The Markets in Crypto-Assets Regulation (MiCA) introduces a unified regulatory framework for crypto-assets across the European Union (EU), promoting legal certainty, investor protection, and market stability. One of the core requirements under MiCA is obtaining a Crypto-Asset Service Provider (CASP) license, mandatory for businesses offering crypto asset services.
This licensing ensures compliance with strict standards on governance, security, and anti-money laundering (AML), enabling licensed CASPs to operate seamlessly across all EU member states. Whether you are an emerging startup or an established operator, obtaining a CASP license is essential to access the EU’s vast and dynamic market for digital assets.
In Croatia, the Financial Services Supervisory Agency (Hrvatskoj agenciji za nadzor financijskih usluga / HANFA) is the competent authority overseeing CASP licensing under MiCA. Businesses operating or planning to provide crypto-asset services in Croatia must adhere to local implementation requirements alongside MiCA’s EU-wide provisions.
Our firm has a thorough knowledge of Croatian law, ensuring that your compliance efforts are efficient and effective.
We can help your business meet compliance requirements and unlock the potential of the EU crypto market!
In Croatia, the HANFA is the competent authority overseeing CASP licensing under MiCA
Key Numbers about a CASP License in Croatia
3 monthsaverage term of obtaining CASP license after application submission |
up to €150kamount of the share capital depending from CASP activity |
at least severaldirectors in a CASP |
18%corporate income tax (CIT) rate |
from 15% to 33%personal income tax (PIT) rate |
20%capital gains tax (CGT) rate |
Legal Opinion about a CASP License in Croatia
Ganna Voievodina
Manimama
|
CEO
“Obtaining a CASP license in Croatia is essential for businesses offering crypto-asset services. Applicants must meet requirements, including robust AML/CFT compliance, a formal governance structure, and sufficient operational capital. Once licensed, CASPs must adhere to ongoing reporting obligations and maintain compliance with Croatian and EU regulations. A CASP license enhances credibility and provides access to the EU market under a clear regulatory framework”.
Types of Activities with a CASP License in Croatia
Providing custody and administration of crypto-assets on behalf of clients
This service means safekeeping or controlling, on behalf of third parties, crypto-assets or the means of access to such crypto-assets, where applicable in the form of private cryptographic keys. Holdings of crypto-assets on behalf of the clients shall be segregated from CASP’s holdings
Operation of a trading platform for crypto-assets
This service contains of the management of one or more multilateral systems, which brings together or facilitates the bringing together of multiple third-party buying and selling interests for crypto-assets – in the system and in accordance with its rules – in a way that results in a contract, either by exchanging one crypto-asset for another, or a crypto-asset for funds
Exchange of crypto-assets for funds
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for funds by using proprietary capital
Exchange of crypto-assets for other crypto-assets
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other crypto-assets by using proprietary capital
Execution of orders for crypto-assets on behalf of clients
This service means concluding agreements to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets on behalf of third parties and includes the conclusion of agreements to sell crypto-assets at the moment of their issuance
Placing of crypto-assets
This service includes the marketing, on behalf of or for the account of the offeror or of a party related to the offeror, of crypto-assets to purchasers. Before placing the crypto-assets a CASP shall obtain the agreement of the issuers or any third party acting on their behalf
Reception and transmission of orders for crypto-assets on behalf of clients
This service means the reception from a person of an order to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets and the transmission of that order to a third party for execution
Providing advice on crypto-assets
This service means offering, giving or agreeing to give personalized recommendations to a third party, either at the third party’s request or on the initiative of the a CASP providing the advice, in respect of one or more transactions relating to crypto-assets, or the use of crypto-asset services
Providing portfolio management on crypto-assets
This service includes managing portfolios in accordance with mandates given by clients on a discretionary client-by-client basis where such portfolios include one or more crypto-assets
Providing transfer services for crypto-assets on behalf of clients
This service means transfer, on behalf of a natural or legal person, crypto-assets from one distributed ledger address or account to another. Such service may be provided without virtual currency wallet opened for a CASP’s client
Benefits of Obtaining a CASP License in Croatia
Regulatory clarity under Croatian law:
- Croatia has fully implemented the EU’s MiCA, ensuring a clear legal framework for CASPs
- HANFA provides transparent licensing procedures, reducing legal uncertainties
Strategic geographic location:
- Positioned in Central and Southeastern Europe, Croatia provides a convenient business hub for European and global crypto ventures
- Proximity to major financial centers like Vienna, Milan, and Zurich enhances business connectivity
Progressive approach to blockchain and crypto regulation:
- The Croatian government actively supports blockchain development, fostering a crypto-friendly ecosystem
- Several blockchain innovation hubs and regulatory sandboxes have been introduced to help startups
Growing crypto adoption among businesses and consumers:
- A rising number of Croatian businesses, including retailers, real estate firms, and tourism operators, accept cryptocurrency payments
- This creates a vibrant market for CASPs to offer services such as crypto payment processing
EU-wide passporting under MiCA:
- CASPs are able to offer services across the EU without additional licensing
- This enables companies to expand into 27 EU countries seamlessly
Growing pool of blockchain and IT talent:
