COMMISSION STAFF WORKING DOCUMENT 2024 Rule of Law Report Country Chapter on the rule of law situation in Croatia Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2024 Rule of Law Report The rule of law situation in the European Union
Date: 2024-07-24
Institutions: European Commission, Secretariat-General
Subjects: Croatia, administrative transparency, corruption, democracy, freedom of the press, independence of the judiciary, infringement of EU law, pluralism in the media, rule of law, whistleblowing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 24.7.2024  SWD(2024) 811 final  COMMISSION STAFF WORKING DOCUMENT 2024 Rule of Law Report        Country Chapter on the rule of law situation in Croatia Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS 2024 Rule of Law Report                  The rule of law situation in the European Union {COM(2024) 800 final} - {SWD(2024) 801 final} - {SWD(2024) 802 final} - {SWD(2024) 803 final} - {SWD(2024) 804 final} - {SWD(2024) 805 final} - {SWD(2024) 806 final} - {SWD(2024) 807 final} - {SWD(2024) 808 final} - {SWD(2024) 809 final} - {SWD(2024) 810 final} - {SWD(2024) 812 final} - {SWD(2024) 813 final} - {SWD(2024) 814 final} - {SWD(2024) 815 final} - {SWD(2024) 816 final} - {SWD(2024) 817 final} - {SWD(2024) 818 final} - {SWD(2024) 819 final} - {SWD(2024) 820 final} - {SWD(2024) 821 final} - {SWD(2024) 822 final} - {SWD(2024) 823 final} - {SWD(2024) 824 final} - {SWD(2024) 825 final} - {SWD(2024) 826 final} - {SWD(2024) 827 final} - {SWD(2024) 828 final} - {SWD(2024) 829 final} - {SWD(2024) 830 final} - {SWD(2024) 831 final}  
 
 
ABSTRACT 

The level of remuneration increased for judges, state attorneys and court staff, and legislation 
to set objective remuneration criteria is expected in 2024. Efforts to maintain and improve the 
integrity of judges and state attorneys continued. The Government plans to present in 2024 a 
broader set  of amendments  to the Law on the State Attorney’s Office which would include 
removing  the  legal  basis  for  periodic  security  checks  on  all  state  attorneys.  Following 
discussions around the election of the new State Attorney General, there were questions as to 
the selection procedure and whether it offers sufficient safeguards to ensure the autonomy of 
that position.  The level  of perceived judicial independence increased,  while remaining  very 
low. Electronic communication increased between courts and users and further initiatives are 
being taken to close the digitalisation gap in the justice system. Despite having implemented 
several  measures  to  reduce  the  length  of  court  proceedings,  backlogs  and  length  of 
proceedings remain a serious concern. 

Legislation  on  lobbying  was  adopted  and  laws  on  bribery  of  foreign  public  officials  were 
strengthened.  Steps  were  taken  to  make  the  investigation  and  prosecution  of  corruption 
offences more efficient, while a revision of the Criminal Procedure Code and the Law on the 
Investigations, 
specialised  anti-corruption  prosecution 
prosecutions  and  convictions  of  corruption,  including  at  high-level,  continued.  Anti-
corruption authorities continued to optimise their resources. The State Electoral Commission 
and State Audit Office encountered less irregularities in the implementation of political party 
financing  rules.  Croatia  is  raising  awareness  on  the  new  whistleblower’s  legislation.  Some 
measures  have  been  taken  to  detect  and  prevent  corruption  in  public  procurement,  which 
remains a high-risk area.  

remain  outstanding. 

service 

The  legal  framework  provides  safeguards  for  media  freedom  and  pluralism  as  well  as  the 
right to information. Concerns about the political independence of the Council for Electronic 
Media  and  the  public  service  broadcaster  HRT  persist.  HRT  also  faces  criticism  regarding 
potential  conflicts  of  interest.  There  are  positive  developments  as  regards  the  safety  of 
journalists on which authorities and journalists’ representatives have concluded a cooperation 
agreement.  While  media  ownership  information  is  available,  some  challenges  remain  as 
regards ownership transparency. The framework for a fair and transparent allocation of state 
advertising  raises  concerns  both  at  national  and  local  level  and  no  steps  were  taken  to 
strengthen  it.  Awareness  raising  efforts  continue  on  the  issue  of  strategic  lawsuits  against 
public  participation  (SLAPPs)  targeting  journalists,  which  remain  a  concern.  Although 
journalists are exempt from the offence of disclosure of information from ongoing criminal 
investigations,  there  is  still  strong  criticism  from  stakeholders,  and  efforts  continue  to  be 
made to address it. 

The new Law on Better Regulation Policy Instruments introduced a strengthened framework 
on impact assessment and evaluation, and additional standards for public consultations. New 
Law on Administrative Disputes includes measures to encourage the swift implementation of 
administrative  courts’  judgments.  Some  further  steps  were  made  on  the  follow-up  to  the 
People’s Ombudsperson’s recommendations, while some challenges on access to information 
remain.  There  has  been  a  gradual  shift  towards  the  multiannual  funding  of  civil  society 
organisations,  while  the  new  National  Plan  for  Creating  an  Enabling  Environment  remains 
outstanding. 

1 

 
RECOMMENDATIONS  

Overall, concerning the recommendations in the 2023 Rule of Law Report, Croatia has made: 

•  Significant  progress  on  continuing  structural  efforts  to  address  the  remuneration  of 
judges,  state  attorneys  and  judicial  staff,  taking  into  account  European  standards  on 
resources and remuneration for the justice system. 

•  Significant  progress  on  adopting  comprehensive  legislation  in  the  area  of  lobbying, 
including  on  persons  with  top  executive  positions,  and  set  up  a  public  register  of 
lobbyists. 

•  Some progress to increase the efficiency of investigations and prosecution of corruption 
offences, but not on revising the Criminal Procedure Code and the Law on the Office for 
the  Suppression  of  Corruption  and  Organised  Crime,  as  set  out  in  the  Anti-Corruption 
Strategy. 

•  No  progress  on  advancing  with  strengthening  the  framework  for  a  fair  and  transparent 
allocation of state advertising, by establishing clear criteria, good practices and oversight 
measures to guarantee the effective functioning  of the public tender procedure for local 
and regional media. 

•  Some further progress on the recommendation to make further efforts to address the issue 
of  strategic  lawsuits  against  public  participation  targeted  at  journalists,  including  by 
reviewing  the  legal  provisions  on  defamation  and  encouraging  wider  use  of  procedural 
rules  that  allow  dismissing  groundless  lawsuits,  taking  into  account  the  European 
standards on the protection of journalists. 

•  Some further progress was made on further improving the follow-up to recommendations 
and ensuring a more systematic response to information requests of the Ombudsperson. 

On this basis, and considering other developments that took place in the period of reference, 
and  in  addition  to  recalling  the  relevant  commitments  made  under  the  Recovery  and 
Resilience Plan, it is recommended to Croatia to: 

•  Revise  the  Criminal  Procedure  Code  and  the  Law  on  the  Office  for  the  Suppression  of 
Corruption  and  Organised  Crime,  in  line  with  the  Anti-Corruption  Strategy,  so  as  to 
further increase the efficiency of investigations and prosecution of corruption offences. 
•  Step up efforts to strengthen the legal framework and oversight mechanisms to ensure a 
fair  and  transparent  allocation  of  state  advertising  at  national,  regional  and  local  level, 
including the public tender procedure. 

•  Continue  efforts  to  address  the  issue  of  strategic  lawsuits  against  public  participation 
targeted  at  journalists,  including  by  reviewing  the  legal  provisions  on  defamation  and 
encouraging  wider  use  of  procedural  rules  that  allow  dismissing  groundless  lawsuits, 
taking into account the European standards on the protection of journalists. 

•  Further  improve  the  follow-up  to  recommendations  and  ensure  a  more  systematic 

response to information requests of the Ombudsperson. 

2 

 
 
 
I. 

JUSTICE SYSTEM  

Croatia has a three-tiered justice system, with courts of general and  specialised jurisdiction. 
The  first  instance  courts  of  general  jurisdiction,  dealing  with  civil  and  criminal  cases,  are 
composed  of  municipal  courts  (34),  while  the  county  courts  (15)  are  the  second  instance 
courts of general jurisdiction, with some competences as first instance courts. The courts of 
specialised  jurisdiction  comprise  nine  Commercial  and  four  Administrative  courts  at  first 
instance, and the High Criminal Court, the High Misdemeanour Court, the High Commercial 
Court and the High Administrative Court at second instance. The Supreme Court deals with 
all types of cases. The Constitutional Court conducts constitutional review. An independent 
State  Judicial  Council  ensures  the  autonomy  and  independence  of  the  judiciary1.  The  State 
Attorney’s  Office  (DO)  is  an  autonomous,  independent  judicial  body.  It  acts  as  the 
prosecution  service,  and  undertakes  legal  actions  for  the  protection  of  state  property  and 
applies legal remedies for the protection of the Constitution and laws. Each State Attorney’s 
Office  is  headed  by  a  State  Attorney.  The  State  Attorney  General  is  the  head  of  the  State 
Attorney Office of the Republic of Croatia (DORH), as the highest state attorney office. The 
powers over appointment and career of state attorneys and deputy state attorneys rest with the 
State Attorney’s Council, while the powers over representation and management rest with the 
State  Attorney  General2.  The  State  Attorney’s  Council  is  an  independent  self-governance 
body tasked with  ensuring the  autonomy and independence of the State  Attorney’s Office3. 
Croatia  participates  in  the  European  Public  Prosecutor’s  Office  (EPPO).  The  Croatian  Bar 
Association is an independent, self-governing professional organisation, which is in charge of 
disciplinary proceedings regarding lawyers4. 

Independence  

The  level  of  perceived  judicial  independence  in  Croatia  continues  to  be  very  low  both 
among the general public and companies. Overall, 23% of the general population and 28% 
of  companies  perceive  the  level  of  independence  of  courts  and  judges  to  be  ‘fairly  or  very 

1   The  State  Judicial  Council  is  a  judicial  self-governance  body  with  11  members,  7  judges  elected  by  their 
peers, 2 university professors of law and 2 members of Parliament, 1 of whom is from the opposition. They 
are elected for a four-year term and can be re-elected once. The Council appoints/dismisses judges and court 
presidents,  decides  on  the  immunity,  transfer  and  external  activities  of  judges,  conducts  disciplinary 
proceedings and decides on the disciplinary responsibility of judges. The Council also participates in training 
of judges, adopts a methodology for evaluating judges, and verifies asset declarations of judges. 

2   Figures  55-57,  2019  EU  Justice  Scoreboard;  Figure  54,  2020  EU  Justice  Scoreboard,  and  Figures  55-56, 

2021 EU Justice Scoreboard. 

3   The State Attorney’s Council is a prosecutorial self-governance body with 11 members, seven deputy state 
attorneys  elected  by  their  peers,  two  university  professors  of  law  and  two  members  of  Parliament,  one  of 
whom is from the opposition. They are elected for a four-year term and can be re-elected once. The Council's 
mandate includes the appointment, dismissal and transfers of state attorneys, decisions on external activities, 
on  objections  to  evaluations,  and  participation  in  trainings.  The  Council  also  keeps  personal  records  and 
verifies the asset declaration of state attorneys and deputy state attorneys, as well as conducting disciplinary 
proceedings and deciding on the disciplinary responsibility of deputy state attorneys. 

4   The  Assembly  of  the  Bar  elects,  in  accordance  with  the  Statute  of  the  Croatian  Bar  Association,  the 
Disciplinary  Court  (which  consists  of  at  least  five  members  and  decides  on  more  serious  violations  and 
appeals  against  Disciplinary Councils’  decisions),  and  the  Higher  Disciplinary  Court  (which  consists  of  at 
least five members and decides on appeals against Disciplinary Court’s decisions). The Executive Board of 
the Bar elects Disciplinary Councils, which consist of three members and decide on less serious violations. 

3 

 
 
good’  in  20245.  Among  the  general  public,  this  figure  has  slightly increased  in  comparison 
with  2023  (22%),  but  it  is  slightly  lower  than  in  2020  (24%).  The  perceived  judicial 
independence  among  companies  has  increased  in  comparison  with  2023  (18%)  as  well  as 
with  2020  (16%).  The  main  reasons  cited  by  the  general  public  and  by  companies  for  the 
perceived  lack  of  independence  of  courts  and  judges  are  the  perception  of  interference  or 
pressure from the Government and politicians, and interference or pressure from economic or 
other  specific  interests,  respectively6.  More  detailed  surveys  to  identify  the  underlying 
reasons  of  different  stakeholders  for  the  continuously  low  level  of  perceived  judicial 
independence are not available7. 

The Government plans to present in 2024 a broader set of amendments to the Law on 
the  State  Attorney’s  Office  which  would  include  removing  the  legal  basis  for  periodic 
security  checks  on  all  state  attorneys.  The  2022  Rule  of  Law  Report  had  recommended 
Croatia  to  ‘reconsider  the  newly  introduced  periodic  security  checks  conducted  by  the 
National Security Agency on all judges and state attorneys by ensuring their integrity based 
on  other  existing  mechanisms,  taking  into  account  European  standards  on  judicial 
independence and autonomy of prosecutors and the opinion of the Venice Commission’8. The 
2023  Rule  of  Law  Report  found  that  there  was  significant  progress  regarding  the  2022 
recommendation  since  the  periodic  security  checks  on  judges  were  removed  by  way  of  a 
Constitutional Court decision9 and amendments were being drafted to remove them regarding 
state attorneys10. While the relevant provision introducing the periodic security checks on all 
state attorneys remains in force11, no security checks were conducted on state attorneys based 
on  this  provision12.  The  Government  plans  to  remove  the  legal  basis  for  periodic  security 

5   Figures 51 and 53, 2024 EU Justice Scoreboard, and Figures 50 and 52, 2022 EU Justice Scoreboard. The 
level  of  perceived  judicial  independence  is  categorised  as  follows:  very  low  (below  30%  of  respondents 
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%). 

6   Figures 52 and 54, 2024 EU Justice Scoreboard. 
7   The last comprehensive survey of court users and professionals on the accessibility and quality  of the court 
services was in 2015. See Figure 45, 2017 EU Justice Scoreboard, Figure 49, 2018 EU Justice Scoreboard, 
Figure 42, 2019 EU Justice Scoreboard, Figure 42, 2020 EU Justice Scoreboard, Figure 37, 2021 EU Justice 
Scoreboard, Figure 40, 2022 EU Justice Scoreboard, Figure 39, 2023 EU Justice Scoreboard, and Figure 41, 
2024 EU Justice Scoreboard showing that in 2016-2023, no surveys were conducted. 48% of the companies 
in Croatia are either fairly or very confident that their investments are protected by the law and courts in the 
Member State. 28% of the surveyed companies see the quality, efficiency or independence of justice as one 
of  the  main  reasons  for  concern  about  investment  protection  in  the  country.  Figures  55  and  56,  2024  EU 
Justice Scoreboard. 

8   2022  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law  situation  in  Croatia,  p.  2.  The  Venice 
Commission  found  that  the  reform  was  not  justified  and  that  the  existing  Croatian  legislation  already 
provided for a wide array of mechanisms to  ensure integrity of the judicial corpus, for example: (i) annual 
asset  declarations  which  are  checked  by  the  State  Judicial  Council;  (ii)  annual  assessments  by  the  court 
presidents (regarding the minimum output and the behaviour of the judge concerned); (iii) the possibility of 
disciplinary  proceedings;  (iv)  the  possibility  of  criminal  liability  (judges  only  enjoy  functional  immunity); 
and (v) the existing possibilities for security checks. Venice Commission opinion (CDL(2022)005), para. 36. 
9   On  7  February  2023,  the  Constitutional  Court  annulled  the  provisions  of  the  Law  on  Courts  which 
introduced the periodic security checks on judges. Judgment of the Constitutional Court of 7 February 2023, 
U-I-2215/2022. Considering positive developments in 2023, the 2023 Rule of Law Report did not take over 
the 2022 recommendation to reconsider the security checks. 

