The EU AI Act in Croatia

Per Croatia - AI Act Transposition Process (2025)

• Ministry of Justice, Administration and Digital Transformation (Ministarstvo pravosuđa, uprave i digitalne transformacije) — Lead for drafting national implementing legislation and coordinating inter-ministerial working group.
• Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka - AZOP) — National data-protection supervisory authority; designated among competent authorities for fundamental-rights oversight; provides guidance on GDPR/AI Act interactions.
• Agency for Electronic Media (Agencija za elektroničke medije - AEM) — Sectoral regulator for media-related AI uses and part of the national oversight architecture where audiovisual and media applications intersect.
• Office of the Ombudsperson (Ured pučke pravobraniteljice) — Institution for fundamental-rights oversight and participant in the working group; acts on discrimination and fundamental-rights complaints related to AI deployments.

Per Croatia - National AI Development Plan

• Ministry of Justice, Public Administration and Digital Transformation (MPUDT) — Lead coordinating authority for drafting and overseeing the National AI Plan; convenor of the inter-ministerial working group.
• Government of the Republic of Croatia — Policy sponsor and endorsing authority; coordinates strategic priorities and inter-ministerial decisions.
• Relevant sector ministries (Finance; Health; Economy; Science and Education; Transport; Interior; Agriculture) — Sectoral implementers, lead agencies for sector-specific pilots and regulatory alignment.

Per Croatia - Smart Specialisation Strategy

• Ministry of Science and Education (MZO) — Co-author, publisher of full S3 text and responsible for parts of implementation and monitoring related to research and education
• Ministry of Economy and Sustainable Development (MGOR) — Co-author and implementing ministry for economic and innovation measures, programme alignment and EU funds coordination
• National Innovation Council (NIV) — Strategic coordination body for S3 governance and stakeholder engagement (as described in S3 governance annexes)
• Managing Authorities for EFRR / Operational Programmes — Programme-level financial management, compliance checks and enforcement of enabling conditions tied to S3

Per Croatia - Digital Transformation Strategy

• Central State Office for the Development of Digital Society (Središnji državni ured za razvoj digitalnog društva) — Lead implementing body and coordination secretariat for the Strategy
• Ministry of Justice and Public Administration (Ministarstvo pravosuđa i uprave) — Policy coordination, oversight for public administration digitalisation and NRRP implementation support
• Croatian Parliament (Hrvatski sabor) — Adopting authority (legal adoption of the Strategy) and political oversight
• Croatian Personal Data Protection Agency (AZOP) — Supervision and enforcement of personal data protection obligations for Strategy projects
• National CERT / National cybersecurity authorities — Operational cybersecurity coordination, incident response and implementation of the cybersecurity baseline

Per Croatia - National Development Strategy

• Ministry of Regional Development and EU Funds (Ministarstvo regionalnoga razvoja i fondova Europske unije) — Coordinating Body for strategic planning, responsible for organizing, coordinating and monitoring preparation and implementation of the NRS 2030
• Croatian Parliament (Hrvatski sabor) — Adopting authority and oversight recipient of annual implementation reports
• Government of the Republic of Croatia (Vlada Republike Hrvatske) — Executive oversight and coordination of policy implementation across ministries

Per Croatia - Recovery and Resilience Plan

• Government of the Republic of Croatia - National Recovery and Resilience Plan Secretariat — Overall coordination and publication of Plan documents, monitoring and public reporting
• Ministry of Finance, Republic of Croatia — Main contact point with the European Commission for payments, financial management and verification
• European Commission - Directorate‑General for Economic and Financial Affairs (DG ECFIN) — Assessment, verification of milestones and targets, and authorisation of RRF payments

Per Croatia - AI Act Transposition Process (2025)

• Administrative fines aligned to the AI Act: for the most serious infringements, fines may reach the EU-level maxima (up to €35 million or up to 7% of total worldwide annual turnover), with proportional national administrative procedures to calculate and impose penalties.
• Lower-tier administrative fines for lesser breaches (documentation, registration or procedural failures) with graduated scales determined by the national implementing law.
• Administrative corrective measures such as suspension of placing on the market, recall, or temporary prohibition of use.
• Criminal or civil liability remains subject to national law for intentional wrongdoing, harm, or negligence causing personal injury or material loss.
• Obligations to publish corrective statements and remedial actions in the event of systemic breaches.

Per Croatia - National AI Development Plan

• The draft strategy itself does not prescribe fines; enforcement and penalties will be defined in later implementing legislation (including transposition of the EU AI Act). ([mpudt.gov.hr](https://mpudt.gov.hr/pristup-informacijama-6341/savjetovanja-sa-zainteresiranom-javnoscu/radne-skupine-za-izradu-nacrta-prijedloga-zakona-drugih-propisa-i-akata/6230?lang=tr&utm_source=openai))
• Expected enforcement measures (to be developed) include administrative fines, market surveillance actions, withdrawal of non-compliant products from procurement, and funding withdrawal for projects failing regulatory conditions.
• Civil liability and redress mechanisms are to be aligned with national civil law and EU-level rules in subsequent regulations.

Per Croatia - Smart Specialisation Strategy

• Ineligibility for programme funding where projects do not meet S3 alignment or enabling conditions.
• Administrative suspension of payments pending corrective action for non-compliant projects.
• Financial corrections and recovery of funds where use is found non-compliant with program rules or S3 governance requirements.
• Denial of future programme participation for repeated non-compliance by implementing entities (programme-level sanctions).
• Standard administrative and judicial appeal routes remain available for beneficiaries contesting funding decisions or recoveries.

Per Croatia - Digital Transformation Strategy

• Administrative sanctions and corrective measures as established under applicable sectoral laws (e.g., procurement, public finance rules) for non-compliance with implementation and reporting obligations.
• GDPR fines and supervisory measures for personal data breaches, imposed by the Croatian Data Protection Authority in accordance with EU law.
• Financial corrective actions or repayment obligations where misuse of EU/RR funds or non-compliant procurement is identified during audits.
• Standard administrative review and judicial remedies available under Croatian administrative law for contested implementing acts.

Per Croatia - National Development Strategy

• The Strategy itself does not create criminal penalties, but non-compliance with programming and reporting obligations can trigger administrative corrective measures under sectoral laws.
• Failure to align subordinate strategies and action plans may result in reprogramming or withholding of centrally coordinated national funds.
• Misuse of EU-allocated funds or failure to meet grant conditions may lead to decommitment, financial corrections or repayment liabilities according to EU funding rules.
• Administrative oversight by competent audit bodies may produce findings that require remedial actions and can lead to reputational and fiscal consequences.
• Non-fulfilment of statutory reporting duties can lead to formal inquiries by the Parliament or Government oversight bodies.

Per Croatia - Recovery and Resilience Plan

• Financial corrections and recoveries ordered by the European Commission based on unmet milestones, misreporting or irregularities.
• Suspension of further disbursements until remedial measures and corrective actions are implemented.
• National administrative sanctions and contractual penalties under domestic public finance and procurement law.
• Obligation to reimburse misspent funds by beneficiaries found non‑compliant in audits.
• Potential exclusion from future participation in nationally funded projects for serious breaches by implementing bodies or beneficiaries.