Judgment — ECLI:EU:C:2024:979
Date: 2024-11-21
Language of the case: Croatian
Court formation: Tenth Chamber
Subject matter: Approximation of laws
Procedure: Reference for a preliminary ruling
Origin: Croatia

Translation C-336/23–1 
Case C-336/23 
Request for a preliminary ruling 
Date lodged: 
26 May 2023 
Referring court: 
Visoki upravni sud Republike Hrvatske 
Date of decision to refer: 
25 May 2023 
Appellant: 
HP – Hrvatska pošta d.d. 
Respondent: 
Povjerenik za informiranje 
  
[…] 
[…] 
Judge of the Visoki upravni sud 
Republike Hrvatske (Administrative 
Court of Appeal of the Republic of 
Croatia) 
[…] 
Court of Justice of the European Union 
[…] 
Request for a preliminary ruling 
pursuant to Article 19(3)(b) of the Treaty on European Union [(OJ 2012 C 326 
p. 1)] and Article 267 of the Treaty on the Functioning of the European Union (OJ 
2016 C 202, p. 1), in accordance with the Recommendations to national courts and 
tribunals in relation to the initiation of preliminary ruling proceedings (OJ 2016 
C 439, p. 1). 
Application for an expedited procedure 
EN 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
2  
pursuant to Article 105 of the Rules of Procedure of the Court of Justice of the 
European Union of 25 September 2012 (OJ 2012 L 265), as amended on 18 June 
2013 (OJ 2013 L 173, p. 65), 19 July 2016 (OJ 2016 L 217, p. 69), 9 April 2019 
(OJ 2019 L 111, p. 73), and 26 November 2019 (OJ 2019 L 316, p. 103) 
I. Questions 
1. Is the term ‘re-use of information’ for the purposes of Article 2(11) of 
Directive (EU) 2019/1024 of the European Parliament and of the Council of 
20 June 2019 on open data and the re-use of public sector information ([OJ 2019] 
L 172, [p. 56]) (‘the Directive’) to be understood as meaning access to any 
information which a public sector body/public undertaking has produced or holds, 
and which a user (natural or legal person) requests from a public sector body for 
the first time? 
2. Can a request for information which a public sector body/public undertaking 
has produced or which it holds, and which was generated within the scope of its 
activities or in connection with its organisation and work, be regarded as a request 
for information to which the provisions of that directive apply, that is to say, do 
the provisions of that directive apply to all requests for information held by public 
sector bodies? 
3. Are the entities obliged to provide information, listed in Article 2 of the 
Directive, only those public sector bodies to which requests for re-use of 
information are made, or do the new definitions concern all public sector bodies 
and all information held by those bodies, that is to say, are the entities listed in 
Article 2 of the Directive obliged to provide information they have produced or 
hold, or are the entities listed in Article 2 of the Directive considered to be obliged 
to provide information only where the information is re-used? 
4. Can the exceptions to the obligation to make information available under 
Article 1(2) of the Directive be regarded as exceptions by virtue of which public 
sector bodies may refuse to provide information produced or held by them, or are 
they exceptions which apply only where requests have been made to the public 
sector bodies for re-use of the information? 
II. Parties to the main proceedings 
Appellant: HP – Hrvatska pošta d.d., Zagreb […] 
Respondent: Povjerenik za informiranje (Information Commissioner), Zagreb […] 
Interested party: STAS d.o.o, Dugo Selo […] 
HP – HRVATSKA POŠTA 
 
3 
III. Legal background 
European Union law: 
Directive (EU) 2019/1024 of the European Parliament and of the Council of 
20 June 2019 on open data and the re-use of public sector information ([OJ 2019] 
L 172, [p. 56]) 
Article 1 
Subject matter and scope 
1. In order to promote the use of open data and stimulate innovation in 
products and services, this Directive establishes a set of minimum rules governing 
the re-use and the practical arrangements for facilitating the re-use of: 
(a) existing documents held by public sector bodies of the Member States; 
(b) existing documents held by public undertakings that are: 
(i) active in the areas defined in Directive 2014/25/EU; 
(ii) acting as public service operators pursuant to Article 2 of Regulation (EC) 
No 1370/2007; 
(iii) acting as air carriers fulfilling public service obligations pursuant to 
Article 16 of Regulation (EC) No 1008/2008; or 
(iv) acting as Community shipowners fulfilling public service obligations pursuant 
to Article 4 of Regulation (EEC) No 3577/92; 
(c) research data pursuant to the conditions set out in Article 10. 
