The fundamental legal framework governing bribery and corruption in the Republic of Croatia is the Criminal Code (Narodne novine Nos. 125/2011, 144/2012, 56/2015, 61/2015, 101/2017, 118/2018, 126/2019, 84/2021, 114/2022, 114/2023, 36/2024, 136/2025 – hereinafter: the Criminal Code). The relevant provisions regulating the described corrupt offences are contained in Chapter XXIV – Criminal Offences against Official Duty and Chapter XXVIII – criminal offences against official duty.

There is also the Act on the Liability of Legal Persons for Criminal Offences (Narodne novine Nos. 151/2003, 110/2007, 45/2011, 143/2012, 114/2022, 114/2023 – hereinafter: ZOPOKD).

It is also necessary to point to several anti-corruption regulations such as the Conflict of Interest Prevention Act (Narodne novine, Nos. 143/21, 64/24), the Whistleblower Protection Act (Narodne novine, Nos. 46/22, 136/25), the Public Procurement Act (Narodne novine, Nos. 120/16, 114/22), the Act on the Financing of Political Activities, Election Campaigns and Referenda (Narodne novine, Nos. 29/19, 98/19).

The competent authorities for the investigation and prosecution of financial crime in the Republic of Croatia are primarily the State Attorney’s Office of the Republic of Croatia (hereinafter: DORH), which is authorized to initiate and conduct criminal proceedings. Within DORH, municipal and county state attorney’s offices operate, as well as the Office for the Suppression of Corruption and Organized Crime (hereinafter: USKOK), which specializes in prosecuting corruption and organized crime offences.

Since 1 June 2021, the European Public Prosecutor’s Office (EPPO) has also been operating in Croatia as an independent EU body responsible for investigating, prosecuting, and bringing charges for criminal offences affecting the financial interests of the European Union, including fraud, corruption, money laundering, and cross-border VAT fraud.

The Ministry of the Interior also plays a role in detecting and investigating financial crime through specialized criminal police units, particularly the National Police Office for the Suppression of Corruption and Organized Crime (PNUSKOK). PNUSKOK monitors and analyses forms of corruption, organized crime, and terrorism, their trends and methods, and conducts complex criminal investigations at the national level in close cooperation with USKOK.

At early stages of proceedings, the Tax Administration and the Anti-Money Laundering Office also play a role. The Tax Administration supervises compliance with tax

obligations and participates in financial investigations, while the Anti-Money Laundering Office analyses suspicious financial transactions and provides relevant data to competent authorities.

In Croatian criminal law, in the context of the Criminal Code, the terms “bribery” and “corruption” are not defined as unified general concepts, but are normatively elaborated through several individual criminal offences.

“Bribery” represents concrete criminal conduct regulated through the criminal offences of receiving and giving bribes (in the public and private sectors), while “corruption” represents a broader, doctrinal and practical concept encompassing various forms of abuse of entrusted powers for the purpose of obtaining unlawful benefit. Such an approach is in accordance with continental criminal-law systems, where incriminations are defined exhaustively, and not through general definitions.

In the area of the public sector, the basic criminal offences of bribery and corruption are receiving a bribe (Article 293 of the Criminal Code) and giving a bribe (Article 294 of the Criminal Code). Receiving a bribe is committed by an official or responsible person who requests or receives a bribe or accepts an offer or promise of a bribe in order to perform an act which he or she should not perform or to omit an act which he or she should have to perform, that is, also when the bribe is given for a lawful act.

In addition to the basic forms of bribery, the Criminal Code also specifically incriminates trading in influence (Article 295 of the Criminal Code) and giving a bribe for trading in influence (Article 296 of the Criminal Code), where criminal liability extends also to situations in which a person uses his or her real or presumed influence on an official person in order to mediate in decision-making in exchange for consideration. In this way, so-called “intermediary corruption” is also sanctioned, regardless of whether there is direct contact with the decision-maker.

In the private, that is, economic sector, the Criminal Code provides for the specific criminal offences of receiving a bribe in economic business operations (Article 252 of the CC) and giving a bribe in economic business operations (Article 253 of the Criminal Code).

The Criminal Code also encompasses special situations of corruption in certain proceedings, such as bribery in bankruptcy proceedings (Article 251 of the Criminal Code), where both the receiving and the giving of a bribe for the purpose of influencing the decision-making of creditors or the bankruptcy trustee are punishable, with penalties that may reach up to eight years of imprisonment.

In Croatian criminal law there is a clear and normatively elaborated distinction between bribery in the public sector and bribery in the private (economic) sector.

In the area of the public sector, the basic criminal offences of bribery and corruption are receiving a bribe (Article 293 of the Criminal Code) and giving a bribe (Article 294 of the Criminal Code). Receiving a bribe is committed by an official or responsible person who requests or receives a bribe or accepts an offer or promise of a bribe in order to perform an act which he or she should not perform or to omit an act which he or she should have to perform, that is, also when the bribe is given for a lawful act. The essential elements of this criminal offence are the status of the perpetrator (official or responsible person), the existence of a bribe as consideration, and the causal connection between the bribe and the official act. Criminal-law protection in this area is exceptionally strict, so the prescribed penalties, depending on the form of the offence, range from one to ten years of imprisonment. On the other hand, giving a bribe is committed by any person who offers, promises or gives such a bribe to an official or responsible person in order to influence his or her conduct. Although the penalties for giving a bribe are milder, it is still a serious criminal offence punishable by prison sentences of up to several years.

In addition to the basic forms of bribery, the Criminal Code additionally incriminates the so-called intermediary forms of corruption through the criminal offences of trading in influence (Article 295 of the Criminal Code) and giving a bribe for trading in influence (Article 296 of the Criminal Code). These provisions extend criminal liability to situations in which a person uses his or her real or presumed influence on an official person in order to mediate in the making of a certain decision in exchange for consideration. In this way, the legislator also encompasses so-called indirect or intermediary corruption, regardless of whether there is direct contact between the giver of the bribe and the decision-maker.

As opposed to this, in the private, that is, economic sector, the Criminal Code provides for specific criminal offences of receiving a bribe in economic business operations (Article 252 of the Criminal Code) and giving a bribe in economic business operations (Article 253 of the Criminal Code). Receiving a bribe in this context exists when a person in economic business operations requests or receives a bribe or accepts a promise of a bribe in order to favour a certain person in the conclusion or performance of a transaction, thereby at the same time causing damage to the entity whose interests he or she represents. In the milder form, even the mere receiving of a bribe as consideration for favouring is punishable. For these forms, prison sentences ranging from six months to eight years are prescribed. Giving a bribe in economic business operations is committed by a person who offers or gives a bribe to another for the purpose of such favouring, whereby the existence of a connection between the bribe and the specific business decision is necessary, and the penalties range up to five years of imprisonment.

The Criminal Code additionally recognizes specific forms of corruption connected with particular proceedings, such as bribery in bankruptcy proceedings (Article 251 of the Criminal Code), where both the receiving and the giving of a bribe for the purpose of influencing the decision-making of creditors or the bankruptcy trustee are punishable. For these offences, penalties are prescribed which may reach up to eight years of imprisonment, thereby additionally protecting the legality and transparency of bankruptcy proceedings.

With regard to the subjects of criminal-law protection, it is important to point out that the Criminal Code broadly defines the term official person (Article 87 of the Criminal Code), encompassing not only domestic public office-holders and public servants, but also persons who perform public powers. Furthermore, the Croatian legislator expressly includes foreign public office-holders as well. This is particularly visible through the criminal offence of bribery of representatives from Article 339 of the Criminal Code, which incriminates both passive and active bribery of representatives, whereby protection is extended to representatives in the Croatian Parliament and local representative bodies, but also to representatives in the European Parliament and to representatives in legislative or representative bodies of foreign states and international public organisations. In this way, Croatian law is fully aligned with international standards in the field of combating corruption and clearly confirms that there is no difference in the criminal-law treatment of domestic and foreign public office-holders.

