After an urgent adoption procedure to meet one of the key requirements for joining the OECD, on 13 November 2025 Croatia’s Foreign Investment Screening Act (Croatian: Zakon o provjeri stranih ulaganja) entered into force. Even though certain implementing acts are yet to be adopted (e.g., the Government’s regulation prescribing a detailed list of covered (sub)sectors including the criteria for determining target entities), the key aspects of the regime are already known.
Scope of screening
The focus is on third-country (i.e., non-EU / non-EEA) investments in Croatian entities active in sensitive sectors, that result in the acquisition of a qualified share (such as at least 10% of shares or voting or property rights) or control via different means (such as board appointment or veto rights, etc.).
The act applies accordingly to concessions, public-private partnership agreements, free zones and concentrations regulated by competition law.
Sensitive sectors include, for example, energy, transport, healthcare, water and waste management, food industry, research, defence, media, information and communication technologies, digital infrastructure, postal and railway services, banking and financial market infrastructure.
- Foreign investors include third-country persons, as well as legal entities established in the EU/EEA controlled by a foreign investor or a third country.
- Target entities are traders / companies established in Croatia that operate (or will be incorporated) in connection with a foreign investment (i.e., both greenfield and brownfield investments are covered).
Already completed foreign investments may also be subject to screening within three years of the act’s entry into force.
Screening mechanism
The application for approval may be submitted by the foreign investor or by the Croatian target entity. In any case, the investment cannot be lawfully completed before the clearance is granted by the Ministry of Finance.
The Ministry of Finance bases its final decision on the opinion of the FDI Screening Committee, which evaluates potential risks and takes into consideration comments from the European Commission and the Member States.
The procedure should not exceed 120 - 150 days after submission of the complete application.
The Ministry of Finance may also initiate the screening ex officio whenever there is a suspicion of non-compliance with the law.
Decisions of the Ministry of Finance cannot be appealed, but a dispute may be initiated before the Croatian High Administrative Court.
Non-compliance and confidentiality
Sanctions include the revocation of the approval and divestment order within nine months (or, in exceptional cases, within fifteen months). Until the sale is completed, restrictions on disposing of shares or interests and on exercising any related voting or property rights remain in effect.
The public will be familiarised only with the statistical data, while the lists of investors and the identified target entities remain confidential.
