The internal reporting channel duty in Croatia
Croatia transposed Directive (EU) 2019/1937 with Zakon o zaštiti prijavitelja nepravilnosti, »Narodne novine« br. 46/2022 (objavljen 15. travnja 2022.); izmijenjen i dopunjen Zakonom o izmjenama i dopunama Zakona o zaštiti prijavitelja nepravilnosti, »Narodne novine« br. 136/2025 (objavljen 5. studenoga 2025.) (Act on the Protection of Reporters of Irregularities (Whistleblower Protection Act)). Below is what the national act itself says, with the sources, so your counsel can check every line.
2022-04-23 (Art. 45: eighth day after publication in NN 46/2022 of 15 April 2022). The NN 136/2025 amendments entered into force on 13 November 2025 (eighth day after publication on 5 November 2025).
Employers who employ at least 50 workers must establish an internal reporting system ("Poslodavac koji zapošljava najmanje 50 radnika dužan je uspostaviti sustav unutarnjeg prijavljivanja nepravilnosti", Art. 19(2)); employers with fewer than 50 workers may do so voluntarily. By way of exception, an employer covered by the acts listed in Part I, point B and Part II of the Annex (financial services, AML/CFT, transport safety, environmental protection) must establish the system regardless of the number of employees (Art. 19(3)).
No separate deadline - Croatia did not use the 17 December 2023 option. The duty applied to every employer with at least 50 workers from entry into force on 23 April 2022. Under Art. 41(2)-(3), the employer had to adopt the internal general act within two months of entry into force (by 23 June 2022) and appoint the confidential person and deputy within three months (by 23 July 2022). Both dates are directly backed by fines in Art. 35(1)(1) and (5).
Not required. The Act does not oblige employers to accept, or take follow-up action on, anonymous reports. Art. 12(2) only provides that persons who reported or publicly disclosed information anonymously, who meet the conditions in Art. 12(1) and whose identity is subsequently established and who suffer retaliation, are entitled to protection notwithstanding that they reported anonymously.
Pučki pravobranitelj / Ombudswoman of the Republic of Croatia - the body competent for external reporting (Arts. 24 ff.). Persons who report irregularities directly to the police or the State Attorney's Office within their competence get the same protection as those who use the external channel (Art. 12(4)). The Ombudswoman may herself lodge the misdemeanour charge for offences under the Act (Art. 39).
Text-accurate but misleading as written. Croatia replaced the kuna with the euro on 1 January 2023, and the Act was not amended between NN 46/2022 and NN 136/2025, so from 1 January 2023 to 12 November 2025 those statutory kuna figures applied as their euro equivalents at 7.53450 HRK/EUR: Art. 35 EUR 1,327.23-3,981.68, Art. 36 EUR 3,981.68-6,636.14. Say "expressed in the statutory text as HRK..., applied in euro from 1 January 2023 at the conversion rate". (The original Art. 35(2)-(3) band for responsible persons and sole traders was HRK 1,000-10,000 and Art. 36(2)-(4) HRK 3,000-30,000, if you keep the historical comparison at all.)
Yes, but the appointee must be a natural person. Art. 6(10) defines the povjerljiva osoba (confidential person) as "fizička osoba zaposlena kod poslodavca ili treća fizička osoba imenovana od strane poslodavca" - a natural person employed by the employer or a third natural person appointed by the employer - to receive reports, communicate with the reporter and conduct the protection procedure. A company cannot itself be the confidential person; an individual from an external provider can be appointed. The appointment is made on the proposal of the works council, or of a trade union representative exercising works council powers, or of at least 20% of the workers where no works council exists (Art. 20(1)(2)); if no such proposal is made, the employer appoints without one (Art. 20(3)). The confidential person and deputy must consent in writing (Art. 20(6)). Private sector entities with 50-249 workers may share resources for receipt of reports and conduct of the procedure (Art. 19(4)).
Croatia is the most process-heavy of the six. Beyond the channel itself the employer must adopt a written general act governing the internal reporting procedure and the appointment of the confidential person and deputy (Art. 21), make it and the system easily accessible and comprehensible to everyone in the work environment (Art. 21(2)), and appoint a named confidential person plus a named deputy. A general act that conflicts with the Act has no legal effect (Art. 21(4)). Time limits: acknowledge receipt within 7 days; give feedback as a rule within 30 days and no later than 90 days from acknowledgement; notify the Ombudswoman in writing of reports received and their outcome within 30 days of deciding (Art. 22(2)). A purely anonymous, unattended hotline does not satisfy Croatian law - the named confidential person is the core statutory requirement. NN 136/2025 also extended the Annex to further EU acts.
One channel for a group that operates in more than one member state
A group with entities in Croatia and elsewhere in the EU does not get one law, it gets one per country: different rules on anonymous reports, different authorities, different deadlines and penalties. We set the channel up once and configure it per entity against each national act, from the same verified reference you are reading.