In conclusion, the Croatian Criminal Code establishes a dual system of incriminations which clearly distinguishes corruption in the public and private sectors through separate criminal offences, while at the same time extending criminal-law protection to intermediary forms of corruption and the international context. At the same time, it should be emphasized that Croatian law does not recognize a separate criminal offence of “failure to prevent”, such as exists in certain Anglo-Saxon legal systems. Criminal liability is based on active participation in corrupt conduct, while possible failures in supervision or prevention are sanctioned through other criminal offences or through the liability of legal persons, but not as an independent incrimination of that type.

In Croatian criminal law, liability for bribery is not limited exclusively to natural persons, but also encompasses legal persons, whereby a dual system of criminal liability has been established.

First of all, natural persons represent the basic subjects of criminal offences of bribery. In that sense, liability may be borne both by perpetrators on the side of receiving a bribe (e.g. official or responsible persons), and by perpetrators on the side of giving a bribe (any person who offers, promises or gives a bribe). The criminal liability of natural persons is based on the general principles of criminal law, including the existence of guilt (intent) and all the statutory elements of the specific criminal offence.

However, the Croatian legal system also provides for the criminal liability of legal persons, pursuant to which a legal person may be liable for the criminal offence of bribery if it was committed in its name, for its account or for its benefit, by a responsible person or another person acting within the scope of authority within the legal person.

The liability of the legal person does not exclude the liability of the natural person, but rather parallel conduct of proceedings and the imposition of sanctions on both the natural person and the legal person for the same criminal offence is possible, and all of this is regulated by the provisions of ZOPOKD.

Victims of criminal offences in the area of bribery and corruption may exercise the right to compensation for damage in several ways: by means of a property-law claim within criminal proceedings, by initiating civil proceedings or, in certain cases, through special legal mechanisms, such as those provided for by the Act on Monetary Compensation to Victims of Criminal Offences (Narodne novine No. 80/2008, 27/2011).

Within criminal proceedings, the injured party may request compensation for damage, return of a seized item or annulment of a legal transaction, and the court may decide on such a claim already in the judgment itself. If the court assesses that there is not sufficient basis for this, it shall refer the injured party to exercise his or her right in civil proceedings before the competent civil or commercial court, depending on the nature of the legal relationship.

Pursuant to Article 51 paragraph 1 item 2 of the Criminal Procedure Act, the injured party may submit a property-law claim until the completion of the criminal proceedings, on which the court decides in the judgment by which it decides on the criminal liability of the defendant. Such a claim is decided upon by the court before which the criminal proceedings are being conducted, whether municipal or county, whereby this is the so-called adhesion procedure, that is, joined adjudication of a civil-law claim within criminal proceedings. This institute is regulated in more detail in Chapter XI (Articles 153 – 162) of the Criminal Procedure Act.

A property-law claim represents the injured party’s claim for compensation for damage or restitution of property arising from the criminal offence, on which the court discusses exclusively upon the proposal of the injured party. Such a claim may encompass everything that would otherwise be the subject of civil litigation, which means that the injured party may avoid initiating a separate procedure if the conditions for adjudication are fulfilled in criminal proceedings. The substantive-law basis of these claims is found in the rules of civil law, so the injured party may request compensation for pecuniary and non-pecuniary damage, return of items or annulment of legal transactions concluded under the influence of fraud, coercion or other illegality.

Criminal proceedings may end by the rendering of a decision on discontinuance or of a judgment, whereby the judgment may be dismissing, acquitting or convicting. In the case of a convicting judgment, the court may fully or partially uphold the property-law claim, provided that during the proceedings facts have been established which enable such a decision. If this is not the case, the injured party is referred to initiate civil proceedings. Similarly, in the event of discontinuance of the proceedings or the rendering of a dismissing judgment, the injured party is also referred to civil litigation for the purpose of exercising his or her rights. It is important to note that in such situations there is a so-called conditional interruption of limitation periods, provided that the injured party files a lawsuit in civil proceedings within three months from the finality of the decision, pursuant to Article 243 of the Civil Obligations Act (Narodne novine Nos. 35/2005, 41/2008, 125/2011, 78/2015, 29/2018, 126/2021, 114/2022, 156/2022, 145/2023, 155/2023 – hereinafter: ZOO).

The criminal-law consequences of criminal offences of bribery and corruption in the Republic of Croatia are primarily manifested mainly through the prescribed prison sentences, the range of which depends on the type and gravity of the criminal offence.

In the public sector, for the criminal offence of receiving a bribe (Article 293 of the Criminal Code), strict prison sentences ranging from one to ten years are prescribed, depending on the form of the offence. For giving a bribe (Article 294 of the Criminal Code), prison sentences of up to eight years are envisaged.

In the case of so-called intermediary corruption, that is, the criminal offences of trading in influence (Article 295 of the Criminal Code) and giving a bribe for trading in influence (Article 296 of the Criminal Code), prison sentences are also prescribed, whereby the severity of the sanction is determined according to the specific circumstances and the intensity of the unlawful influence.

In the private (economic) sector, for receiving a bribe in economic business operations (Article 252 of the Criminal Code), a prison sentence ranging from six months to eight years is prescribed, while for giving a bribe in economic business operations (Article 253 of the Criminal Code), a prison sentence of up to five years may be imposed.

For special forms of corruption, such as bribery in bankruptcy proceedings (Article 251 of the Criminal Code), prison sentences are envisaged which may reach up to eight years.

In addition to the above, the criminal-law system also provides for confiscation of pecuniary benefit obtained through the criminal offence as a mandatory measure, and in the case of legal persons the imposition of fines and other sanctions is possible in accordance with a special law.

In conclusion, Croatian criminal law provides for a wide range of sanctions for corrupt criminal offences, with emphasis on prison sentences which in the more severe forms reach up to ten years, thereby ensuring a strong repressive and preventive effect.

In the criminal-law sense, Croatian regulations do not lay down explicit, numerically determined limits for hospitality, travel or entertainment expenses in the context of criminal law; rather, their permissibility is assessed through the general criminal-law norms regulating bribery. According to the Criminal Code, any gift or other benefit may constitute a bribe if it is given or received for an unlawful purpose and in connection with the performance of an official or business act. It follows from this that hospitality, travel or entertainment expenses are not prohibited in themselves, but they may acquire the characteristics of a criminal offence if they serve as a means of influencing the making of decisions or the conduct of a certain person. In each concrete case, the decisive role is played by circumstances such as the purpose of such expenses, their proportionality and customary nature in business practice, and the existence of a connection between the benefit given and the expected conduct of the recipient.

In relation to the public sector, additional restrictions arise from special regulations, especially the Conflict of Interest Prevention Act (Narodne novine Nos. 143/2021, 36/2024), as well as from ethical codes and internal rules of public authorities. These rules seek to prevent any conduct that could call into question the impartiality of public office-holders and public servants, so as a rule only gifts of small value and those customary within the framework of protocol or socially acceptable relations are permitted, while all other benefits that may influence decision-making are impermissible.

When it comes to foreign public officials, Croatian criminal law does not establish a special regime with regard to permissible expenses, but equates them with domestic official persons. The same bribery rules apply to them, in accordance with the international obligations of the Republic of Croatia, including the standards of the OECD and the United Nations, which means that any benefit having the characteristics of a bribe may be criminally sanctioned regardless of the nationality of the official.

Ultimately, the Croatian legal system does not recognize generally applicable monetary thresholds that would in advance determine the permissibility of certain expenses, but instead relies on a qualitative assessment of each individual case. Such an approach allows flexibility in the application of the law, but at the same time requires caution, since even seemingly ordinary expenses may, in certain circumstances, be qualified as an impermissible benefit and thereby constitute the criminal offence of bribery.