10   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 4-5.  
11   Article 99.a of the Law on State Attorney’s Office, adopted by Parliament on 11 February 2022. 
12   Information received from the Ministry of Justice and Public Administration and from the State Attorney’s 

Office in the context of the country visit to Croatia. 

4 

 
 
checks on all state attorneys as part of a broader set of amendments to the Law on the State 
Attorney’s Office13.  

Efforts to maintain and improve the integrity of judges and state attorneys continued. 
In  2023,  competent  bodies  continued  to  conduct  investigations  and  proceedings  regarding 
judges  and  state  attorneys  in  reaction  to  allegations  of  misconduct  and  criminal  acts.  The 
State Judicial Council received 52 requests to initiate criminal proceedings regarding judges14 
and,  at  the  request  of  competent  authorities,  started  12  disciplinary  proceedings  regarding 
judges15.  Additionally,  the  State  Judicial  Council  continued  exercising  its  control  function 
over the external activities of judges16. On 14 March 2024, Parliament adopted amendments 
to the Law on Courts, which introduced some additional rules on external activities of judges 
with the aim of improving their impartiality17. In 2023, the State Attorney’s Council received 
three  requests  from  competent  authorities  to  start  disciplinary  proceedings  regarding  state 
attorneys18.  Making  full  use  of  the  electronic  registers  (IT  tools)  and  dedicated  human 
resources19, the State Judicial Council and the State Attorney’s Council verified all incoming 
asset declarations of judges and state attorneys, respectively, following the submission of the 
annual updates, where only few irregularities were identified20.  

13   Input  from  Croatia  for  the  2023  Rule  of  Law  Report,  p. 3,  and  information  received  from  the  Ministry of 

Justice and Public Administration in the context of the country visit to Croatia. 

14   In 2 cases, the State Judicial Council approved pre-trial detention of judges, while in 32 cases this request 
was  denied.  Written  contribution  from  the  State  Judicial  Council  in  the  context  of  the  country  visit  to 
Croatia. 

15   These disciplinary proceedings were initiated on request from competent authorities such as court presidents 
as the State Judicial Council decides on disciplinary sanctions and cannot initiate the proceedings itself. The 
number  of  initiated  disciplinary  proceedings  in  2023  was  lower  than  in  2022  when  22  disciplinary 
proceedings were initiated (23 in 2021, 13 in 2020). In 2023, the State Judicial Council issued 5 sanctions 
(16 in 2022, 13 in 2021, 1 in 2020), including 4 fines and 1 reprimand (in 2022: 4 dismissals, 1 conditional 
dismissal, 2 fines and 9 reprimands). Written contribution received from the State Judicial Council following 
the country visit to Croatia. 

16   In  2023,  the  State  Judicial  Council  received  76  requests  from  judges  regarding  external  activities,  all  of 
which it approved (in 2022: also 76 requests, 64 of which were approved, remaining were allowed according 
to the law). Written contribution received from the State Judicial Council in the country visit to Croatia. 
17   The  amendment  to  article  91  of  the  Law  on  Courts  prohibited  participation  of  judges  in  the  work  of  the 

courts of honour, and in disciplinary proceedings in professional chambers and associations. 

18   In  2023,  the  State  Attorney’s  Council  started,  on  request  from  competent  authorities,  three  disciplinary 
proceedings  (one  in  2022)  and  issued  three  reprimands  (in  2022:  one  dismissal  and  two  reprimands). 
Information received from the State Attorney’s Council in the context of the country visit to Croatia. 

19   Improving the IT tools and resources of both Councils by the beginning of 2022 was a milestone under the 
Recovery  and  Resilience  Plan,  which  Croatia  successfully  fulfilled.  The  Council  adopted  the  Council 
Implementing Decision of 28 July 2021 on the approval of the assessment of the recovery and resilience plan 
for  Croatia,  under  which  the  Milestone  no.  214  states:  ‘Electronic  tools  and  adequate  administrative 
capacities shall be in operation for the State Judicial Council […] and the State Attorney's Council […], in 
order to improve the quality of the work of both Councils. Their human resources shall be increased by 50% 
compared to 2021 baseline (by recruiting at least 4 persons) and the linking the DSV and the DOV to the 
common land registry and cadastre (ZIS) and tax administration information system, shall be implemented in 
order  to  establish  an  effective  mechanism  for  verifying  the  asset  declarations  of  state  officials’.  The 
Commission found the milestone to be satisfactorily fulfilled on 10 November 2022. Communication to the 
Commission on the positive preliminary assessment of the second payment request of Republic of Croatia 
pursuant to Regulation (EU) 2021/241, C(2022)8209 final. 

20   Based on the land registry data, the State Judicial Council identified nine cases where judges did not report 
all real estate they owned. However, since these were minor omissions, it did not issue any sanctions. In one 
case based on a journalist’s request, the Council approached the tax authority to verify judge’s assets from 

5 

 
 
 
Following discussions around the election of the new State Attorney General, there were 
questions  as  to  the  selection  procedure  and  whether  it  offers  sufficient  safeguards  to 
ensure the autonomy of that position. In view of the expiry, on 26 May 2024, of the State 
Attorney General’s term of office, the State Attorney’s Council, following the procedure set 
in law, transmitted to the Government the names of four candidates deemed to have met the 
eligibility check21. After the parliamentary committee hearings, the Government proposed a 
candidate to Parliament, where he was elected, on 7 February 2024 as the new State Attorney 
General, and assumed his position on 27 May 2024. On 15 February 2024, the President of 
the High Criminal Court in agreement with the President of the Supreme Court, submitted a 
complaint against the elected candidate for violation of the Code of Judicial Ethics22, which 
was rejected unanimously by the Council of Judges at the High Criminal Court on 22 May23. 
This led to a wider public debate on the elected candidate, as well as whether the procedure 
for  the  selection  of  the  State  Attorney  General  offers  sufficient  safeguards  to  ensure  the 
autonomy  of  the  position24.  Under  the  current  procedure,  the  State  Attorney’s  Council 
publishes the vacancy, checks whether the applications meet the conditions and transmits the 
eligible candidates to the Government but does not give an opinion on the candidates. In the 
procedure  of  appointing  a  Prosecutor  General,  advice  on  the  professional  qualification  of 
candidates  should  be  taken  from  relevant  persons,  such  as  representatives  of  the  legal 
community (including prosecutors) and of civil society25. GRECO expressed similar concerns 
and called for decisive involvement of the State Attorney’s Council26. According to European 

2019, when the asset declarations were not yet online. The State Attorney’s Council used the IT tools and 
their updated functionalities. Information received from the State Judicial Council and the State Attorney’s 
Council in the context of the country visit to Croatia. 

21   Four candidates applied, following the publication of the public call on 29 November 2023: an attorney, the 
current  deputy  State Attorney  General,  a  deputy  County  State Attorney,  and  a  judge  at  the  High  Criminal 
Court. State Attorney’s Council, Press release: Four applications to the public call received, 5 January 2024. 
According to Article 25 of the Law on the State Attorney’s Office, the State Attorney Council only performs 
an eligibility check and does not issue any opinion on the candidates. According to Article 23 of the same 
law, the competent committee of Parliament must give an opinion on the candidates prior to the selection. 
Investigative journalists published reports about alleged contacts between one of the candidates proposed by 
the  State  Attorney  Council,  a  sitting  judge  at  the  High  Criminal  Court,  and  a  high-ranking  Government 
official  and  one  other  individual,  investigated  or  indicted  for  corruption  offences.  Following  these 
publications,  on  5  February  2024,  the  President  of  the  Supreme  Court  expressed  concerns  about  the 
information  that  was  unearthed  on  the  selected  candidate  and  stated  he  will  commence  the  appropriate 
proceedings to clarify the situation, which could mean possible disciplinary proceedings against the selected 
candidate in his role as a judge. N1 news portal, Supreme Court is requesting documentation on Turudić, 5 
February 2024. 

22   Supreme Court, Press release of 15 February 2024. 
23   High Criminal Court, Press release: The Council of Judges of the High Criminal Court made a decision on a 

complaint to initiate a procedure for violation of the Code of Judicial Ethics, 23 May 2024. . 

24   The revelations also gave rise to opposition parties’ demonstrations on 17 February 2024 in Zagreb against 

the election of the candidate to the post of the State Attorney General. 

25   Venice Commission, Report on European Standards as regards the independence of the Judicial System: Part 

II – the prosecution Service, para. 35. 

26   GRECO  in  its  2018  Evaluation  Report  found  that  its  2014  recommendation  (ix)  to  Croatia  to  "consider 
reviewing the procedures of selection, appointment and mandate renewal of the Prosecutor General in order 
to increase their transparency and minimise  risks of improper political influence” has been dealt with in a 
satisfactory  manner.  However,  GRECO  stressed  that  despite  the  2018  legislative  amendments  “further 
transparency and objectivity assurances are to be infused in the system of selection and appointment of the 
Prosecutor  General”.  GRECO  stated  that  it  “specifically  called  for  decisive  involvement  of  the  State 
Prosecutorial Council. With the new law, the State Prosecutorial Council is merely given a depositary role.” 
GRECO also encouraged the authorities to “further advance in their efforts to increase the transparency and 
minimise  risks  of  improper  political  influence  in  the  appointment  of  the  Prosecutor  General.”  GRECO, 

6 

 
 
 
standards, the method of appointment of the Public Prosecutor General should be such as to 
gain the confidence of the public and the respect of the judiciary and the legal profession27. 
Statements  on  the  State  Attorney  General’s  competence  to  decide  on  attribution  of  cases 
between national prosecutors and the EPPO gave rise to a public debate28.  

The  Court  of  Justice  considered  the  internal  procedural  mechanism  to  avoid 
inconsistencies in a court’s case-law incompatible with the principle of effective judicial 
protection29. The High Commercial Court asked the Court of Justice to rule on a practice in 
courts  of  second  instance  whereby  the  registrations  judge,  when  finding  a  judgment 
inconsistent with other judgments or the 'legal position' previously accepted at that court, may 
stay  the  delivery  of  the  adopted  judgment  and  request  that  a  section  meeting  be  convened. 
The  section  meeting  is  able  to  put  forward  a  'legal  position'  that  is  binding  on  all  judicial 
panels  belonging  to  the  section30.  The  Court  of  Justice  ruled  that  such  a  practice  of  the 
registrations  judge  is  incompatible  with  the  requirements  inherent  in  the  right  to  effective 
judicial protection31. It also set out several conditions that a procedural mechanism aiming to 
avoid  or  resolve  conflicts in  case-law would need to  observe to  be compatible with  Article 
19(1) of the TEU32. 

Fourth  Evaluation  Round,  Second  Compliance  Report  –  Croatia,  7  December  2018,  GrecoRC4(2018)14, 
paras. 33-38. According to the Government, the 2022 amendments to the Law on the State Attorney’s Office 
contributed to further implementation of GRECO recommendation for  a more decisive involvement of the 
State Attorney’s Council, taking into account that the Constitution  determines the roles of Government and 
Parliament in the appointment process.  

27   Venice Commission, Report on European Standards as regards the independence of the Judicial System: Part 
II  –  the  prosecution  Service,  para.  34,  Opinion  No.  9  (2014)  of  the  Consultative  Council  of  European 
Prosecutors  to  the  Committee  of  Ministers  of  the  Council  of  Europe:  European  norms  and  principles 
concerning prosecutors, p. 79, para 56. For a comparative perspective on the procedures for appointment of 
Prosecutors General, see Figure 62, 2023 EU Justice Scoreboard. 

28   European Public Prosecutor’s Office, Press release – Croatia: 29 suspects arrested in investigation involving 
University of Zagreb, 8 November 2023; European Public Prosecutor’s Office, Press release - Croatia: EPPO 
conducts  new  searches  in  investigation  into  University  of  Zagreb,  16  February  2024.  According  to  the 
Government,  EPPO  has  the  right  to  investigate  cases  in  Croatia,  however,  in  that  particular  case,  national 
prosecutors  should  be  competent  to  investigate,  as  EU  funds  have  not  been  used.  Croatian  Government, 
Press release: There is no pressure on the EPPO. We stand for the legal spending of European funds that the 
Government  fought  for,  11  March  2024.  Croatian  Government,  Press  release:  Plenković:  We  are  in  the 
largest investment cycle in education in the history of Croatia, worth EUR 2.5 billion, 2 May 2024. 

29   Court of Justice of the European Union, judgment of 11 July 2024, Joined Cases C-554/21 Hann-Invest, C-

622/21 Mineral-Sekuline and C-727/21 Udruga Khl Medvešcak Zagreb.  

30   See Figure 57, 2022 EU Justice Scoreboard, which specifies in footnote that there are in Croatia registration 
judges on each county court and on the High Commercial  Court, the High Misdemeanour Court, the High 
Administrative, the High Criminal Court and the Supreme Court, which register the judgments after which 
they  can  be  notified  to  the  parties,  and  may  alert  a  judge/chamber  on  a  deviation  from  existing  'legal 
position'  and  propose  to discuss  the  divergence  at  a  section  meeting pursuant  to Article  40  of  the  Law  on 
Courts, in order to issue a decision of the section which is binding on all judges in the court. It should be 
noted that the Law on Courts expressly provided that ‘legal positions’ were binding on all courts, including 
judges at 1st instance courts, until the 2013 amendments adapted the provision before Croatia’s accession to 
the EU. 
31   Para. 69.  
32   Paras.  74-80. The  Court  considered  incompatible  with  the right  to  an  effective  judicial protection  national 
legislation which allows a section meeting to compel, through a ‘legal position’, a panel to alter the content 
of its decision which it previously adopted, even though that section meeting also includes judges other than 
those  belonging  to  that  panel  or  persons  from  outside  the  court  before  whom  the  parties  do  not  have  the 
opportunity to put forward their arguments. Para. 79. 

7 

 
 
Quality  

The  Supreme  Court  adopted  guidelines  to  improve  communication about  the  work  of 
the judiciary, following up on the People’s Ombudsperson’s recommendation. The 2023 
Rule of Law Report found that the communication about the work of the judiciary could be 
improved, as most  courts have dedicated staff for communicating with  the public but  press 
events to present the regular work of courts and state attorney’s offices were not common33. 
On  25  September  2023,  following  up  on  the  People’s  Ombudsperson’s  recommendation34, 
the Supreme Court adopted ‘Guidelines for communication of the judiciary with the public’ 
to  contribute  to  the  timely,  accurate  and  transparent  communication  about  the  content  and 
meaning  of  decisions  for  which  there  is  public  interest35.  The  Guidelines  are  addressed 
primarily  to  the  spokespersons  and  information  officers  at  the  courts.  Developing 
communication skills in the courts was also a target under the Recovery and Resilience Plan, 
which Croatia successfully fulfilled in April 202436. 

Following  difficult  discussions  and  negotiations,  significant  progress  was  achieved  on 
the level of remuneration of judges, state attorneys and judicial staff, and legislation to 
set  objective  remuneration  criteria  is  expected  in  2024.  The  2023  Rule  of  Law  Report 
recommended  Croatia  to  ‘continue  structural  efforts  to  address  the  remuneration  of  judges, 
state  attorneys  and  judicial  staff,  taking  into  account  European  standards  on  resources  and 
remuneration  for  the  justice  system’37.  The  2023  Report  found  that  legislative  amendments 
adopted  in  June  2023  brought  the  salary  base  of  judges  and  state  attorneys,  when  taken 
together  with  the  2019  increase,  slightly  above  the  2009  level38.  These  amendments  were 
agreed with representatives of judges as a first measure, with the expectation that additional 
regulatory  changes  would  follow  by  the  end  of  2023  to  address  the  outstanding  need  for 
defining  objective  criteria  for  adjusting  salaries  of  judges  and  state  attorneys,  such  as 
indexation39.  As  no  further  measures  were  initially  introduced,  in  January  2024  the  judges, 

33   Furthermore, despite  improvements,  the  level  of perceived  judicial  independence  in  Croatia  has  remained, 
since  2016,  very  low  both  among  the  general  public  and  companies.  Figures  51  and  53,  2024  EU  Justice 
Scoreboard.  

