Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

Croatia

(Adopted by the Global Forum in June 2026)

Croatia joined the Global Forum in 2014. Croatia underwent its Second Round of EOIR Peer Review in 2019 (Croatia’s 2019 Report),1 which assessed its legal and regulatory framework in force as at 26 April 2019 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 January 2015 to 31 December 2017. Croatia received an overall rating of Largely Compliant and the individual Elements were rated as follows:

 

	A1	A2	A3	B1	B2	C1	C2	C3	C4	C5	Overall
Determinations	i.p.b.	i.p.b.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	LC	LC	C	C	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

Croatia received six in-box recommendations in relation to Elements A.1, A.2, B.1, C.4 and C.5.

This monitoring report assesses the actions taken by Croatia to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that two recommendations are “in the process of being addressed”, two recommendations are “no longer sufficiently material” and two recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”. For one of them, the report issues a new corresponding recommendation to monitor the implementation of the legislative change. The report also advises on actions required.

Element A.1: Availability of ownership and identity information

1. Identity information on holders of bearer shares

 

Recommendation (A.1, framework)	Croatia should take measures to ensure that information on all holders of bearer shares that are still in circulation is available.
Underlying factor	The Croatian law allows circulation of bearer shares of joint stock companies issued prior to April 2008. However, there are certain measures which allow identification of holders of these shares and the number of such shares is limited and cannot expand. Despite the adoption of a new [AML] [L]aw in 2017 and the prohibition of bearer shares, the legacy issues linked to bearer shares issued prior to 2008 remains. (see paragraphs 111 et seq. of Croatia’s 2019 Report for more information)
Summary of actions reported	The 2018 amendments to Article 226(2) of the Companies Act, requiring shareholders to inform companies whether shares are held by shareholders or on behalf of other persons, and the related penalties regime have facilitated the conversion of bearer shares. The Beneficial Ownership Register contains records of two joint stock companies that had issued bearer shares. An additional 20 joint stock companies (11 of which are undergoing bankruptcy or liquidation proceedings) have not yet registered with the Beneficial Ownership Register. Therefore, no information is available whether they had issued bearer shares. By July 2027, in line with EU Regulation 2024/1624, Croatia will introduce provisions that require bearer shares to be converted into registered shares, to be immobilised or to be deposited in a financial institution.
Conclusion	Croatia has made progress to address the recommendation. While the amended Article 226(2) may have facilitated the conversion of bearer shares, there is still evidence of joint stock companies that have bearer shares. Provisions that require bearer shares to be converted, immobilised and deposited have not yet been put in place. Croatia should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Croatia should – Report statistical information on the number of joint stock companies that still have bearer shares and number of bearer shares in circulation. Report on appropriate mechanisms to ensure that owners of bearer shares are identified in line with the standard. Report on progress in introducing provisions that require bearer shares to be converted, immobilised or deposited with a financial institution.

2. Implementation of the Beneficial Ownership Register

 