Political donations in the Republic of Croatia are regulated in detail by a special regulation, first and foremost by the Act on the Financing of Political Activities, Election Campaigns and Referenda (NN 29/19, 98/19), which establishes a transparent and restrictive system of financing political subjects.

That Act prescribes that political parties, independent representatives and candidates may receive donations from natural and legal persons, but subject to clearly determined restrictions. Donations are permitted exclusively from lawful sources and must be recorded and publicly disclosed, thereby ensuring the transparency of the financing of political activities. There are also express prohibitions on donations, so certain entities may not make donations, such as foreign states, foreign legal persons and individuals, public authorities, companies majority-owned by the state or by units of local self-government, as well as legal persons exercising public powers.

The Act also prescribes annual donation limits, whereby natural persons may donate up to a certain maximum amount per political subject, while the limits for legal persons are higher, but also limited. Donations above the prescribed amounts are not permitted, and excesses may result in the obligation to return the funds and in the initiation of misdemeanour proceedings.

Special rules apply during the election campaign period, when the sources and amount of financing are additionally regulated, as well as the obligation to keep special accounts and report to the competent authorities. Supervision of the legality of financing is carried out by the State Electoral Commission, which controls financial reports and may impose sanctions in the event of irregularities.

It is important to emphasize that, although political donations are in themselves lawful if they are in accordance with the regulations, they may acquire the characteristics of a criminal offence if they are given or received with the aim of influencing official conduct, whereby they may fall within the sphere of the criminal-law provisions on bribery or trading in influence.

Croatian law does not recognize a special legal institute of so-called “facilitation payments”, nor does it expressly regulate them as a permitted category of payments. On the contrary, such payments are as a rule considered prohibited because they may constitute the criminal offence of bribery under the provisions of the Criminal Code.

Namely, the Criminal Code does not make a distinction between a “classic” bribe and so-called payments for facilitating procedures. Any gift or other benefit given to an official or responsible person for the purpose of speeding up, facilitating or ensuring the performance of an official act – even if it is an act that such person would otherwise be obliged to perform – may constitute the criminal offence of giving a bribe (Article 294 of the Criminal Code), while acceptance of such a benefit may constitute receiving a bribe (Article 293 of the Criminal Code). In other words, the fact that it concerns a “routine” or lawful act does not exclude criminal liability.

Such an approach is in line with international anti-corruption standards, especially within the framework of the OECD and the United Nations Convention against Corruption, which advocate a restrictive approach to all forms of informal payments to public officials.

In practice, this means that so-called facilitation payments are treated as an unlawful benefit if there is a connection with the performance of official duty, regardless of their amount or frequency. Therefore, business entities and individuals are recommended to refrain completely from such payments, since there is no legal exception that would make them permissible.

In Croatian criminal law, there are no special, autonomous “defences” specifically related to bribery and corruption offences; rather, the general rules of criminal law on the exclusion of unlawfulness and guilt apply to these criminal offences, as well as certain legal institutions which may affect the criminal liability or punishability of the perpetrator.

First of all, the defence may be based on the absence of the statutory elements of the criminal offence, for example if there is no gift or other benefit, if there is no causal link between the benefit and the official or business act, or if the perpetrator’s intent has not been proven. In that sense, contesting the existence of an unlawful benefit or its purpose often constitutes a key element of the defence. Furthermore, general legal institutions such as self-defence, necessity, mistake (of fact or of law) or lack of criminal capacity also apply, although in practice they are rarely relevant to corrupt criminal offences. Also, the issue of lack of guilt may be relevant, for example if the perpetrator was not aware of all the essential elements of the offence.

Specifically with regard to the criminal offence of giving a bribe, the Criminal Code provides for the possibility of exemption from punishment for the perpetrator who gave the bribe at the request of an official person and who reported such offence before it was discovered (the so-called institution of active repentance). This institution aims to encourage the reporting of corruption and the breaking of corrupt relationships.

In addition, in a broader sense, certain circumstances such as cooperation with the criminal prosecution authorities, confession of the offence or disclosure of other perpetrators may have significance as mitigating circumstances when determining the sentence or may lead to more lenient punishment, but they do not constitute formal defences in the narrower sense.

In conclusion, although there are no special “anti-corruption defences”, the legal framework enables a defence through the general institutions of criminal law, with the existence of limited special mechanisms such as exemption from punishment in the case of voluntary reporting of the giving of a bribe.

Under Croatian law, compliance programmes are not expressly regulated as an independent basis for the exclusion of criminal liability for bribery and corruption offences. The criminal liability of natural persons is based on the existence of the statutory elements of the criminal offence and guilt, so the existence of internal rules or control mechanisms, as a rule, does not lead to exemption from liability if the offence has been committed.

However, compliance programmes may have indirect significance in the criminal-law sense. In the case of natural persons, they may be taken into account as a mitigating circumstance when determining the sentence, especially if they show that the perpetrator acted contrary to clearly established rules or if the legal person took measures to prevent and detect irregularities.

Their role is considerably more pronounced in the context of the liability of legal persons under the Act on the Liability of Legal Persons for Criminal Offences. In that sense, the existence of an effective system of supervision, internal controls and compliance measures may be relevant for the assessment of whether the criminal offence was committed due to a failure of supervision or control, and to what extent the legal person took the necessary measures to prevent such offences.

Although even in that case a compliance programme does not automatically exclude liability, it may have a significant impact on the mitigation of punishment, the choice of the type of sanction, and even on the assessment of the degree of guilt of the legal person. In practice, subsequent measures are also additionally evaluated, such as the conduct of internal investigations, cooperation with the competent authorities and improvement of the compliance system after the discovery of irregularities.

Therefore, although Croatian law does not recognize a model in which a compliance programme in itself excludes criminal liability (as in some foreign systems), it may play an important role as a mitigating circumstance and a relevant factor in the assessment of liability, especially with respect to legal persons.

In the Republic of Croatia there are no uniform, comprehensive and legally binding government guidelines which would regulate in detail the manner of compliance with anti-bribery and anti-corruption regulations in the way this has been developed in some other jurisdictions. However, certain forms of guidance and recommendations nevertheless exist through strategic and institutional documents and the practice of the competent authorities.

First of all, the Government of the Republic of Croatia adopts national anti-corruption strategies and action plans, which define goals, measures and recommendations for the prevention of corruption in the public and private sectors. These documents, although not directly binding on private entities, represent an important framework for the development of internal compliance policies.

However, it is important to point out that the Croatian Parliament, at its session on 29 October 2021, adopted a key document entitled the Anti-Corruption Strategy for the period from 2021 to 2030. In that document, a clear definition of corruption was given and it represents a “socially unacceptable phenomenon which directly endangers human rights, destroys morality and endangers the stability and economic progress of the state. Apart from being contrary to positive legal regulations, it also represents a deviation from the fundamental principles of society. Therefore, the fight against corruption represents a basic precondition for the development of an open and democratic society.”

In that document it was emphasized that it should be borne in mind that Article 21 of the Act on the Office for the Suppression of Corruption and Organised Crime prescribes corruption criminal offences in the narrower sense. In addition, Article 87 paragraph 24 of the Criminal Code defines a bribe as any undue reward, gift or other pecuniary or non-pecuniary benefit regardless of value.

Additionally, certain bodies, such as the Ministry of Justice and Public Administration, the Commission for Decision-Making on Conflict of Interest and the Anti-Money Laundering Office, publish various guidelines, recommendations and educational materials relating to integrity, prevention of conflicts of interest and recognition of corruption risks. In the area of anti-money laundering, there are also more detailed instructions for obliged entities which, although primarily aimed at the AML system, are also significant for broader anti-corruption controls.

