Croatia requires a MiCA licence for crypto ATM exchange, and five firms hold one after the 1 July 2026 deadline
In Croatia, HANFA lists exchanging crypto for money through ATMs as a crypto-service that needs authorisation under MiCA. The transition period ended on 1 July 2026. On 8 October 2026 its register lists five licensed firms, the first approved on 9 April 2026. None of the licence decisions reviewed mentions ATMs.
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5
Firms licensed by HANFA under MiCA, first on 9 April 2026
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1 Jul 2026
End of the MiCA transition period for existing providers
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17
Providers in the HANFA VASP register during the transition
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In Croatia, HANFA lists exchanging crypto-assets for money through ATMs as a crypto-service that needs authorisation under MiCA.2 The transition period ended on 1 July 2026.1 On 8 October 2026 its register lists five licensed firms, the first approved on 9 April 2026.4,5 None of the licence decisions reviewed mentions ATMs.5,8,9
Last updated: October 2026
Regulatory Framework
Croatia applies the EU Markets in Crypto-Assets Regulation (MiCA) directly. The implementing law was adopted by Parliament on 12 July 2024 and published in the Official Gazette on 19 July 2024 (85/24).3 HANFA, the financial services supervisory agency, handles crypto-asset service providers. The Croatian National Bank handles asset-referenced and e-money tokens (Articles 6 and 8).3 MiCA became applicable in Croatia on 30 December 2024.2
HANFA names ATMs in its guidance for consumers. Its notice of 2 January 2025 lists exchanging crypto-assets for money through ATMs as a crypto-service, next to buying and selling crypto-assets and storing private keys.2 The notice is guidance and not a legal text, and the implementing law and the licence decisions reviewed do not mention ATMs.3,5,9
Croatian companies need HANFA approval before they provide crypto-services. Providers from other EU member states can serve Croatia on their home licence after notifying their intent, and some financial institutions supervised by HANFA or the National Bank can provide the services after a notification.1
Licensing Timeline
| Date | What happened |
|---|---|
| 30 Dec 2024 | MiCA applies in Croatia. Existing providers supervised only for AML keep operating until they obtain authorisation, at the latest on 1 July 20262 |
| 9 Apr 2026 | HANFA Board authorises Electrocoin d.o.o. for exchange of crypto for money, exchange of crypto for crypto, and custody and administration5 |
| 23 Apr 2026 | White Tech d.o.o. is authorised for exchange, transfer and custody services6 |
| 1 Jun 2026 | Digital Assets d.o.o., Split, is authorised as a crypto-asset service provider7 |
| 17 Jun 2026 | Bitblock d.o.o. and IN Kapital d.o.o. are authorised8. The Bitblock decision covers exchange of crypto-assets for money and lists no other service9 |
| 1 Jul 2026 | Transition ends. Providers without a licence may no longer provide crypto-asset services1 |
HANFA reported on 3 July 2026 that 17 providers were listed in its VASP register during the transition, and that five obtained a licence before the deadline.1 On 8 October 2026 its register of authorised providers lists five firms: Bitblock, Digital Assets, Electrocoin, IN Kapital and White Tech.4 The register does not show authorisation dates, and the 3 July notice said IN Kapital was waiting for entry after its court registration.1,4
What Applies to Providers
HANFA lists the licensing requirements as suitability of management board members and shareholders, sufficient own funds, internal controls and an adequate organisational structure, AML and counter-terrorist financing arrangements, and ICT and security risk management. It adds that there is no guarantee an applicant will be authorised.1 Once authorised, a provider is supervised by HANFA for all its crypto-asset activities and not only for AML.1
Providers that did not obtain a licence must tell clients they actively served that the services have ceased and return client funds and crypto-assets on their instructions. HANFA monitors wind-down plans, client communications and the return of assets. They can apply at any time, and may provide services again only after authorisation is granted.1
The authority can warn management board members, revoke authorisations and apply supervisory measures. These include suspending services for up to 30 consecutive working days and publishing non-compliance (Articles 15, 21, 22 and 47).3
What Is Not Known
The amount of penalties for providing crypto-asset services without authorisation could not be confirmed, because the text of the law reviewed ended before its penalty provisions.3 HANFA does not publish a list of crypto ATM operators, and no source reviewed says which licensed firms run machines. The sources do not say whether an ATM operator needs anything beyond the standard MiCA authorisation, whether siting a machine needs a local permit, how customer due diligence thresholds apply to ATM transactions, or how long an application takes. These are questions for Croatian counsel and HANFA.
Sources and references
1. HANFA, Provision of crypto-asset services from 1 July 2026, 3 July 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
2. HANFA, Notification for persons intending to trade crypto-assets, 2 January 2025 (PRIMARY, guidance, accessed 8 October 2026) | hanfa.hr
3. Law on the Implementation of Regulation (EU) 2023/1114 on markets in crypto-assets, Official Gazette 85/2024 (PRIMARY, excerpt, accessed 8 October 2026) | narodne-novine.nn.hr
4. HANFA, Register of entities authorised to provide crypto-asset services (PRIMARY, accessed 8 October 2026) | hanfa.hr
5. HANFA, Decision authorising Electrocoin d.o.o., Board session of 9 April 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
6. HANFA, Board meeting: White Tech obtains authorisation to operate under MiCA, 23 April 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
7. HANFA, Board meeting: third authorisation issued under MiCA (Digital Assets), 1 June 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
8. HANFA, Board meeting: two new crypto licences issued (Bitblock, IN Kapital), 17 June 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
9. HANFA, Decision authorising Bitblock d.o.o., 17 June 2026 (PRIMARY, accessed 8 October 2026) | hanfa.hr
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with HANFA before considering market entry.