CroatiaAct on the Requirements for the Accessibility of Products and Services, services covered, service providers, Annex I requirements for services, exemptions and transitional rules
NN 89/2025 čl. 3. st. 2. i 3., čl. 4., 6. st. 2., čl. 7., 15., 16. st. 3., 36. i 37. te Prilog I. odjeljci III. i IV. Zakona o zahtjevima za pristupačnost proizvoda i usluga
In force since .
An accessibility requirements rule binding public and private bodies.
What it requires
- If you provide to consumers an electronic communications service (other than machine-to-machine transmission), a service giving access to audiovisual media services, the website, mobile service, app, electronic ticket, travel-information and interactive self-service terminal elements of air, bus, rail or waterborne passenger transport, a consumer banking service, e-books and dedicated software, or an e-commerce service, design and provide the service to meet the accessibility requirements of Annex I, sections III and IV (urban, suburban and regional transport: section IV only) (Art. 3(2), 6(2) and 15(1); implements Directive (EU) 2019/882, Art. 4(1) and (3) and Art. 13(1)).
- Make the products you use to provide the service accessible under Annex I, sections I and II; give information about how the service works and about the accessibility features of the products used and their interoperability with assistive devices, through more than one sensory channel, in an understandable and perceivable way, in text that can be turned into alternative formats, in suitable fonts with sufficient contrast, with a text alternative for non-text content; keep websites (including related web applications) and mobile services and apps consistently perceivable, operable, understandable and robust; and where you offer support services (help desks, call centers, technical support, relay services, training), give information on the accessibility of the service and its compatibility with assistive technologies through accessible means of communication (Annex I, section III, point (d), as corrected from by the Act published in Narodne novine 114/2026).
- For an electronic communications service, offer real-time text alongside voice, total conversation where video is offered with voice, and synchronized voice and text (with video where offered) in communications to emergency services, passed to the most appropriate emergency answering point (Annex I, section IV, point (a)).
- For a service giving access to audiovisual media services, provide electronic program guides that are perceivable, operable, understandable and robust and show whether accessibility is enabled, and transmit access services (subtitles for the deaf and hard of hearing, audio description, spoken subtitles, sign language interpretation) with appropriate quality, synchronized with sound and video, under the user's control (Annex I, section IV, point (b)).
- For air, bus, rail or waterborne passenger transport, give information on the accessibility of vehicles, surrounding infrastructure and built environment and on assistance for persons with disabilities, and information on smart ticketing, real-time travel information and additional service information such as staff at stations, lifts out of order and temporarily unavailable services (Annex I, section IV, point (c)); for urban, suburban and regional transport, make the self-service terminals accessible under section I (Annex I, section IV, point (d)).
- For a consumer banking service, provide electronic identification, electronic signature, secure element and payment-service methods that are perceivable, operable, understandable and robust, and keep information understandable and no more complex than level B2 of the Croatian language in the Common European Framework of Reference for Languages (Annex I, section IV, point (e)).
- For e-books and dedicated software, provide synchronized text and audio where an e-book has audio content, do not prevent assistive technology from working, give access to content, navigation and display with a flexible structure and choice of presentation, allow alternative presentations that work with different assistive technologies, make e-books findable through accessibility metadata, and do not let digital rights management block accessibility features (Annex I, section IV, point (f)).
- For an e-commerce service, give information on the accessibility of the products and services sold where the responsible operator supplies it, make identification, security and payment functions that are part of the service perceivable, operable, understandable and robust, and provide identification, electronic signature and payment-service methods that are perceivable, operable, understandable and robust (Annex I, section IV, point (g)).
- Prepare the information required by Annex V explaining how the service meets the accessibility requirements, state it in your general terms or an equivalent document, make it available to the public in written and oral form including in a manner accessible to persons with disabilities, and keep it for as long as the service is provided (Art. 15(2) and (3); implements Directive (EU) 2019/882, Art. 13(2)).
- Have a procedure that keeps the service in conformity, taking into account changes in the characteristics of the service, in the accessibility requirements, and in the harmonized standards or technical specifications on which conformity is based (Art. 15(4)).
- If the service does not conform, take the corrective measures needed and notify without delay the competent authorities of the Member States where the service is provided, with details of the non-conformity and the measures taken; on a reasoned request of the inspector, give all information needed to show conformity and cooperate on the measures taken (Art. 15(5) and 16(3)).