2. This Directive does not apply to: 
(a) documents the supply of which is an activity falling outside the scope of the 
public task of the public sector bodies concerned as defined by law or by other 
binding rules in the Member State, or, in the absence of such rules, as defined in 
accordance with common administrative practice in the Member State in question, 
provided that the scope of the public tasks is transparent and subject to review; 
(b) documents held by public undertakings: 
(i) produced outside the scope of the provision of services in the general interest 
as defined by law or other binding rules in the Member State; 
(ii) related to activities directly exposed to competition and therefore, pursuant to 
Article 34 of Directive 2014/25/EU, not subject to procurement rules; 
[…] 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
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Article 2 
Definitions 
For the purpose of this Directive, the following definitions apply: 
(1) ‘public sector body’ means the State, regional or local authorities, bodies 
governed by public law or associations formed by one or more such authorities or 
one or more such bodies governed by public law; 
(2) ‘bodies governed by public law’ means bodies that have all of the following 
characteristics: 
(a) they are established for the specific purpose of meeting needs in the general 
interest, not having an industrial or commercial character; 
(b) they have legal personality; and 
(c) they are financed, for the most part by the State, regional or local authorities, 
or by other bodies governed by public law; or are subject to management 
supervision by those authorities or bodies; or have an administrative, managerial 
or supervisory board, more than half of whose members are appointed by the 
State, regional or local authorities, or by other bodies governed by public law; 
(3) ‘public undertaking’ means any undertaking active in the areas set out in point 
(b) of Article 1(1) over which the public sector bodies may exercise directly or 
indirectly a dominant influence by virtue of their ownership of it, their financial 
participation therein, or the rules which govern it. A dominant influence on the 
part of the public sector bodies shall be presumed in any of the following cases in 
which those bodies, directly or indirectly: 
(a) hold the majority of the undertaking’s subscribed capital; 
(b) control the majority of the votes attaching to shares issued by the undertaking; 
(c) can appoint more than half of the undertaking’s administrative, management or 
supervisory body; 
[…] 
(11) ‘re-use’ means the use by persons or legal entities of documents held by:  
(a) public sector bodies, for commercial or non-commercial purposes other than 
the initial purpose within the public task for which the documents were produced, 
except for the exchange of documents between public sector bodies purely in 
pursuit of their public tasks; or 
(b) public undertakings, for commercial or non-commercial purposes other than 
for the initial purpose of providing services in the general interest for which the 
documents were produced, except for the exchange of documents between public 
HP – HRVATSKA POŠTA 
 
5 
undertakings and public sector bodies purely in pursuit of the public tasks of 
public sector bodies; 
[…] 
Article 19 
Repeal 
Directive 2003/98/EC, as amended by the Directive listed in Annex II, Part A, is 
repealed with effect from 17 July 2021, without prejudice to the obligations of the 
Member States relating to the time limits for the transposition into national law 
and the dates of application of the Directives set out in Annex II, Part B. 
References to the repealed Directive shall be construed as references to this 
Directive and shall be read in accordance with the correlation table in Annex III. 
