CroatiaAct on the Requirements for the Accessibility of Products and Services, duties common to economic operators: identification, cooperation, fundamental alteration and disproportionate burden, presumption of conformity
In force since .
An accessibility requirements rule binding public and private bodies.
What it requires
- On the inspector's request, give the identity of every economic operator that supplied you with the product and every operator you supplied it to, and keep and be able to show that information for five years after the product was supplied to you and five years after you supplied another operator (Art. 14; implements Directive (EU) 2019/882, Art. 12).
- As manufacturer, importer or distributor, give the inspector on a reasoned request, in Croatian and Latin script, all information and documentation needed to show conformity, and cooperate on measures to remove non-conformity; an authorized representative cooperates on any action taken within its mandate (Art. 16(1) and (2)).
- The accessibility requirements apply only so far as compliance (a) needs no significant change that fundamentally alters the basic nature of the product or service and (b) imposes no disproportionate burden on you; carry out that assessment yourself on the criteria of Annex VI (Art. 17(1) and (2); implements Directive (EU) 2019/882, Art. 14(1) and (2)).
- Document the assessment and keep all relevant results for five years from the day the product was last made available on the market or the service was last provided, and give the inspector a copy on request (Art. 17(3) and (4)).
- If you are a micro entity of the small economy that deals with products, you need not document the assessment, but give the inspector on request the facts relevant to it if you relied on Article 17(1) (Art. 17(5)).
- If you provide a service and rely on the disproportionate-burden limit, repeat the assessment for each category or type of service when you change the service, when the inspector asks and at least every five years (Art. 17(6)).
- You may not rely on the disproportionate-burden limit where you receive funding from sources other than your own resources, public or private, to improve accessibility (Art. 17(7)).
- Unless you are a micro entity of the small economy, notify the relevant market surveillance authority or conformity-checking authority of the Member State where the product is placed on the market or the service provided when you rely on Article 17(1) for a specific product or service (Art. 17(8)).
- A product or service that conforms to the harmonized standards, or parts of them, whose references are published in the Official Journal of the European Union is presumed to meet the accessibility requirements those standards cover, and the same holds for conformity with technical specifications published there or set by an implementing act of the European Commission; the Act names no standard other than harmonized standards and technical specifications of that kind (Art. 18; implements Directive (EU) 2019/882, Art. 15).
These lines are LexLint's reading of the law's text.
If you get it wrong
Penalty structure
The ceiling shown is the highest tier, which Articles 32, 33 and 36 set for a manufacturer, authorized representative or service provider that is a legal person; Article 34 sets EUR 66,360.00 for an importer and Article 35 sets EUR 13,270.00 for a distributor. The minimum shown is the lowest floor in those articles, EUR 1,320.00, which Article 35(2) and (3) set for the responsible person in a distributor and for a self-employed distributor. Every one of those articles fines not documenting or keeping the Article 17 assessment. As amended by the Act published in Narodne novine 114/2026, Articles 32 to 35 (manufacturer, authorized representative, importer, distributor) also fine not giving the inspector the information of Article 14(1), not keeping and presenting it for five years under Article 14(2), not cooperating with the inspector under Article 16, not giving a copy of the Article 17 assessment (Article 17(4)) or its facts (Article 17(5)) on request, relying on the disproportionate-burden limit while funded to improve accessibility (Article 17(7)), and not notifying the market surveillance authority of reliance on Article 17 (Article 17(8)). Article 36 (service provider) fines not cooperating under Article 16(3), and from not giving a copy of the assessment, not repeating it under Article 17(6), relying on the limit while funded, and not notifying the authority; it carries no Article 14 or Article 17(5) offence. 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
- 1,320
- Currency
- EUR
- Fixed cap
- 132,720
Who enforces it
Enforcement body
Electronic communications inspectors of HAKOM and market inspectors of the State Inspectorate for products (Art. 22(2) and (3)), and for services the authorities named in Art. 25
What it reaches
Instrument type
an act of a legislature
Applicability criteria
- As of
- Combinator
- Any of
- Criteria
- a manufacturer, authorized representative, importer, distributor or service provider within the Act (Article 5, point 20; point 16 until ); a micro entity of the small economy is relieved of the documentation duty of Article 17(3) for products (Article 17(5)) and of the notification duty of Article 17(8)
What this law does
Article 5, point 20 (point 16 until ), defines an economic operator as a manufacturer, authorized representative, importer, distributor or service provider.
Article 14 requires a manufacturer, authorized representative, importer or distributor to give the inspector, on request, the identity of every operator that supplied it with the product and every operator it supplied, and to keep that information for five years after the product was supplied to it and five years after it supplied another operator.
Article 16(1) requires a manufacturer, importer and distributor to give the inspector on a reasoned request, in Croatian and Latin script, all information and documentation needed to show conformity of the product, and to cooperate on measures to remove non-conformity.
Article 17(1) makes the accessibility requirements binding only so far as accessibility needs no significant change that fundamentally alters the basic nature of the product or service and causes no disproportionate burden on the economic operator.
Article 17(2) to (4) requires the economic operator to carry out the assessment itself on the criteria of Annex VI, to document it and keep the results for five years from the last time the product was made available or the service last provided, and to give the inspector a copy on request.
Article 17(5) exempts a micro entity of the small economy that places products on the market from documenting its assessment, but requires it to give the inspector on request the facts relevant to the assessment. Article 17(6) requires a service provider that relies on the disproportionate-burden limit to redo its assessment for each category or type of service when it changes the service, when the inspector asks, and at least every five years.
Article 17(7) denies the disproportionate-burden limit to an economic operator that receives funding from other sources than its own, public or private, to improve accessibility. Article 17(8) requires an economic operator other than a micro entity of the small economy that relies on Article 17(1) for a product or service to notify the relevant market surveillance authority or conformity-checking authority of the Member State where the product is placed on the market or the service provided.
Article 18 presumes that a product or service that conforms to the harmonized standards, or the parts of them, whose references are published in the Official Journal of the European Union, or to the technical specifications published there or set by an implementing act of the European Commission, meets the accessibility requirements those standards or specifications cover.
Article 8 provides that placing a conforming product on the market or providing a conforming service in Croatia cannot be prevented for reasons connected with the accessibility requirements. Article 30(1) makes the accessibility requirements of Annex I mandatory accessibility requirements for the description of the procurement object and the technical specifications under the public procurement law, for the products and services in Article 3.
Article 30(2) presumes that a product or service whose features, elements or functions meet the accessibility requirements of Annex I, section V, meets the corresponding accessibility obligations of other acts of the European Union for those features, elements or functions, unless those acts provide otherwise.
When LexLint raises it
When your app profile says your app ships a consumer interface or distributes a software product.
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