Recommendation (A.1, practice)	Croatia should ensure that the new obligations regarding the Beneficial Ownership Register are effectively implemented in practice.
Underlying factor	Until June 2019, information on beneficial ownership of legal entities and arrangements was available only to the extent they had a relationship with an AML-obliged person. The [AML] Law now foresees the establishment of a Beneficial Ownership Register, which is designed with robust obligations for legal entities and arrangements, and for AML-obliged persons. However, its effectiveness in practice could not be assessed, as it only becomes operational as from 3 June 2019, with the obligation to populate the Register by end 2019. (see paragraphs 98-108 of Croatia’s 2019 Report for more information).
Summary of actions reported	The Central Beneficial Ownership Register is operational since 3 June 2019. The reporting rate as on 30 October 2025 was 95%. In 2019, to facilitate submission of beneficial ownership information and the register’s operating aspects, the Ministry of Finance issued the Rulebook on Beneficial Ownership Register and related instructions on how to determine beneficial owners and enter data into the register. Beneficial ownership information must be reported within 30 days from the registration of an entity or change of beneficial owner. In case of trusts, the 30-day deadline is counted from the establishment of residence or seat in Croatia by the trustee. The Beneficial Ownership Register is jointly supervised by the Financial Agency (focused on formal aspects related to correctness and timeliness of the submitted data) and the Tax Authority (responsible for ad hoc audits of information entered in the Register). The Tax Authority may carry out audits in relation to beneficial ownership information as part of tax audits or as a stand-alone supervisory activity. All AML-obliged persons and certain authorities having access to the Beneficial Ownership Register are required to report discrepancies to the Anti-Money Laundering Office which reviews them and directs relevant discrepancy reports for further examination by the Tax Authority. Interconnection of the Beneficial Ownership Register with other registers provides for automated data accuracy controls. Penalties for non-compliance range from EUR 660 to EUR 46 450 for legal entities and from EUR 660 to EUR 9 950 for trusts.
Conclusion	Croatia has made progress to address the recommendation. It should report further progress in its next self-assessment. The Rulebook issued by the Ministry of Finance and related instructions address aspects of submission of beneficial ownership information and explain the meaning of complex ownership structures and control through other means, but lack guidance on joint control and ownership. Further, there is no obligation to periodically verify whether information reported to the Beneficial Ownership Register is still up to date.
Status determined	In the process of being addressed.
Actions required	In its next self-assessment, Croatia should – Continue to report on actions taken and supporting implementation details to ensure that the information contained in the Beneficial Ownership Register is adequate, accurate and up to date.

Element A.2: Availability of accounting information

3. Availability of accounting records after an entity has ceased to exist

 

Recommendation (A.2, framework)	Croatia should ensure the availability of accounting records after an entity or arrangement ceased to exist.
Underlying factor	When a company is deleted ex-officio [without completing liquidation proceedings] from the Commercial Register, the relevant documentation is not always available with the Commercial Register or the Tax Administration. (see paragraphs 143, 162 et seq. of Croatia’s 2019 Report for more information)
Summary of actions reported	In 2022, Croatia amended the Companies Act to require that business records of entities deleted ex-officio be kept by a member of the company or a professional storage services provider. Members must also inform the Commercial Register of the location of the business records.
Conclusion	Croatia appears to have taken appropriate actions to address the recommendation by amending the Companies Act. The implementation and enforcement in practice of these legislative amendments is yet to be ascertained. Therefore, Croatia is expected to report progress on the implementation of the changes in the legal and regulatory framework under a new recommendation. Croatia is recommended to monitor the implementation of the legislative amendments on the retention of accounting records of entities deleted ex-officio, i.e. without completing liquidation proceedings.
Status determined	Existing recommendation: considered provisionally addressed in the context of the monitoring process, subject to detailed validation New recommendation issued
Actions required	Existing recommendation: No immediate action required New recommendation: In its next self-assessment, Croatia should – Report on the measures implemented to monitor compliance with record keeping requirements for entities that cease to exist without liquidation proceedings.

Element B.1: Access to information

4. Professional secrecy definition

 

Recommendation (B.1, framework)	Croatia should ensure that the scope of professional secrecy is in line with the international standard.
Underlying factor	Exception from obligation to provide information to the Tax Administration in respect of lawyers, tax consultants and auditors is too broad and goes beyond the standard as it covers all information obtained by them acting in their professional capacity. (see paragraphs 170 et seq. of Croatia’s 2016 Report, paragraphs 231 et seq. of Croatia’s 2019 Report for more information)
Summary of actions reported	Lawyers, tax consultants and auditors are not an important source of information for tax purposes in Croatia. Officials conducting tax procedures at the regional level have reported no need to contact professionals for information. Despite its substantial experience in EOI, Croatia did not have experience with access to information held by professionals, neither for domestic nor for international purposes, and did not receive any EOI requests that required contacting professionals who can claim professional secrecy.
Conclusion	Since the adoption of the 2019 Report, Croatia has not identified any case where professional secrecy has prevented access to information. This recommendation can be considered as no longer sufficiently material. Croatia is no longer required to report on this recommendation in future monitoring cycles in application of paragraph 61 of the Enhanced Monitoring Methodology.
Status determined	No longer sufficiently material
Actions required	No immediate action required.