Law of the Republic of Croatia: 
Zakon o pravu na pristup informacijama (Law on the right of access to 
information) (NN 25/13, 85/15, 69/22; ‘Law on the right of access to 
information), in force since 5 June 2022 
Terms 
Article 5 (NN 85/15) 
The individual terms in this Law shall have the following meaning: 
(1) ‘User of the right to access information and re-use information’ (‘user’) 
means any national or foreign natural or legal person; 
(2) ‘Public bodies’ within the meaning of this Law are: bodies of State 
administration, other State bodies, local and regional authority units, legal persons 
and other entities exercising public powers, legal persons whose founder is the 
Republic of Croatia or a local and regional authority unit, legal persons exercising 
public powers, legal persons which, under separate provisions, are financed 
mainly or entirely from the State budget or from the budgets of local and regional 
authority units, that is to say from public funds (taxes, fees, etc.), and also 
commercial companies in which the Republic of Croatia and local and regional 
authority units have, individually or jointly, a majority shareholding; 
(3) ‘Information’ is any data held by a public body in the form of a document, 
record, file, or register, irrespective of the way in which it is presented (written, 
drawn, printed, recorded, on a magnetic medium, optical, electronic or by another 
medium), which the body has produced itself or in collaboration with other 
authorities or obtained from another person, and which was generated within the 
scope of its activities or in connection with the organisation and work of a public 
body; 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
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(4) ‘International information’ means information provided to the Republic of 
Croatia by a foreign State or an international organisation with which the Republic 
of Croatia collaborates or of which it is a member; 
(5) ‘Right of access to information’ includes the right of a user to request and 
obtain information, and also the obligation on a public body to provide access to 
the requested information, that is to say publish information regardless of the 
request made, when such publication results from an obligation laid down in law 
or other rules; 
(6) ‘Re-use’ means the use of information of a public authority by natural or 
legal persons for commercial or non-commercial purposes other than the initial 
purpose for which the information was generated, and which takes place within 
the scope of activities or tasks customarily considered to be public tasks, as 
defined in law or other rules. The exchange of information between public bodies 
in the pursuit of tasks within the scope of their activities shall not constitute re-
use; 
[…] 
IV. RESTRICTIONS ON THE RIGHT OF ACCESS TO INFORMATION 
Restrictions and the duration thereof  
Article 15 (NN 85/15, 69/22) 
(1) Public bodies shall restrict access to information regarding any proceedings 
conducted by the competent authorities in investigative and criminal proceedings 
for the duration of those proceedings. 
(2) Public authorities may restrict access to information: 
(1) if the information has been classified as secret in accordance with the law 
governing the secrecy of data; 
(2) if the information is a business or professional secret, in accordance with the 
law; 
(3) if the information is a tax secret, in accordance with the law; 
(4) if the information is protected by rules governing personal data protection; 
(5) if the information is protected by rules governing intellectual property rights, 
other than with the express written consent of the copyright holder; 
(6) if access to the information is restricted under international agreements, or if 
the information is generated in the procedure for concluding or acceding to an 
international agreement or negotiating with other States or international 
organisations, until the procedure is completed, or where the information is 
generated in maintaining diplomatic relations; 
HP – HRVATSKA POŠTA 
 
7 
(7) in other cases laid down in law. 
(3) Public bodies may restrict access to information if there are reasonable 
grounds to believe that publication thereof would: 
(1) prevent the effective, independent and impartial conduct of judicial or 
administrative proceedings or other proceedings governed by law, or the 
enforcement of a judicial decision or a penalty; 
(2) prevent the work of a body conducting an internal audit in administration or 
an administrative or compliance review. 
(4) Public bodies may restrict access to information if: 
(1) the information is in the process of being drawn up within one or more 
public bodies, and publication thereof prior to the production of the complete and 
final information could seriously disrupt the process of its production; 
(2) the information was generated in the coordination process in the enactment 
of legislation and other acts and in the exchange of positions and views within one 
or more public bodies, and the publication thereof could lead to misinterpretation 
of the content of the information, or jeopardise the process of enacting legislation 
and acts or the freedom to express views and set out positions. 
(5) If the requested information also contains data subject to restriction under 
paragraphs 2 and 3 of this Article, the remaining parts of the information shall be 
made available. 
(6) Information restricting the right of access on the grounds listed in paragraph 
(2)(5) of this Article shall become available to the public if so decided by the 
person to whom the publication of the information could cause harm, but no later 
than 20 years from the date on which the information was generated, except where 
a longer period is laid down in law or other rules. 
(7) Information referred to paragraphs (2) and (3) of this Article shall become 
available to the public when the reasons for which the public body restricted the 
right of access to the information no longer exist. 
(8) Access to information referred to paragraph 4(1) of this Article may also be 
restricted after the information has been completed, in particular if such 
publication would seriously disrupt the decision-making process and the 
expression of views or would lead to a misinterpretation of the content of the 
information, except where there is an overriding public interest in publishing the 
information. 
