CroatiaAct on the Requirements for the Accessibility of Products and Services, products covered, manufacturers and authorized representatives, conformity assessment, EU declaration and CE marking
In force since .
An accessibility requirements rule binding public and private bodies.
What it requires
- If you place on the market a consumer general purpose computer hardware system (including a personal computer, notebook, smartphone or tablet) or an operating system for one, a payment terminal, an ATM, ticketing machine, check-in machine or interactive self-service information terminal, consumer terminal equipment with interactive computing capability used for electronic communications services or for access to audiovisual media services, or an e-reader, design and manufacture it to meet the accessibility requirements of Annex I, sections I and II (a self-service terminal: section I only) (Art. 3(1) and 6(1); implements Directive (EU) 2019/882, Art. 4(1) and (2)).
- Under Annex I, section I, design and make the product so that its foreseeable use by persons with disabilities is maximized: give the information on its use (labels, instructions, warnings) and the instructions made available by other means, such as a website, through more than one sensory channel, in an understandable and perceivable way, in fonts of adequate size and shape with sufficient contrast and adjustable spacing, with content in text formats usable for alternative assistive formats, a text alternative for non-text content, and descriptions of the user interface, of the accessibility functions and of the connection to assistive devices; and give the product and its user interface the features of point 2(a) to (n), among them more than one sensory channel, alternatives to speech, to color and to auditory signals, flexible magnification, brightness and contrast, volume and speed control, sequential control and alternatives to fine motor control, no need for extended reach or great strength, no triggering of photosensitive seizures, privacy when accessibility features are used, an alternative to biometric identification, sufficient and adjustable time, and software and hardware interfaces to assistive technologies (Annex I, section I, points 1 and 2).
- Except for a self-service terminal, make the packaging and the information on it (opening, closing, use, disposal, and the product's accessibility features where given) accessible, on the packaging where possible, and make installation, maintenance, storage and disposal instructions that are not on the product, but made available by other means such as a website, available to the public when the product is placed on the market and meeting the same information requirements (Annex I, section II).
- Meet the sector requirements of Annex I, section I, point 2(o): a self-service terminal provides text-to-speech, lets the user use personal headsets, warns through more than one sensory channel where a response is expected within a time, allows that time to be extended, has controls that are contrasted and tactilely distinguishable, does not require an accessibility feature to be activated before it can be used, and works with hearing technologies where it uses sound; an e-reader provides text-to-speech; consumer terminal equipment used for electronic communications services provides real-time text where it offers voice and text, supports high quality audio reproduction, provides total conversation where it offers video with text and voice, connects wirelessly and effectively to hearing technologies, and avoids interference from assistive devices; and consumer terminal equipment used to access audiovisual media services makes available the accessibility components that the audiovisual media service provider supplies for user access, selection, control, personalization and transmission to assistive devices (Annex I, section I, point 2(o)).
- As manufacturer, before you place the product on the market, verify that it is designed and made to meet the accessibility requirements, draw up the technical documentation and carry out (or have carried out) the conformity assessment of Annex IV, draw up the EU declaration of conformity and affix the CE marking, and keep the technical documentation and declaration for five years after placing the product on the market (Art. 9(1) to (4); implements Directive (EU) 2019/882, Art. 7).
- Keep series production in conformity, taking into account changes in the design or characteristics of the product and in the harmonized standards or technical specifications named in the EU declaration (Art. 9(5)).
- Give the product a type, batch or serial number or other identifier (on the packaging or an accompanying document where size or nature does not allow it), show your name, registered trade name or registered trade mark and a single contact address on the product, packaging or an accompanying document, with the contact details in Croatian and Latin script, and attach instructions and safety information, and any labelling, in Croatian and Latin script that is clear, understandable and intelligible (Art. 9(6) to (9)).
- If you find, or have reason to believe, that a product you placed on the market does not conform, take without delay the measures needed to bring it into conformity or withdraw it; if it does not meet the accessibility requirements, tell the competent national authorities of the Member States where you made it available, with details of the non-conformity and the measures taken, and keep a record of non-conforming products and related complaints (Art. 9(10) and (11)).
- The EU declaration of conformity states which accessibility requirements are subject to the exception of Article 17 (Art. 19(2)); from its form is drawn up in Croatian or translated into Croatian where the product is placed on the market in Croatia (Art. 19(4), added by the Act published in Narodne novine 114/2026).
- Affix the CE marking visibly, legibly and indelibly on the product or its data plate before placing it on the market, or on the packaging and accompanying documents where that is not possible or is justified by the nature of the product (Art. 20 and 21).
- If you act as an authorized representative appointed in writing, perform the tasks in the manufacturer's mandate, including keeping the EU declaration and technical documentation available to the inspector for five years and giving the inspector, on a reasoned request, the information and documentation needed to show conformity; the manufacturer's duty under Article 9(1) and the drawing up of the technical documentation are not yours (Art. 10; implements Directive (EU) 2019/882, Art. 8).
- The accessibility requirements apply only so far as compliance needs no significant change that fundamentally alters the basic nature of the product and imposes no disproportionate burden; assess both against Annex VI, document the assessment, give the inspector a copy on request and, unless you are a micro entity of the small economy, notify the market surveillance authority when you rely on the limit (Art. 17(1) to (5) and (8); implements Directive (EU) 2019/882, Art. 14).
These lines are LexLint's reading of the law's text.