- Croatia has a highly skilled workforce in blockchain development, IT security, and fintech
- The presence of universities and tech hubs focused on blockchain research supports industry growth
Our Services
STEP 1
Incorporation stage
- Company formation in Croatia
- Provision of a registered address for 1 year
- Opening corporate bank account and transferring the share capital
- Appointment and employment of a local director
- Detailed company structure documentation
STEP 2
Pre-licensing stage
- Preparation and submission legal and financial documents (non-exhaustive list) according to MiCA
- Review of existing policies and procedures, if the company already has them
STEP 3
Licensing stage
- CASP license application assistance
- Conducting communication with the HANFA during the license process
Our Experts in this Area
Step by Step Description
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Initial setup
- Initiating a preliminary project assessment
- Creating an action plan
- Preparation and filing of the package of documents
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Company registration
- Selection of a company name (it is selected at the window of the HITRO.HR entrepreneurial service at one of the branches of the Croatian Financial Agency)
- Certification of required documents (all documentation in a foreign language shall be translated by a sworn translator)
- Registration in the Court Register
- Publication of company registration
- Opening a bank account
- Registration for tax purposes
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Obtaining a CASP license
- Preparation of documents according to MICA
- Submission an application to the licensing authority - HANFA
- Reviewing the application to ensure it is complete (if any documents or information are missing, the applicant will be notified and given a specific deadline to provide the necessary additional documentation)
- Assessment of the documents` content submitted (a detailed review to verify that all regulatory requirements are met)
- Requesting of additional details (if applicable)
- Notification of grant or refusal of the CASP license
- Granting or refusal notification to European Securities and Markets Authority (ESMA)
- Publication in ESMA register
National Legislation of Croatia
In Croatia, the transition period means that applicants may continue to provide services related to the provision of crypto-asset services until July 1, 2026
Regulation:
In July 2024, the Croatian Parliament adopted the Zakon o provedbi Uredbe (EU) 2023/1114 o tržištima kriptoimovine (Implementing Act for MiCA) (Official Gazette no. 85/2024), which serves as the primary legal framework for the regulation of crypto-assets within the country
Licensing authority:
The Croatian Financial Services Supervisory Agency (HANFA) is designated as the competent authority overseeing CASPs in Croatia. HANFA is responsible for the authorization, supervision, and enforcement of regulations pertaining to crypto-asset services, monitor potential abuse in that market, and cooperate with the ESMA. Prior to MiCA's implementation, entities involved in virtual asset transactions were required to register with HANFA in accordance with the AML and CTF Act
Procedure, timelines, fees:
Following the full application of MiCA, i.e. after 30 December 2024, the HANFA must assess within 25 working days of receiving an application for authorisation whether all of the required information has been included in the application. At this stage, however, the HANFA will not assess the quality of the information provided. The HANFA may ask the applicant to supplement the application if some or all of the required information is missing. The HANFA will set a deadline for the submission of any missing information. After the submission of missing information, the HANFA will have 40 working days to make a qualitative assessment of the application. During this period, the HANFA has the opportunity to submit additional requests for clarification, but only the first of these requests will suspend the 40 working day assessment period, for a maximum of 20 working days
There is no fee for registration with the HANFA
Transition period:
MiCA provides for a transitional period to allow existing CASPs to comply with the new regulatory framework. In Croatia, this period extends no later than July 1, 2026. CASPs that were registered with HANFA before December 30, 2024, are permitted to continue offering services during this transitional phase. However, they are limited to the services for which they were originally registered. If a CASP wishes to expand or modify its service offerings after December 30, 2024, it must obtain the necessary authorization from HANFA before doing so
Requirements for Obtaining a CASP License in Croatia
Capital requirements for a CASP vary depending on what services the company will provide - from €50,000 to €150,000
Physical office requirements
A CASP shall have a registered office in Croatia where it carries out at least part of their crypto-asset services
Requirements for key persons
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Senior managers (directors):
- Number: MICA does not specify a minimum and maximum number of directors. However, MICA states (part 2, article 59) that there shall be at least several directors.
- Residency requirements: At least one director must be an EU resident.
- General requirements: Directories must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record;
- a detailed CV;
- statements on time commitment and past professional conduct.
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Shareholders:
- Number: MICA does not specify a minimum and maximum number of shareholders.
- Residency requirements: There is no restriction.
- General requirements: Shareholders must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record;
- an ownership structure chart.
Capital requirements
Capital requirements vary depending on what services the company will provide:
Class 1: A CASP authorized for the following crypto-asset services:
- execution of orders on behalf of clients;
- placing of crypto-assets;
- providing transfer services for crypto-assets on behalf of clients;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets; and/or
- providing portfolio management on crypto-assets.
