatian law provides register checks and tax supervision, but no explicit rule was identified empowering the register authority to carry out checks including on-site inspections at business premises or registered offices. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 36; Pravilnik o Registru stvarnih vlasnika, Arts. 18-19)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration. No. The ordinance allows incomplete or inconsistent paper filings to be returned before entry, but no explicit rule was identified on withholding, refusing or suspending a valid certificate of proof of registration because of inconsistencies or errors. (Pravilnik o Registru stvarnih vlasnika, Art. 13(5)-(7))
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership. No. Croatian law provides sanctions for non-possession, non-entry and failure to provide documents, but no explicit rule was identified giving the register authority itself power to apply measures or sanctions covering all failures to provide accurate, adequate and up-to-date beneficial ownership information. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 36; Art. 153(4)-(18))
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States. No. Croatian law grants direct free access to the Office and listed state bodies, but no explicit rule was identified covering the full set of authorities named in the indicator, including AMLA, EPPO, OLAF, Europol and Eurojust. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 34(1)-(2); Pravilnik o Registru stvarnih vlasnika, Arts. 26-29)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers. No. Obliged entities may access register data against a fee set by the Agency with ministry approval, but no explicit cost-cap or non-undermining-access rule was identified. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 34(3); Pravilnik o Registru stvarnih vlasnika, Art. 32)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest. No. Access for third parties depends on proving a justified legal interest tied to the applicant’s legal position in proceedings and to AML/CFT, which is narrower than the indicator and does not extend to legal arrangements generally. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 34(4), 35(1)-(3))
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Croatian law does not expressly deem journalism, reporting or other media expression to constitute justified legal interest for register access. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 35)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Croatian law does not expressly deem civil society organisations or academia to constitute justified legal interest for register access. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 35)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing; No. Croatian law does not expressly deem persons likely to enter into a transaction with a legal entity or legal arrangement to have justified legal interest for register access. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 35)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure; No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing; No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing. No. Absent from legal framework
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days. No. Absent from legal framework
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679. Yes. Croatian law contains operative conditions that can function as grounds for refusal: access for third parties depends on demonstrating justified legal interest, and the Office determines whether that interest exists. Under the stated methodology for AML-39, the existence of at least one such refusal condition is sufficient. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 34(4), 35(1)-(4))
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed. No. Croatian law allows case-by-case access restrictions in exceptional circumstances, but the rule covers legal entities only and not legal arrangements generally as stated in the indicator. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 34(5)-(7))

Supervision of obliged entities

Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113. Yes. Croatia subjects obliged entities to AML/CFT supervision and designates multiple national supervisors with statutory sectoral competences. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 81-82)

Financial Intelligence Units (FIUs)

Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing. Yes. Croatia establishes the Office for the Prevention of Money Laundering as its financial intelligence unit. (Zakon o sprječavanju pranja novca i financiranja terorizma, Art. 99(1)-(3))
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing. Yes. The Office is the central national unit responsible for receiving and analysing suspicious transaction reports and other AML/CFT-relevant information. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 101(1), 110(1)(1), 111)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing. Yes. The Office must disseminate the results of its operational analyses and other relevant information to competent authorities when suspicion grounds exist. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 101(2), 138(1))
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference. Yes. The Office is expressly defined as independent and operationally autonomous, including autonomous decision-making and protection from undue political or private-sector influence. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 99(3), 102(1))
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information. Yes. The Office has statutory access to financial, administrative and law-enforcement-related information needed for its tasks, including direct or indirect access from public bodies and additional data from obliged entities. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 110(1)(2), 113, 116)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction. Yes. The Office may order an obliged entity to suspend a suspicious transaction for a limited period and may also order ongoing monitoring of a customer's financial business. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 117, 119)

Mutual legal assistance (MLA) and International Cooperation

Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU. Yes. Croatian law expressly requires the Office, when responding to a request from another EU FIU concerning a reporting entity headquartered in Croatia, to apply all powers under the AML law without delay to obtain the requested information. This substantively satisfies the requirement to use the whole range of available domestic powers when replying to another FIU. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 129(1)-(2), 127)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange. Yes. The Office must exchange relevant information with foreign FIUs, both on request and spontaneously, regardless of organisational status and even when the predicate offence is not yet identified. (Zakon o sprječavanju pranja novca i financiranja terorizma, Arts. 127(1)-(4), 129(1), 130(1), 133)

