Croatia AI Regulation Overview

Overview

Croatia's overall approach to artificial intelligence regulation is centered on European Union regulatory alignment, strategic policy coordination, and digital transformation. The governance landscape is currently anchored by high-level national policy frameworks, including the National Development Strategy to 2030 (NRS 2030), the Digital Croatia Strategy for the period to 2032, the Smart Specialisation Strategy (S3 2029), and the National Recovery and Resilience Plan 2021–2026 (NPOO). These policy instruments establish digital transition and technological innovation as core state priorities, using European Union cohesion policy and Recovery and Resilience Facility (RRF) funding to upgrade national information infrastructure, expand digital public services, and foster research and development across economic sectors.

In parallel, Croatia is preparing a dedicated national AI regulatory and policy structure through two primary draft initiatives: the draft National Plan for the Development of Artificial Intelligence to 2032 (Nacionalni plan za razvoj umjetne inteligencije do 2032. godine), accompanied by an operational Action Plan for 2026–2028, and the formal national transposition process for the EU Artificial Intelligence Act (Regulation (EU) 2024/1689). The Ministry of Justice, Administration and Digital Transformation acts as the primary institutional lead, chairing inter-ministerial working groups that include central ministries, data protection bodies, ombudsperson offices, academic institutions, and business associations to establish domestic governance, market surveillance, and legal oversight mechanisms.

Regulatory Approach

Croatia adopts a policy-led, risk-proportionate regulatory approach that combines soft-law strategic guidance with direct legislative harmonization under European Union law. The national strategic framework treats artificial intelligence as both a specific technical domain and a horizontal enabler across economic and public sector activities. For instance, the Smart Specialisation Strategy (S3 2029) elevates a dedicated vertical for 'Digital products and platforms' to move domestic industry toward high-value ICT products while embedding machine learning and artificial intelligence as cross-cutting tools in sectors such as healthcare, mobility, energy, and security.

From a normative standpoint, binding regulatory requirements for AI systems in Croatia are anchored in the EU Artificial Intelligence Act (Regulation (EU) 2024/1689). The inter-ministerial working group tasked with national transposition is preparing a draft law to establish domestic administrative workflows, procedural requirements for high-risk AI systems, and national supervisory designations. Rather than developing separate, divergent domestic statutory rules, Croatia focuses on institutional coordination across existing administrative authorities—such as the Personal Data Protection Agency (AZOP) and fundamental rights ombudsmen—to execute market surveillance, registration, and rights oversight in alignment with EU single-market principles.

Key AI Legislation

Croatia's AI legal and policy framework is comprised of national strategic plans, EU transposition bills, and broader digital strategy acts, including:

• National transposition process for the EU Artificial Intelligence Act (Draft Bill, 2025): Initiated to prepare domestic implementing legislation and administrative arrangements for Regulation (EU) 2024/1689. The initiative coordinates market surveillance, conformity assessment procedures, incident reporting, and the formal designation of national competent authorities, including AZOP and ombudsperson offices.
• Nacionalni plan za razvoj umjetne inteligencije do 2032. godine (Draft Policy, 2025): A draft national strategy led by the Ministry of Justice, Administration and Digital Transformation, accompanied by an operational Action Plan (2026–2028). It defines priorities across regulatory alignment, research and innovation investment, digital skills, secure data access, and public-sector AI adoption.
• Strategija digitalne Hrvatske za razdoblje do 2032. godine (Adopted Policy, 2022): The national digital strategy published in Narodne novine (No. 1/2023), establishing goals for digital economy growth, public administration digitalisation, State Shared Services Centre (CDU) expansion, high-capacity network deployment, and digital literacy.
• Strategija pametne specijalizacije (S3 2029) (Adopted Policy, 2023): National RDI strategy that defines seven thematic priority areas and introduces the 'Digital products and platforms' vertical to promote applied AI, machine learning, and cybersecurity capabilities.
• Nacionalna razvojna strategija RH do 2030. godine (NRS 2030) (In Force Policy, 2021): The top-level strategic planning instrument establishing national vision and development directions, including green and digital transitions.
• Nacionalni plan oporavka i otpornosti 2021–2026 (NPOO) (In Force Policy, 2021): RRF-backed framework funding digital public administration reforms, e-justice projects, judicial decision anonymisation tools, and digital infrastructure investments.

Governance & Enforcement Bodies

AI governance and digital policy execution in Croatia are managed through a combination of central executive ministries, independent supervisory agencies, and inter-institutional councils. The Ministry of Justice, Administration and Digital Transformation (MPUDT) serves as the primary administrative lead. MPUDT absorbed functions from the former Central State Office for the Development of Digital Society (SDURDD) and chairs the working groups drafting the National AI Plan and the domestic implementing legislation for the EU AI Act.

Independent regulatory and supervisory bodies play a central role in fundamental rights and data governance. The Personal Data Protection Agency (AZOP) acts as the data protection authority and has been designated among the national competent authorities submitted to the European Commission under Article 77(2) of the EU AI Act. Ombudsperson offices are formally included in transposition working groups to supervise fundamental-rights impacts. High-level policy alignment and RDI investments are further coordinated by the National Innovation Council (co-chaired by the Ministry of Economy and the Ministry of Science, Education and Youth) and the National Council for Digital Transformation.