[…] 
VI. RIGHT TO RE-USE INFORMATION 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
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Right to re-use information and open data  
Article 27 (NN 85/15, 69/22) 
(1) Every user shall have the right to re-use information for commercial or non-
commercial purposes in accordance with the provisions of this Law. 
(2) A public body shall enable users to access open data and re-use information 
by making public information suitable for re-use or on the basis of requests for re-
use. 
(3) The Government of the Republic of Croatia shall encourage public bodies to 
create and publish information generated in the pursuit of public tasks by adopting 
policies and action plans by which, in accordance with the principle of openness 
by design and by default, it shall ensure the development of open data standards, 
by facilitating conditions for adaptation, (timely) planning of publication 
deadlines for information on specific thematic categories and creating an open 
data portal and encouraging the creation of special portals, and also by linking 
portals with portals at the European Union level. 
(4) The Government of the Republic of Croatia shall support the availability of 
research data by adopting an open access policy and action plans to ensure that all 
research organisations and research funding organisations implement an open 
access policy for publicly funded research data, in accordance with the principle 
of ‘open by default’, and which are findable, accessible, interoperable and re-
usable, taking into account concerns relating to privacy, personal data protection, 
confidentiality, national security, and legitimate commercial interests, such as 
business secrets and intellectual property rights of third parties, in accordance with 
the principle of ‘as open as possible, as closed as necessary’. 
(5) For the purpose of re-use, public bodies shall not be obliged to generate and 
adapt information or extract parts thereof if this requires a disproportionate 
consumption of time or resources; nor may a public body be required to update, 
improve or store the information for the purpose of re-use. 
(6) The other provisions of this Law shall apply mutatis mutandis to matters not 
specifically governed by this Law. 
Request for re-use of information and protection of users’ rights  
Article 29 (NN 85/15, 69/22) 
(1) In a request for the re-use of information, the applicant must, in addition to 
the data referred to in Article 18(3) of this Law, state the information he or she 
wishes to re-use, the form and manner in which he or she wishes to receive the 
content of the requested information, and also the purpose of the use of the 
information (commercial or non-commercial purpose). 
(2) The following entities shall not be obliged to act in accordance with a 
request for re-use of information: 
HP – HRVATSKA POŠTA 
 
9 
1. educational institutions, scientific research organisations, and research 
funding organisations; 
2. commercial companies in which the Republic of Croatia or a local or 
regional authority unit exercises, or may exercise, directly or indirectly, a 
dominant influence by virtue of its ownership of it, financial participation therein 
or the rules which govern its actions and which: 
– carry on activities related to the sectors of gas and heat, electricity, water 
management, transport services, airports, sea and river ports, postal services, oil 
and gas extraction, and exploration or extraction of coal or other solid fuels, in 
accordance with the law governing public procurement, 
– act as public service operators under Article 2 of Regulation (EC) 
No 1370/2007 of the European Parliament and of the Council of 23 October 2007 
on public passenger transport services by rail and by road and repealing Council 
Regulations (EEC) Nos 1191/69 and 1107/70 (OJ 2007 L 315, p. 1), 
– act as an air carrier operating a public service obligation under Article 16 of 
Regulation (EC) No 1008/2008 of the European Parliament and of the Council of 
24 September 2008 on common rules for the operation of air services in the 
Community (OJ 2008 L 293, p. 3), or 
– act as a Community shipowner operating a public service obligation under 
Article 4 of Council Regulation (EEC) No 3577/92 of 7 December 1992 applying 
the principle of freedom to provide services to maritime transport within Member 
States (maritime cabotage) (OJ 1992 L 364, p. 7). 
(3) The Republic of Croatia or a local and regional authority unit shall be 
deemed to exercise dominant influence within the meaning of paragraph 2(2) of 
this Article if it directly or indirectly: 
1. holds a majority of the company’s subscribed capital, or 
2. controls a majority of the votes attached to the shares issued by the 
company, or 
3. can appoint more than half of the members of the company’s supervisory, 
administrative or management body. 
(4) The public authority shall determine the request for the re-use of information 
by way of a decision within 15 days of the submission of the duly drafted request. 
The decision shall obligatorily contain the type of licence concerned, which shall 
set out the conditions for use and the amount and method of calculation of costs. 