34   The People’s Ombudsperson stated in its recommendation that the Justice Academy should, in cooperation 
with the media, conduct training of journalists on the work of the judiciary. The Ombudsperson stressed that 
in addition to courts’ press releases, more structured communication with the media could contribute to the 
delivery of accurate and complete information to the public. People’s Ombudsperson, 2022 Report, p. 128. 
35   Supreme Court, Guidelines for communication of the judiciary with the public in line with the Action plan 
for 2022-2024 based on the Strategy for the Prevention of Corruption 2021-2030, 25 September 2023, and 
Contribution from the Supreme Court to the 2023 Rule of Law Report, p. 19.  

36   The Council adopted the Council Implementing Decision of 28 July 2021 on the approval of the assessment 
of  the  recovery  and  resilience  plan  for  Croatia,  under  which  the  Target  no.  217  states:  ‘Six  new  training 
programmes  shall  be  completed  as  part  of  the  judicial  training  programme  for  judicial  officials  and 
officers of the  judicial  authorities  in  the  Judicial  Academy:  Developing  different  skills  (management  and 
management  skills  for  court  presidents,  court  management  for  heads  of  court  administration  and 
communication  skills  for  court  staff  –  three  programmes).  […]’.  The  Commission  found  the  target  to  be 
satisfactorily fulfilled on 29 February 2024. Communication to the Commission on the positive preliminary 
assessment  of  the  fourth  payment  request  of  Republic  of  Croatia  pursuant  to  Regulation  (EU)  2021/241, 
C(2024)1439 final. 

37   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 2. 
38   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 7. 
39   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 7-8. 

8 

 
 
with  the  support  of  state  attorneys,  conducted  a  warning  strike40.  In  February  2024, 
negotiations with the Government resumed41 and led to an agreement to increase the salary 
base  of  judges  and  state  attorneys  by  11,5%.  On  14  March  2024,  Parliament  adopted  the 
amendment  to  the  Law  on  Judicial  Officials’  Salaries  and  Other  Material  Rights42.  Apart 
from  the  increase  of  the  salary  base,  the  law  adjusted  the  coefficients  for  judges  and  state 
attorneys  at  different  instances  and  prescribed  additional  material  rights43.  However, 
representatives  of  judges  stated  that  whilst  the  increase  adjusted  their  salaries  to  inflation, 
they  expected  a  more  thorough  revision  of  the  law  in  2024,  to  introduce  objective 
remuneration criteria, such as indexation44. As regards the remuneration of judicial staff, the 
situation led to an eight-week strike in summer 2023, which ended after an agreement with 
the  Government  on  a  12%  salary  increase45.  As  the  level  of  remuneration  of  judges,  state 
attorneys and judicial staff was increased, and a law setting objective remuneration criteria is 
expected in 2024, significant progress was achieved regarding the recommendation made in 
the 2023 Rule of Law Report.  

The  use  of  electronic  communication  systems between  courts  and  users  increased  and 
further  initiatives  are  being  taken  to  close  the  digitalisation  gap  in  the  justice  system. 
According to the 2024 EU Justice Scoreboard, the digitalisation of the justice system further 
improved in all areas but a few46. After having integrated all remaining courts into the unified 

40   According  to  information  from  the  Association  of  Judges,  more  than  85%  of  judges  participated  in  the 
warning strike that lasted from 22 January until 2 February 2024. Association of Judges, Press release: of 28 
January 2024. During the warning strike, judges could postpone non-urgent hearings and judicial decisions, 
as detailed in the Instruction of the President of the Supreme Court of 22 January 2024. In January 2024, the 
Association of Judges addressed a complaint to the European Commission raising concerns on respect for 
judicial independence due to the remuneration situation. 

41   Association of Croatian Judges, Press release: The judges’ warning strike will end on 2 February 2024. 
42   This will lead to an increase of monthly salaries by about EUR 790 gross.  
43   Revised  Article  8  of  the  law  added  annual  end  of  year  holidays  allowance,  child  allowance,  holiday 

allowance and right to paid systemic medical exam.  

44   Association  of  Croatian  Judges,  Press  release: Amendment  to  the  Law  on  Judicial  Officials’  Salaries  and 

Other Material Rights announced, 27 February 2024. 

45   According  to  the  Government,  the  Law  on  Salaries  in  the  Civil  Service  and  Public  Services  (entered  into 
force  on  1  January  2024)  and  the  Regulation  on  job  titles,  job  requirements  and  salary  calculation 
coefficients (entered into force on 1 March 2024) significantly increased coefficients for the job positions of 
civil  servants  and  public  employees  in  courts.  For  example,  the  salary  calculation  coefficient  of  court 
reporters in judicial bodies was 0.990 before the reform of the salary system, is now 1.44, which represents 
an  increase  of  approximately  46%.  This  position  is  taken  as  an  example,  because  the  largest  number  of 
administrative  staff  (civil  servants  and  public  employees)  occupy  it.  Written  contribution  from  the 
Government in the context of the country visit to Croatia and input from Croatia for the 2024 Rule of Law 
Report, p. 1. The strike was held from 5 June until 26 July 2023. The Supreme Court on 19 June 2023 ruled 
that the  strike was legal. Supreme Court,  Press release: The  Supreme Court has ruled  - the strike  of court 
officials and employees is legal, 20 June 2023.  During the court staff strike, the  President of the Supreme 
Court stated that the justice system was on the verge of collapse, as 870 court staff left their positions in the 
first half of 2023, while 1 166 positions remained unoccupied – also due to low attractiveness of court staff 
jobs; Supreme Court, Press release: Judicial system on the verge of collapse - mass departure of officials, 3 
July 2023. On 26 June 2023, the Supreme Court President addressed an open letter to the Prime Minister on 
way to resolve the remuneration situation of judicial staff. Supreme Court (2023), Letter from President of 
Supreme Court to the Prime Minister, 26 June 2023. 

46   Figures  42-50,  2024  EU  Justice  Scoreboard.  Except  for  electronic  communication  in  prosecution  service 
(Figure 46) and the online access to published judgments by the general public (Figure 49), the electronic 
tools incrementally improved in all other areas. 

9 

 
 
‘e-Communication’  system47,  efforts  have  intensified  to  deploy  electronic  communication 
tools in different areas, particularly in criminal justice. The implementation of the Recovery 
and  Resilience  Plan  is  well  underway  and  includes  several  milestones,  targets  and 
investments  related  to  the  digitalisation  of  justice48.  Efforts  are  under  way  in  relation  to 
another investment  under the Recovery and Resilience Plan, which aims  to  further upgrade 
the  court  case  management  e-File  system,  especially  its  module  on  e-Communication.  The 
system is connected to the e-Citizens and the e-Authorisation systems, in which legal persons 
will  be  able  to  independently  register49.  In  2023,  the  overall  use  of  the  ‘e-Communication’ 
system increased among most of the professional users, as well as among citizens and legal 
persons50.  To  increase  the  publication  of  first  and  second  instance  court  judgments,  which 
remains  very  limited51,  on  14  March  2024  Parliament  adopted  amendments  to  the  Law  on 
Courts,  which  provide  for  the  obligation to  publish  all  court  decisions  on  a  special  website 
with prior anonymisation, to ensure compliance with the rules on the protection of  personal 
data52. The development of an IT solution for automatic and semi-automatic anonymisation, 
using artificial intelligence, is underway53. The Ministry of Justice and Public Administration 
is  preparing  the  public  procurement  regarding  the  introduction  of  audio  recording  in 
courtrooms to increase transparency54. 

Efficiency 

The  overall  number  of  pending  cases  and  the  length  of  trials  in  most  cases  increased. 
According to the 2024 EU Justice Scoreboard, the backlogs and length of proceedings remain 
a serious concern, particularly in litigious civil and commercial cases, where backlog is the 

47   Only misdemeanour cases are not yet integrated (handled before Municipal Courts), as there is no legal basis 
in  national  law  for  their  inclusion.  Written  contribution  from  the  Ministry  of  Justice  and  Public 
Administration in the context of the country visit to Croatia, and 2023 Rule of Law Report, Country Chapter 
on the rule of law situation in Croatia, p. 7. 

48   Croatia submitted two payment requests in 2023, corresponding to 61 milestones and targets in the plan. The 
third  payment  request  was  disbursed  in  December  2023  (EUR  700  million  net  amount  in  grants)  and 
included the satisfactory fulfilment of milestone 229 C2.5. R1-I6 (All courts of first instance are equipped 
and  meet  the  conditions  for  hearing  remotely).  The  fourth  payment  request  was  disbursed  in April  2024 
(EUR 162.5 million net amount in grants) and included the satisfactory fulfilment of milestone 218 C2.5 R1 
(Adoption of amendments to the legislative framework in the area of justice with the new Non-contentious 
Procedure Act). 

49   The system will be redesigned, navigation and displays will be improved, and it will be connected to the e-
Signature, the e-Seal and the e-Fees systems. This investment is due to be completed by 31 December 2024. 
Input from Croatia for the 2024 Rule of Law Report, pp. 7-8.  

50   In  2023,  the  electronic  communication  among  companies  and  legal  professionals  (e.g.,  court  experts, 
insolvency  administrators,  court  interpreters,  state  attorneys)  measured  by  the  number  of  exchanged 
electronic documents further increased by 2% and 7%, compared to 2022, respectively (nearly 1,1 million 
documents  were  exchanged  by  companies  alone).  Among  lawyers,  it  slightly  decreased,  but  remained 
sizeable  at  nearly  3,1 million  documents  exchanged  in  2023. Among  citizens,  the  use  increased  to  around 
21 000 documents exchanged (up from 19 000 in 2022). Written contribution from Ministry of Justice and 
Public Administration in the context of the country visit to Croatia. 

51   Figure 49, 2024 EU Justice Scoreboard. 
52   Input from Croatia for the 2024 Rule of Law Report, p. 8. 
53   Input  from  Croatia  for  the  2024  Rule  of  Law  Report,  p.  8.  Publication  of  new  judgments  is  planned  for 
January  2025,  while  the  already  published  and  anonymised  judgments  will  be  transferred.  Written 
contribution  from  the  Ministry  of  Justice  and  Public Administration  in  the  context  of  the  country  visit  to 
Croatia. 

54   Input from Croatia for the 2024 Rule of Law Report, p. 8. 

10 

 
 
 
largest  in  the  EU55.  Despite  improvements  in  some  types  of  cases,  backlogs  and  length  of 
proceedings, in most cases, increased, which remains a serious concern. In 2023, the average 
length of proceedings in the first instance courts remained among the longest in the EU and 
increased  to  1 334  days  in  litigious  commercial  cases  (1 187  in  2022)  and  to  764  days  in 
litigious civil cases (709 in 2022)56. However, the average length of proceedings decreased in 
first instance criminal cases before municipal courts (776 days in 2023, down from 1 054 in 
2022) and before county courts (808 days in 2023, down from 965 in 2022). In bribery cases, 
the average length of proceedings before first instance courts also decreased in 2022 to 532 
days  (down  from  632  days  in  2021)57.  End  2023,  the  overall  number  of  pending  cases 
increased  (compared  to  2022)  before  municipal,  commercial  and  administrative  courts58. 
However, the Supreme Court and the High Commercial Court again saw a large decrease in 
pending cases and a slight decrease in the average length of case processing59. In 2023, the 
total  number  of  oldest  pending  cases  (10  years  and  older)  further  decreased  (by  8%)60. 
Croatia has implemented several measures to reduce the length of court proceedings61. 

55   The  data  for  2022  show  particular  challenges  in  litigious  civil  and  commercial  cases  and  all  non-criminal 
cases (Figures 5, 12, 13 of the 2024 EU Justice Scoreboard), although the positive sign is that in 2022, the 
clearance rate in litigious civil and commercial cases and the non-criminal cases were the highest and second 
highest in the EU, respectively (Figures 10 and 9, 2024 EU Justice Scoreboard). 

56   All data on average length of proceedings are from the written contribution from the Ministry of Justice and 

Public Administration in the country visit to Croatia. 

57   Figure 23, 2024 EU Justice Scoreboard. 
58   By  4%  in  Municipal  Courts,  27%  in  Commercial  Courts,  and  by  59%  in Administrative  Courts.  In  High 
Criminal Court, High Administrative Court and in County Courts, the pending cases increased only slightly. 
59   In  2023,  pending  cases  in  Supreme  Court  decreased  by  37%,  and  average  length  of  proceedings  was  556 
days  (590  in  2022).  In  High  Commercial  Court,  pending  cases  decreased  by  23%  and  average  length 
remained stable at 223 days. Written contribution from the Ministry of Justice and Public Administration in 
the context of the country visit to Croatia. 

60   From  1 752  pending  cases  (end  2022)  to  1 606  cases  (end  2023).  However,  the  number  of  pending  cases 

older than 7 years increased to 3 807 (from 3 742 end 2022). 

61   The draft Law on Service of Judicial Documents, adopted by the Government on 30 November 2023, aims at 
speeding  up  and  streamlining  proceedings  for  the  service  and  receipt  of  judicial  documents61.  A  secure 
online  platform  with  connections  to  other  Member  States  was  set  up  to  easilly  find  courts  and  competent 
authorities  in  criminal  matters  and  to  quickly  exchange  evidence  and  requests.  Further  measures  include 
milestone  220  ”New  Framework  Benchmarks  for  the  work  of  judges  adopted  and  an  active  judicial  case 
management tool introduced“. The Commission found the milestone to be satisfactorily fulfilled on 12 June 
2024.  Communication  to  the  Commission  on  the  positive  preliminary  assessment  of  the  fifth  payment 
request of Republic of Croatia pursuant to Regulation (EU) 2021/241, C(2024) 4170 final.  

11 

 
 
 
 
II. 

ANTI-CORRUPTION FRAMEWORK  

The Ministry of Justice and Public Administration is the central corruption prevention body, 
with  a  dedicated  Sector  for  Preventing  Corruption.  There  is  a  government  Council  for  the 
Prevention  of  Corruption62  and  a  Parliamentary  Council  for  the  monitoring  of  the 
implementation  of  the  Strategy  for  Combating  Corruption63.  A  specialised  National  Police 
Office for the Suppression of Corruption and Organised Crime (PNUSKOK) works hand in 
hand  with  the  prosecutor’s  Office  for  the  Suppression  of  Corruption  and  Organised  Crime 
(USKOK).  They  prosecute  corruption  and  organised  crime  cases  in  first  instance  county 
courts  in  Zagreb,  Split,  Osijek  and  Rijeka,  with  the  High  Criminal  Court  acting  as  the 
appellate  court  for  these  cases.  The  Commission  for  the  Resolution  of  Conflicts  of  Interest 
(CRC) has competences to prevent corruption and strengthen the integrity of public officials, 
such as the supervision of asset declarations. The State Commission for Supervision of Public 
Procurement  Procedures  is  an  independent  tribunal  responsible  for  reviewing  appeals 
regarding  public  procurements.  The  People’s  Ombudsperson  is  managing  reports  made  by 
whistleblowers.  