Element C.4: Rights and safeguards

5. Scope of professional secrecy under international agreements

 

Recommendation (C.4, framework)	Croatia should ensure that the scope of professional secrecy under its domestic laws is in line with the international standard.
Underlying factor	Croatia’s EOI agreements do not define the term “professional secret” and the scope of this term under its domestic laws may have negative impact on effective exchange of information. (see paragraphs 292-293 et seq. of Croatia’s 2019 Report for more information)
Summary of actions reported	Lawyers, tax consultants and auditors are not an important source of information for tax purposes in Croatia. Officials conducting tax procedures at the regional level have not reported any issues to obtain information which is relevant for a taxation procedure nor any need to contact professionals for information. Croatia did not have experience with access to information held by professionals neither for domestic nor for international purposes and did not receive any EOI requests that required contacting professionals who can claim professional secrecy.
Conclusion	Since the adoption of the 2019 Report, Croatia has not identified any case where professional secrecy has prevented access to information. This recommendation can be considered as no longer sufficiently material. Croatia is no longer required to report on this recommendation in future monitoring cycles in application of paragraph 61 of the Enhanced Monitoring Methodology.
Status determined	No longer sufficiently material
Actions required	No immediate action required.

Element C.5: Effective exchange of information

6. Status updates

 

Recommendation (C.5, practice)	Croatia is recommended to improve communication with partners and send status updates whenever the 90-day deadline cannot be met.
Underlying factor	While Croatia answered EOI requests within 90 days in [73%] of the cases, when it took longer, Croatia provided status updates or partial responses only in 13% of the cases. (see paragraph 300 et seq. of Croatia’s 2019 Report for more information)
Summary of actions reported	The statistics for the monitoring period indicate that final responses were provided within 90 days in 73% of cases. For cases where it took longer to respond, Croatia has provided status updates within 90 days in 80% of cases.
Conclusion	Croatia appears to have taken appropriate actions to address the recommendation.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	In its next self-assessment, Croatia should provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the methodology for enhanced monitoring.

EOIR experience

Over the monitoring period 2023-2024, Croatia received 275 requests and sent 234 requests. Germany, Slovenia and Serbia were the top three partners in respect of incoming requests. Austria, Germany and Slovenia were the key partners in respect of outgoing requests. Croatia reported providing full and final responses in 93% of all the received requests and indicated 6% as pending requests. The remaining 1% (i.e. 2 requests) represent requests withdrawn by the requesting jurisdiction.

Eleven members provided peer input on Croatia. Peers reported general satisfaction in respect of their EOIR experience with Croatia.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Croatia or have otherwise come to light.

Next steps

Croatia should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, one new recommendation is issued to Croatia.

7. Monitoring availability of accounting records after an entity has ceased to exist

 

Recommendation (A.2, practice)	Croatia is recommended to monitor the implementation of the legislative amendments on the retention of accounting records of entities deleted ex-officio, i.e. without completing liquidation proceedings.
Underlying factor	In 2022, Croatia amended the Companies Act and now requires that business records and relevant documentation of entities deleted without liquidation proceedings are kept either by a member of the company or are handed over to a person providing professional record keeping services. The Commercial Register must be informed of the location where business records and relevant documentation are kept.

The following next steps are expected from Croatia:

• Submit its next self-assessment, including on the new recommendation issued, in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and Methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation” and the next steps expected on recommendations that are “no longer sufficiently material”.

Views/response of the monitored jurisdiction

Croatia is thanking the Peer Review and Monitoring Group (PRMG) for the excellent job of drafting this report, which we consider as fair assessment of Croatia.

We highly appreciate that the report highlights the substantive progress Croatia has made since the 2018 Report and shows that Croatia is strictly committed to transparency. We fully accept the remaining recommendations where this has been found necessary. We want to highlight our ongoing commitment to continue working on addressing and resolving the remaining recommendations as soon as possible.

Note

← 1.  OECD (2019), Global Forum on Transparency and Exchange of Information for Tax Purposes: Croatia 2019 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/ccacbca7-en.