Minimum capital requirements - €50,000.
Class 2: A CASP authorized for any crypto-asset services under Class 1 and:
- providing custody and administration of crypto-assets on behalf of clients;
- exchange of crypto-assets for funds; and/or
- exchange of crypto-assets for other crypto-assets.
Minimum capital requirements - €125,000.
Class 3: A CASP authorized for any crypto-asset services under Class 2 and:
- operation of a trading platform for crypto-assets.
Minimum capital requirements - €150,000.
Documentation requirements
There are list of documents that must be submitted with the application:
-
Documents required for all CASPs:
- The articles of association of the applicant CASP
- Identity and proof of good repute, knowledge, skills, experience and of sufficient time commitment of the members of the management body
- Information relating to shareholders or members with qualifying holdings
- A program of operations setting out the types of crypto-asset services that the applicant CASP wishes to provide, including where and how these services are to be marketed
- A description of the applicant CASP’s prudential safeguards (insurance policy)
- A description of the applicant CASP’s governance arrangements and internal control mechanisms
- A description of the applicant CASP’s business continuity plan
- Detection and prevention of money laundering and terrorist financing (full packet of policies)
- Descriptions both in technical and non-technical language of applicant CASP’s IT systems and security arrangements
- A description of the applicant CASP’s procedures to handle complaints from clients
- Documents required in case CASP wishes to offer services in other countries:
- List of EU countries where the company wishes to offer its services
- Documents required for certain services (each of the 10 services requires its own documents):
- Custody and administration policy
- A description of the procedure for the segregation of client’s crypto-assets and fund
- The operating rules of the trading platform and market abuse detection
- Information on the exchange of crypto-assets for funds or other crypto-assets (commercial policy)
- The execution policy
- Information on the provision of advice or portfolio management on crypto-assets
- Information on transfer services
Taxes in Croatia
The CIT rates are 18% and 10% applies for companies in Croatia
Corporate Income Tax (CIT)
The CIT is usually levied at a rate of 18%.
A 10% rate applies to taxpayers whose income for the tax period does not exceed €1 million.
Profits from cryptocurrency transactions are subject to the standard CIT rates.
Capital Gains Tax (CGT)
The rate of 12% on capital gains derived from the sale or exchange of financial assets, including cryptocurrencies.
Gains from assets held for more than 2 years are exempt from taxation.
Personal Income Tax (PIT)
Croatia employs a progressive personal income tax system with rates varying based on income levels and the taxpayer's place of residence:
- ranges from 15% to 23% - for a monthly basis up to €5,000 (€60,000 per year)
- ranges from 25% to 33% - for a monthly basis of €5,000 (€60,000 per year)
If the representative body of the local self-government unit has not made a decision to prescribe the level of tax rates, a rate of 20% is applied to the tax base up to €50,400 per year and 30% to the part of the tax base that exceeds the amount of €50,400 per year.
Frequently Asked Questions
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What is a CASP license in Croatia?A CASP license is a regulatory authorization required for companies providing cryptocurrency-related services such as exchanges, custodial services, advisory services, etc. in Croatia.
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Who issues the CASP license in Croatia?The HANFA issues CASP licenses.
-
What services can be provided under a CASP license?
It allows services such as:
- Providing custody and administration of crypto-assets on behalf of clients
- Operation of a trading platform for crypto-assets
- Exchange of crypto-assets for funds
- Exchange of crypto-assets for other crypto-assets
- Execution of orders for crypto-assets on behalf of clients
- Placing of crypto-assets
- Reception and transmission of orders for crypto-assets on behalf of clients
- Providing advice on crypto-assets
- Providing portfolio management on crypto-assets
- Providing transfer services for crypto-assets on behalf of clients
-
What are the key requirements to obtain a CASP license in Croatia?Companies must meet physical office requirements, requirements for managers and shareholders, minimum capital requirements, documentation requirements.
-
Is it mandatory to have a physical office in Croatia to obtain a CASP license?Yes, a local office in Croatia is required for regulatory oversight.
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Is there a minimum capital requirement for obtaining a CASP license?Yes, applicants must meet specific financial and operational adequacy standards, but the exact minimum capital depends on the services offered (€50,000, €125,000, €150,000).
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What is the process for applying for a CASP license?The process involves submitting an application to the HANFA with detailed documentation on the company structure, management, AML policies, and financial plans, etc.
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How long does it take to obtain a CASP license?The preparation of documents and the review process typically takes several months, depending on the completeness of the application and the authority's workload.
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Can CASPs provide cross-border services in the EU?Yes, once licensed under MiCA, CASPs can offer services across the EU without needing separate licenses in other Member States.
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Why is a CASP license necessary in Croatia?A CASP license ensures compliance with Croatian and EU financial regulations under the MiCA Regulation, providing legal security and consumer protection.
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