Law / Croatia

Zakon o provedbi Uredbe (EU) 2022/2065 (Act on the Implementation of the Digital Services Act), Coordinator, Orders, Remedies and Fines

Act on the Implementation of the Digital Services Act (Zakon o provedbi Uredbe (EU) 2022/2065, Narodne novine 67/2025, br. 857) Articles 4 to 26

In force since .

A transparency and process rule binding public and private bodies.

Obligation class
Disclosure, Reporting, Governance

As of .

What it requires

  • Act without delay on an order to act against illegal content (Article 9 of Regulation (EU) 2022/2065) or an order to provide information (Article 10), tell the issuing authority without delay that you have carried it out and when, and give the affected recipient the information Article 9(5) requires.
  • Designate a point of contact for authorities and one for recipients of your service, and appoint a legal representative if you are not established in the European Union (Articles 11 to 13 of the Regulation).
  • Meet the terms and conditions, transparency reporting, notice and action and statement of reasons duties of Articles 14 to 17 of the Regulation, which the Act punishes as misdemeanors.
  • If you run an online platform, set up an internal complaint-handling system, take measures against misuse, and meet the transparency reporting, interface design, advertising, recommender system and protection of minors duties of Articles 20 and 23 to 28 of the Regulation.
  • If your online platform lets consumers conclude distance contracts with traders, meet the trader traceability, interface design and consumer information duties of Articles 30 to 32 of the Regulation.
  • If you are established in Croatia, notify the Coordinator that you provide intermediary services within three months of the Coordinator publishing how to notify; the notification is not a condition for providing the service.

If you get it wrong

Penalty structure

Articles 18(1), 19(1) and 20(1) fine a legal person from EUR 6,630 to EUR 66,360 or up to 6 percent of annual worldwide turnover in the previous financial year, whichever is higher. The responsible person in the legal person and a sole trader face fines of EUR 1,320 to EUR 6,630. Article 22 sets up to 1 percent of worldwide turnover for incorrect, incomplete or misleading information, failure to answer or correct it, and refusal of an inspection.

Rule
Higher of
As of
Minimum
6,630
Currency
EUR
Fixed cap
66,360
Turnover percentage cap
6

Who enforces it

Enforcement body

Croatian Regulatory Authority for Network Industries (HAKOM), the Digital Services Coordinator and the prosecutor for most misdemeanors; the authorities in Article 6(1) for Articles 25, 26 and 30 to 32; the Personal Data Protection Agency for Articles 27 and 28; the Zagreb Municipal Misdemeanor Court for objections to orders.

What this law does

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Research summary

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Article 4(1) of the Act on the Implementation of Regulation (EU) 2022/2065 names the Croatian Regulatory Authority for Network Industries (Hrvatska regulatorna agencija za mrežne djelatnosti, HAKOM) the Digital Services Coordinator within the meaning of Article 49 of the Regulation. Article 4(2) gives the Coordinator the powers under Articles 51 and 53 of the Regulation and the powers over out-of-court dispute settlement bodies and the award of trusted flagger status.

Article 6(1) names the authorities that issue orders to act against illegal content and orders to provide information under Articles 9 and 10 of the Regulation, among them the State Attorney's Office and the Ministry of the Interior for offences, the Personal Data Protection Agency, the Customs Administration for intellectual property, the State Inspectorate, the Ministry of Health and the Electronic Media Agency.

Article 6(3) requires an order to act against illegal content to contain all the elements of Article 9 of the Regulation and to be issued in Croatian, with the elements in Article 9(2)(a) and (b) translated into the language the provider has chosen or that is agreed bilaterally. Article 7 makes the Personal Data Protection Agency the authority for Articles 27 and 28 of the Regulation.

Article 8 makes the authorities in Article 6(1) responsible, each in its own field, for Articles 25, 26 and 30 to 32 of the Regulation. Article 12 gives a provider or recipient eight days from receipt of an order under Article 9 or 10 to file an objection with the Zagreb Municipal Misdemeanor Court through the authority that issued the order.

Article 17(2) gives an authority that finds a breach of Articles 25 to 28 or 30 to 32 of the Regulation all the powers in Article 51, including ordering measures by decision with a suitable deadline to end the breach.

Article 18(1) punishes a provider of intermediary services that is a legal person with a fine of EUR 6,630 to 66,360, or up to 6 percent of its annual worldwide turnover in the previous financial year, whichever is higher, if it does not act without delay on an order to act against illegal content.

The same fine applies under Article 18(1) points 6 to 12 to a provider that fails to designate points of contact, appoint a legal representative, meet the terms and conditions, transparency reporting, notice and action, and statement of reasons duties in Articles 11 to 17 of the Regulation.

Article 19(1) applies the same fine to a provider of online platforms that fails to set up an internal complaint-handling system, to take measures against misuse, or to meet the transparency reporting, interface design, advertising, recommender system and protection of minors duties in Articles 20 and 23 to 28 of the Regulation.

Article 20(1) applies the same fine to an online platform that lets consumers conclude distance contracts with traders and fails to meet the trader traceability, interface design and consumer information duties in Articles 30 to 32 of the Regulation. Article 22 sets a fine of up to 1 percent of worldwide turnover for supplying incorrect, incomplete or misleading information, for not answering or correcting it, and for not consenting to an inspection.

Article 25(1) ended the application of Articles 16, 17, 18 and 21 of the Electronic Commerce Act when this Act took effect. Article 26 brought the Act into force on the eighth day after its publication in the Narodne novine.

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