- The accessibility requirements apply only so far as compliance needs no fundamental alteration of the service and imposes no disproportionate burden; assess both against Annex VI, document the assessment and keep it for five years from the day the service was last provided, give the inspector a copy on request, repeat the burden assessment for each category or type of service when the service changes, when the inspector asks and at least every five years, and notify the authority of the Member State where the service is provided when you rely on the limit (Art. 17(1) to (4), (6) and (8)).
- A passenger transport service that meets the accessible-information and accessibility-information requirements of Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) 2021/782, (EU) No 1177/2010 and (EU) No 181/2011 and of the Croatian railway safety and interoperability law and the law establishing the agency for the investigation of air, maritime and rail accidents is treated as meeting the corresponding requirements of the Act, except where the Act sets an additional requirement (Art. 7; Directive (EU) 2019/882, Art. 5).
- The Act does not apply to micro entities of the small economy that provide services (Art. 4(2); Directive (EU) 2019/882, Art. 4(5)).
- The Act does not apply to pre-recorded time-based media and office file formats published before , to online maps and mapping services where the key information is given in an accessible digital way for maps intended for navigation, to third-party content that you did not fund or develop and that is not under your control, or to archive content that is not updated or edited after (Art. 4(1)).
- Until you may keep providing your services with products you lawfully used for similar services before that date, service contracts concluded before may continue unchanged until they expire but for no more than five years from that date, and self-service terminals you lawfully used for services before may stay in use until the end of their economically useful life but for no more than twenty years after they entered use (Art. 37(1) to (3); Directive (EU) 2019/882, Art. 32).
These lines are LexLint's reading of the law's text.
If you get it wrong
Penalty structure
Article 36(1) fines a service provider that is a legal person EUR 6,630.00 to EUR 132,720.00 for not cooperating with the inspector, not ensuring that the design and provision of the service meet the requirements, not preparing and making available the Annex V information or not keeping it for the period of the service, not running the procedure that keeps the service in conformity, not taking corrective measures or notifying the authorities of non-conformity, and not documenting or keeping the Article 17 assessment. Article 36(2) fines the responsible person in the legal person EUR 2,650.00 to EUR 6,630.00 and Article 36(3) fines a service provider that is a craftsperson or other self-employed natural person EUR 2,650.00 to EUR 6,630.00. The Act published in Narodne novine 114/2026 added to Article 36(1) the offences of not giving the inspector a copy of the Article 17 assessment on request, not repeating the burden assessment when the service changes, when the inspector asks and at least every five years, relying on the disproportionate-burden limit while funded to improve accessibility, and not notifying the 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
By service (Art. 25): electronic communications inspectors of the Croatian Regulatory Authority for Network Industries (HAKOM) for electronic communications services and for e-books and dedicated software; the Agency for Media (Agencija za medije, named Agencija za elektroničke medije in the Act as published) for services giving access to audiovisual media services; the Croatian Civil Aviation Agency for air passenger transport; road traffic inspectors of the ministry responsible for sea, transport and infrastructure for bus transport; HAKOM rail market regulation and passenger rights inspectors for rail; navigation safety inspectors or authorized persons of that ministry for waterborne transport; the Croatian National Bank and the Croatian Financial Services Supervisory Agency (HANFA), each within its competence under special regulations, for consumer banking services; and market inspectors of the State Inspectorate for e-commerce
What it reaches
Instrument type
an act of a legislature
Applicability criteria
Article 4(2) does not reach products: a micro entity of the small economy that makes, imports or distributes a product within Article 3(1) stays bound.
- As of
- Combinator
- All of
- Criteria
- a service listed in Article 3(2) of the Act that is provided to consumers: an electronic communications service (other than machine-to-machine transmission), a service giving access to audiovisual media services, the elements named in Article 3(2) of air, bus, rail and waterborne passenger transport services, a consumer banking service, e-books and dedicated software, or an e-commerce service
- a provider that is not a micro entity of the small economy; a micro entity is a person with fewer than ten workers on average per year that, on the financial statements of the previous year, has annual operating income of up to the equivalent of EUR 2 million, or total assets (for a profit-tax payer) or long-term assets (for an income-tax payer) of up to the equivalent of EUR 2 million (Article 4(2) and Article 5, point 22; point 18 until )
What this law does
Article 3(2) applies the Act to the following services provided to consumers: electronic communications services other than machine-to-machine transmission, services giving access to audiovisual media services, elements of air, bus, rail and waterborne passenger transport services, consumer banking services, e-books and dedicated software, and e-commerce services.