Legislation

Political Activity and Election Campaign Financing Act, 2011, amended 2016missing file:
Criminal Code, No 110/​1997missing file:

*Last update: 2017

Asset Recovery

Quantitative Data

Primary Metric

201220152016201720202024Trend
Asset Offices100
Confiscation78
International cooperation75

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

We are frequently reviewing and refining our data, so in case you notice any mistake in our assessment, feel free to send us an email by clicking the button ()

Country score

Asset Offices

Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters. Yes. Croatia has a central authority for tracing, freezing and confiscating proceeds of crime and managing international cooperation on confiscation through designated units within the Ministry of Justice and State Attorney’s Office, (Criminal Procedure Act (Zakon o kaznenom postupku), Official Gazette 152/08 et seq., Part on international legal assistance and execution of foreign confiscation orders; Act on the Procedure of Confiscation of Pecuniary Gain Acquired through a Criminal Offence or Misdemeanour, Art. 3.)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order. Yes. Croatian law entrusts courts and the Ministry of Justice with the management, safekeeping and disposal of seized and confiscated assets, (Criminal Procedure Act, Arts. 558–566 (management of seized and confiscated property); Act on the Procedure of Confiscation of Pecuniary Gain Acquired through a Criminal Offence or Misdemeanour, Arts. 12–18.)

Confiscation

Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures) Yes. The Criminal Procedure Act allows temporary securing measures, including provisional seizure and freezing of assets suspected to originate from criminal offences, (Criminal Procedure Act, Arts. 552–557 (temporary securing of pecuniary gain, seizure and freezing).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation) Yes. The Criminal Code (Criminal Code (Kazneni zakon), Official Gazette 125/11 et seq., Arts. 77–79 (Confiscation of property gain, Confiscation of objects).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value) Yes. Where the property gain cannot be confiscated, (Criminal Code, Art. 77(3); Act on the Procedure of Confiscation of Pecuniary Gain Acquired through a Criminal Offence or Misdemeanour, Art. 2.)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation) Yes. Confiscation of property gain may be ordered from third parties to whom the gain was transferred without appropriate compensation, (Criminal Code, Art. 77(4); Act on the Procedure of Confiscation of Pecuniary Gain Acquired through a Criminal Offence or Misdemeanour, Arts. 4–5.)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation) Yes. Extended (Criminal Code, Art. 78 (Extended confiscation of property gain).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation) Yes. Croatian law allows non‑conviction based confiscation in specific cases, including when the proceedings cannot be completed due to procedural obstacles, (Criminal Procedure Act, Art. 560 (confiscation where proceedings cannot be conducted or completed); Criminal Code, Art. 77(6).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation) Yes. Non‑conviction based confiscation is tied to proceedings for confiscation of pecuniary gain and is limited to serious offences, (Criminal Procedure Act, Arts. 558–560; Criminal Code, Arts. 77–78.)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth) No. Although extended confiscation exists, Croatian law had not, by 31 December 2024, introduced a separate confiscation of unexplained wealth regime aligned with Article 16 of Directive (EU) 2024/1260. (Criminal Code, Art. 78 (extended confiscation); no separate unexplained‑wealth confiscation provision in force by 31.12.2024.)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027) No. Croatian law does not provide for a specific national asset recovery strategy with a mandatory five‑year update cycle; this obligation arises from Directive (EU) 2024/1260 (No explicit asset recovery strategy requirement in Criminal Code, Criminal Procedure Act or confiscation procedure act by 31.12.2024.)

International cooperation

To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters. Yes. The Criminal Procedure Act regulates mutual legal assistance for tracing, freezing and confiscation of proceeds of crime, (Criminal Procedure Act, Arts. 541–551 (international legal assistance in criminal matters, including freezing and confiscation).)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information Yes. Croatia (Criminal Procedure Act, Arts. 541–551; national designation of contact points for Council Decision 2007/845/JHA (EU Asset Recovery Offices).)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders. No. Croatian legislation on confiscation and mutual legal assistance does not contain an explicit rule on cost‑sharing (No explicit cost‑sharing provision identified in Criminal Procedure Act)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions Yes. Croatian (Criminal Procedure Act, provisions on disposal and distribution of confiscated assets in international mutual legal assistance cases (PC‑OC Mod (2017)08Bil.rev, Croatia section).)

Legislation

Political Activity and Election Campaign Financing Act, 2011, amended 2016missing file:
Criminal Code, No 110/​1997missing file:

*Last update: 2017