(5) By way of derogation from paragraph (4) of this Article, public bodies shall 
not issue a decision when they allow re-use through a standard open licence and 
free of charge. 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
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(6) A public body shall consider the request for re-use of information through 
electronic means where possible and appropriate. 
(7) An appeal against a decision on the re-use of information may be lodged 
with the Commissioner within 15 days of the delivery of the decision. An appeal 
against the Commissioner’s decision is inadmissible, but administrative court 
proceedings may be initiated before the Visoki upravni sud Republike Hrvatske 
(Administrative Court of Appeal of the Republic of Croatia). 
(8) Where a public body rejects a request for re-use on the ground of protection 
of intellectual property rights, it shall be obliged to inform the applicant of the 
entity to which the intellectual property rights belong, if known, or of the licensee 
from whom the public body received the information in question. 
Information to which re-use does not apply 
Article 30 (NN 85/15, 69/22) 
(1) The provisions of this Law on the re-use of information shall not apply to 
the following information: 
(1) information referred to in Article 15(1), (2) and (3) of this Law, 
(2) confidential statistical information, in accordance with the law, 
(3) information in relation to which the user must demonstrate a legal interest, 
(4) logos, crests and insignia, 
(5) information held by public service bodies: radio, television and electronic 
media, 
(6) information held by educational institutions other than that held by higher 
education institutions concerning research data, 
(7) information held by scientific research institutions and research funding 
organisations, including organisations established for the transfer of research 
results, except where the information concerns research data, 
(8) information held by cultural institutions other than libraries, including 
libraries of higher education institutions, museums and archives, 
(9) information not collected in the pursuit of public tasks, 
(10) information access to which is excluded or restricted on grounds of sensitive 
critical infrastructure protection related information as defined in the law 
governing critical infrastructure, 
(11) information held by commercial companies referred to in Article 29(2)(2) of 
this Law: 
HP – HRVATSKA POŠTA 
 
11 
– which is produced outside the scope of the provision of services in the 
general interest, as defined by law or other rules; 
– related to activities directly exposed to competition and therefore, pursuant 
to procurement legislation, not covered by public procurement rules. 
(2) When considering a request for re-use of information under paragraph 1 of 
this Article, public bodies shall reject the request for re-use of information by way 
of a decision. 
Conditions for re-use of information  
Article 31 (NN 85/15, 69/22) 
(1) A public body shall make data available to the user for re-use without 
restriction, for free use and in an open format. 
(2) In justified cases, the public body may lay down conditions for re-use. 
Where conditions for re-use are laid down, their content and application shall not 
unjustifiably restrict possibilities for re-use or be used to restrict competition in 
the market. 
(3) Conditions for re-use may not be discriminatory in comparison with the 
same or similar types of information or commercial or non-commercial 
exploitation, including cross-border re-use. 
(4) A public body which re-uses its information as a basis for commercial 
activities outside the scope of its public tasks shall be subject to the same 
conditions as other users. 
(5) The minister competent for administration shall determine in a regulation the 
types and content of licences setting the conditions for re-use in accordance with 
standard open licences. 
(6) A public body shall be obliged to publish on its website the licences setting 
out the conditions for re-use or links to such licences, in accordance with standard 
open licences. 
[…] 
IV. Succinct presentation of the subject matter of the dispute 
6. The decision of the respondent [Povjerenik za informiranje (Information 
Commissioner)] annulled the decision of HP – Hrvatska pošta d.d. (also ‘HP’ or 
‘the appellant’), by which, following a proportionality and public interest test, HP 
dismissed the request for information (construction contract, interim payment 
certificates, declaration of transfer and acceptance, etc.); the Povjerenik za 
informiranje (Information Commissioner) also ordered HP to provide the 
requested documents. 
REQUEST FOR A PRELIMINARY RULING OF 25.5.2023 – CASE C-336/23 
 
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7. As the result of an action brought by Hrvatska pošta d.d., the Visoki upravni 
sud Republike Hrvatske (the Administrative Court of Appeal of the Republic of 
Croatia) referred the case back to Povjerenik za informacije (Information 
Commissioner) (‘respondent’) since the time limit for transposing the Directive 
had already expired at the time the decision was given. At the same time, the court 
expressed the view that the obligation regarding information imposed on HP by 
the respondent should be considered in the light of the new definitions of, and 
exemptions from, the obligation to disclose information under the Directive. 
