Croatia
EU AI Act implementation, 2026
Croatia notified its Article 77 fundamental-rights bodies in December 2024 but has designated no market surveillance authority, notifying authority or single point of contact; the implementing act (Zakon o provedbi Uredbe (EU) 2024/1689) was scheduled for Q1 2026 in the Sabor's EU-alignment plan, yet as of October 2026 no draft has been published for consultation and nothing has appeared in Narodne novine.
- Implementing law
- Draft bill
- Penalty regime (Art. 99)
- Not adopted
- Regulatory sandbox
- Planned
- Readiness rank
- 25 of 27score 20 / 100
Key findings
- No Article 70 authorities designated or notified as of October 2026; the only AI Act designations are the seven Article 77 fundamental-rights bodies from December 2024.
- The implementing act is being drafted by a 42-member MPUDT working group (ministries, AZOP, Ombudsperson, CARNET, universities, chambers, CroAI); no draft text or e-savjetovanja consultation was found.
- The Q1 2026 target in the Sabor's EU-alignment plan was missed, and no later official timetable has been published.
- AZOP is a candidate for market surveillance in the data-protection-heavy Annex III areas but has only an Article 77 role today; no national penalty rules or sandbox exist.
- Croatia has no adopted national AI strategy; the National AI Development Plan to 2032 is still in preparation.
National authorities
Not designated or not confirmed as of 21 Oct 2026.
Not designated or not confirmed as of 21 Oct 2026.
Not designated or not confirmed as of 21 Oct 2026.
Implementing law, penalties and sandbox
Zakon o provedbi Uredbe (EU) 2024/1689 (Akt o umjetnoj inteligenciji) – Act implementing Regulation (EU) 2024/1689
narodne-novine.nn.hr (opens in new tab)No national penalty rules under Article 99 are in force; regulators rely on existing powers.
The implementing act is expected to provide the domestic legal basis for an AI regulatory sandbox; none has been established or announced.
No national AI strategy identified.
Notable developments
-
Croatia notifies seven Article 77 fundamental-rights authorities
The Ministry of Justice, Public Administration and Digital Transformation (MPUDT) notified the Commission of the Ombudswoman, the Ombudswomen for Children, Gender Equality and Persons with Disabilities, the Personal Data Protection Agency (AZOP), the State Electoral Commission and the Agency for Electronic Media.
mpudt.gov.hr (opens in new tab) -
Government launches drafting of a National AI Development Plan to 2032
On 2 May 2025 the government decided to draft a National Plan for AI Development to 2032 with a 2026-2028 action plan, led by MPUDT under Minister Damir Habijan, with a special expert working group of academics, industry and state bodies.
tportal.hr (opens in new tab) -
Article 70 designation deadline missed
No market surveillance or notifying authority was notified by 2 August 2025. Civil society (Politiscope, an EDRi member, in May 2025) had urged that the data protection authority be made the single market surveillance authority, with a public register of public-sector AI and a ban on live biometric surveillance.
edri.org (opens in new tab) -
Sabor's 2026 EU-alignment plan schedules the AI implementing act for Q1
The Plan for the Alignment of Croatian Legislation with the EU Acquis for 2026 (adopted by the Sabor 6 March, published NN 26/2026 on 13 March) lists the Act implementing Regulation (EU) 2024/1689 as item 27 for the first quarter under MPUDT; the slot lapsed without a bill.
narodne-novine.nn.hr (opens in new tab) -
Commission list still has no Croatian single point of contact
The Commission's SPOC list (last update 7 Sept 2026) shows no entry for Croatia; a 42-member MPUDT working group chaired by Brankica Alujević Grgas continues to draft the act.
mpudt.gov.hr (opens in new tab)
Analysis
Croatia was an early mover on the easy part of AI Act governance, notifying its fundamental-rights authorities within weeks of the November 2024 deadline, but has stalled on the hard part. Responsibility sits with MPUDT, which is simultaneously drafting the implementing act and the national AI development plan. The size of the working group (42 members spanning regulators, academia and industry) signals an inclusive process but also explains the slow pace; a year on from the Article 70 deadline there is no public draft.
The institutional question is who will supervise. Croatia has no obvious single candidate: HAKOM is the DSA coordinator, AZOP is the data protection authority, and the State Inspectorate handles product market surveillance. Advocacy groups have pushed for AZOP as the lead; the Sabor plan merely assigns the file to MPUDT. Until the act defines the split, the Commission's Article 258 route is the only enforcement pressure and Croatian deployers have no domestic regulator to notify of serious incidents.
Timing now hinges on whether MPUDT sends the draft to e-savjetovanja in late 2026. With the Digital Omnibus postponing Annex III high-risk obligations to December 2027, the Croatian act could still be in force before the obligations it is designed to police, but the Article 50 transparency duties and prohibited-practice rules already apply without a national supervisor.
EU AI Act 2026 Q3 Report
All 27 member-state profiles including Croatia, the readiness ranking, the Omnibus timeline and every source, as one print-ready PDF.
Sources
- Zakon o provedbi Uredbe (EU) 2024/1689 (Akt o umjetnoj inteligenciji) – Act implementing Regulation (EU) 2024/1689 (opens in new tab) narodne-novine.nn.hr
- Croatia notifies seven Article 77 fundamental-rights authorities (opens in new tab) mpudt.gov.hr
- Government launches drafting of a National AI Development Plan to 2032 (opens in new tab) tportal.hr
- Article 70 designation deadline missed (opens in new tab) edri.org
- Commission list still has no Croatian single point of contact (opens in new tab) mpudt.gov.hr