Croatia EAA Fines: Up to €132,720, for Services Too

Croatia's €132,720 Accessibility Fine Is a Kuna Figure in Disguise

The oddest number in any EU accessibility law turns out to be one million Croatian kuna, converted at the fixed euro rate and rounded down. Every band in the schedule is. And unlike almost every other member state, Croatia fines an inaccessible service exactly as hard as a non-compliant product.

Quick answer

Croatia's EAA law — the Zakon o zahtjevima za pristupačnost proizvoda i usluga, published in Narodne novine 89/2025 on 13 June 2025 and in force on 28 June 2025 — sets fines by economic-operator role. A legal person that is a manufacturer, authorised representative or service provider faces €6,630 to €132,720. Importers face €3,310–€66,360, distributors €1,990–€13,270. The responsible individual inside the company is fined separately, €1,320–€6,630 depending on role. Supervision sits with the Državni inspektorat. Amendments went to public consultation in July 2026, leaving the penalties untouched.

Where €132,720 comes from

Croatia adopted the euro on 1 January 2023, at the irrevocably fixed rate of 7.53450 kuna to the euro. Take round kuna figures, divide by that rate, round down to the nearest ten euros — and you get every band in the fine schedule:

Eight for eight. The number that appears in every "EAA fines by country" table as Croatia's distinctive high ceiling was never chosen in euros at all — it's one million kuna, carried across the currency changeover.

This is the second time this pattern has appeared in the 27. Portugal's maximum of €44,891.81 is an escudo amount converted at the euro changeover. When a national accessibility ceiling looks arbitrary and oddly precise, the usual explanation is not policy — it's arithmetic from a former currency.

What the law says

The bands are set operator by operator in Arts. 32–36, each in the same form:

« 6630,00 do 132.720,00 eura » — legal person (Art. 32, manufacturer; Art. 33, authorised representative; Art. 36, service provider)

« 2650,00 do 6630,00 eura » — responsible person in the legal person, and sole trader/craftsperson

« 3310,00 do 66.360,00 eura » — importer, legal person (Art. 34), with « 1990,00 do 6630,00 eura » for the responsible person

« 1990,00 do 13.270,00 eura » — distributor, legal person (Art. 35), with « 1320,00 do 6630,00 eura » for the responsible person

— Zakon o zahtjevima za pristupačnost proizvoda i usluga, NN 89/2025, Arts. 32–36 (Narodne novine)

Set out as a hierarchy:

Services are punished as hard as products — which is unusual

Look at where the service provider sits: in the top band, identical to the manufacturer's.

Almost every member state treats services more leniently than products. Slovenia, immediately across the border, caps manufacturers at €40,000 and a large company's inaccessible e-commerce service at €10,000 — a four-to-one ratio. Croatia applies the same €132,720 to both. For a business whose Croatian exposure is a website rather than a physical product, that single drafting choice makes Croatia roughly thirteen times the risk of Slovenia, for the same conduct, across a shared border.

That comparison is worth more than either country's headline figure. Both transposed the same directive; the divergence is entirely a matter of national choice about how seriously to price an inaccessible service.

Note too that the responsible individual is a separate respondent, fined €2,650–€6,630 in their own name. Slovenia does the same thing at €50–€250. Croatia's personal exposure is an order of magnitude larger.

Fix it during the inspection and there's usually no charge

Art. 28 contains Croatia's most practically valuable provision — an opportunity principle governing whether the inspector files a misdemeanour charge at all.

The inspector will generally not file for a first-time breach where the economic operator either corrects the irregularity during the inspection or before the decision issues, complies with an executive decision, or commits in writing to a corrective deadline and then meets it.

Three conditions attach, and they're the part to plan around:

• Repeat breaches lose the leniency entirely.
• Missing a deadline you committed to in writing triggers a mandatory misdemeanour filing within 15 days — the discretion evaporates.
• The protection covers the charge, not the underlying obligation.

This is the same instinct as Slovakia's § 10(3) waiver, drafted differently: Slovakia makes the waiver mandatory and automatic on remediation; Croatia leaves it to the inspector's judgement, but converts it into a hard obligation to prosecute the moment you break a promise you made in writing.