Also, in practice, international standards and recommendations (e.g. OECD, GRECO, UNCAC), which Croatia implements through legislation and policies, also play a significant role, and they indirectly shape expectations with regard to compliance systems.

In conclusion, although there is no single “compliance manual” at the government level, various strategic documents and guidelines are available which, in combination with the legal framework and international standards, provide a relevant framework for compliance with anti-bribery and anti-corruption regulations.

Croatian criminal law does not recognize the institutions of deferred prosecution agreements (DPAs) or non-prosecution agreements (NPAs) in the form in which they exist in certain Anglo-Saxon legal systems.

However, there are certain functionally similar mechanisms within the criminal procedural system which enable a certain degree of flexibility in criminal prosecution.

First of all, the Criminal Procedure Act provides for the possibility of a plea agreement between the defendant and the state attorney, whereby the parties may agree on the type and amount of punishment, and the court confirms such agreement if it is lawful and well-founded. This institution may have the practical effect of accelerating the proceedings and reducing the sentence, but it does not lead to avoidance of criminal prosecution.

Furthermore, in certain cases of less serious criminal offences there is the possibility of conditional abandonment of criminal prosecution (the so-called opportunity principle), when the state attorney may postpone or discontinue prosecution subject to the fulfilment of certain obligations by the suspect (e.g. compensation for damage, payment for humanitarian purposes). However, this institution has limited application and as a rule is not used for more serious corruption offences.

In substantive criminal law there is also the institution of exemption from punishment in the case of giving a bribe, if the perpetrator reports the criminal offence before it is discovered, which constitutes an incentive for the detection of corruption, but does not constitute an agreement with the prosecution authorities in the classic sense.

Namely, under Article 206.c of the Criminal Procedure Act, the state attorney may by decision dismiss a criminal complaint or abandon criminal prosecution although there is reasonable suspicion that a criminal offence prosecuted ex officio has been committed and for which a fine or imprisonment of up to five years is prescribed, if, having regard to the circumstances, it is probable that in criminal proceedings the defendant will be exempted from punishment, criminal sanctions are being executed against the defendant and the initiation of criminal proceedings for another criminal offence has no purpose having regard to the gravity, nature of the offence and the motives from which it was committed, as well as to the results which the punishment or another measure has achieved on the perpetrator so that he or she will not commit criminal offences in the future, the defendant has been extradited or surrendered to a foreign state or an international criminal court for the purpose of conducting proceedings for another criminal offence, the defendant has been reported for several criminal offences by which he or she has fulfilled the elements of two or more criminal offences, but it is expedient that the perpetrator be convicted only for one, because the initiation of criminal proceedings for the other criminal offences would have no significant effect on the imposition of punishment or other measures on the perpetrator.

In addition, the state attorney may, after previously obtaining the consent of the victim or injured party, by decision conditionally postpone or abandon criminal prosecution, although there is reasonable suspicion that a criminal offence prosecuted ex officio has been committed and for which a fine or imprisonment of up to five years is prescribed, if the suspect or defendant undertakes the obligation to perform some act for the purpose of remedying or compensating the damage caused by the criminal offence, to pay a certain amount in favour of a public institution, for humanitarian or charitable purposes, to pay due statutory maintenance and regularly pay due obligations, to perform community service at liberty, to undergo treatment or withdrawal from drugs or other addictions in accordance with special regulations, to undergo psychosocial therapy for the purpose of eliminating violent behaviour without leaving the family community or, with the consent of the suspect, to leave the family community for the duration of the therapy. In the decision, the state attorney shall determine the time limit within which the suspect or defendant must fulfil the undertaken obligations under paragraph 1 of this Article, which may not exceed one year.

In addition to the above, the defendant and the state attorney may, even before the beginning of the trial part of the court proceedings, reach an agreement on the type and measure of punishment, judicial admonition, suspended sentence, partial suspended sentence, special obligations, protective supervision, confiscation of objects and the costs of the proceedings, and the role of the Court is then to render a judgment on the basis of such agreement pursuant to Article 361 of the Criminal Procedure Act.

In the Republic of Croatia, the protection of whistleblowers who report financial crime is regulated primarily by the Whistleblower Protection Act, which represents implementation of EU Directive 2019/1937 and establishes a relatively developed system of protection.

A whistleblower is any natural person who, in a work-related environment, reports irregularities, including financial crime, corruption or abuses. The Act provides for several levels of protection, among which the key ones are protection of identity and confidentiality, prohibition of retaliation (e.g. dismissal, demotion or harassment), the right to judicial protection and compensation for damage, as well as the right to free legal aid and certain forms of institutional support.

It is particularly important that the law protects not only the whistleblower himself or herself, but also related persons (e.g. colleagues or family members) and persons who receive and process reports (trusted persons), thereby further extending the system of protection.

As regards incentives, the Croatian system does not provide for financial rewards to whistleblowers (unlike some Anglo-Saxon systems), but it provides strong legal and institutional incentives through protection against retaliation and legal certainty, which is the key motivation mechanism for reporting.

The Act establishes a multi-channel reporting system, which includes internal channels (within the employer), external channels (competent authorities) and, under certain conditions, public disclosure. Employers (especially those with 50 or more employees) are obliged to establish internal reporting systems, including the appointment of a trusted person and the definition of procedures for handling reports.

With regard to anonymity, the law enables anonymous reporting, whereby the employer is obliged to act upon such a report if it contains sufficient information. In addition to anonymity, the emphasis is also on the confidentiality of the identity of the whistleblower, which may not be disclosed without his or her consent, except in exceptions prescribed by law.

Protection is, however, conditional upon the whistleblower acting in good faith, that is, that he or she has a reasonable belief in the truthfulness of the reported information; otherwise, he or she may bear misdemeanour liability for intentionally false reports.

In conclusion, the Croatian system does not offer financial rewards, but ensures a wide range of legal protections, institutional mechanisms and the possibility of anonymous reporting, thereby seeking to encourage the detection of financial crime while at the same time protecting the whistleblower from negative consequences.

Croatian law does not recognize the classic institution of an agreement with the prosecution by which complete immunity from criminal prosecution would be guaranteed in advance in exchange for cooperation, such as exists in certain Anglo-Saxon systems. Nevertheless, there are certain mechanisms which enable the cooperation of perpetrators with the criminal prosecution authorities with the possibility of more favourable treatment, especially with regard to mitigation of punishment.

First of all, the Criminal Procedure Act provides for the institution of a plea agreement, by which the defendant may admit the offence and agree with the state attorney on the type and amount of punishment. In that context, providing information and evidence may be a relevant circumstance affecting more lenient punishment, but it does not lead to exclusion of criminal prosecution.

The Criminal Code also in certain cases provides for the possibility of exemption from punishment, for example in the case of giving a bribe if the perpetrator reports the offence before it has been discovered, thereby encouraging the uncovering of corrupt relationships.

The institution of the so-called crown witness is particularly significant, introduced by the provisions of the Act on the Office for the Suppression of Corruption and Organised Crime (Narodne novine Nos. 76/2009, 116/2010, 145/2010, 57/2011, 136/2012, 148/2013, 70/2017, 136/2025: hereinafter: ZUSKOK). It is a suspect or defendant who, in exchange for cooperation with the prosecution authorities, may acquire a special procedural status and testify about criminal offences, most often in the context of corruption and organised crime. In practice, such a person is colloquially called a “repentant one”. The procedure for granting that status is strictly formalized. Before the court, on the motion of the state attorney, grants him or her the status of a crown witness, that person is examined by the authorized prosecutor in the capacity of a witness, whereby his or her statement is assessed both by the state attorney and by the court in a special procedure. Only after that may the court approve such status.

