CroatiaAct on the Requirements for the Accessibility of Products and Services, market surveillance authorities, inspection, corrective measures and orders, and the misdemeanour procedure
NN 89/2025, čl. 22. do 28. i 36.a Zakona o zahtjevima za pristupačnost proizvoda i usluga
In force since .
An accessibility requirements rule binding public and private bodies.
What it requires
- If an inspector finds that a product does not meet the accessibility requirements, take the corrective measures the inspector requests within the period set, which must be reasonable and proportionate to the nature of the non-conformity (Art. 23(2)).
- Correct a formal non-conformity (a misplaced or missing CE marking, a missing or wrongly drawn EU declaration, missing or incomplete technical documentation, missing or wrong identification information, or another administrative requirement of Article 9 or 11) that carries no health or safety risk within the period set in the inspection record; if you do not, the inspector decides to prohibit placing the product on the market or to order its withdrawal (Art. 23(3) and (4)).
- Comply with an inspector's decision, where a product does not meet the requirements or poses a risk to health or safety, to remove the non-conformity within a period set, to stop placing the product on the market or making it available, to withdraw it immediately or recall it from end users and publish information on the risks, to destroy it where necessary to protect health or safety, to stop supply and display temporarily while examinations and tests run, or to put clear warnings in Croatian and Latin script on the product or give them to end users (Art. 23(5) to (7)).
- If you operate a public communications service, an internet access service or a hosting service, cooperate with the inspection authorities, and when a decision under Article 23(9) orders it for a non-conforming product sold at a distance, remove the content, restrict access to the online interface or display an explicit warning to end users; if you run a domain registry, delete the fully qualified domain name and let the authority register it (Art. 23(9) and (11)).
- Bear the cost of a product sample, examination or test if the sample is found not to meet the accessibility requirements, and the cost of an examination, test or expert assessment of an e-commerce service found not to conform, from (Art. 22(7) and 25(12), added by the Act published in Narodne novine 114/2026).
- If an inspector finds that a service does not conform, take the corrective measures requested in the inspection record within the period set, and comply with the decision ordering you to remove the non-conformity within the period it sets (Art. 26(1) and (2)).
These lines are LexLint's reading of the law's text.
Who enforces it
Enforcement body
For products, the electronic communications inspectors of HAKOM (radio equipment) and the market inspectors of the State Inspectorate (all other products) (Art. 22(2) and (3)); for services, the authorities named in Art. 25(1) to (9): HAKOM, the Agency for Media, the Croatian Civil Aviation Agency, the road traffic inspectors and the navigation safety inspectors of the ministry responsible for sea, transport and infrastructure, the Croatian National Bank, HANFA and the State Inspectorate
What it reaches
Instrument type
an act of a legislature
Applicability criteria
From the bar on appeal in Article 27(1) does not apply to public procurement procedures under the public procurement law (Article 27(2)), and the misdemeanour provisions of Articles 32 to 36 do not apply to those procedures (Article 36a).
- As of
- Combinator
- Any of
- Criteria
- an economic operator whose product within Article 3(1) or service within Article 3(2) is subject to inspection under Articles 22 to 26 of the Act
- an operator of public communications services, an internet access provider, a hosting provider or a domain registry, for a decision under Article 23(9) concerning a product sold online or by other distance sale (Article 23(9) and (11))
What this law does
Article 22(2) and (3) assign the market surveillance of products to the electronic communications inspectors of the Croatian Regulatory Authority for Network Industries (HAKOM) where the product is radio equipment, and to the market inspectors of the State Inspectorate for all other products. Article 22(1) has the market surveillance of products carried out in accordance with the provisions of Regulation (EU) 2019/1020 that it lists.
Article 22(4) requires the competent inspector of Article 22(2), where an economic operator relies on Article 17, to check that it carried out the assessment, to review the assessment and its results, including the correct use of the Annex VI criteria, and to check conformity with the accessibility requirements.