The perception among experts and business executives is that the level of corruption in 
the public sector remains high. In the 2023 Corruption Perceptions Index by Transparency 
International,  Croatia  scores  50/100,  ranks  23rd  in  the  European  Union  and  57th  globally64. 
This  perception  remained  relatively  stable65  over  the  past  five  years.  The  2024  Special 
Eurobarometer  on  Corruption  shows  that  92%  of  respondents  consider  corruption  to  be 
widespread  in  their  country  (EU  average  68%)  and  60%  of  respondents  feel  personally 
affected by corruption in their daily lives (EU average 27%)66. As regards businesses, 85% of 
companies consider that corruption is widespread (EU average 65%) and 61% consider that 
corruption  is  a  problem  when  doing  business  (EU  average  36%)67.  Furthermore,  33%  of 
respondents find that there are enough successful prosecutions to deter people from  corrupt 

62   A government advisory body composed of 24 representatives of public institutions and 7 non-governmental 
organisations.  It  is  mandated  to  monitor  the  implementation  of  Action  Plans,  with  the  assistance  of  the 
Sector  for  Preventing  Corruption  of  the  Ministry  of  Justice  and  Administration,  and  to  design,  improve, 
systematically monitor and evaluate national-level strategic and operational documents related to preventing 
corruption.  

63   This is a permanent working body of Parliament, comprised of 11 members: its President (from the ranks of 
the opposition), 4 members of Parliament, as well as 6 members appointed through a public call representing 
employers, trade unions, civil society organisations, academia, media, and experts.  

64   Transparency International (2024), Corruption Perceptions Index 2023. The level of perceived corruption is 
categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public  sector 
corruption scores above 79); relatively low (scores between 79-60), relatively high (scores between 59-50), 
high (scores below 50). 

65   In  2019,  the  score  was  47,  while  in  2023,  the  score  was  50.  The  score  significantly  increases/  decreases 
when  it  changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively 
stable (changes from 1-3 points) in the last five years. 

66   Special Eurobarometer 548 on Citizens’ attitudes towards corruption in the EU (2024). The Eurobarometer 
data  on  citizens’  corruption  perception  and  experience  is  updated  every  year.  The  previous  data  set  is  the 
Special Eurobarometer 534 (2023). 

67   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). The Eurobarometer 
data  on  business  attitudes  towards  corruption  as  is  updated  every  year. The  previous  data  set  is  the  Flash 
Eurobarometer 524 (2023). 

12 

 
 
practices  (EU  average  32%)68,  while  18%  of  companies  believe  that  people  and  businesses 
caught for bribing a senior official are appropriately punished (EU average 31%)69.   

The  implementation  of  the  first  action  plan  for  2022-2024  under  the  Anti-Corruption 
Strategy is well on track.  On 17 August 2023, the Government adopted the Report on the 
implementation in 2022 of the Action Plan 2022-2024, which has a total of 206 activities. Of 
the 42 activities to be implemented in 2022, 29 activities were carried out, 8 activities were 
partially  implemented  and  5  continue  to  be  implemented.  Implemented  activities  include, 
among  others,  the  development  of  guidelines  for  employers  for  the  effective  application  of 
the Law on the Protection of Persons who report irregularities and Systemic overview of all 
provisions regarding conflict of interest and the list of public officials to whom they apply70. 
The implementation of the action plan remained on track in 2023, with 21 of the 43 planned 
activities  implemented,  8  activities  partially  implemented,  and  14  activities  continue  to  be 
implemented71.  

Croatia strengthened its legislation on bribery of foreign public officials. As noted in the 
2023 Rule of Law Report, Croatia committed to taking legislative action in the context of its 
accession to the Organisation for Economic Co-operation and Development (OECD)72. On 28 
September 2023, Parliament adopted legislation that extends the scope of bribery offences to 
foreign  public  officials  and  representatives,  extends  the  scope  of  liability  of  legal  persons, 
and raises sanction levels for legal persons. A legal person may now be fined up to 10% of 
their total annual turnover obtained in the business year preceding the judgment. Finally, an 
explicit prohibition on the deduction of bribes on profit tax was introduced73. On 30 October 
2023,  Croatia  became  a  member  of  the  OECD  Working  Group  against  Bribery  in 
International Business Transactions and on 21  January 2024, the Convention on Combating 
Bribery of Foreign Public Officials in International Business Transactions entered into force 
for Croatia74.  

Investigations,  prosecutions  and  convictions  of  corruption,  including  at  high-level, 
continued.  The  specialised  anti-corruption  police  (PNUSKOK)  and  prosecution  (USKOK) 
continued to report that in 2023 their cooperation worked well, also with the EPPO75, which 
investigated 13 corruption offences in 202376. In 2023, 747 corruption offences were reported 

68   Special Eurobarometer 548 on Citizens’ attitudes towards corruption in the EU (2024). 
69   Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024). 
70   Croatian Government, Report for 2022 on the implementation of the Action Plan for the period from 2022 to 
2024 accompanying the Strategy for the prevention of Corruption for 2021-2030, 17 August 2023. There are 
more activities included in the Action Plan that are explained later in this report. CRC, Systemic overview of 
provisions on conflict of interest, 8 December 2023. 

71   Written  contribution  from  the  Ministry  of  Justice  and  Public Administration  in  the  context  of  the  country 

visit to Croatia. 

72   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 12. 
73   Input from Croatia for the 2024 Rule of Law Report, p. 28-30. The OECD Working Group against Bribery 
notes  that  more  implementation  is  needed  regarding  the  tax  deductibility  prohibition. The Working  Group 
considered  that  Croatia’s  legislation  largely  conforms  to  the  standards  of  the  Convention,  subject  to  some 
issues  which  will  be  followed  up  during  Croatia’s  Phase  2  evaluation.  OECD  (2023)  Implementing  the 
OECD Anti-Bribery Convention in Croatia Phase 1, p. 23. 
74   Input from Croatia for the 2024 Rule of Law Report, p. 27. 
75   Information  received  from  PNUSKOK  and  USKOK  in  the  context  of  the  country  visit  to  Croatia,  and 

contribution from EPPO for the 2024 Rule of Law Report.  

76   EPPO, Annual report 2023, p. 21. This concerns almost 16% of all cases investigated by EPPO in 2023. 

13 

 
 
by  PNUSKOK  to  the  USKOK  (1 187  in  2022)77.  The  offence  of  abuse  of  position  and 
authority continues to be the most reported offence and involves the most material damage78. 
The  2023  Report  of  the  State  Attorney’s  Office79  shows  that  the  number  of  suspects  of 
corruption  offences  in  2023  slightly  increased80  and  that  the  number  of  criminal 
investigations  remained  stable81.  In  2023,  the  State  Attorney’s  Office  indicted,  after 
investigation, 121 persons, compared to 178 in 2022 (while there were 69 in 2021 and 84 in 
2020)82.  In  the  same  period,  the  courts  continued  to  deliver  more  judgments  than  in  past 
years83. High-level corruption cases continued to be well represented among investigated and 
finalised corruption court cases, including a case involving a former State Secretary84. There 
were also charges brought against dozens of public officials for abuse of office and trading in 
influence  in  2023,  as  well  as  some  charges  against  judges85  and  police  officers86.  Several 
suspects in high-level corruption were convicted to imprisonment, including a former head of 
the  former  Prime  Minister’s  Office87.  In  terms  of  public  perception,  civil  society 
organisations  are  of  the  opinion  that  political  white-collar  corruption  is  one  of  the  main 
reasons why the public in Croatia has a negative perception on the fight against corruption88. 
They agree with PNUSKOK and USKOK, who consider that preventive measures – such as 

77   The statistics in PNUSKOK count criminal offences, not number of cases or suspects like USKOK. A single 
suspect may have committed several offences. Written contribution from PNUSKOK in the country visit to 
Croatia. 

78  In 2023, all criminal notifications from PNUSKOK on corruption concerned the alleged material damage (to 
the  public  authorities  or  to  the  private  entities)  in  the  amount  of  EUR  4,5  million  (EUR  32,6  million  in 
2022). There were 813 counts of abuse of office in 2022 and 588 in 2023, which represented 68% and 78% 
of the total reported offences, respectively. Written contribution from PNUSKOK following the country visit 
to Croatia. 

79   State Attorney’s Office, 2023 Report, 28 April 2024, pp. 212-215. 
80   In  2023,  the  State  Attorney’s  Office  received  criminal  notifications  regarding  1 491  alleged  suspects  of 
corruption  offences  (up  from  1 165  in  2022  and  1 366  in  2021),  representing  83%  of  the  total  criminal 
notifications  received  by  USKOK.  As  in  the  past,  the  the  State  Attorney’s  Office  submits  that  the  vast 
majority of the criminal notifications in 2023 were dismissed (1 354) as as they were mostly submitted by 
citizens without much evidence and made in the context of legal proceedings of which they did not like the 
outcome.  

81   In 2023, investigations were opened concerning 128 persons, compared to 130 in 2022, 135 in 2021, 108 in 

2020 and 142 in 2019. 

82   In addition, 9 persons were indicted without prior investigation (3 in 2022).   
83   There were judgments concerning 179 persons in 2023 and 182 in 2022, which is considerably more than the 
67 in 2021 and 92 in 2020. Out of the 179 final judgments in 2023, 118 were convictions for corruption (i.e., 
conviction rate of 66%, compared to 84% in 2022 and 88% in 2021). As regards the sanctions for corruption 
offences, out of 47 persons who received a prison sentence in 2023 (65 in 2022, 36 in 2021, 31 in 2020), for 
28 persons prison sentence was changed into work for the public good (24 in 2022), with another 71 persons 
receiving  conditional  sentences  (87  in  2022,  19  in  2021  and  47  in  2020).  State  Attorney’s  Office,  2023 
Report, 28 April 2024, p. 212. 

84   Input received from Croatia for the 2024 Rule of Law Report, p. 30. In a case against four former ministers 
and  a  mayor,  the  High  Criminal  Court  ruled  on  7  December  2023  that  the  Zagreb  County  Court  has  to 
provide  better  reasoning  on  why  it  dismissed  the  defence’s  request  to  exclude  evidence.  Index,  The  High 
Criminal Court takes an important decision in favor of Plenković's former ministers, 7 December 2023.  
85   Input received from Croatia for the 2024 Rule of Law Report, p. 30-31. In July 2023, USKOK indicted three 
judges in cases related to Croatian football manager Zdravko Mamić, Index, Indictment filed against Mamić 
and the Osijek judges, 7 December 2023.  

86   Information received from PNUSKOK in the context of the country visit to Croatia. 
87   Input received from Croatia for the 2024 Rule of Law Report, pp. 31-33. 
88   Information received from Human Rights House Zagreb, Centre for Democracy and Law Miko Tripalo and 

GONG in the context of the country visit to Croatia.  

14 

 
 
awareness-raising,  increased  transparency,  and  digitalisation  –  are  more  effective  than 
sanctions in reducing corruption89. 

There has been some progress to improve the efficiency of investigation and prosecution 
of corruption offences. The 2023 Rule of Law Report recommended Croatia to ‘revise the 
Criminal Procedure Code and the Law on the Office for the Suppression of Corruption and 
Organised Crime, as set out in the Anti-Corruption Strategy, so as to increase the efficiency 
of  investigations  and  prosecution  of  corruption  offences’90.  The  Anti-Corruption  Strategy 
envisages revisions to the Criminal Procedure Code and the Law on the USKOK, as well as 
increasing  the  capacity  of  the  specialised  prosecution,  also  with  a  view  of  ensuring  the 
completion of proceedings within a reasonable timeframe. The amendments would ensure the 
completion  of  proceedings  within  a  reasonable  timeframe91.  The  Ministry  of  Justice  and 
Public  Administration  explained  that  legislative  amendments  on  domestic  violence  were 
prioritised  over  this  revision  of  the  Criminal  Procedural  Code92.  Nevertheless,  Croatia  did 
take other measures with the aim of reducing the length of court proceedings and the average 
length of court proceedings in bribery cases decreased93. In 2023, the length of investigations 
led by the state attorneys in USKOK was overall reduced. The percentage of USKOK cases94 
where  the  investigation  was  finished  within  six months  or  sooner  decreased,  but  so  did  the 
percentage of  cases lasting more than a year95. Therefore, there has been some progress  on 
the implementation of the recommendation made in the 2023 Rule of Law Report. 

Anti-corruption authorities continue to optimise their resources96. On 1 February 2024, 
USKOK was employing 32 out of 34 state attorney positions, but it was unable to fill most of 

89   Information received from PNUSKOK and USKOK in the context of the country visit to Croatia.  
90   2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p 2. The Recovery and 
Resilience  Plan  contains  a  target  which  requires  Croatia  to  reduce  the  average  length  of  court  cases  (i.e. 
adjudication) for corruption and organised crime offences by the end of June 2026. The Council adopted the 
Council  Implementing  Decision  of  28  July  2021  on  the  approval  of  the  assessment  of  the  recovery  and 
resilience  plan  for  Croatia,  under  which  the Target  no.  238  states:  ‘Reduction  by  200  days  of  the  average 
length  of  court  cases  for  corruption  and  organised  crime  offences  compared  to  Q1/2021  (999  days)’.  The 
target is part of tenth payment request, hence it has not yet been assessed by the Commission. 

91   The  Anti-Corruption  Strategy  envisages  revisions  to  the  Criminal  Procedure  Code  and  the  Law  on  the 
USKOK, as well as increasing the capacity of the specialised prosecution, also with a view of ensuring the 
completion of proceedings within a reasonable timeframe. 

92   Information received in the context of the country visit to Croatia from the Ministry of Justice and Public 
Administration.  In  2022,  working  groups  were  established  for  the  preparation  of  the  amendments  to  the 
Criminal  Procedure  Code  and  the  Law  on  the  Office  for  the  Suppression  of  Corruption  and  Organized 
Crime. 

93   See the efficiency data in section ‘Efficiency’ under I. Justice system. Despite a decrease (from 632 days in 
2021, to 532 days in 2022), in 2022, the  average  length at first instance courts when dealing with bribery 
cases was third longest in the EU. Figure 23, 2024 EU Justice Scoreboard.   

94   Whereas  USKOK  is  competent  in  corruption  and  organised  crime,  the  vast  majority  of  its  cases  concern 

corruption offences.  

95   Information  received  from  USKOK  in  the  context  of  the  country  visit  to  Croatia,  and  State  Attorney’s 
Office, 2023 Report, p. 177. Cases where where the investigation was finished within six months or sooner: 
16% in 2023 (compared to 25 % in 2022 and 35% in 2021). More investigations were finished within a year, 
namely about 57% in 2023 (29% in 2022, 40% in 2021). This significantly reduced the percentage of cases 
lasting more than a year, which amounted to 27%, compared to 46% in 2022 (and 25% in 2021) 

96   Under its Recovery and Resilience Plan, Croatia should by June 2024 increase, compared to 2020, its staff 
budget  for  employees  of  anti-corruption  bodies  in  the  justice  system  with  10%  and  increase  by  20%  the 
budget  for  computer  services  and  IT  equipment  for  anti-corruption  authorities  in  the  judicial  system,  see 
Council  Implementing  Decision  of  28  July  2021  on  the  approval  of  the  assessment  of  the  recovery  and 

15 

 
 
 
its  administrative  vacancies  –  also  due  to  the  limited  attractiveness  of  these  administrative 
positions97. Furthermore, no one applied for the position of head of USKOK in 2023, and the 
position  was  finally  filled  on  28  May  202498.  Both  USKOK  and  PNUSKOK  hope  that  the 
expected  increase  in  salaries99  will  ease  the  situation  and  attract  more  applicants  to  vacant 
posts100. In 2023, the financial resources of the Commission for the Resolution of Conflicts of 
Interest  (CRC)  further  increased,  even  though  it  remained  challenging  to  fill  all  open 
vacancies.  Throughout  2023  and  into  2024,  the  CRC  continued  developing  an  IT  platform 
that  would  allow  it  to  exchange  data  with  other  state  registers  so  as  to  facilitate  the 
verification of asset declarations101. However, the CRC notes that it remains difficult, if not 
impossible,  to  fulfil  its  obligation  for  an  annual  verification  of  all  asset  declarations  with 
available human resources102. This is partly due to the fact that not all submitted data can be 
verified yet through the abovementioned IT system and that the procedures to draft a report 
on  asset  declarations  are  complicated103.  In  response,  the  CRC  plans  to  prioritise  the 
verification  of  declarations,  starting  with  a  random  sample  of  high-level  officials,  ranging 
from the executive, parliament, as well as local and regional-level officials. In addition, the 
CRC will continue to pursue citizen complaints and media information, as appropriate104.  

