European Accessibility Act Compliance in Croatia (NN 89/2025)
Croatia transposed the European Accessibility Act through the Zakon o zahtjevima za pristupačnost proizvoda i usluga (Act on Accessibility Requirements for Products and Services), published in Narodne novine 89/2025 and in force since 28 June 2025, three years after the EU deadline. It covers e-commerce, consumer banking, electronic communications, e-books, audiovisual media access services and passenger transport. The European Commission still treats the transposition as incomplete.
Scan your site freeWho has to comply in Croatia
The Act applies to businesses placing covered products on the Croatian market or providing covered services to consumers in Croatia. Article 3(2) covers electronic communications, audiovisual media access services, passenger transport by air, bus, rail and water, consumer banking, e-books and dedicated software, and e-commerce. Article 4(2) exempts micro-enterprises that provide services, and Article 5(18) defines one as averaging fewer than 10 employees a year and, on the previous year's accounts, having revenue or total assets of no more than EUR 2 million. Both tests must hold, and the exemption covers services only, so a micro-enterprise that makes, imports or distributes a covered product still has product obligations. Public bodies fall under a separate regime, the Zakon o pristupačnosti mrežnih stranica i programskih rješenja za pokretne uređaje tijela javnog sektora (Narodne novine 17/2019), which transposes Directive (EU) 2016/2102, is supervised by the Povjerenik za informiranje, and is not the EAA.
The deadlines that matter
EU deadline to transpose Directive (EU) 2019/882. Croatia missed it and received a Commission letter of formal notice in July 2022
Hrvatski sabor adopts the Zakon o zahtjevima za pristupačnost proizvoda i usluga, published in Narodne novine 89/2025 on 13 June 2025
The Act enters into force under Article 38, the same day EAA obligations begin to apply across the EU
European Commission sends Croatia an additional reasoned opinion, INFR(2022)0306, holding that transposition is still incomplete
The responsible ministry opens public consultation on a bill amending the Act, covering electronic communications provisions, Croatian-language declarations of conformity, and wider penalty coverage
Under Article 37, last day service providers may keep using products they were already using lawfully before 28 June 2025. This is not a general grace period for the service itself
Prove your Croatia compliance
Conforma scans your site against WCAG 2.2 AA and EN 301 549, the standard behind the presumption of conformity in Article 18 of the Zakon o zahtjevima za pristupačnost proizvoda i usluga. You get a Croatia-specific accessibility statement and a dated record of what was found and when it was fixed. Automated testing does not reach every requirement in EN 301 549, so manual checks stay part of the work.
Croatia EAA questions, answered
When does the EAA apply in Croatia, and is there a transition period?
The Act has been in force since 28 June 2025, so products placed on the market and services newly provided from that date must comply. The 2030 date is narrower than it is usually reported. Article 37 lets service providers keep using products they already used lawfully before 28 June 2025 until 28 June 2030, and lets contracts agreed before that date run to expiry, at most five years. Self-service terminals lawfully in use may run out their useful life, capped at 20 years from first use. The service itself gets no general grace period.
Is my small business exempt from the Croatian accessibility Act?
Article 4(2) exempts micro-enterprises that provide services. Article 5(18) sets the test: an average of fewer than 10 employees a year and, on the previous year's accounts, annual revenue or total assets of no more than EUR 2 million. Both conditions must hold. The exemption applies to services only, so a micro-enterprise that manufactures, imports or distributes a covered product is still bound by the product requirements.
Which accessibility standard applies in Croatia?
The Act names no standard. Article 18 gives a presumption of conformity to products and services that follow harmonised standards whose references are published in the Official Journal of the European Union. In practice that means EN 301 549, which Hrvatski zavod za norme has also adopted nationally as HRN EN 301 549 V3.2.1:2021. EN 301 549 in turn references the WCAG success criteria.
Who enforces the Act and what are the penalties?
Article 22 covers products and Article 25 covers services. E-commerce and non-radio products go to Državni inspektorat; electronic communications, e-books, radio equipment and rail to HAKOM; audiovisual media access services to Agencija za elektroničke medije; consumer banking to Hrvatska narodna banka and HANFA; air, bus and water transport to the transport authorities. Under Articles 32 to 36 a manufacturer or service provider that is a legal person faces EUR 6,630 to EUR 132,720, with lower ranges for importers and distributors.
This page is a plain-English summary, not legal advice. Check the cited national law for specifics.
Common fixes to check
Most sites fail the same WCAG checks first. Each guide has a plain-language fix and a before/after snippet you can copy.
See where your site stands in seconds
A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Croatia-specific accessibility statement when you need one.