Loading…
Loading…
Until late 2025 Croatia was one of the very last EU Member States with no horizontal FDI-screening regime. Sectoral approvals existed (banking, insurance, broadcasting, telecoms), but there was no cross-cutting national-security screening framework comparable to those in Germany (AWG), France (R.151), Italy (Golden Power), the Netherlands (Wet Vifo), Czechia (Act 34/2021), Romania (Law 164/2023), Sweden (Lag 2023:560) or Finland (Act 172/2012, as amended 2020).
The Act on Screening of Foreign Direct Investments — adopted unanimously by the Hrvatski sabor on 24 October 2025, published in Narodne Novine 136/2025, in force 13 November 2025 — closes that gap:
as natural or legal persons from outside the EU (i.e. third-country investors), as well as EU-domiciled vehicles ultimately controlled from outside the EU.
indirect acquisition of at least 10 % of share capital, voting rights or property rights in a target entity operating in a designated sensitive sector.
defence, dual-use, critical infrastructure (energy, transport, water, health, communications, financial markets), critical raw materials, emerging technologies (AI, semiconductors, quantum, biotech, robotics), media, and access to sensitive personal data.
standstill — notifiable transactions cannot close before clearance. The screening authority must issue a decision within 120 days of a complete application, extendable to 150 days in exceptional cases.
recommendation, may approve, condition or block the transaction; for completed transactions found to threaten national security or public order, the Government may order unwinding.
into the Article 6 Reg 2019/452 cooperation mechanism — Croatian authorities will both notify cases to the Commission and respond to Commission opinions on cases notified by other Member States.
With Croatia in place, only a small handful of EU MS (Cyprus, Bulgaria) remain without operational horizontal regimes — at the same moment the EU is finalising the political agreement on the recast FDI-screening Regulation (mandatory minimum coverage across all MS, formally agreed 11 December 2025).
the Adriatic. Croatia hosts substantial inward investment in maritime, port and defence-adjacent assets (Rijeka, Ploče, Pula), segments where third-country interest — including Chinese state-linked capital — has been visible over the last decade.
By bringing its screening regime up to EU standard now, Croatia positions itself as a reviewing authority for Article 6 opinions affecting Bosnia & Herzegovina, Serbia and Montenegro cases routed through Croatian holding vehicles.
targets in energy (HEP-linked assets, INA), digital infrastructure (data centres, telecoms backbone), media (private TV/print consolidation), defence-electronics and ports/logistics. Expect parallel filings before the Croatian Competition Agency (AZTN) and the FDI authority where thresholds overlap.
the 25th MS to plug into the Article 6 process, modestly increasing the volume of cross-border opinions in circulation.
in the operational sense — the Ministry of Finance has led the drafting but the implementing regulations (to be issued post 13 November 2025) will allocate day-to-day case-handling.
sets the 10 % shareholding trigger but does not appear to specify a minimum transaction value; implementing regulations will determine whether a EUR-denominated de minimis (cf. Romania's EUR 2 m threshold) is introduced.
the authority to unwind and to penalise gun-jumping, but the applicable fine cap (as % of turnover or absolute euro amount) is to be fixed by implementing regulation.
third-country FDI; first-year case volume is likely to be small (single digits per quarter), with media and digital-infrastructure deals the most probable early flashpoints.