Although  codes  of  ethics  are  in  place  at  almost  all  levels  of  the  administration  and 
government, their practical application, in particular through requests for guidance, is 
limited.  In  2023,  no  requests  were  made  to  the  Committee  on  the  Constitution,  Rules  of 

resilience plan for Croatia, targets no. 235 and 236. The targets are part of sixth payment request, hence they 
have not yet been assessed by the Commission. 

97   Information received from DORH and USKOK in the context of the country visit to Croatia. 
98   In  April  2023,  the  USKOK  director  resigned  due  to  personal  reasons  and  the  State  Attorney  General 
appointed an acting director. In September 2023, there were no applications for the vacancy of the USKOK 
director, and a new competition is planned once the next State Attorney General assumes office from 26 May 
2024 onwards (see above, the section on ‘Independence’ under I. Justice systems). USKOK considered that 
the  high  level  of  responsibility  and  risk  of  negative  press  could  have  been  the  reasons  for  the  absence  of 
applications for the post of USKOK director.  

99   See above, section on ‘Quality’ under I. Justice system.  
100  Information  received  from  USKOK  and  PNUSKOK  in  the  context  of  the  country  visit  to  Croatia.  Low 
remuneration and high workload were reported in 2023 as greatest challenges to attract and retain staff, see 
2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 8-9, pp. 14-15.  

101  The IT platform that would allow it to exchange data with other state registers it is still not operational due 
to the technical reasons. Information received from the CRC in the context of the country visit to Croatia. 
Another IT tool will help officials declare their assets, particularly by pre-filling data that the Government 
already has, such as tax and land registry data. The  tool should be finalised by mid-2024, in line with the 
national Recovery and Resilience Plan, see  2022 Rule of Law Report, Country Chapter on the  rule of law 
situation in Croatia, p. 15; Council Implementing Decision on the approval of the assessment of the recovery 
and resilience plan for Croatia of 28 July 2021, Milestone no. 241. The milestone is part of sixth payment 
request, hence it has not yet been assessed by the Commission.  

102  All  (between  3 500  and  4 000)  obliged  entities  have  to  declare  their  assets  once  a  year  in  January,  when 
taking up duties, ending duties and one year thereafter. See 2023 Rule of Law Report, Country Chapter on 
the rule of law situation in Croatia, pp. 15-16.  

103  In September 2023, it was by information from journalists that the CRC discovered that a Minister failed to 
declare  profits  from  his  stake  in  a  company.  The  CRC  explained  that  an  investigator  must  first  draft  a 
complete  report for submission to the official that is the  object of the report,  wait for their reply and then 
draft the final report. More practical problems were described in 2023 Rule of Law Report, Country Chapter 
on  the  rule  of  law  situation  in  Croatia,  p.  15-16.  There  are  no  plans  to  amend  the  2021  Law  on  the 
Prevention of Conflicts of Interests. 

104  Information  received  in  the  context  of  the  country  visit  to  Croatia  from  the  CRC.  The  CRC  imposed  a 
sanction of EUR 5 300 in that case. NGO GONG, Press release: Gong to the Commission: Check the highest 
level officials first, 22 December 2023.  

16 

 
 
Procedure and Political System in relation to alleged breaches of the parliamentary Code of 
Ethics105. As regards the 2022 Code of Conduct for State Officials in Executive Bodies106, the 
Implementation  Council  did  not  receive  any  request  to  provide  its  opinion  on  compliance 
with the Code in 2023, but it did provide training on the Code to most of the officials covered 
by it107. The CRC remains the body in charge in relation to conflicts of interests and can open 
a case at any time. On 19 April 2024, members of the Council for the Implementation of the 
Code of Conduct for State Officials in Executive Bodies participated in a meeting with CRC 
members,  where  cooperation  between  the  two  bodies  and  joint  education  on  the  topic  of 
conflict  of  interest  prevention  were  discussed108.  The  number  of  opinions  that  the  CRC 
provided to public officials decreased to 214 in 2023, compared to 706 in 2022 (which was a 
threefold increase compared to 2021)109. At local level, codes of conduct were adopted by all 
but  one  local  and  regional  administration.  In  June  2024,  the  Government  submitted  to 
Parliament  amendments  to  the  Law  on  Local  and  Regional  Self-Government  Officials  and 
Employees, which includes an obligation on local officials to sign a declaration of absence of 
conflict  of  interests  at  the  start  of  their  work,  just  like  the  Civil  Service  Act  adopted  in 
December 2023110.  As regards the police, a new Code of Ethics  for Police Officers entered 
into force in December 2023, and a handbook was published in March 2024, illustrating the 
Code of Ethics with concrete examples111.  

With the adoption of the new law on lobbying, significant progress was made regarding 
the introduction of comprehensive legislation in this area. The 2023 Rule of Law Report 
recommended Croatia to ‘adopt comprehensive legislation in the area of lobbying, including 
on persons with top executive positions, and set up a public register of lobbyists’112. The law 
on lobbying was adopted on 14 March 2024 and will enter into force on 1 October 2024. It 
regulates  lobbying,  the  organisation,  content  and  manner  of  keeping  a  lobby  register, 
restrictions  on  lobby  activities  and  sets  rules  on  the  verification,  enforcement  and  penalties 

105  Information received from the Parliament Secretariat in the context of the country visit to Croatia. Violations 
of the Code of Ethics are not subject to sanctions. According to information received from the Parliamentary 
National  Council  for  Monitoring  Anti-corruption  Strategy  Implementation  in  the  context  of  the  visit  to 
Croatia, the Code lacks effectiveness as it does not contain clear obligations or means of enforcement. 

106  For more details, see 2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 
16-17. The Recovery and Resilience Plan contains a milestone which requires Croatia to adopt the code of 
ethics  for  parliamentarians  and  a  code  of  ethics  for  officials  in  the  executive  bodies.  See  the  Council 
Implementing  Decision of  28  July 2021 on  the  approval of  the  assessment  of  the  Recovery  and  resilience 
plan  for  Croatia,  Milestone  234.  The  Commission  found  the  milestone  to  be  satisfactorily  fulfilled  on  12 
June 2024. Communication to the Commission on the positive preliminary assessment of the fifth payment 
request of Republic of Croatia pursuant to Regulation (EU) 2021/241, C(2024) 4170 final. 

107  As of March 2024, 17 out of 89 officials covered by the Code did not undergo the first training provided by 
the Council. The Council implemented its rules of procedure and became operational in April 2023. It can 
provide an opinion at the request of the official, its immediate superior, or at the request of the Office of the 
Prime  Minister. Between July 2023 and February 2024, the Implementation Council held four information 
sessions with subjects of the Code of Conduct about its purpose and application, their obligations as well as 
the  role  of  the  Implementation  Council.  Information  received  from  the  Implementation  Council  in  the 
context of the country visit to Croatia. 

108  Information received  from  the  Ministry  of  Justice  and  Public Administration  in  the  context  of  the  country 

visit to Croatia. 

109  Information received from the CRC in the context of the country visit to Croatia. In 2023, the Commission 
made, both in public and close meetings, 226 decisions to initiate procedures (56 in 2022), 102 decisions not 
to initiate a procedure (51 in 2022), and reached 204 final decisions (59 in 2022).  

110  Input from Croatia for the 2024 Rule of Law Report, pp. 21-22.  
111  Input from Croatia for the 2024 Rule of Law Report, pp. 21-22, update 2 April 2024, p. 4.  
112  2023 and 2022 Rule of Law Reports, Country Chapter on the rule of law situation in Croatia, p. 2. 

17 

 
 
for violations of the law. An electronic lobby register is to be managed by the CRC, which 
will be reinforced with five staff. The CRC is to maintain a temporary register until the end of 
2024 with existing tools and resources113. The register will contain data on the lobbyists and 
not on the meetings that took place. Lobbyists are required to report annually to the CRC on 
their activities, including who they meet, but they will not be made public. Lobbied persons 
must  disclose  important  meetings  with  third  parties  through  the  website  of  the  authority  in 
which  the  official  holds  office,  and  through  social  networks114.  The  law  prohibits  the 
lobbying  of  public  bodies  by  a  person  who  held  office  in  that  body  for  18  months  upon 
termination of office. This cooling-off period is limited to managerial positions and to legal 
persons with which the body had a business relationship or conducted supervisory functions 
over  it  during  their  term  of  office115.  Therefore,  there  has  been  significant  progress  on  the 
implementation of the recommendation made in previous years.  

The State Electoral Commission and State Audit Office encountered fewer irregularities 
in the implementation of political party financing rules.  Political actors116 are obliged to 
submit their financial reports, which are made available online on the web-page of the State 
Electoral  Commission117.  The  State  Electoral  Commission  informed  the  State  Attorney’s 
Office of 71 cases where political actors had not submitted the annual accounts for 2022 (248 
for  2021,  194  for  2020)  and  decided  in  41  cases  (61  for  2021,  40  for  2020)  to  temporarily 
suspend the disbursement of the funds. It issued 29 decisions (50 for 2021) on forfeiture of 
the payment of part of the funds for regular annual funding because these 27 individuals and 
2 parties did not submit by the end of 2023 the annual accounts for 2022118. In 2022, the State 
Audit Office carried out financial audits of 48 political parties (5 less than the previous year) 
and  5  independent  representatives,  for  which  it  issued  266  recommendations  regarding 
irregularities (350 in 2021)119. However, as in previous years, less than half of the State Audit 

113  Information received from the Ministry of Justice and Public Administration and the CRC in the context of 

the country visit to Croatia.  

114  The  Code  of  Conduct  for  State  Officials  in  Executive  Bodies  does  not  define  precisely  what  ‘important 
meetings’ are, leaving it to the discretion of the reporting person, which could lead to the situation in which 
the public and anti-corruption authorities do not have a complete overview of contacts with lobbyists. The 
OECD guidelines on lobbying, as revised in 2024, recommend making publicly available online and easily 
accessible,  in  an  open  data  format  that  is  reusable  for  public  scrutiny,  timely,  comprehensive  and  detailed 
information on all lobbying activities.  

115  Article 23 of the Law on Prevention of Conflicts of Interest prohibits the legal person to appoint or employ 

the public official within the same time-frame.    

116  Political  actors  are  political  parties,  independent  representatives  and  members  of  representative  bodies  of 

local and regional self-government units elected from a list of a group of voters. 

117  2022 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 16-17. 
118  Annual  reports  of  2021  and  2022  of  the  State  Electoral  Commission,  published  on  5  January  2023  and  8 
January  2024. The decrease  could  be  explained by  the  awareness-raising  activities  on  the  applicable  rules 
and the fact that political actors are getting more used to the online application; information received from 
the Ministry of Justice and Public Administration in the context of the country visit to Croatia.  

119  The State Audit Office informs the State Attorney's Office and submits all documentation on all established 
violations of the Law. The State Audit Office had again a decrease in the number of employees compared to 
the  previous year, mostly due to retirement (with 296 employees in total in 2022, and 282 in 2023). They 
were able to hire 5 new employees through transfer because the foreseen 20 posts were blocked by Decision 
of the Government which prohibited new employment in all state administration bodies. In 2024, the State 
Audit Office could hire 15 more employees. Information received from the State Audit Office in the context 
of the country visit to Croatia. 

18 

 
 
Office’s recommendations from 2021 had been implemented by the authorities to which they 
were addressed by the end of 2022120. 

Croatia is raising awareness about the new whistleblower legislation. With the revision of 
the law in 2022, more irregularities were reported that year to the Ombudsperson121. Both the 
number of external and internal reports stabilised in 2023122. In January 2024, Croatia started, 
a  national  media  campaign  to  raise  awareness  of  existing  anti-corruption  mechanisms, 
including  protection mechanisms for persons reporting irregularities and the harmfulness of 
corruption123.  The  Ombudsperson’s  Office  held  three  training  courses  for  judges  and 
prosecutors  on  the  application  of  the  2022  Law  and  a  guide  on  whistleblowing  will  be 
published in the first half of 2024. In 2023, the Office organised two workshops for persons 
designated to receive reports (“confidential persons”) and their deputies124. New rules on the 
method of providing emotional support to whistleblowers were adopted in September 2023, 
which govern how to provide emotional support to whistleblowers and other persons entitled 
to it under the Law125. 

Some  measures  have  been  taken  to  detect  and  prevent  corruption  in  public 
procurement, which remains a high-risk area of corruption. The Flash Eurobarometer on 
Businesses’ attitudes towards corruption in the EU shows that 21% of companies in Croatia 
(EU average 27%, last year 26%) think that corruption has prevented them from winning  a 
public  tender  or  a  public  procurement  contract  in  practice  in  the  last  three  years126.  Media 
reports about alleged irregularities in public procurement continued, including on the practice 
of  fraudulent  competing  bids  and  artificial  splitting  of  public  contracts127.  Police  and  state 

120  Information received from the State Audit Office in the context of the country visit to Croatia. Reports  are 

available on https://www.revizija.hr/.  

121  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 18.  
122  57  external  reports  in  2023,  compared  to  53  in  2022,  and  38  internal  reports  in  2023,  compared  to  37  in 
2022; the private sector seems to use more internal reporting whereas the public sector tends to make more 
external reports directly to the Ombudsperson. People’s Ombudsperson, 2023 Report,  29 March 2024, pp. 
231 and 234, and information received from the Ombudsperson in the context of the country visit to Croatia.  
123  The campaign includes the organisation of a conference and other events on a topic in this field, roundtables 
for  central  and  local  government  officials  and  representatives  of  NGOs. As  part  of  the  campaign,  during 
January 2024, education on preventing corruption was held in 15 high schools in Zagreb, Split, Rijeka and 
Osijek.  Input  from  Croatia  for  the  2024  Rule  of  Law  Report,  p.  24  and  p.  51.  Croatia’s  Recovery  and 
Resilience  Plan  contains  a  milestone  which  requires  Croatia  to  evaluate  the  effects  of  the  national 
information campaign against corruption by end June 2025. See the Council Implementing Decision of 28 
July 2021 on the approval of the assessment of the recovery and resilience plan for Croatia, Milestone 239. 
The milestone is part of the eighth payment request, which is not yet due to be assessed by the Commission. 
hence it has not yet been assessed by the Commission 

124  Input from Croatia for the 2024 Rule of Law Report, p. 24. The analysis of the implementation of the Law 
on the Protection of Persons who report Irregularities in State-owned Legal Persons showed that respondents 
mainly called for further education of persons designated to receive reports and for awareness raising on the 
necessity of reporting irregularities among staff and on their rights as whistleblowers. Information received 
from the Ministry of Justice and Public Administration in the context of the country visit to Croatia. 

125  An  external  company  was  procured  in  June  2024  to  implement  the  legislation  on  emotional  support  to 
whistleblowers. The support should be operational soon after initial training for the providers on the relevant 
legislation. Information received from the Ministry of Justice and Public Administration in the context of the 
country visit to Croatia.   

126  Flash Eurobarometer 543 on Businesses’ attitudes towards corruption in the EU (2024).  
127  Forbes,  “How  to  fix  the  public  procurement  system,  through  which  10  billion  euros  pass  annually?”,  23 

February 2024. 