It is important to emphasize that the status of a crown witness is not unconditional. If the person later departs from the statement given during the proceedings, criminal prosecution against him or her may continue for the same criminal offence. In that case, the court may also use the record of his or her earlier examination before the state attorney, conducted according to the rules on the examination of witnesses, which constitutes an exception to the general rules of evidence. In addition, cooperation with the prosecution authorities, including disclosure of other perpetrators or provision of key information, is as a rule taken into account as a mitigating circumstance when determining the sentence.

In conclusion, although Croatian law does not provide for formal immunity agreements, it enables certain forms of cooperation with the prosecution, including the institution of the crown witness, which may result in a significantly more favourable criminal-law position, but subject to strictly prescribed conditions and judicial control.

Investigations by state authorities in relation to allegations of bribery and corruption are not uncommon, especially in the segment of so-called medium-level and high-level corruption. Their frequency stems from an institutionally developed system of criminal prosecution, in which specialized bodies such as USKOK and PNUSKOK play a key role, as well as from the obligations arising from membership in the European Union and international anti-corruption mechanisms (e.g. GRECO, OECD).

In practice, it can be observed that a significant number of proceedings relate to abuses in public administration and local self-government, public procurement, economic crime connected with the public sector, as well as to cases connected with the use of EU funds (in which EPPO plays an additional role).

With regard to effectiveness, the criminal prosecution system as a rule shows a relatively high degree of success at the stage of bringing indictments and rendering convicting judgments, especially in cases handled by USKOK. Statistical data and practice indicate a high share of confirmed indictments and a significant percentage of convicting judgments in relation to the indictments brought.

However, effectiveness is not the same at all stages of the proceedings. Investigations and court proceedings, especially in complex corruption cases, are often lengthy and procedurally demanding, which may affect the perception of their effectiveness. Additional challenges include proving subjective elements (e.g. the existence of unlawful benefit and intent), complex financial flows and the need for international legal assistance.

In relation to legal persons, criminal prosecution exists, but in practice it is rarer than in relation to natural persons, although the legislative framework enables their liability. The reasons for this lie in the complexity of proving organizational liability and the link between the acts of individuals and the legal person.

In conclusion, investigations relating to bribery in Croatia are relatively frequent and institutionally supported, and in a certain number of cases they lead to effective criminal prosecution and convictions, especially in more serious forms of corruption. Nevertheless, challenges with regard to the duration of proceedings and evidentiary standards still affect the overall effectiveness of the system.

In the last several years in the Republic of Croatia, a number of trends have been observable in the field of investigations and enforcement in relation to criminal offences of bribery and corruption, which indicate a gradual strengthening of the institutional framework and a change in the focus of criminal prosecution. One of the most noticeable trends is the focus on the high political and administrative level, that is, on so-called “high-level corruption”. In that context, proceedings have been initiated against persons who held the highest executive functions in state authority, including ministers, as well as against high-ranking officials in public administration and local self-government. This confirms the willingness of the criminal prosecution authorities to act also in politically sensitive cases, which represents an important step forward compared to earlier periods.

At the same time, a trend of increased supervision over public procurement systems and the management of public funds is visible, especially in sectors with high financial risk such as healthcare, construction and коммунal services. In these cases, complex patterns of favouring, bid-rigging and related financial flows are often involved, which requires specialized investigative methods and an interdisciplinary approach.

Additionally, there is an increasingly pronounced focus on the economic dimension of corruption, including the connection between the public and private sectors, whereby legal persons are also investigated, although their criminal prosecution is still rarer compared to natural persons. In that sense, the significance of financial investigations, analysis of money flows and the application of measures of confiscation of pecuniary benefit is growing.

An important newer trend is also the increased role of European bodies, especially the European Public Prosecutor’s Office (EPPO), in cases involving the misuse of European Union funds. This further internationalizes criminal prosecution and strengthens supervision over the use of public funds.

With regard to procedural tools, more frequent use of special evidentiary actions can be observed, such as covert surveillance, monitoring of communications and undercover investigative measures, as well as the increased significance of institutions such as plea agreements and the cooperation of defendants.

Despite the above positive developments, certain challenges are still present, especially with regard to the duration of proceedings and the complexity of proof, which is particularly pronounced in high-level corruption cases involving a larger number of participants and complex financial constructions.

Therefore, recent trends indicate a gradual strengthening of the repressive and institutional response to corruption, with emphasis on a high level of political accountability, financial investigations and international cooperation, which contributes to greater visibility and effectiveness of the system in the fight against corruption.

In the Republic of Croatia there are several forms of judicial review of decisions and actions of state authorities, whereby legal protection is exercised depending on the nature of the specific act or procedure. The system is not uniformly regulated through one institution of “judicial review” in the Anglo-Saxon sense, but rather through several complementary mechanisms.

In the area of administrative law, judicial control is exercised through an administrative dispute, regulated by the Act on Administrative Disputes (Narodne novine No. 36/2024). In that procedure, the administrative courts examine the legality of individual decisions of public authorities, as well as their action or failure to act. The procedure is initiated by filing a lawsuit, and the court may quash or annul the challenged act, order the adoption of a new decision or, in certain cases, itself resolve the administrative matter. In this way, full judicial control of the legality of administrative acts is ensured.

In criminal proceedings, the legality of the actions of state authorities (the police and the state attorney’s office) is ensured through procedural mechanisms provided for by the Criminal Procedure Act. This includes the right to appeal against court decisions, judicial control of investigative actions, as well as the possibility of excluding unlawful evidence. The court has a key role in protecting the rights of the defendant and the legality of the proceedings.

At the constitutional-law level, an additional form of judicial protection is provided by a constitutional complaint before the Constitutional Court of the Republic of Croatia. It is admissible after exhaustion of ordinary legal remedies, if an individual’s constitutional right or freedom has been violated by a decision or action of a state authority. The Constitutional Court may quash the challenged decision and remit the case for re-decision.

In addition, in certain situations it is possible to initiate civil proceedings for compensation for damage against the state due to the unlawful or improper work of its authorities, or unlawful detention.

The key features of the system of judicial review in Croatia include multi-level protection, judicial control of legality and, in certain cases, a decision on the merits by the court. Remedies include appeals, lawsuits in administrative disputes, constitutional complaints and claims for compensation for damage.

In conclusion, although there is no single institution of judicial review, the Croatian legal system ensures effective judicial control of the actions and decisions of state authorities through various procedures and legal remedies.

In the past 12 months, significant legislative developments have been recorded in the Republic of Croatia which have a direct impact on the area of combating bribery and corruption, particularly through the amendments to the Criminal Code adopted in October 2025, as well as the amendments to the Criminal Procedure Act from February 2026.

Through the amendments to the Criminal Code, the normative framework for the criminal liability of legal persons has been further strengthened, especially in the international context. Namely, the application of the criminal legislation of the Republic of Croatia has been expressly extended to legal persons for criminal offences committed not only on the territory of the Republic of Croatia, but also on domestic ships and aircraft, as well as to legal persons registered in the Republic of Croatia for criminal offences committed abroad, subject to the condition of double criminality. Also, foreign legal persons which have a branch in the Republic of Croatia for criminal offences committed outside the territory of the state have also been covered. Such extension of jurisdiction represents an important step forward in harmonization with international standards, especially in the context of combating transnational corruption and bribery of foreign public officials.

Additionally, procedural efficiency has also been improved by introducing the possibility of conducting criminal proceedings against a legal person even in situations where the responsible person is not available in the territory of the Republic of Croatia, thereby removing obstacles in the prosecution of complex economic and corruption-related criminal offences. In the substantive-law sense, the amendments to the Criminal Code also clarified and supplemented certain incriminations relevant to international political corruption, especially through the amendments to the criminal offence of bribery of representatives, by which the circle of protected persons was expressly extended to representatives in the European Parliament and representatives in the legislative and representative bodies of foreign states and international organizations. In this way, the criminal-law protection of the integrity of political decision-making in the international environment has been additionally strengthened, in accordance with the obligations arising from international instruments, including OECD recommendations.