8. After reconsidering the case, the respondent again ordered that the requested 
information be provided. 
9. HP brought an action against that decision of the respondent, which forms 
the subject matter of the present administrative court proceedings. 
10. The action essentially argues that the contested decision is unlawful, that 
Directive 2019/1024 has not been correctly transposed into the Zakon o pravu na 
pristup informacijama (Law on the right of access to information) because the 
Directive contains different definitions of public bodies and public undertakings, 
that the ratio of the definitions in Directive 2019/1024 applies equally to the right 
of access to information and the re-use of information, that the requested 
information is related to the appellant’s sectoral activities, and that it constitutes a 
business secret. 
11. However, the respondent points out that this particular case does not concern 
exercise of the right to re-use information, but exercise of the right of access to 
information, that the Zakon o pravu na pristup informacijama (Law on the right of 
access to information) governs two areas: the right of access to information, 
defined as the ‘right of the user to request and obtain information, and also the 
obligation of the public body to provide access to the requested information, that 
is to say publish information regardless of the request made, when such 
publication arises from an obligation laid down in law or other rule’ 
[Article 5(1)(5) of the Zakon o pravu na pristup informacijama (Law on the right 
of access to information)], and re-use, which means ‘the use of information of a 
public authority by natural or legal persons for commercial or non-commercial 
purposes other than the initial purpose for which the information was generated, 
and which takes place within the scope of activities or tasks customarily 
considered to be public tasks, as defined by law or other rule’ [Article 5(1)(6) of 
Zakon o pravu na pristup informacijama (Law on the right of access to 
information)]. It concludes that the Directive on open data and the re-use of public 
sector information, as the name of the Directive implies, establishes a legal 
framework for the re-use of public sector information and concerns both open data 
and re-use of public sector information, and not the right of access to information, 
and therefore does not concern exceptions to the obligation to make information 
available when making such information available following a request for 
information. 
HP – HRVATSKA POŠTA 
 
13 
Presentation of the arguments 
12. Hrvatska pošta d.d. was established as a commercial company providing 
services in the general interest, which is fully owned by the Republic of Croatia, 
but, in addition to the universal postal service, also carries out other kinds 
commercial activity. Under Article 5 of the Zakon o pravu na pristup 
informacijama (Law on the right of access to information), it certainly belongs to 
the group of entities obliged to provide access to information which it holds, and 
having regard to the public importance of the service it provides, it also belongs, 
in the view of the referring court, to the entities obliged under Article 2 of the 
Directive, known as ‘public undertakings’. 
13. The previous case-law of the referring court has accepted the reasoning of 
the respondent, namely that there are two different procedures: one conducted on 
the basis of a request for information, to which the general provisions of the 
Zakon o pravu na pristup informacijama (Law on the right of access to 
information) apply, and the other conducted on the basis of request for the re-use 
of information, to which the new provisions of that law, which transposed the 
Directive, apply. 
14. Since in the present proceedings the subject matter of dispute between the 
parties is whether Hrvatska pošta d.d., after carrying out a proportionality and 
public interest test, is obliged to provide information which does not directly 
relate to the provision of services in the general interest, and in view of the dispute 
as to the meaning of the term ‘re-use of information’ and the resulting different 
approach to considering a request for information which a public sector body has 
generated or holds, and consideration of a request for re-use of information, the 
court has decided to stay the proceedings in the present administrative case 
pending an answer to the questions raised. 
15. Proceedings related to exercise of the right of access to information are of an 
urgent nature and the case-law is not uniform, owing to different points of view on 
the content of the Directive, as recently the decisions of the Povjerenik za 
informiranje (Information Commissioner), reiterating the position that one set of 
rules applies to a request for information and another to a request for re-use of 
information, have frequently been upheld. Therefore, since it is important to 
achieve uniform case-law and consideration of requests for information and 
requests for re-use of information, we ask the Court of Justice of the European 
Union to hear the case urgently in order to bring about legal certainty. 
At Zagreb, 25 May 2023 
[…] 
[…] [electronic signature] 
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[…] [details of attached documents] 
[…]