19 

 
 
attorneys  continued  to  identify  public  procurement,  the  energy  sector128,  and  regional  and 
local  government  authorities  as  sectors  with  a  high  risk  of  corruption,  which  are  by  their 
nature  also  more  difficult  to  investigate.  A  new  central  IT  system  (e-HZZO)  is  operational 
from  June  2024,  which  will  increase  supervision  within  the  health  system,  particularly 
regarding the management and monitoring of the flow of funding in line with the healthcare 
services  provided  and  the  monitoring  of  waiting  lists129.  The  State  Commission  for  the 
Supervision  of  Public  Procurement  Procedures  (DKOM)  continued  reviewing  appeals 
regarding  decisions  on  public  procurement  procedures  in  its  role  as  an  independent 
tribunal130.  Its  financial  resources  increased  in  2024  approximately  by  10%.  The  mandate 
expired for two out of nine members (of which one deputy president in September 2023) and 
Parliament has not appointed new members yet131. As a result, out of three councils solving 
appeals  only  two  councils  are  operational.  This  may  affect  average  time  needed  to  address 
appeals in the future. However, the number of appeals decreased further to 712 in 2023 (885 
in  2022)  and 
the  “e-appeal  system”,  operational  since  2023,  has  reduced  paper 
communication  and  sped  up  the  procedure  in  general.  This  led  to  a  further  decrease  of  the 
share of public procurement procedures reviewed by the State Commission to only 3,6% of 
all  published  procedures  in  2023  (down  from  4,8%  in  2022,  6,8%  in  2021  and  7,2%  in 
2020)132.  Among  the  likely  reasons  for  this  situation,  the  increase  of  the  review  fees  in 
October  2022  has  been  mentioned,  when  it  also  became  mandatory  to  introduce  appeals 
electronically133.  

128  As  an  example  of  a  trend  of  high-profile  cases  in  the  recent  years,  in  July  2023,  USKOK  entered  the 
premises  of  Hrvatska  Elektroprivreda  (HEP),  the  national  power  company,  because  it  was  discovered  that 
HEP  was  buying  gas  at  higher  prices  and  selling  it  cheaply.  Index,  Investigation  into  HEP  because  of  the 
huge gas affair, 11 July 2023. In 2023 Rule of Law Report, Country Chapter on the rule of law situation in 
Croatia,  p.  13,  alleged  criminal  offences  involving  the  energy  companies  INA  (involving  damage  of  EUR 
133 million) and JANAF were mentioned.   

129  Input from Croatia for the 2023 Rule of Law Report, p. 26. 
130  State  Commission  for  Supervision  of  Public  Procurement  Procedures  is  not  responsible  for  ex-post 
monitoring  of  the  implementation  of  the  public  procurement.  It  also  does  not  supervise  situations  where 
public procurement procedures were not used. In 2024, media reported on a case where the Director of HRT, 
the  public  service  media,  awarded  EUR  717 000  to  his  former  company  without  any  public  procurement 
procedure, despite the Commission for Resolution of Conflicts of Interests warning of a high corruption risk.  
131  Candidates  have  been  interviewed,  but  the  Government  made  no  proposal  for  appointment  to  Parliament. 
Information  received  from  DKOM  in  the  context  of  the  country  visit  to  Croatia.  The  2022  Rule  of  Law 
Report  found  that  safeguards  for  the  State  Commission’s  independence,  particularly  regarding  the 
appointment  and  discipline  of  the  members  of  the  State  Commission,  could  be  further  improved.  In  the 
current  system,  candidates  are  proposed  for  appointment  to  Parliament  by  the  Government  following  a 
public vacancy, without the involvement of an independent body. Parliament is also responsible for potential 
disciplinary  measures.  Recommendation  CM/Rec(2010)12  of  the  Council  of  Ministers  of  the  Council  of 
Europe, paras. 66 and 69. According to EU law, the requirement of independence means that the disciplinary 
regime regarding judges must display the necessary guarantees in order to prevent that the regime is used as 
a system of political control of the content of judicial decisions. 

132  Written contribution from DKOM following the country visit to Croatia. 2023 Rule of Law Report, Country 

Report on the rule of law situation in Croatia, p. 19. 

133  Information received from DKOM in the context of the country visit to Croatia. 

20 

 
 
 
 
III.  MEDIA PLURALISM AND MEDIA FREEDOM 

The Croatian legal framework on media freedom and pluralism and the access to information 
is based on the Constitution and sectoral  legislation134. This includes notably the Electronic 
Media Act, last revised in 2021, and the Media Act, the revision of which has been expected 
for some time. In December 2023, a National Plan for the Development of Culture and Media 
for the period from 2023 to 2027 was adopted135, including among its objectives the overall 
improvement  of  the  situation  of  journalists  and  media,  fostering  pluralism,  and  providing 
effective support to the media sector. The plan  was accompanied by an Action Plan for the 
Development  of  Culture  and  Media  for  the  period  from  2023  until  2024136  proposing 
measures in support of these objectives.137.  

The  Agency for Electronic Media  enjoys independent financing but there are calls for 
changes to its appointment process to further strengthen its independence. The Agency 
for Electronic Media continues to play a major role in managing funds for the promotion of 
media pluralism. While the independent financing of the agency remains ensured, observers 
and stakeholders continue to doubt  the political  independence of the Council for Electronic 
Media, considering its appointment by the parliamentary majority138. Longstanding calls by 
the 
journalist  associations,  supported  by  civil  society  stakeholders, 
independence of the Agency and its Council continue139; this is done also in the light of plans 
to establish a joint independent media regulator for electronic media and the press, which is 
currently  not  regulated  by  the  Agency  for  Electronic  Media140.  The  2024  Media  Pluralism 
Monitor indicator on the independence and effectiveness of the media authority continues to 
indicate a medium risk141. 

to  strengthen 

While  media  ownership  information  is  publicly  available,  some  challenges  remain  as 
regards  transparency  of  beneficial  ownership.  While  the  revised  Electronic  Media  Act 
requires  that  ownership  information  of  electronic  media  publications  be  made  publicly 
available via the registry of the Agency for Electronic Media, reports point to gaps regarding 
the coverage of the registry142. In addition, stakeholders continue to point out that in certain 
cases the underlying ownership structures of media may remain hidden, notwithstanding the 
requirement  of  the  Electronic  Media  Act  to  back-up  the  information  in  the  registry  with 
extracts  from  the  register  of  ultimate  beneficial  ownership143.  The  2024  Media  Pluralism 

134  Article 38 of the Croatian Constitution. 
135  National Plan for the Development of Culture and Media for the period from 2023 to 2027. 
136  Action Plan for the Development of Culture and Media for the period from 2023 until 2024. 
137  Croatian Journalists’ Association, Working document of new Media Act  – unacceptable; Contribution from 
the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 19. Croatia ranks 48 th in the 2024 
Reporters without Borders World Press Freedom Index compared to 42nd in the previous year. 

138  Euromedia Ownership Monitor, Croatia - Country report 2023. Contribution from the Civil Liberties Union 

for Europe for the 2024 Rule of Law Report, pp. 17-18. 

139  Croatian Journalists’ Association, Working document of new Media Act  – unacceptable; Contribution from 
the Human Rights House Zagreb and Centre for Democracy and Law Miko Tripalo, pp. 12-13; Contribution 
from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, pp. 17-18.  
140  Action Plan for the Development of Culture and Media for the period from 2023 until 2024. 
141  2024 Media Pluralism Monitor, pp. 12-13. 
142  Euromedia Ownership Monitor (2023), Croatia - Country report 2023; Contribution from the Human Rights 
House  Zagreb and Centre for Democracy and Law  Miko Tripalo for the 2024 Rule of Law  Report,  p. 14; 
Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 20.  

143  Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 20. Information 

received from the Croatian Journalists’ Association in the context of the country visit to Croatia. 

21 

 
 
Monitor continues to indicate a medium risk for the transparency of media ownership, as in 
the previous year144. Under the Recovery and Resilience Plan the Government has committed 
to set up an information system to publish information on ownership of all types of media in 
a single register145. The project has been launched by the Agency for Electronic Media and is 
currently  in  development146.  The  rules  on  media  concentration  remain  the  same  since  the 
2022 Rule of Law Report147. 

The framework for a fair and transparent allocation of state advertising raises concerns 
and  there  has  been  no  progress  to  strengthen  it.  The  2023  Rule  of  Law  Report 
recommended  Croatia  to  ‘advance  with  strengthening  the  framework  for  a  fair  and 
transparent  allocation  of  state  advertising,  by  establishing  clear  criteria,  good  practices  and 
oversight measures to guarantee the effective functioning of the public tender procedure for 
local  and regional media’148.  Based on the latest available data covering the year 2022, the 
register  of  the  Agency  for  Electronic  Media  on  funds  spent  under  this  provision  includes 
information from 41 public authorities and institutions as well as predominately state-owned 
companies, which is indicating substantial gaps in the reporting by the concerned entities149. 
While the law requires such funds to be distributed based on a public call including relevant 
criteria,  it  does  not  specify  these  criteria  or  any  procedural  safeguards150.  Since  the 
introduction  of  the  provision  in  2021,  concerns  have  been  raised  by  stakeholders  regarding 
the fair and transparent  allocation of the concerned funds151. They often refer to close links 

144  2024 Media Pluralism Monitor, p. 14. 
145  Currently, ownership information for audiovisual and digital media is available via a public register managed 
by the Agency for Electronic Media, while the information for print media is gathered by the Chamber of 
Commerce.  The  Council  adopted  Council  Implementing  Decision  of  28  July  2021  on  the  approval  of  the 
assessment of the recovery and resilience plan for Croatia, under which the Milestone no. 27 states: ‘[…] a 
system of media fact-checking shall be set up by the Electronic Media Agency, including the development of 
procedures and rules, the creation of registers and the strengthening of the digital competence capacities of 
fact-checkers,  as  well  as 
technological  programmes,  platforms  and  media 
communication  systems  […]’.  The  milestone  is  part  of  the  tenth  payment  request  and  has  not  yet  been 
assessed by the Commission. 

the  development  of 

146  Information received from the Agency for Electronic Media in the context of the country visit to Croatia. 
147  As reported in the 2022 Rule of Law Report, the revision of the Electronic Media Act ended the prohibition 
of  vertical  concentration  between  broadcasters  and  operators. A  provider  of  media  services  and  electronic 
publications whose total annual revenue has reached 40% of all providers is considered to have reached a 
dominant  role  in  the  market,  and  is  then  prohibited  amongst  others  from  acquiring  new  licences  or 
concessions and launching new electronic publications. 2022 Rule of Law Report, Country Chapter on the 
rule of law situation in Croatia, pp. 19-20. 

148  2023  and  2022  Rule  of  Law  Reports,  Country  Chapter  on  the  rule  of  law  situation  in  Croatia,  p.  2.  The 
referred procedure was introduced by the amendments to the Electronic Media Act in 2021 as an addition to 
the  requirement  for  public  authorities  and  institutions  as  well  as  predominately  state-owned  companies  to 
spend a minimum of 15% of their annual funds earmarked for the promotion of their services or activities for 
advertising in regional or local television or radio programmes or electronic publications. In the 2023 Rule 
of Law Report, the Commission concluded that no further progress was made on the implementation of the 
recommendation. 2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 21-
22. 

149  Taking into consideration that for 2020 and 2021 the register contained respectively 123 and 188 entries and 
that the overall number of potentially concerned entities is assumed to be around 1 180. Information received 
from the Agency for Electronic Media in the context of the country visit to Croatia. 
150  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 21. 
151  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 21-22; Information 
received from the Croatian Newspaper Publishers’ Association, the Trade Union of Croatian Journalists and 
the  Croatian  Journalists’ Association  in  the  context  of  the  country  visit  to  Croatia;  Contribution  from  the 

22 

 
 
 
between  local  governments  and  regional  or  local  media  and  the  lack  of  independent  and 
critical coverage at local level because of the strong financial dependency of such media on 
state advertising152. In this context, clear criteria, good practices and oversight measures are 
missing to guarantee the effective and transparent functioning of the allocation procedure153. 
Furthermore,  stakeholders  continue  to  see  concerns  regarding  the  allocation  of  state 
advertising  to  media  outlets  at  national  level154.  In  this  regard,  the  Euromedia  Ownership 
Monitor report points to a lack of transparency concerning state advertising practices around 
conferences  organised  by  ministries  and  government  agencies  and  the  related  media 
coverage155.  In  January  2024,  a  criminal  investigation  into  an  alleged  case  of  corruption 
involving  a  public  official  allegedly  misusing  advertising  funds  led  to  the  dismissal  of  that 
official  and  the  relevant  Minister156.  While  the  investigation  is  ongoing157,  stakeholders 
expressed concern that this may not be an isolated case158, raising further questions regarding 
the  fair  and  transparent  allocation  of  state  advertising.  While  certain  municipalities  are 
reported  to  have  adopted  good  practices  suggested  by  journalist  representatives  to  ensure 
objective and transparent procedures under the public tender procedure159, no measures were 
taken  by  the  Government  regarding  the  fair  allocation  of  state  advertising.  Therefore,  there 
has  been  no  progress  on  the  implementation  of  the  recommendation  made  in  the  previous 
years. 

Public service broadcaster HRT faces criticism regarding potential conflicts of interests 
and the perceived lack of political independence. An internal HRT audit conducted in 2023 
found  substantial  irregularities  regarding  its  business  with  an  external  service  provider160, 
raising  questions  as  regards  the  administration  and  accountability  of  the  public  service 
broadcaster161. The conduct of business with the external service provider was subject to two 

Human Rights House Zagreb and Centre for Democracy and Law Miko Tripalo for the 2024 Rule of Law 
Report, p. 14.  

152  Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 26; Osservatorio 

Balcani Caucaso Transeuropa (2024), Croatia, the assault on the local press.  

153  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, pp. 21-22. 
154  Information  received  from  GONG  in  the  context  of  the  country  visit  to  Croatia;  Contribution  from  the 
Human Rights House Zagreb and Centre for Democracy and Law Miko Tripalo for the 2024 Rule of Law 
Report, pp. 13-14; 2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 22. 

155  Euromedia Ownership Monitor (2023), Croatia - Country report 2023. 
156  In  the  case,  the  official,  adviser  to  a  minister,  allegedly  offered  to  allocate  advertising  funds  from  state 
owned companies to a media company in return for a part of the advertising money. Telegram (2024), This is 
unreal. Media racket exposed, and the Government assures the EU that state advertising in the media is great 
for us.  

157  USKOK  (2024),  An  investigation  was  launched  against  the  defendant  due  to  suspicion  of  “extracting” 

money from a TV station. 

158  Information received from the Trade Union of Croatian Journalists and the Croatian Journalists’ Association 
in the context of the country visit to Croatia; Contribution from the Human Rights House Zagreb and Centre 
for Democracy and Law Miko Tripalo for the 2024 Rule of Law Report, p. 13. 

159  Osservatorio Balcani Caucaso Transeuropa (2024), Croatia, the assault on the local press.  
160  The internal audit was requested in April 2023 by the HRT Supervisory Board and in September 2023, the 
State Attorney’s Office started an investigation on the basis of its findings. Telegram (2024), ‘We came to a 
scandalous audit finding on HRT: they illegally pay out millions and declare it a business secret’.  

161  According to reports, HRT had continued to award contracts to the former company of its Director General 
without public tender, setting aside internal advice regarding a potential conflict of interest. Telegram (2024), 
‘We bring a discovery that would make the entire administration fly in every regulated country: HRT paid 
1.25 million euros to the former company of its boss without a tender’; Telegram (2024), ‘Fantastic HRT. 
The  supervisory  board  confirmed  Telegram’s  scandalous  revelations  about  director  Šveb  but  blamed  the 
former administration for everything’. 

23 

 
 
opinions  of  the  Commission  for  Conflict  of  Interests  (CRC)162.  In  March  2024,  in  another 
case, the CRC fined the HRT Director General for irregularities in payments concerning the 
Director General himself163. Regarding the financing of HRT, the public service broadcaster 
is predominantly financed by a monthly fee collected from households164. In December 2023, 
the  Government  and  HRT  agreed  on  an  annex  on  the  HRT  programming  for  2023-2027  to 
close gaps  in  the  financing of HRT with  additional  funding from  the state budget165. There 
continue  to  be  some  concerns  regarding  the  political  independence  of  HRT  as  the  existing 
framework  gives  the  parliamentary  majority  a  strong  influence  over  the  public  service 
broadcaster166.  The  2024  Media  Pluralism  Monitor  indicator  on  the  independence  of  public 
service media shows a medium risk167. 