At the same time, the amendments to the Criminal Code also covered the broader field of criminal law, including the introduction of the definition of an artificial intelligence system and a new criminal offence related to dangers arising from the use of such systems, as well as amendments to the criminal offence of trafficking in human beings for the purpose of harmonization with the acquis of the European Union. Although these changes are not directly aimed at corruption, they indicate a general trend of modernization of criminal legislation and its adaptation to new forms of social risks.

Parallel to this, the amendments to the Criminal Procedure Act from February 2026, according to the idea of the legislator, are aimed at increasing the efficiency of criminal prosecution, including the acceleration of proceedings and strengthening of procedural mechanisms, which is of particular importance in complex corruption and economic crime cases, but in the public sphere there are well-founded doubts concerning the effectiveness of the said amendments, especially because through them defence counsel lose certain rights which they had under the provisions of the earlier law (e.g. attendance at sessions of the indictment council, lodging an appeal against a decision on the exclusion of unlawful evidence, etc.).

Viewed as a whole, the said amendments represent an important step in the further development of the Croatian criminal-law system, with emphasis on strengthening the international dimension of criminal prosecution, more efficient prosecution of legal persons and harmonization with international and European standards in the fight against corruption.

At this moment, in the Republic of Croatia there are no publicly published, concrete drafts of comprehensive reforms which would fundamentally change the system of criminal-law regulation of bribery and corruption in the narrower sense. However, several realistic directions of further development can be identified, which arise from recent legislative amendments, international obligations and institutional practice.

First of all, further amendments to the Criminal Code are possible in the direction of additional harmonization with OECD standards, especially in the area of the liability of legal persons and international bribery. The amendments already implemented in 2025, which extended jurisdiction over legal persons and clarified the international aspect of corruption, indicate that the focus in the future as well will be on transnational forms of corruption and business bribery. Further strengthening of the normative and institutional framework related to the criminal liability of legal persons may also be expected, including the potentially more precise definition of standards of supervision and internal control, although at present there are no concrete proposals in that direction.

At the procedural level, further development is possible through the continuation of reforms of the Criminal Procedure Act, with the aim of increasing efficiency and accelerating proceedings in complex corruption cases, especially through digitalization, strengthening of evidentiary tools and case management.

An important influence will continue to be exercised by the European legal framework, including the practice and jurisdiction of the European Public Prosecutor’s Office (EPPO), as well as future directives and recommendations of the European Union, which may result in additional legislative adjustments, especially in the area of protection of the financial interests of the Union and the fight against fraud and corruption connected with EU funds.

In addition to legislative amendments, continued development is also expected through strategic documents, such as national anti-corruption strategies and action plans, which will continue to direct practice and institutional priorities in the fight against corruption.

In conclusion, although there are currently no announced radical reforms, it is likely that the Croatian legal framework will continue to develop incrementally, through harmonization with international standards, strengthening the liability of legal persons, improving procedural mechanisms and increasing the efficiency of criminal prosecution.

The Republic of Croatia has acceded to a number of key international conventions and instruments in the field of the fight against corruption, thereby harmonizing its legal framework with international standards, and I will highlight the most significant ones.

First of all, Croatia is a party to the United Nations Convention against Corruption (UNCAC), which represents the fundamental global instrument for prevention, criminalization and international cooperation in the fight against corruption.

At the level of the Council of Europe, Croatia has acceded to the Criminal Law Convention on Corruption, as well as the Additional Protocol to the Criminal Law Convention on Corruption, which regulate criminal-law protection against various forms of corrupt conduct, including bribery of domestic and foreign public officials. It is also a party to the Civil Law Convention on Corruption, which regulates issues of compensation for damage and other civil-law consequences of corruption.

Croatia has furthermore acceded to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, which is particularly important for the criminal-law sanctioning of bribery in international business operations and represents a key instrument in the area of transnational corruption.

As a Member State of the European Union, Croatia is also obliged to apply the relevant legal acts of the European Union in this area, including directives and other instruments relating to the protection of the financial interests of the Union and the fight against fraud and corruption.

In conclusion, the Republic of Croatia is integrated into all key international anti-corruption mechanisms, which is also reflected in its internal legal framework and the practice of criminal prosecution.

As regards the subject matter of legal privilege, lawyer-client communication enjoys the protection of professional secrecy, which also includes internal investigations conducted by lawyers.

As a matter of principle, in the Republic of Croatia legal privilege is regulated by the Legal Profession Act (Narodne novine Nos. 9/1994, 117/2008, 50/2009, 75/2009, 18/2011, 126/2021, 98/2025), the Article 13 of which prescribes that a lawyer is obliged to keep secret all facts and data learned in the performance of his or her activity, including everything communicated to him or her by the client or learned during the provision of legal assistance. The Code of Lawyer’s Ethics (Articles 26–34) additionally determines that legal secrecy consists of all files, records and deposits of clients in the office and that the lawyer must ensure that secrecy is respected by other persons in the office as well. A lawyer must not use confidential information to the detriment of the client or of the legal person to whom he or she provides legal assistance.

In criminal proceedings, a lawyer is exempt from the duty to testify about what he or she learned from the defendant (Article 285 paragraph 1 item 5 of the Criminal Procedure Act), and written communications of the defendant to defence counsel are not subject to temporary seizure, unless the defendant determines otherwise (Article 262 paragraph 1 item 2 of the Criminal Procedure Act). Exceptionally, the protection does not apply if there is a probability that the lawyer participated in the criminal offence or assisted the defendant (Article 262 paragraph 2 of the Criminal Procedure Act). An item seized contrary to those provisions could not be used as evidence in the proceedings.

In the context of criminal proceedings, therefore, a lawyer has the right to refuse to testify about facts learned in the performance of his or her duty, and searches of lawyers’ offices and temporary seizure of items are subject to special, stricter conditions and judicial control. In this way, the protection of the confidentiality of the lawyer-client relationship is ensured, which is crucial also for the conduct of internal investigations led by lawyers.

In practice, this means that investigations conducted by external counsel are, as a rule, covered by legal privilege, provided that they are connected with the provision of legal assistance to the client.

On the other hand, the position of in-house counsel is different. Although they may be bound by an obligation of confidentiality under labour-law and internal rules, their communication as a rule does not enjoy the same level of protection as legal privilege in the criminal-law sense, especially if they are not entered in the register of lawyers and do not act as independent lawyers.

Therefore, internal investigations conducted by in-house counsel do not automatically enjoy the same level of legal protection as those conducted by external counsel.

Combating bribery and corruption in the Republic of Croatia represents a high political and institutional priority, which follows both from the legislative framework and from strategic documents and the practice of the competent authorities. The Government continuously adopts national anti-corruption strategies and action plans, which define goals, measures and institutional mechanisms for the prevention and suppression of corruption in the public and private sectors. Additionally, membership in the European Union and participation in international monitoring mechanisms (e.g. GRECO, OECD) impose high standards and regular evaluation of the effectiveness of the system.

At the normative level, the Croatian legal framework is to a large extent harmonized with international standards, including the United Nations Convention against Corruption, Council of Europe instruments and the OECD Convention on Bribery of Foreign Public Officials. The recent amendments to the Criminal Code from 2025, especially in the part relating to international jurisdiction and bribery of foreign officials, additionally confirm the intention of the legislator to follow and implement the recommendations of international bodies.

Institutionally, Croatia has specialized bodies such as USKOK and PNUSKOK, as well as court departments specialized in corruption and organized crime, which represents an important element of the effectiveness of the system.

Also, the activity of the European Public Prosecutor’s Office (EPPO) has additionally strengthened capacities in cases relating to the financial interests of the European Union.

