Croatia - AI Act Transposition Process (2025)

Overview

Croatia’s national transposition process for the EU Artificial Intelligence Act is organised through an inter-ministerial working group convened by the Ministry of Justice, Administration and Digital Transformation. The group’s mandate is to prepare a draft implementing law and related administrative measures that will operationalise Regulation (EU) 2024/1689 within Croatia, identify the national supervisory and market surveillance authorities required by the AI Act, and coordinate technical and sectoral guidance to stakeholders. The working-group membership published by the ministry includes representatives from central ministries, the Croatian Personal Data Protection Agency (AZOP), the ombudsperson's offices, academic and research institutions and industry bodies, reflecting an approach designed to balance rights protection, market functioning and innovation. The national transposition work explicitly references the EU instrument and timelines (Regulation (EU) 2024/1689) and coordinates with national authorities already designated for fundamental-rights oversight. See the ministry’s official listing and AZOP’s role for initial guidance. Ministry working-group roster and AZOP information.

Definitions

The working group’s draft transposition text will adopt and interpret key definitions from the AI Act—"AI system", "provider", "deployer", "general-purpose AI model", "high-risk AI system", "remote biometric identification" and "fundamental rights impacts"—to ensure legal coherence across national law. Definitions will mirror the EU regulation where possible to preserve the harmonised single market approach, while clarifying procedural terms for Croatia's administrative processes (e.g., registers, notification and supervisory coordination). Clarifying the scope of excluded uses (military, national security, strictly research activities where permitted) and the threshold for what constitutes "placing on the market" or "putting into service" will be essential to give effect to obligations for providers and deployers in domestic context.

Governance and Institutional Framework

Croatia’s working group is chaired by the Ministry of Justice, Administration and Digital Transformation and includes the Ministry of Economy, the Ministry of Science, Education and Youth, Ministry of Sea, Transport and Infrastructure, CARNet, AZOP and multiple ombudsperson offices, along with academic and industry representatives. This institutional mix aims to synchronize: (a) designation and publication of national competent bodies for fundamental-rights oversight and high-risk AI monitoring (as required by Article 77 of the AI Act); (b) assignment of market surveillance roles under product-safety analogues; (c) responsibilities for conformity assessment and registration; and (d) national enforcement mechanisms. Official lists submitted by Croatia to the Commission and summarized by AZOP identify prime bodies for oversight; the transposition bill will formalise these institutional roles and their coordination mechanisms. The ministry-hosted roster provides the authoritative membership list of the drafting group. Working group membership and AZOP publication.

Key Focus Areas

The transposition effort concentrates on several substantive and procedural focus areas. Substantively, the draft must translate the AI Act’s risk-based rules into enforceable national obligations: prohibitions of unacceptable practices (e.g., social scoring and certain biometric categorisations), obligations for high-risk systems (risk management systems, data governance and documentation), transparency and human oversight measures, and specific duties for general-purpose AI models where applicable. Procedurally, the transposition bill must create or empower registration systems, designate conformity assessment authorities, align sanctions and administrative procedures with the AI Act’s enforcement framework, and guarantee effective judicial and administrative redress for affected persons. Additional focus includes (1) aligning the AI Act’s requirements with GDPR and national data-protection law; (2) defining the interface between sectoral authorities (finance, healthcare, transport) and the central supervisory bodies; (3) specifying technical and organisational requirements for cybersecurity, adversarial testing and model evaluation; (4) building national capacity for market surveillance and technical evaluation labs; and (5) developing guidance and transitional arrangements for small and medium-sized enterprises and public sector procurers. The working group aggregates expertise from public administration, data protection, academia and industry to shape risk-calibrated obligations and practical compliance pathways.

Implementation Framework

The proposed implementation framework will include: (a) a legal instrument (primary legislation or amendments) that gives domestic effect to the AI Act’s requirements where national measures are allowed or needed (administrative designations, enforcement powers, penalty schedules); (b) secondary (subordinate) regulation or ministerial rules describing registry procedures, reporting templates and market surveillance workflows; (c) technical guidance and sectoral annexes for healthcare and financial services to clarify compliance expectations; and (d) a stakeholder consultation and phased rollout plan aligned with EU application dates. The ministry-led drafting process will coordinate input from AZOP (data protection), Agencija za elektroničke medije (media oversight for related uses), ombuds institutions (fundamental rights concerns) and industry stakeholders to ensure the domestic framework is implementable and coherent with EU obligations. For the full EU legal baseline, see the official publication of Regulation (EU) 2024/1689. EU official text.

Monitoring and Evaluation

Monitoring will rely on a combination of national supervisory authorities and sectoral market surveillance bodies. AZOP has already outlined the initial applicability timetable and published a list of national competent authorities; formal transposition will set out reporting obligations, data collection and incident reporting channels for serious incidents and systemic risks. Evaluation will include periodic reviews against the Act’s review clauses and technical standards, and cooperation through the European AI Board. The national framework will require mandated reporting from conformity assessors, registries of high-risk systems, and centralized incident reporting channels to enable aggregate risk analysis and targeted inspections. Capacity-building plans for inspection, technical testing and judicial training are expected components of the evaluation strategy. AZOP guidance.

Penalties, Liability, and Appeals

The transposition draft will align national administrative penalties and enforcement pathways with the AI Act’s sanctioning architecture, which includes substantial maximum fines for the most serious breaches at EU level. Domestic implementing rules will specify administrative procedures, rights to appeal before administrative courts, and the interplay with civil liability regimes where injured persons seek redress. The bill must ensure legal certainty in enforcement (procedural safeguards, proportionality principles) and provide for cooperation between national enforcement authorities and the European AI Board for cross-border cases.

Relationship to Other Instruments

The national implementing framework must be harmonised with the GDPR (Regulation (EU) 2016/679), product safety and sectoral legislation (healthcare, transport, financial services), the national data-protection law and other relevant statutes. The working group will assess overlaps, carve-outs and subsidiarity points, ensuring the transposition respects EU primacy where the AI Act is directly applicable while integrating national procedural rules for surveillance, sanctioning and judicial remedies. Practical measures will include cross-references, delegated powers for agencies, and formal memoranda of understanding between enforcement bodies.

International Alignment

Croatia’s transposition is explicitly framed to preserve the EU single-market approach and avoid fragmentation; the ministry’s process therefore adopts the EU definitions and obligations to maintain cross-border legal certainty. National authorities will cooperate with EU structures (the European AI Board and the new AI Office where relevant) and align with international data-protection and human-rights frameworks. This alignment will be reflected in the transposition bill’s emphasis on interoperability with EU-level conformity assessments, cross-border supervisory cooperation and adherence to EU guidance documents and standards.

Implementation Timeline

Sources and References