Certain  delays  persist  regarding  access  to  information  and public  documents,  and  the 
processing  of  requests  from  journalists.  The  legal  framework  ensuring  access  to 
information  and  public  documents  is  in  place168.  As  reported  in  previous  Rule  of  Law 
Reports,  stakeholders  point  to  delays  in  the  processing  of  requests  by  public  authorities  in 
certain cases169. In 2023, 24 complaints and 30 appeals from journalists concerning access to 
information were received by the Office of the Information Commissioner170. The Office of 
the  Information  Commissioner  continues  its  activities  to  raise  awareness  among  journalists 
on  the  rules  and  procedures  in  place.  The  2024  Media  Pluralism  Monitor  indicator  on  the 
protection of the right to information shows a medium risk171.  

Authorities and journalists’ representatives have concluded a cooperation agreement to 
further improve the safety of journalists. Since the 2023 Rule of Law Report, the Council 
of  Europe’s  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  has 
registered  seven  alerts  relating  to  events  in  Croatia,  and  the  Mapping  Media  Freedom 
platform  –  17  alerts172.  Overall,  journalist  representatives  continue  to  consider  that  police 

162  The CRC assessed the conditions under which the HRT Director General could approve business contracts 
with an external service provider, a media company, which he used to co-own. CRC, Opinion M-136-21, 29 
October 2021; CRC, Opinion M-19-22, 21 January 2022. 

163  Telegram (2024), ‘The Commission for Conflict of Interest confirmed Telegram's discovery: the scandalous 

head of HRT paid himself fees that did not belong to him’. 

164  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 22.  
165  Annex to the contract between HRT and the Republic of Croatia for the period from 1 January 2023 to 31 

December 2027; Information received from HRT in the context of the country visit to Croatia. 
166  Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, pp. 22-23. 
167  2024 Media Pluralism Monitor, p. 20. 
168  Changes  to  the  Right  to Access  Information Act  entered  into  force  in  June  2022,  aiming  to  improve  and 
harmonise  practices  concerning  requests  for  access  to  information.  In  addition,  specific  provisions 
concerning journalists are included in the Media Act. See 2023 Rule of Law Report, Country Chapter on the 
rule of law situation in Croatia, p. 23.  

169  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 23. Contribution from 
the Croatian Journalists’ Association to the 2024 Rule of Law Report, p. 22; Contribution from the Human 
Rights House Zagreb and Centre for Democracy and Law Miko Tripalo for the 2024 Rule of Law Report, p. 
15. 

170  Information  Commissioner,  Report  for  2023,  pp.  15  and  51.  In  2022,  there  were  23  complaints  and  43 

appeals from journalists. Information Commissioner, Report for 2022, pp. 20 and 72. 

171  2024 Media Pluralism Monitor, p. 12. 
172  Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists,  Croatia. 
Mapping Media Freedom, Croatia (as of 25 June 2023). Including in relation to verbal attacks by politicians 
against journalists and media outlets as well as physical attacks and threats. Mapping Media Freedom (2023) 
and (2024); Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 29. 

24 

 
 
authorities  react  appropriately  in  cases  of  attacks  or  threats  against  journalists173.  In 
September  2023,  the  Ministry  of  the  Interior  signed  an  agreement  with  the  Croatian 
Journalists’  Association  and  the  Croatian  Journalists’  Union  on  the  cooperation  of  police 
authorities  and  journalists174.  The  objective  of  the  agreement  is  to  foster  mutual 
understanding,  and to  ensure a safe  environment  for journalists, particularly when  covering 
public events or protests. The agreement is accompanied by two implementing protocols: one 
on the behaviour of the police, journalists, and media workers at public gatherings175, and the 
other  on  the  behaviour  of  the  police  in  the  context  of  criminal  offences  committed  against 
journalists and other media workers in connection with the performance of media activities. 
While  the  practical  impact  of  these  protocols  will  need  to  be  established  over  time,  they 
highlight  the  willingness  of  the  authorities  and  journalists’  representatives  to  improve  the 
safety of journalists.  

Although  journalists  are  exempt  from  the  offence  of  disclosure  of  information  from 
ongoing  criminal  investigations,  there  is  still  strong  criticism  from  stakeholders,  and 
efforts  continue  to  be  made  to  address  it.  In  June  2023,  the  Government  submitted 
amendments to the Criminal Code to Parliament to introduce a criminal offence regarding the 
unauthorised  disclosure  of  information  from  ongoing  criminal  investigations176.  The 
Government considered these changes necessary to prevent leaks from investigations during 
non-public  pre-trial  procedures177.  Journalist  associations  and  other  stakeholders  strongly 
criticised  these  plans,  voicing  concerns  that  the  proposed  changes  would  risk  impacting 
investigative journalism and more generally the free media coverage of important matters of 
public  interest,  such  as  corruption  cases178.  Moreover,  concerns  were  raised  that  the  new 
criminal offence could expose journalists to investigations and risk impacting the protection 
of  journalistic  sources179.  As  a  reaction,  at  the  beginning  of  2024,  the  amendments  were 
further revised to expressly exempt journalists and disclosures that are predominantly in the 
public interest from the scope of the new criminal offence180. Notwithstanding these changes 
to  the  draft,  journalists’  representatives  continued  to  express  criticism  of  the  amendments 
based on the potential implications for journalists181. On 14 March 2024, Parliament adopted 

173  Information received from the Croatian Journalists’ Association in the context of the country visit to Croatia. 
174  Written contribution from the Ministry of Culture in the context of country visit to Croatia. 
175  The objective of the protocol is to improve the mutual cooperation between the police, journalists and other 
media  professionals  in  the  context  of  public  gatherings,  notably  by  improving  communications  and 
establishing a specific space for media professionals at such gatherings.  

176  Input from Croatia for the 2024 Rule of Law Report, pp. 36-37. 
177  Input from Croatia for the 2024 Rule of Law Report, p. 38. 
178  Croatian  Journalists’  Association  (2023),  Croatian  Government  proposes  a  law  of  dangerous  intentions; 
Information received from the Croatian Newspaper Publishers’ Association and civil society organisations in 
the context of the country visit to Croatia. 

179  Croatian  Journalists’  Association  (2023),  Public  consultation:  HND  strongly  opposes  Article  307a  of  the 

Criminal Code. 

180  Paragraph 2 of the proposed Article 307a of the Criminal Code, expressly stipulates that a person performing 
journalistic  work  cannot  be  neither  the  perpetrator  nor  the  participant  (persons  who  aid  or  abet)  in  the 
commission  of  the  criminal  offense  referred  to  in  paragraph  1  of  that Article, Additionally,  on  14  March 
2024, Parliament adopted amendments to the Code on Criminal Procedure which, among others, prescribe 
the obligation to warn all participants in a criminal case that the unauthorised disclosure of the content of an 
inquiry  and  evidentiary  actions  carried  out  during  non-public  pre-trial  procedures  constitutes  a  criminal 
offence. Input from Croatia for the 2024 Rule of Law Report, pp. 37-38. 

181  Croatian Journalists’ Association (2024), HND’s open letter to citizens about the dangers of changes to the 
Criminal  Code.  The  letter  was  co-signed  by  the  editors  of  19  Croatian  media  outlets.  Free  speech 
organisation “Article 19” stated that the amendments represent a disproportionate interference with freedom 

25 

 
 
 
the  amendments  to  the  Criminal  Code,  which  exempted  journalists  and  included  a  public 
interest  exemption.  Envisaged  amendments  of  State  Attorney’s  Office  Act  would  in  more 
detail  elaborate the provisions  on communication by the state attorney's  offices on cases  of 
public interest in accordance with the recommendations of the Council of Europe182.  

There  was  some  further  progress  on  addressing  the  issue  of  strategic  lawsuits  against 
public  participation  (SLAPPs)  targeting  journalists,  with  improved  awareness  of  the 
issue.  The  2023  Rule  of  Law  Report  recommended  Croatia  to  ‘[m]ake  further  efforts  to 
address  the  issue  of  strategic  lawsuits  against  public  participation  targeted  at  journalists, 
including  by  reviewing  the  legal  provisions  on  defamation  and  encouraging  wider  use  of 
procedural rules that allow dismissing groundless lawsuits, taking into account the European 
standards  on  the  protection  of  journalists’183.  A  survey  conducted  among  media  by  the 
Croatian Journalists’ Association in 2024 counted 752 active lawsuits against journalists and 
the media in Croatia (compared to 945 in 2023, 951 in 2022 and 905 in 2020)184. While it is 
difficult to compile exact statistics and not all of these cases may qualify as SLAPPs, the data 
show  that  lawsuits  against  journalists  continue  to  be  an  issue185.  In  May  2024,  preliminary 
results  of  a  new  granular  research  which  examined  at  more  than  1 333  court  judgments 
involving journalists, found that more than 40% fulfilled at least one criterion for SLAPP186. 
It  also  found  that  civil  court  proceedings  in  which  relatively  high  damages  were  sought 
prevailed187.  At  the  same  time,  the  number  of  new  or  prominent  cases  seems  to  have 
decreased, providing some signs of improvement188. An analysis of  the Ministry of Justice, 
Public  Administration  and  Digital  Transformation  of  civil  and  criminal  cases  for  2023 
showed  that  out  of  the  total  number  of  cases  closed  in  2023,  the  SLAPP  actions  could  be 
subject to 39 cases of which 8 criminal cases and 31 civil cases. Out of the 31 civil cases, 12 

of  expression  and  media  freedom.  Article  19,  Press  release:  “Croatia:  Scrap  plan  to  criminally  penalise 
disclosure of ‘non-public’ information”, 13 June 2024. 

182  Written contribution from the Ministry of Justice, Public Administration and Digital Transformation in the 

context of the country visit to Croatia. 

183  2023 and 2022 Rule of Law Reports, Country Chapter on the rule of law situation in Croatia, p. 2. In the 
2023 Rule of Law Report, the Commission concluded that some progress was made on the implementation 
of the recommendation. 

184  21 media replied to the survey, while last year, when 945 active lawsuits were reported, 30 media replied. 
HND, Press release: ‘At least 752 active lawsuits weighing EUR 4.1 million, and in 1 333 cases adjudged – 
40% were pure SLAPP’, 24 May 2024;  2023  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Croatia, p. 24.  

185  Contribution from the Civil Liberties Union for Europe for the 2024 Rule of Law Report, p. 31. Coalition 
Against SLAPPs in Europe (2023), SLAPPS: A Threat to Democracy Continues to Grow. The mapping of 
the Coalition Against SLAPPs in Europe (CASE) indicated that Croatia is among the EU countries with a 
notable cases of SLAPP lawsuits (with one of the highest number of cases in relation to its population).  
186  The  research  covered  judgments  delivered  from  2016  to  2023.  Out  of  the  40%  indicated,  more  than  50% 
fulfilled  several  (more  than  one)  criteria  for  SLAPP.  Centre  for  Democracy  and  Law  Miko  Tripalo  and 
Croatian Journalists’ Association, Research Fighting SLAPP in Croatia, May 2024. 

187  In most cases, relatively high amounts were demanded: in half of the cases over EUR 5 000. By analysing 
court decisions, it was possible to identify the so-called "serial" plaintiffs, 12 of them, who frequently file 
lawsuits  against  the  media  and  journalists,  often  with  the  same  arguments.  The  length  of  civil  court 
proceedings  was  high:  1 326  days  on  average  (1 557  days  on  average  for  those  ending  with  a  judgment). 
According  to  the  same  research,  plaintiffs  often  initiate  multiple  civil  proceedings  against  the  same 
defendant/journalist,  and  sometimes,  in  addition  to  the  civil  proceedings,  they  also  initiate  criminal 
proceedings. Centre for Democracy and Law Miko Tripalo and  Croatian Journalists’ Association, Research 
Fighting SLAPP in Croatia, May 2024. 

188  Information received from the Trade Union of Croatian Journalists and the Croatian Journalists’ Association 

in the context of the country visit to Croatia. 

26 

 
 
were finally completed while others were non-final. Out of the 8 criminal cases, 6 are final 
and  2  are  non-final189.  The  expert  working  group  on  the  issue  of  SLAPPs  targeting 
journalists,  established  by  the  Ministry  of  Culture  and  Media  in  2021,  continues  to  raise 
awareness  on  the  topic190.  However,  there  have  been  no  changes  to  the  legal  framework  to 
address  the  issue.  Stakeholders  continue  to  see  a  need  to  decriminalise  defamation191.  The 
2024 Media Pluralism Monitor indicator on journalistic profession, standards, and protection 
indicator shows a high risk192. In its Action Plan for the Development of Culture and Media 
for  the  period  from  2023  until  2024,  the  Ministry  of  Culture  and  Media  lists  among  the 
envisaged measures a mechanism for the early recognition and dismissal of SLAPPs, which 
however has not yet been implemented193. Overall, only some further progress has been made 
on the implementation of the recommendation made in the 2023 Rule of Law Report. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Croatia  has  a  unicameral  parliamentary  system  of  government,  in  which  the  Constitutional 
Court  can  carry  out  ex-post  constitutional  reviews,  including  in  concrete  cases  based  on  a 
constitutional  complaint.  Draft  laws  can  be  tabled  by  any  member  of  Parliament  or  the 
Government.  The  People’s  Ombudsperson,  who  is  responsible  for  the  promotion  and 
protection of human rights  and freedoms and  fulfils the role of the National  Human Rights 
Institution,  the  Information  Commissioner,  and  the  Ombudsperson  for  Gender  Equality194, 
which fulfils the role of the equality body, are all independent bodies that play a role in the 
system of checks and balances.  

The  new  Law  on  Better  Regulation  introduced  a  comprehensive  overhaul  of  impact 
assessments  and  evaluations,  and  additional  standards  for  public  consultations.  On  15 
December 2023, Parliament adopted the Law on Better Regulation Policy Instruments, which 
entered  into  force  in  January  2024.  The  new  law  introduces  an  obligation  to  carry  out  a 
regulatory impact assessment for each legislative proposal with stipulated exceptions  to the 
procedure,  a  simplification  from  two-step  to  one-step  regulatory  impact  assessment 
procedure,  and  a  new  instrument  for  the  evaluation  of  regulations  (replacing  the  ex-post 
regulatory  impact  assessment)195.  The  law  also  sets  additional  standards  for  the  public 
consultation  process,  which  must  last  for  30  days  in  case  of  draft  laws  and,  based  on 
jurisprudence and practice, lists exemptions from the public consultations196. The 2023 Rule 

189  Written contribution from the Ministry of Justice, Public Administration and Digital Transformation in the 

context of the country visit to Croatia. 

190  Input from Croatia for the 2024 Rule of Law Report, p. 33. 
191  Information received from the Trade Union of Croatian Journalists and the Croatian Journalists’ Association 

in the context of the country visit to Croatia. 

192  2024 Media Pluralism Monitor, p. 12. 
193  Action  Plan  for  the  Development  of  Culture  and  Media  for  the  period  from  2023  until  2024.  Input  from 

Croatia for the 2024 Rule of Law Report, p. 33. 

194  It should be noted that the mandate of the Ombudsperson for Gender equality can be terminated if his/her 

annual report is rejected in the Parliament. 