Article 22(5), added by the Act published in Narodne novine 114/2026, lets the State Inspectorate's inspectors carry out the examinations and tests of products needed to determine conformity and take product samples for testing. Article 22(7), added by the same Act, makes the State Inspectorate bear the cost of the sample, examination or test if the samples meet the requirements, and the economic operator bear it if they do not.
Article 22(6), added by the same Act, lets those inspectors entrust particular steps of the inspection to an expert institution or other expert legal person where they lack the expertise or equipment.
Article 22(8), numbered 22(5) until , lets the inspector give consumers, on request and in an accessible form, the information it holds on economic operators' conformity with the accessibility requirements and on the Article 17 assessment, unless confidentiality under Article 17 of Regulation (EU) 2019/1020 prevents it.
Article 23(2) lets the inspector require an economic operator to take all appropriate corrective measures within a reasonable period proportionate to the nature of the non-conformity. Article 23(3) and (4) require the inspector to demand, through the inspection record, correction of formal non-conformities within a set period, and to decide to prohibit placing the product on the market or to order its withdrawal if the operator does not act within it.
Article 23(5) lets the inspector, where a product does not meet the requirements or poses a risk to health or safety, order by decision one or more of correction within a period, a ban on placing it on the market or making it available, immediate withdrawal or recall with public information on the risks, destruction where necessary, a temporary ban during examinations and tests, and warnings in Croatian.
Article 23(8) requires the inspector to notify the economic operator before a corrective measure and to give it at least ten working days to respond, unless urgency or another public-interest reason makes that impossible.
Article 23(9) lets the inspector, for products sold online or by other distance sale where corrective measures leave no other effective means of removing a serious risk, order operators of public communications services, internet access providers and hosting providers to remove content, restrict access to the online interface or display an explicit warning, and order domain registries to delete the fully qualified domain name so that the authority can register it.
Article 23(11) requires those operators, providers and hosting providers to cooperate with the inspection authorities. Article 23(10) gives an operator of public communications services, an internet access provider or a hosting provider that suffers damage from such a decision the right to claim compensation from the economic operator under the general rules on damages.
Article 25 assigns the market surveillance of services to HAKOM inspectors for electronic communications services and e-books, the media agency for services giving access to audiovisual media services, the Croatian Civil Aviation Agency, road traffic inspectors, rail market regulation inspectors and navigation safety inspectors for the transport services, the Croatian National Bank and HANFA for consumer banking services, and the State Inspectorate for e-commerce.
Article 4 of the amending Act replaces the Agency for Electronic Media with the Agency for Media in Article 25(2). Article 25(10), added by the amending Act, requires the market surveillance authorities for services to make information on their organization, identity, competences and procedures under the Act available, in an accessible form on request.
Article 25(12), added by the amending Act, makes the State Inspectorate bear the cost of the examination, test or expert assessment of an e-commerce service that is found to conform, and the economic operator bear it if the service does not conform. Article 26 requires the inspector, for a service that does not conform, to demand correction through the inspection record within a set period and, failing that, to decide that the provider must remove the non-conformity within a period it sets.
Article 27 provides that no appeal lies against an inspector's decision but an administrative dispute may be started. Article 5 of the amending Act makes that rule paragraph (1) of Article 27 and adds a paragraph (2) that disapplies it to public procurement procedures under the public procurement law. Article 36a, added by the amending Act, disapplies the misdemeanour provisions of Articles 32 to 36 to public procurement procedures under the public procurement law.
Article 30(5) of Directive (EU) 2019/882 provides that its article on penalties does not apply to procurement procedures subject to Directive 2014/24/EU or Directive 2014/25/EU.
Article 28(1) provides that, except where the same offence is found again, the inspector files no indictment proposal and issues no misdemeanour payment order if the operator removes the irregularities during the inspection or before the decision, complies with the enforceable decision, or undertakes by its statement on the record to remove irregularities for which no administrative measure is prescribed.
Article 28(3) requires the inspector to file the indictment proposal or issue the misdemeanour payment order without delay, and within 15 days of the end of the inspection or of the deadline in the written order, if the operator does not act as described.
When LexLint raises it
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