One procedural warning under Art. 27: there is no administrative appeal against an inspector's decision. The only route is an administrative court action (upravni spor). If you intend to contest a finding, you are going to court, not to a review body.

Who enforces it

The Državni inspektorat (State Inspectorate) runs market surveillance, with specialised agencies taking specific product and service categories — the financial ones going to HNB (the Croatian National Bank) and HANFA (the financial services supervisor). For services, Art. 26 sets the sequence: the inspector orders corrective measures with a deadline in the inspection record, and if the provider doesn't comply, issues a formal decision setting a new deadline.

Compared with Portugal's ten-way split, Croatia is relatively consolidated — one lead inspectorate with a small number of sectoral carve-outs.

Passed fifteen days before the deadline — and already being amended

Croatia was among the last member states to transpose. The act was published on 13 June 2025 and took effect on 28 June 2025: fifteen days between publication and application, for a law imposing design obligations that take months to implement. Any Croatian business that waited for the national text had no meaningful lead time at all.

Amendments went to public consultation on 14 July 2026. The Ministry of Labour describes them as « nomotehničko usklađivanje s europskom Direktivom » — technical harmonisation with the Directive — rather than substantive change, and the fine bands stay as they are. The proposed changes clarify the electronic-communications rules, require the EU declaration of conformity to be in Croatian, and oblige regulatory bodies to publish their own information accessibly.

That last one is a small but telling addition: a year in, Croatia is legislating to make its accessibility regulators accessible.

If your Croatian analysis is based on an older instrument or a pre-2025 citation, re-base it on NN 89/2025 — that is the operative act.

Has it been enforced yet?

No accessibility misdemeanour proceedings or fines have been reported. The Državni inspektorat publishes enforcement totals across its remit — figures in the millions of euros for its general inspection work — but nothing attributable to the accessibility act.

Art. 28 offers a partial explanation: in Croatia, a first-time breach corrected during the inspection produces no charge at all. A regime designed that way will generate corrections long before it generates a reportable penalty, so an empty enforcement record here is weaker evidence of inactivity than it would be in, say, Austria.

What this means for your business

1. If you provide a service to Croatian consumers, don't assume services are the cheap side. On paper this is one of the harshest markets in the EU for services — the same top band as a manufacturer, €132,720, plus €2,650–€6,630 against a named individual.
2. If an inspector arrives, Art. 28 is the whole game. Correcting during the inspection, or committing in writing to a deadline and hitting it, is the difference between no charge and a misdemeanour. The one unforgivable move is committing to a date and missing it — that removes the inspector's discretion and starts a 15-day clock.
3. Budget for Croatian-language conformity documentation. It's proposed to become explicit in the amendments, and it follows the same pattern as Czechia, which already requires it.

Frequently asked questions

What is the EAA fine in Croatia?

€6,630–€132,720 for a legal person that is a manufacturer, authorised representative or service provider; €3,310–€66,360 for importers; €1,990–€13,270 for distributors. Responsible individuals are fined separately, from €1,320 to €6,630.

Why is the maximum such a strange number?

Because it isn't a euro figure. €132,720 is one million kuna divided by the fixed rate of 7.53450 and rounded down — as is every other band in the schedule.

Is Croatia harsher than its neighbours?

For services, substantially. A large company's inaccessible e-commerce service caps at €10,000 in Slovenia and €132,720 in Croatia.

Can I avoid a fine by fixing the problem?

Usually, for a first breach. Art. 28 means the inspector generally won't file a misdemeanour charge if you correct during the inspection or meet a deadline you committed to in writing. Break that commitment and filing becomes mandatory within 15 days.

Can I appeal an inspector's decision?

Not administratively. Art. 27 allows only an administrative court action (upravni spor).

Related

• ← Back to EAA Fines by Country — the full 27-state comparison
• Official text: Zakon o zahtjevima za pristupačnost proizvoda i usluga, NN 89/2025 (Narodne novine)
• Slovenia's EAA fine — the same border, a thirteenth of the service ceiling
• Portugal's EAA fine — the other ceiling inherited from a pre-euro currency
• Slovakia's EAA fine — the other "fix it and the fine goes away" regime, drafted as a mandatory waiver