CNB prescribes the documentation for the authorization to p…

Zagreb, October 9, 2026. — The Croatian National Bank has published in the Official Gazette (Narodne novine) no. 115/2026 the Decision on documentation and information to be attached to the request for the issuance of authorization to provide financial services, under official reference no. 1378. The Decision was adopted on September 28, 2026, by the Governor dr. sc. Ante Žigman, and enters into force on the eighth day from the date of publication.

Legal Basis and Scope

The Decision was adopted based on Article 20, paragraph 8 of the Credit Institutions Act (“Official Gazette”, no. 22/2026) and Article 43, paragraph 2, point 10 of the Croatian National Bank Act (“Official Gazette”, no. 75/2008, 54/2013, and 47/2020), under O. no.: 404-091/09-26/AŽ. It regulates which documentation and information are to be attached to a credit institution’s request for authorization to provide financial services, and terms are interpreted in accordance with the Credit Institutions Act and Regulation (EU) No 575/2013.

What the Request Must Contain

The request from a credit institution that has an operating license must contain at least 18 groups of information and documents, including:

institution data: company name, OIB (Personal Identification Number), LEI, MBS, registered office, first and last name of the contact person, e-mail address, and telephone number;
a list of financial services for which authorization is sought, indicating the relevant provision of the Credit Institutions Act;
the name of the regulation and the name of the service regulated by a special regulation, if authorization for such a service is sought;
consent, opinion, or another appropriate act of the Croatian Financial Services Supervisory Agency or another competent body;
a draft of the statutes with visible amendments and supplements;
a description of the actions taken regarding the introduction of the service, along with the approval of the management board or supervisory board;
a description of the reasons for introducing the service, including its alignment with the group’s business model and a risk assessment with grading (high, medium, low) and mitigating factors;
information on whether a change to the credit institution’s business model is planned.

Plan and Projections for at Least Three Years

The central part of the request is a plan covering at least three business years, on an individual and, if applicable, on a consolidated and sub-consolidated basis, including a baseline and stress scenario. The plan must contain an overview of the geographical distribution of services, projections of the balance sheet, profit and loss account, and cash flow, as well as projections of prudential requirement indicators: the CET1 ratio, the Tier 1 ratio, the total capital ratio, total risk exposure amounts, the leverage ratio, the liquidity coverage ratio (LCR), and the net stable funding ratio (NSFR). Additionally, projections for the NPL ratio, the cost-to-income ratio, and the total number of working hours (FTE) are required.

The institution must also attach updated policies and internal acts on the manner of operation, organization of work, and internal governance, including the system of internal controls, authorizations, and responsibilities, as well as information on how the introduction of the new service affects the organization and personnel policy. Amendments to the business plan are also required pursuant to Article 5, paragraph 1, point (a) of Commission Delegated Regulation (EU) 2022/2580 of 17 June 2022.

Outsourcing, business continuity, and IT

If outsourcing is planned in connection with the service, it is necessary to provide the information from Article 5, paragraph 1, point (f) of Commission Delegated Regulation (EU) 2022/2580, comply with the subordinate legislation on outsourcing, and submit evidence and the contract or draft contract. The request must also contain evidence that the service is included in the business continuity plan, as well as the impact on the recovery plan, resolution strategy, and minimum requirements for regulatory capital and eligible liabilities (MREL). A cost-benefit analysis, a description of changes in organization and job systematization, including any changes to members of the management board or supervisory board and holders of key functions, and information on changes in tangible assets and information technology are also required.

The request is concluded with a statement signed by the person authorized to represent the credit institution stating that the information and documentation are true, accurate, up-to-date, and complete, and that the Croatian National Bank will be immediately notified of any change. If the request is submitted pursuant to Article 20, paragraph 4 of the Credit Institutions Act, the documentation from Article 60, paragraph 7 of Regulation (EU) 2023/1114 and the delegated regulations adopted on the basis of its Article 60, paragraph 13, shall also be attached to the documentation.

Upon the entry into force of this Decision, the Decision on the documentation to be attached to the request for the issuance of authorization for the operation of a credit institution and the request for the issuance of authorization for the provision of financial services (“Narodne novine”, No. 135/2023 and 107/2024) shall cease to be valid. All procedures for the issuance of authorization for the provision of financial services initiated before the entry into force shall be completed according to the provisions of the new Decision.

The Decision on prior consent for the acquisition of a qualifying holding in a credit institution (No. 1377) was also published in the same issue of Narodne novine, which provides for reduced information requirements for repeated acquisition procedures and the possibility of referring to documentation already submitted to the Croatian National Bank within the framework of supervision.

Significance

The new Decision for banks and companies planning to expand financial services means a clearer, yet more demanding framework: in addition to data on the institution and the service, the regulator now explicitly requires three-year projections in base and stress scenarios, a risk assessment with gradation, and evidence of the service’s inclusion in the business continuity plan and recovery strategy. For institutions in preparation, this means earlier planning of capital, IT, and personnel, while legal certainty increases as the requirements for approval to provide financial services are now regulated by a single, comprehensive act.

Source: Narodne novine, no. 115/2026 of October 9, 2026, Decision on documentation and information to be attached to the request for the issuance of approval for the provision of financial services, no. 1378, O. no.: 404-091/09-26/AŽ, Croatian National Bank, governor dr. sc. Ante Žigman.