If you get it wrong
Penalty structure
Article 32(1) fines a manufacturer that is a legal person EUR 6,630.00 to EUR 132,720.00 for placing on the market a product not designed and made to meet the requirements, not carrying out the conformity assessment or drawing up the technical documentation, not drawing up the EU declaration or affixing the CE marking, not keeping the documentation for five years, failing the series-conformity, identification, name and address and language duties, failing to correct, withdraw or notify, not cooperating with the inspector, not documenting or keeping the Article 17 assessment, misusing the CE marking, and not complying with an enforceable decision of the inspector under Article 23. Article 32(2) fines the responsible person in the legal person EUR 2,650.00 to EUR 6,630.00 and Article 32(3) fines a manufacturer that is a craftsperson or other self-employed natural person EUR 2,650.00 to EUR 6,630.00. Article 33 sets the same three tiers for an authorized representative, and the Act published in Narodne novine 114/2026 replaced Article 33(1) and added to Article 32(1) the offences of not giving the inspector the supply-chain information of Article 14(1), not keeping it for five years, not giving a copy of the Article 17 assessment or its facts on request, relying on the disproportionate-burden limit while funded to improve accessibility, and not notifying the market surveillance authority of reliance on Article 17. The offences are misdemeanours (prekršaj). Under Article 28(3) the inspector, no later than 15 days after the inspection ends or the deadline set in a written order expires, files an indictment proposal to start misdemeanour proceedings or issues a misdemeanour payment order (prekršajni nalog). Under Article 28(1) the inspector does neither, except where the same offence is found again, if the operator removes the irregularities during the inspection, complies with the decision made, or undertakes by a statement on the record to remove irregularities for which no administrative measure is prescribed within a set time.
- Rule
- Fixed only
- As of
- Minimum
- 6,630
- Currency
- EUR
- Fixed cap
- 132,720
Who enforces it
Enforcement body
Electronic communications inspectors of the Croatian Regulatory Authority for Network Industries (HAKOM, Hrvatska regulatorna agencija za mrežne djelatnosti) for products that are radio equipment, and market inspectors of the State Inspectorate (Državni inspektorat) for all other products covered (Art. 22(2) and (3))
What it reaches
Instrument type
an act of a legislature
Applicability criteria
The microenterprise exemption of Article 4(2) reaches services only; a micro entity of the small economy that makes, imports or distributes a listed product is bound, with the relief of Article 17(5).
- As of
- Combinator
- Any of
- Criteria
- a product listed in Article 3(1) of the Act: a consumer general purpose computer hardware system or an operating system for one, a payment terminal, an ATM, ticketing machine, check-in machine or interactive self-service information terminal (other than one built into a vehicle, aircraft, ship or rail vehicle), consumer terminal equipment with interactive computing capability used for electronic communications services or for access to audiovisual media services, or an e-reader
What this law does
Article 3(1) applies the Act to consumer general purpose computer hardware systems and the operating systems for them, payment terminals, ATMs, ticketing machines, check-in machines and interactive self-service information terminals, consumer terminal equipment with interactive computing capability used for electronic communications services or for access to audiovisual media services, and e-readers.
Article 3(1) leaves out self-service terminals built into vehicles, aircraft, ships or rail vehicles as integral parts. Article 6(1) requires every product within Article 3(1) to meet the accessibility requirements of Annex I, sections I and II, and requires a self-service terminal to meet those of section I only.
Article 9(1) to (4) requires a manufacturer to verify that the product is designed and made to meet the requirements, to draw up the technical documentation and carry out the conformity assessment of Annex IV, to draw up the EU declaration of conformity and affix the CE marking, and to keep the documentation and declaration for five years after placing the product on the market.
Article 9(5) to (11) requires a manufacturer to keep series production in conformity, to mark the product for identification, to show its name and a contact address in Croatian on the product, to attach instructions and safety information in Croatian and Latin script, to correct or withdraw a non-conforming product, and to notify the authorities and keep a record of non-conforming products and complaints.
Article 10 lets a manufacturer appoint an authorized representative in writing, who carries out the tasks in the mandate, including keeping the EU declaration and technical documentation for five years and giving the inspector the information and documentation needed on a reasoned request, but who does not take on the manufacturer's duty under Article 9(1) or the drawing up of the technical documentation.
Article 19(2) requires the EU declaration of conformity to carry a note on the accessibility requirements that are subject to the exception of Article 17. Article 19(4), added by the Act published in Narodne novine 114/2026, requires the form of the EU declaration of conformity to be drawn up in Croatian or translated into Croatian where the product is placed on the market in Croatia.
Article 12(2) of the amending Act corrects the cross-reference in point 2(b) of Annex IV, the conformity assessment procedure, from Article 4 to Article 6. Article 21 requires the manufacturer to affix the CE marking visibly, legibly and indelibly on the product or its data plate before placing the product on the market. Article 32(1) fines a manufacturer that is a legal person EUR 6,630.00 to EUR 132,720.00 for the listed offences.
Article 32(2) and (3) fine the responsible person in the legal person, and a manufacturer that is a craftsperson or other self-employed natural person, EUR 2,650.00 to EUR 6,630.00 for the same offences. Article 33(1), as replaced by the Act published in Narodne novine 114/2026, fines an authorized representative that is a legal person EUR 6,630.00 to EUR 132,720.00 for the listed offences.
Article 33(2) and (3) fine the responsible person in the legal person, and an authorized representative that is a craftsperson or other self-employed natural person, EUR 2,650.00 to EUR 6,630.00.
When LexLint raises it
When your app profile says your app distributes a software product.
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