Despite this, in practice certain challenges are still highlighted, especially with regard to the duration of proceedings, the complexity of proof and the limited application of the liability of legal persons, which affects the perception of the effectiveness of the system. International evaluations as a rule confirm that the legislative framework is well set up, but that there is room for further improvement of its implementation.

In conclusion, it may be assessed that the Republic of Croatia attaches significant importance to the fight against corruption and that its legal and institutional approach is to a large extent harmonized with international standards, with continuous efforts for their further implementation and practical effectiveness.

The level of seriousness with which corporate organizations in the Republic of Croatia approach the prevention of bribery and corruption is not uniform, but rather largely depends on the size of the company, its ownership structure, international exposure and the sector in which it operates.

Larger companies, especially those that are part of international groups or operate on foreign markets, as a rule have more developed compliance systems, including internal anti-bribery policies, codes of conduct, whistleblowing systems and regular employee training. Such companies often implement standards deriving from foreign legal systems (e.g. the UK Bribery Act, the FCPA) or international guidelines, and therefore their level of compliance is as a rule higher.

On the other hand, smaller and medium-sized enterprises, especially those operating exclusively on the domestic market, often have less formalized or insufficiently developed compliance systems, whereby the prevention of corruption is not infrequently reduced to general rules and ad hoc action, without a systematic approach to risk management.

In the last several years, a trend of gradually strengthening awareness of the importance of preventing corruption has been noticeable, prompted both by the legislative framework and the practice of prosecution authorities, and by the requirements of business partners, especially in the context of public procurement and international projects. Also, the introduction of whistleblower protection obligations and greater exposure to financial and reputational risks additionally encourage organizations to develop internal controls.

Despite these positive developments, challenges still remain, including insufficient institutionalization of the compliance function, limited resources for implementing controls, and an occasionally formalistic approach without real implementation in practice.

In conclusion, it may be said that the corporate sector in Croatia shows a growing, but still uneven, level of seriousness in preventing bribery and corruption, with a clear distinction between large, internationally oriented companies and smaller, locally oriented enterprises.

Legal persons in the Republic of Croatia face a number of challenges when internally investigating suspicions of bribery and corruption, arising from a combination of legal, organizational and practical limitations. One of the key challenges is the collection and securing of evidence, especially in the context of complex business relations and communications. Evidence is often located in electronic data, communication channels and financial flows, the collection of which needs to be aligned with personal data protection and privacy regulations, including the GDPR. This makes the swift and effective conduct of internal investigations more difficult.

An additional problem is represented by the limited scope of legal privilege, especially in relation to in-house counsel. Unlike in some other jurisdictions, communication within the company does not always enjoy the same level of confidentiality as communication with external lawyers, which may make the conduct of investigations more difficult and increase the risk of later use of such data in proceedings.

A significant challenge is also the identification and proof of intent, that is, establishing the link between a certain benefit and a specific business or official decision. Corrupt conduct is often concealed through formally lawful transactions, intermediaries or consultancy agreements, which requires complex analysis and expert knowledge. Organizational challenges, on the other hand, include the lack of developed compliance systems, especially in smaller and medium-sized enterprises, as well as limited resources and expertise for conducting internal investigations. In such circumstances, investigations are often reactive rather than systematically planned.

Also, there is the risk connected with managing internal relations, including whistleblower protection, prevention of retaliation and preservation of business reputation, which may affect the willingness of employees to cooperate.

Finally, legal persons also face the challenge of aligning the internal investigation with a potential criminal proceeding, including the question of when and to what extent to cooperate with the competent authorities, how to manage documentation and how to avoid potential criminal liability.

Therefore, the greatest challenges arise from a combination of legal limitations, the complexity of proof, insufficiently developed internal mechanisms and the need for careful balancing between internal control and external legal risks.

The criminal prosecution authorities and regulatory authorities in the Republic of Croatia face a number of structural and operational challenges in investigating and prosecuting criminal offences of bribery and corruption, arising from the very nature of those criminal offences.

One of the key challenges is proving the corrupt relationship, especially the existence of an unlawful benefit and the causal link between that benefit and the specific conduct of the official or responsible person. Corruption offences as a rule take place covertly, without formal traces, often with the use of intermediaries, complex contractual relations or financial transactions which at first sight appear lawful. This requires a high level of expertise, lengthy financial analyses and coordinated action by several bodies.

An additional challenge is represented by the complexity and length of proceedings, especially in high-level corruption cases involving a larger number of defendants, extensive documentation and international elements. Such proceedings often require international legal assistance, which additionally prolongs the duration of investigations and trials.

The authorities also face challenges related to digital evidence and large quantities of data, including the analysis of electronic communications, financial transactions and other digital traces. Managing such data requires technical capacities and specialized knowledge.

In relation to legal persons, a challenge is also represented by proving their criminal liability, that is, establishing the link between the acts of individuals and the organizational structure of the company, as well as the existence of failures in supervision or control.

In order to respond to these challenges, Croatia has developed a specialized institutional framework, including USKOK and PNUSKOK, and special court departments for corruption and organized crime. In practice, special evidentiary actions are increasingly used, such as monitoring of communications, covert surveillance and undercover investigators.

International cooperation has also been strengthened, especially through the activity of the EPPO and European investigative mechanisms, as well as the application of financial investigations and measures for confiscation of pecuniary benefit.

In practice, in the Republic of Croatia there is still a significant number of criminal offences connected with so-called “missing traders” and carousel frauds, especially in the context of tax and economic criminal offences. Such patterns of fraud often include several connected companies, fictitious transactions and complex financial flows, which not only makes their detection more difficult, but also increases the risk that legitimate business entities become inadvertently involved in such schemes. Consequently, business entities will have to devote greater attention to the verification of business partners and the monitoring of transactions.

In the next 12 to 18 months, it may be expected that the focus of the criminal prosecution authorities will be on high-level corruption and cases of public interest, especially in sectors such as public procurement, healthcare and management of public funds. Additionally, further strengthening of activities may be expected in cases involving the misuse of European Union funds, with the active role of the EPPO.

It is also likely that the priority will be the further development of financial investigations, monitoring of money flows and confiscation of pecuniary benefit, as well as improvement of capacities for working with digital evidence.

In the procedural sense, the emphasis will be on increasing efficiency and accelerating proceedings, in accordance with the recent amendments to the Criminal Procedure Act.

The increase in the amount of electronic data in investigations of criminal offences of bribery and corruption represents one of the key challenges for the criminal prosecution authorities in the Republic of Croatia, and the response to that challenge is developing gradually and with certain limitations.

On the one hand, progress is visible through the intensified application of special evidentiary actions, including monitoring of electronic communications, digital forensics and analysis of financial flows, as well as through the development of institutional cooperation between the police, the state attorney’s office and specialized bodies such as USKOK and PNUSKOK. Also, amendments to procedural legislation, especially the Criminal Procedure Act, are moving in the direction of increasing efficiency in the collection and processing of digital evidence. However, despite these developments, certain doubts remain with regard to the level of technological training of police investigators for work on highly sophisticated cases, especially those involving complex digital systems, encrypted communication and advanced methods of concealing traces. The speed of technological development often surpasses institutional capacities, which may affect the effectiveness of investigations.

An additional challenge is also represented by the increasing application of artificial intelligence (AI), both in business operations and potentially in the commission of criminal offences, including sophisticated forms of concealing communications and financial transactions. It is to be expected that precisely AI technology will in the coming period additionally complicate the detection and proof of corrupt acts.

It is particularly important to emphasize that irregularities in handling electronic evidence in the early stages of the proceedings may have serious procedural consequences. In practice, cases have been recorded in which, due to failures in the lawful obtaining, recording or preservation of digital evidence, courts rendered decisions on their exclusion from the case file, which may significantly weaken or prevent criminal prosecution.

