Global FinTech Guide
Country Name
Online banking services
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).


API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.


Attitude of the country towards online-banking services

In recent years online-banking services have become a standard vehicle for managing accounts and carrying out payments.

Legal affairs

Obligations and requirements to provide online-banking services described above

As a consequence of adoption of the Payment Services Directive, the banks have harmonised their third-party access interfaces either through the API Dedicated Interface or through a modified client interface. In both cases, qualified electronic (eIDAS Regulation) certificates (see more in Section 5) are used for the purpose of secure communication between banks and authorised third parties, so that the banks always know who is accessing their interfaces (the clients or third parties on behalf of the clients).

The PSA prescribes that the aforementioned third parties – i.e. registered account information service providers may not provide other payment services except account information services. Natural persons pursuing a business activity registered in Croatia or legal persons intending to provide an account information payment service have to submit to the CNB an application for entry in the register of payment service providers and electronic money issuers, supported by other documentation and information as prescribed by the PSA. Account information services can be provided only after respective payment service has been entered as a business activity of the relevant provider in the court register.

Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area


Economic conditions

Market size for online-banking services and biggest companies in this business area

No comprehensive statistics are available. Generally, banks in Croatia regularly offer online-banking services.

Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area




© 2022, Ilej & Partners, in cooperation with Karanovic & Partners. All rights reserved by Ilej & Partners, in cooperation with Karanovic & Partners as author and the owner of the copyright in this chapter. Ilej & Partners, in cooperation with Karanovic & Partners has granted to Multilaw non-exclusive worldwide license to use and include this chapter in this guide and to sublicense Lexis Nexis, a division of RELX Inc. and its affiliates certain rights to use and distribute this guide.

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.


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