Penalties & Enforcement

Because Croatia’s standalone AI policy documents—such as the draft National AI Plan, NRS 2030, S3 2029, and the Digital Croatia Strategy—are non-binding policy frameworks, they do not establish direct statutory criminal or administrative penalties. Policy compliance and strategic execution are enforced primarily through conditionality in public financing, where alignment with strategy priorities determines project eligibility and co-funding under EU Cohesion Policy, national grant calls, and RRF funding streams. Non-compliance with NPOO targets or reporting rules can trigger financial corrections, suspension, or recovery of allocated EU funds.

Binding legal penalties and administrative sanctions for non-compliance with AI requirements are established via the EU AI Act transposition process. The national implementing bill entry notes that domestic provisions will establish administrative, civil, or criminal penalties calibrated to EU maximum penalty provisions while ensuring procedural due process. Supervisory enforcement powers, market surveillance workflows, and inspection routines will be executed through designated national authorities and sectoral bodies once the implementing statute and subordinate administrative regulations are enacted.

Data Protection Framework

Data protection and privacy in Croatia are governed by the EU General Data Protection Regulation (GDPR) and national implementing laws enforced by the Personal Data Protection Agency (AZOP). AZOP provides official guidance on the interaction between data privacy and artificial intelligence, including applicability timelines under Chapters I and II of the EU AI Act. As a designated competent authority under the AI Act framework, AZOP oversees the alignment of AI models with fundamental privacy rights, lawful data processing standards, and prohibitions on unacceptable biometric categorisations.

National digital strategies actively integrate GDPR compliance with public data availability to foster safe AI development. The Digital Croatia Strategy to 2032 and the draft National AI Plan prioritize secure data infrastructure through the State Shared Services Centre (CDU or "state cloud"), standardized open data frameworks, and automated anonymisation tools—such as automated judicial decision anonymisation in the courts—to provide high-quality, privacy-compliant public datasets for commercial and academic R&D.

Sector-Specific Rules

The supplied corpus contains no record of separate, standalone Croatian statutes establishing sector-specific AI laws for fields such as autonomous vehicles or financial algorithms. Instead, sectoral AI applications are addressed through thematic priorities within horizontal strategies and multi-ministerial working group arrangements. Under the Smart Specialisation Strategy (S3 2029), artificial intelligence and machine learning serve as horizontal enabling technologies integrated into domain-specific priorities including Personalised Health Care, Smart and Green Mobility, Smart and Clean Energy, Sustainable Food, and Security/Dual-Use applications.

Sectoral governance relies on coordinated input from competent ministries, including the Ministry of Sea, Transport and Infrastructure, Ministry of Health, Ministry of Economy, and Ministry of Science, Education and Youth. In the judicial and administrative sectors, the National Recovery and Resilience Plan (NPOO) finances pilot deployments for AI-enabled public services and e-justice enhancements. Sector-specific oversight and compliance guidelines for specialized domains like healthcare and finance will be elaborated through technical annexes and administrative guidance during the implementation phase of the EU AI Act.

International Alignment

Croatia’s AI regulatory architecture is directly aligned with European Union legal standards and international strategy benchmarks. As an EU Member State, Croatia’s baseline binding regulatory framework is Regulation (EU) 2024/1689 (EU AI Act). The national working group led by MPUDT ensures that domestic market surveillance mechanisms, authority notifications under Article 77(2), and technical evaluation standards fully reflect the harmonised rules set by the Union and support active cooperation within the European AI Board.

In addition to EU statutory alignment, Croatia embeds international strategic benchmarks across its national planning documents. Strategic initiatives such as NRS 2030, NPOO, and the Digital Croatia Strategy 2032 align domestic targets with the EU Digital Decade/Digital Compass goals, the European Green Deal, and the UN 2030 Agenda for Sustainable Development. These plans systematically incorporate international operational principles, including the "do no significant harm" (DNSH) environmental principle, OECD-aligned performance monitoring, and rights-respecting frameworks for trustworthy AI deployment.

Future Developments

Future AI policy and regulatory developments in Croatia focus on finalizing draft legal statutes and executing multi-year strategy roadmaps. The primary legal milestone is the completion and legislative passage of the domestic implementing act for the EU AI Act by the MPUDT-led inter-ministerial working group. This statute will formalise the national supervisory architecture, detail market surveillance procedures, establish incident reporting channels, and enact penalty schedules aligned with the phased application schedule of Regulation (EU) 2024/1689 through 2025 and 2026.

Simultaneously, the government will progress the draft Nacionalni plan za razvoj umjetne inteligencije do 2032. godine and its operational Action Plan for 2026–2028. Key programmatic developments include upcoming mid-term evaluations scheduled for 2027 across the Smart Specialisation Strategy (S3 2029) and the Digital Croatia Strategy, as well as the completion of NPOO investment milestones by August 2026. These ongoing efforts are set to establish technical sandboxes, launch targeted RDI funding calls, and expand secure public-sector AI implementations.

Enforcement Bodies

Agency	Mandate	Key Powers	Website
Ministry of Justice, Administration and Digital Transformation (MPUDT)	Lead coordinating ministry for digital transformation, National AI Plan drafting, and EU AI Act national transposition.	Policy formulation, inter-ministerial working group leadership, digital public administration oversight, legislative drafting.