Following the above, although the criminal prosecution authorities in Croatia have undertaken certain steps in adapting to the digital environment, including strengthening technical capacities and using modern investigative tools, challenges related to technological complexity, proper handling of evidence and the accelerated development of new technologies, especially artificial intelligence, still represent a significant factor affecting the efficiency of investigations and criminal prosecution in this area.

In the next 12 to 18 months, I anticipate that business entities in the Republic of Croatia will face several key challenges in the area of bribery and corruption, arising from a combination of regulatory changes, developments in the practice of criminal prosecution and technological circumstances.

One of the most important challenges will be the intensified focus on the liability of legal persons, especially in the context of the recent amendments to the Criminal Code which expanded its application to international situations.

This means that companies will be exposed to a greater risk of criminal prosecution for acts having a cross-border element, including doing business through branches or related companies abroad. In that sense, a higher level of internal control and supervision will be expected from business entities.

Additionally, a continuation of intensive criminal prosecution may be expected in high-risk sectors such as public procurement, healthcare and infrastructure, which increases the exposure of companies doing business with the public sector. Cases involving the use of European Union funds, with the active participation of the EPPO, will also play a special role.

A significant challenge will also be represented by the management of digital evidence and electronic communications. As internal and external communications are increasingly digitized, business entities will have to ensure proper data management, but also be aware that such data may become key evidence in proceedings. At the same time, there is a risk that improperly conducted internal investigations or inadequate handling of data will lead to legal consequences.

In that context, artificial intelligence and advanced technologies will also have increasing significance, both in business operations and potentially in concealing irregularities. Business entities will have to adapt to new risks arising from the use of such technologies, including regulatory requirements that are gradually developing in that area.

Furthermore, a challenge will also be represented by insufficiently developed compliance systems, especially in smaller and medium-sized enterprises. Given the increasingly strict standards and the practice of prosecution authorities, the formal existence of internal rules will no longer be sufficient, but their real and effective implementation will be expected.

Finally, business entities will also face the challenge of balancing between internal investigation and cooperation with the prosecution authorities, including issues of legal protection of communications, management of reputational risk and decision-making on the reporting of irregularities.

In conclusion, the most significant challenges in the coming period will be the strengthening of the liability of legal persons, increased regulatory and criminal-law pressure, management of digital and technological risks, and the need for real, and not merely formal, compliance with anti-corruption standards.

In my opinion, improvement of the Croatian framework for preventing, investigating and prosecuting bribery and corruption should be built in five mutually connected directions: normative clarification, procedural efficiency, forensic-technological strengthening, stronger prevention in legal persons and more consistent confiscation of pecuniary benefit. Such an approach would be most in line with the existing institutional architecture in which USKOK, as a special state attorney’s office, already has specialized jurisdiction over corruption and related criminal offences, while the strategic framework of the state is still set through the Anti-Corruption Strategy 2021–2030 and the Action Plan 2025–2027.

At the normative level, I do not think that Croatia needs a complete recodification, but rather targeted refinement of the existing system. The amendments to the Criminal Code from October 2025 have already shown the direction of further development, especially through the expansion of the reach of criminal legislation to legal persons and through the clarification of the international dimension of bribery of representatives, including representatives in the European Parliament and in the representative bodies of foreign states and international public organizations. Within that framework, it would be useful to further clarify normatively the standards of liability of legal persons in corruption cases, especially the relationship between failures of supervision, organizational deficiencies and criminal attribution to the legal person. Croatian law is not empty in that regard, but practice is still cautious, so greater legislative and judicial elaboration would increase legal certainty and facilitate predictability for business entities.

At the procedural level, the priority must be shortening the duration of complex cases without lowering the standards of a fair trial to the detriment of the defence. This is particularly important because the legislator already intervened in the Criminal Procedure Act in February 2026, and in parallel the Act on USKOK was also amended in 2025, but in my view in a manner unfair to defence counsel because they were deprived of the right to attend sessions of the indictment council and to lodge special appeals against decisions on the unlawfulness of evidence. I think that this disrupted the balance between the prosecution and the defence and that, to the detriment of the defence and the defendant, fundamental procedural standards and convention principles such as equality of arms, the right to adversarial proceedings and confrontation, and the right to an effective remedy were impaired.

In my view, the next step should be stricter case management from the earliest stage, clearer concentration of proof and greater specialization of judges, state attorneys and police investigators for financially complex corruption schemes. In bribery cases, the problem is often not only to detect an individual quid pro quo, but to prove the entire corrupt relationship through fragmented communications, intermediaries, advisory contracts and concealed money flows. Because of this, the procedure should be adapted even more to cases which by their nature are closer to complex financial investigations than to classic proof through direct testimony.

The third and perhaps most urgent direction of improvement is technological and forensic strengthening. Croatian authorities already rely on a specialized model of investigations through USKOK and police structures, but I am not sure that police investigators are technologically trained to a sufficient degree for highly sophisticated cases involving large quantities of electronic data, encrypted communications, cloud environments, complex financial traces and AI tools. USKOK’s institutional specialization exists, but institutional architecture itself is not the same as sufficient digital expertise at the operational level. This is important because failures in handling electronic evidence in the initial phase of the proceedings can lead, and in practice have led, to the exclusion of such evidence from the case file. Therefore, I would insist on mandatory protocols for digital securing, copying, storage and documentation of electronic evidence, along with specialized continuous training of police, state attorneys and judges. It should particularly be taken into account that artificial intelligence will increasingly be used both in lawful business operations and in concealing corrupt patterns, so future investigative standards will have to develop faster than they have so far. It is no coincidence that in 2025 the legislator for the first time introduced into the Criminal Code a definition of an artificial intelligence system and a new criminal offence related to the dangers of the use of such systems; this shows that the technological dimension has already been recognized as criminal-law relevant.

The fourth direction relates to prevention. The Anti-Corruption Strategy 2021–2030 and the new action plan confirm that the preventive component is part of official policy, and implementation reports also show that a large number of activities are indeed being carried out, although not without delays. But in my opinion, prevention will remain insufficient until there is a move from formal compliance to demonstrably effective control mechanisms. This means that legal persons, especially those doing business with the public sector or EU funds, should have not only codes and rulebooks but also documented risk assessments, due diligence of intermediaries and consultants, real whistleblower protection, internal reporting channels, forensically ready data preservation procedures and clear records of representation expenses, donations, sponsorships and intermediary fees. In the Croatian context, this is especially important because of the frequent risks connected with missing traders, carousel frauds, fictitious transactions and the use of intermediary companies, where the line between the tax, economic and corruption components often in fact overlaps.

The fifth direction must be stronger and more consistent financial penalization of corruption. Criminal prosecution that ends with a convicting judgment, but not with actual confiscation of unlawfully acquired assets, has a weaker preventive effect. The Croatian framework already recognizes confiscation of pecuniary benefit, and the strategic documents of the state continuously emphasize integrity and accountability in the management of public resources. However, in practice, parallel financial investigations should be strengthened from the very beginning of the case, earlier freezing of assets when the conditions are met, and better coordination of tax, financial-intelligence and criminal-law bodies. In corruption cases, money is often the only completely reliable trace; therefore, “follow the money” should not be an auxiliary, but rather the central investigative methodology.

If I were to summarize it in one recommendation, I would put it this way: Croatia needs less new symbolic legislation and more in-depth professionalization of enforcement. The basic normative framework already exists and has additionally been strengthened by the amendments to the Criminal Code from 2025, the amendments to ZUSKOK from 2025, and the amendments to the Criminal Procedure Act from 2026, but I believe that lawyers with significant experience in criminal law should also have been involved in the working groups for drafting the said laws. What is now most lacking is predictable and technologically competent enforcement, together with faster proceedings, higher quality digital forensics, a more serious approach to the liability of legal persons and systematic confiscation of corruption profits. Precisely that, in my opinion, would be the scientifically and practically most justified direction of further reform.