For air, bus, rail and waterborne passenger transport, Article 3(2) covers websites, services on mobile devices including apps, electronic tickets and electronic ticketing services, transport information including real-time information on interactive screens in the European Union, and interactive self-service terminals in the European Union. For urban, suburban and regional transport, Article 3(2) covers only the interactive self-service terminals.
Article 3(3) applies the Act to answering communications to the single European emergency number 112 and other emergency numbers, as the electronic communications law defines.
Article 4(1) excludes from the Act pre-recorded time-based media and office file formats published before , online maps where the key information is given in an accessible digital way for navigation maps, third-party content the operator did not fund, develop or control, and archive content not updated or edited after . Article 4(2) excludes micro entities of the small economy that provide services from the Act.
Article 6(2) requires every service within Article 3(2) to meet the accessibility requirements of Annex I, sections III and IV, and requires urban, suburban and regional transport to meet those of section IV only.
Annex I, section III requires the products used to provide a service to be accessible, information on the operation of the service and its accessibility features to be provided in accessible ways, websites and mobile services and applications to be perceivable, operable, understandable and robust, and support services to give accessibility information by accessible means.
Article 12(1) of the amending Act corrects Annex I, section III, point (d), so that support services give information on the accessibility of the service and its compatibility with assistive technologies, in place of information on the accessibility of the product.
Annex I, section IV requires electronic communications services to offer real-time text alongside voice and total conversation where video is offered, and requires emergency communications that use voice and text to be synchronized and passed to the most appropriate emergency answering point.
Annex I, section IV requires services giving access to audiovisual media services to provide electronic program guides that are perceivable, operable, understandable and robust, and to transmit access services such as subtitles for the deaf and hard of hearing, audio description, spoken subtitles and sign language interpretation with appropriate quality, synchronized with sound and video, under the user's control.
Annex I, section IV requires air, bus, rail and waterborne passenger transport services to give information on the accessibility of vehicles, infrastructure and built environment and on assistance for persons with disabilities, and information on smart ticketing, real-time travel information and additional service information.
Annex I, section IV requires consumer banking services to provide electronic identification, electronic signature, secure element and payment methods that are perceivable, operable, understandable and robust, and information that does not exceed level B2 of the Croatian language in the Common European Framework of Reference for Languages.
Annex I, section IV requires e-books to provide synchronized text and audio where an e-book has audio content, not to block assistive technology, to allow navigation and alternative presentation, to carry accessibility metadata, and not to use digital rights management that blocks accessibility features.
Annex I, section IV requires e-commerce services to give information on the accessibility of the products and services sold where the responsible operator supplies it, and to make identification, security and payment functions and methods perceivable, operable, understandable and robust.
Article 7 treats a passenger transport service that meets the accessible-information and accessibility-information requirements of the EU passenger rights regulations and the Croatian railway and accident-investigation laws as meeting the corresponding requirements of the Act, unless the Act sets an additional requirement.
Article 15(1) to (3) requires a service provider to ensure that the design and provision of the service meet the requirements, to prepare the information required by Annex V and explain how the service meets them, to make that information available to the public in written and oral form including in a way accessible to persons with disabilities, and to keep it for the whole period of providing the service.
Article 15(4) and (5) requires a service provider to have a procedure that keeps the service in conformity, to take the corrective measures needed, and to notify without delay the competent authorities of the Member States where the service is provided if the service does not conform. Article 16(3) requires a service provider to give the inspector, on a reasoned request, all information needed to show that the service conforms and to cooperate on measures taken to ensure conformity.
Article 37(1) lets service providers keep providing their services until with products they lawfully used for similar services before that date. Article 37(2) lets service contracts concluded before continue unchanged until they expire, but for no more than five years from that date.
Article 37(3) lets self-service terminals that providers lawfully used before stay in use for similar services until the end of their economically useful life, but for no more than twenty years after they entered use. Article 37(4) applies to the answering of communications to 112 the deadline set by the electronic communications law and its implementing rules.
Article 32(2) of Directive (EU) 2019/882 lets Member States provide that self-service terminals lawfully used by service providers before may continue to be used until the end of their economically useful life, but no longer than 20 years after their entry into use, and Article 37(3) uses that option. Article 36(1) fines a service provider that is a legal person EUR 6,630.00 to EUR 132,720.00 for the listed offences.
Article 36(2) and (3) fine the responsible person in the legal person, and a service provider 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 ships a consumer interface, ships a mobile app, provides telecom services or provides financial services.
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