195  Input from Croatia for the 2024 Rule of Law  Report,  p. 37. The  Recovery and Resilience Plan contains a 
milestone which requires Croatia to adopt amendments to the Act on Regulatory Impact Assessment. See the 
Council  Implementing  Decision  of  28  July  2021  on  the  approval  of  the  assessment  of  the  recovery  and 
resilience plan for Croatia, Milestone 151. The Commission found the milestone to be satisfactorily fulfilled 
on  12  June  2024.  Communication  to  the  Commission  on  the  positive  preliminary  assessment  of  the  fifth 
payment request of Republic of Croatia pursuant to Regulation (EU) 2021/241, C(2024) 4170 final. 

196  According  to  the  Government,  exceptions  to  the  obligation  to  carry  out  the  consultation  procedure  are 
provided  for  only  when  certain  types  of  legislation  are  adopted,  which  cannot  be  influenced  due  to  their 

27 

 
 
 
of Law Report found that in 2022, the number of public consultations via the e-Consultation 
portal increased significantly (to 1 028)197. In 2023, there were 822 consultations, which was 
similar to 2021 (823)198. The length of consultations increased to 21 days on average (19 in 
2022,  21  in  2021)199.  The  share  of  received  comments  that  remained  unanswered  is  still 
considerable  at  21% (22% in  2022, 7% in  2021)200. The  Public Ombudsperson  addressed  a 
recommendation  to  the  Government  authorities  to  provide  a  greater  number  of  reasoned 
replies to comments201. Civil society organisations stated that public consultations continue to 
be held pro forma, with only acknowledgement of the comments made by the public202. The 
quality of law-making and the frequent changes in legislation remain a significant cause for 
concern about the effectiveness of investment protection among companies in Croatia203. In 
December  2023,  the  project  to  upgrade  and  expand  the  e-Consultations  portal  to  local  and 
regional self-government units was concluded. The upgraded portal was launched on 16 May 
2024, opening the possibility for the local and regional self-government units to conduct their 
consultations via the portal. As regards the legislative process, the share of laws adopted by 
urgent  procedure  in  Parliament  has  decreased  to  26%,  the  lowest  level  in  more  than  a 
decade204. 

On  1  January  2024,  Croatia  had  27  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  an  increase  of  one  compared  to  the  previous 
year205.  At  that  time,  Croatia’s  rate  of  leading  judgments  from  the  past  10  years  that 

nature  or  by  the  reasons  for  their  adoption.  Input  from  Croatia  for  the  2024  Rule  of  Law  Report,  p.  37.  
On  15  February  2024,  the  Government  adopted  the  Regulation  setting  the  methodology  for  impact 
assessments, evaluating legislation, and conducting public consultations Croatian Government, Press release: 
Government  adopts  Regulation  for  implementing  the  Law  on  Better  Regulation  Policy  Instruments,  15 
February 2024. 
The Government Legislation Office conducted a number of workshops to assist in the implementation of the 
new law. Information received from the Government Legislation Office in the context of the country visit to 
Croatia. 

197  2023 Rule of Law Report, Country Chapter on the rule of law situation in Croatia, p. 25. 
198  Written contribution from the Government Legislation Office in the context of the country visit to Croatia. 
199  Information received from the Government Legislation Office in the context of the country visit to Croatia. 
200  In 2023, a total of 6 441 individuals and legal entities participated. Altogether, 325 representatives of civil 
society  organisation  took  part  in  public  consultations  and  submitted  2  314  comments  (out  of  total  19  931 
comments). Written contribution from the Government Legislation Office in the context of the country visit 
to Croatia. 

201  People’s Ombudsperson (2023), Report for 2022, 4 April 2023, p. 22, repeated in the Report for 2022, 29 

March 2024, p. 12. 

202  Written contribution prepared by the Human Rights House Zagreb and Centre for Democracy and Law Miko 
Tripalo with contributions from Croatian Journalist Association, Centre for Peace Studies, Rainbow Families 
Croatia, Zagreb Pride, Udruga RODA, Youth Initiative for Human Rights – Croatia, GONG, Green Action, 
DKolektiv, Center for peace, non-violence and human rights and Croatian Platform for International Citizen 
Solidarity-CROSOL in the context of the country visit to Croatia. 

203  In Croatia, 32% of companies perceive the frequent changes in legislation or concerns about quality of law-
making process as a reason for the lack of confidence in investment protection (compared to 30% in 2023). 
Figure  56,  2024  EU  Justice  Scoreboard.  According  to  the  2024  Survey  of  the  Business  Environment  in 
Croatia by the American Chamber of Commerce in Croatia, the quality of legislation is the third main area in 
which  respondents  noticed  the  biggest  deterioration  in  the  preceding  5  years  (32%  of  the  respondents). 
AmCham Croatia, Survey of the Business Environment in Croatia 2024, March 2024, p.8. 

204  In 2023, Parliament adopted 26% of laws using the urgent procedure (52% in 2022, 31% in 2021, 51% in 
2020,  47%  in  2019,  39  in  2018,  46%  in  2017,  77%  in  2016,  73%  in  2015,  and  81%  in  2014).  Written 
contribution from Parliament Secretariat Office in the context of the country visit to Croatia. 

205  The  adoption of necessary execution measures for a judgment by the European Court of Human Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 

28 

 
 
 
remained  pending  was  at  28%  (compared  to  29%  in  2023)  and  the  average  time  that  the 
judgments had been pending implementation was 3 years and 4 months (compared to 2 years 
and 8 months in 2023)206. As regards the respect of payment deadlines, on 31 December 2023 
there were 2 cases in total awaiting confirmation of payments (compared to 6 in 2022)207. On 
1  July  2024,  the  number  of  leading  judgments  pending  implementation  had  increased  to 
28208. 

New  Law  on  Administrative  Disputes  includes  measures  to  encourage  the  swift 
implementation  of  administrative  courts’  judgments.  On  14  March  2024,  Parliament 
adopted a new Law on Administrative Disputes, which is part of the Recovery and Resilience 
Plan209.  The  new  law  aims  to  encourage  a  more  proactive  approach  to  conducting 
administrative court trials, to improve procedural discipline of both parties and to shorten the 
length  of  proceedings.  To  this  end,  the  law  introduces  a  pilot-judgment  procedure  to  be 
applicable  when  in  five  or  more  first-instance  administrative  court  cases  the  subject  of  the 
claim  is  of  the  same  legal  and  factual  nature210.  Furthermore,  the  law  stipulates  a  new 
enforcement  procedure  when  state  authorities  refuse  to  implement  a  final  judgment  of  the 
administrative  court  or  implement  it  in  a  wrong  way.  In  this  special  procedure,  the 
administrative court would be able to fine the head of the administrative body with up to 30% 
of  annual  gross  salary  (approximately  EUR  5 000,  enforceable  via  the  Public  Payments 
Agency FINA) until the judgment is implemented or as a fine for wrong implementation211. 

Some  further  progress  was  made  on  the  follow-up  to  the  People’s  Ombudsperson’s 
recommendations,  while  challenges  on  access  to  information  remain.  The  Public 
Ombudsperson’s  Office  fulfils  the  role  of  the  National  Human  Rights  Institution  and  is 
accredited with A-status212. The 2023 Rule of Law Report recommended Croatia to ‘further 
improve  the  follow-up  to  recommendations  and  ensure  a  more  systematic  response  to 
information requests of the Ombudsperson’213. In October 2023, the Government’s Office for 
Human Rights and Minority Rights sent a questionnaire to all relevant authorities enquiring 
about  the  implementation  of  the  recommendations  from  the  Ombudsperson’s  report  for 

cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

206  All figures are calculated by the European Implementation Network and are based on the number of cases 
that  are  considered  pending  at  the  annual  cut-off  date  of  1  January  2024.  See  the  Contribution  from  the 
European Implementation Network for the 2024 Rule of Law Report, p. 2. 

207  Council  of  Europe  (2024),  Supervision  of  the  execution  of  judgments  decisions  of  the  European  Court  of 

Human Rights – 17th Annual Report of the Committee of Ministers – 2023, p. 137.   

208  Data according to the online database of the Council of Europe (HUDOC). 
209  See the Council Implementing Decision of 28 July 2021 on the approval of the assessment of the recovery 
and  resilience  plan  for  Croatia,  Milestone  218.  The  Commission  found  the  milestone  to  be  satisfactorily 
fulfilled on 29 February 2024. Communication to the Commission on the positive preliminary assessment of 
the  fourth  payment  request  of  Republic  of  Croatia  pursuant  to  Regulation  (EU)  2021/241,  C(2024)1439 
final. 

210  Input from Croatia for the 2024 Rule of Law Report, p. 41. 
211  Articles 154 and 155 of the new Law on Administrative Disputes. 
212  According to the Principles relating to the Status of National Institutions (The Paris Principles). 
213  2023 and 2022 Rule of Law Reports, Country Chapter on the rule of law situation in Croatia, p. 2. The 2023 

Rule of Law Report found that some progress was made on implementing the 2022 recommendation. 

29 

 
 
2022214. According to the Government, the analysis of the questionnaire has shown that 61% 
of recommendations given in 2022 have been implemented, are being implemented or are in 
the implementation plan215. In 2023, according to the Ombudsperson, the implementation of 
recommendations  remained  stable,  as  around  44%  of  all  recommendations  given  in  2022 
have  either  been  already  implemented  or  are  in  the  process  of  being  implemented216.  As 
regards the access to information, according to the Government, in 2023, the Ombudsperson 
submitted  a  written  request  for  data  from  the  Information  System  of  the  Ministry  of  the 
Interior  for  five  cases  on  the  treatment  of  irregular  migrants,  which  the  authorities 
transmitted217. However, according to the Ombudsperson’s Office, they  

continued to experience some challenges when asking for direct access to relevant data from 
the  Ministry’s  protected  information  system218.  Therefore,  there  was  some  further  progress 
achieved  regarding  the  recommendation  made  in  2023  Rule  of  Law  Report.  In  2023,  the 
Ombudsperson’s budget increased, and two new employees are to be hired in 2024219. 

There  has  been  a  gradual  shift  towards  the  multiannual  funding  of  civil  society 
organisations, while the new National Plan for Creating an Enabling Environment still 
remains  outstanding.  The  civic  space  in  Croatia  is  considered  to  be  narrowed220.  The 
previous  Rule  of  Law  Reports221  followed  the  preparatory  steps  towards  adoption  of  the 
National Plan, which intends to further improve the legal, financial and institutional support 
system for the activities of civil society organisations. Since the publication of the 2023 Rule 
of  Law  Report,  the  relevant  Working  Group  tasked  with  developing  the  National  Plan  met 
three more times and ‘technically completed’ the draft for internal governmental consultation, 
which has not progressed further222. According to the Governmental  authorities, the lack of 
adoption  of  the  new  National  Plan  has  not  undermined  the  financing  of  civil  society 

214  Altogether  32  questionnaires  were  sent  to  14  ministries,  governmental  offices,  state  inspectorate,  judicial 
academy,  social  services,  Bar Association,  public  service  media  HRT,  and  two  local  governments,  among 
others. Input from Croatia for the 2024 Rule of Law Report, p. 40. The questionnaire enabled the analysis of 
the implementation on two grounds: quantitative self-assessment and revaluation of the quantitative results 
based  on  qualitative  results,  i.e.,  description  of  the  implementation.  Written  contribution  from  the 
Government in the context of the country visit to Croatia. 

215  Written contribution from the Government in the  context of the country visit to Croatia.  The analysis was 

published in the Report on Implementation of the Ombudsperson's Recommendations in March 2024. 

216  People’s  Ombudsperson,  2023  Report,  29  March  2024,  p.  312.  2022  Ombudsperson  Report  found  that 
around  46%  of  all  recommendations  given  in  the  2021  Ombudsperson’s  Report  have  either  already  been 
implemented or are in the process of being implemented. 

217  Written contribution from the Ministry of the Interior following the country visit to Croatia. 
218  In  July  2023,  during  the  common  visit  with  the  UN  Subcommittee  on  the  Prevention  of  Torture,  the 
authorities  granted  access  to  all  data  regardless  the  form,  while  during  the  other  two  visits  which 
Ombudsperson’s Office conducted alone the data were provided after a written request weeks after the visit 
(for  the  visit  in  April  2023),  and  during  the  December  2023  visit  request  to  print  out  the  data  from  the 
information system was denied (on that occasion, Police did not offer to provide information if requested in 
writing  and  the  Ombudsperson’s  Office  did  not  request  it  in  that  form).  Information  received  from  the 
Ombudsperson’s Office in the context of country visit to Croatia. 

219  Input  from  Croatia  for  the  2024  Rule  of  Law  Report,  p.  15,  and  information  received  from  the  Public 

Ombudsperson’s in the context of the country visit to Croatia. 

220  Rating given by Civicus, Croatia; ratings are on a five-category scale defined as: open, narrowed, obstructed, 

repressed and closed. 

221  2023, 2022, 2021 and 2020 Rule of Law Reports, Country Chapters on the rule of law situation in Croatia. 
222  Input from Croatia for the 2024 Rule of Law Report, p. 43, and Information received from the Government 

Office for cooperation with the CSOs in the context of the country visit to Croatia. 

30 

 
 
organisations223. According to the Government, in 2023, the funding trend shifted from short-
term support towards multiannual systematic and continuous financing224. Some civil society 
organisations raised as a challenge the increasing administrative burden in applying for funds 
as well as the prioritisation in funding225.  

223  Information  received  from  the  Government  Office  for  cooperation  with  the  NGOs  in  the  context  of  the 

country visit to Croatia. 

224  According  to  the  Government,  national  funding  for  key  projects  was  secured  for  the  period  from  the 
completion of ESF-funded projects to the beginning of implementation of the new ESF+ projects. Based on 
Public Payment Agency-FINA's financial report for 2022, 164 out of 50 000 of associations were blocked, 
which  is  8%  less  than  in  2021,  which,  according  to  the  Government,  shows  that  there  is  more  available 
funding.  Written  contribution  from  the  Government  Office  for  cooperation  with  the  NGOs  following  the 
country visit to Croatia. 

225  Some  civil  society  pointed  out  that  funding  is  primarily  focused  on  supporting  civil  society  organisations 
that  provide  social  services,  rather  than  organisations  contributing  to  better  public  policy  management, 
monitoring  reforms  in  the  rule  of  law,  combating  corruption,  and  enhancing  transparency;  written 
contribution prepared by the Human Rights House Zagreb and Centre for Democracy and Law Miko Tripalo 
with  contributions  from  Croatian  Journalist  Association,  Centre  for  Peace  Studies,  Rainbow  Families 
Croatia, Zagreb Pride, Udruga RODA, Youth Initiative for Human Rights  – Croatia, GONG, Green Action, 
DKolektiv, Center for peace, non-violence and human rights and Croatian Platform for International Citizen 
Solidarity-CROSOL following the country visit to Croatia. 

31 

 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2024 Rule of Law report 
can 
https://commission.europa.eu/publications/2024-rule-law-report-targeted-
stakeholder-consultation_en. 

found 

be 

at 

AmCham  Croatia  (2024),  Survey  of  the  Business  Environment  in  Croatia  2024,  March  2024 
https://www.amcham.hr/storage/upload/doc_library/amcham_-
_survey_of_the_business_environment_in_croatia_-_2024_163456.pdf.  

Article  19,  Press  release:  Croatia:  Scrap  plan  to  criminally  penalise  disclosure  of  ‘non-public’ 
information,  13  June  2024  https://www.article19.org/resources/croatia-scrap-plan-to-criminally-
penalise-disclosure-of-non-public-information/.  

Association of Croatian Judges (2024),  Press release: Amendment to the  Law on Judicial Officials’ 
Salaries and Other Material Rights announced, 27 February 2024 https://uhs.hr/archives/40305.  

Association  of  Croatian  Judges  (2024),  Press  release:  The  judges’  warning  strike  will  end  on 
February 2, 2024, 2 February 2024 https://uhs.hr/archives/40275.  

Association  of  Judges  (2024),  Press  release:  During  the  warning  strike,  judges  are  following  the 
instructions of the President of the Supreme Court - Since the beginning of the strike, the Government 
hasn’t invited judges to negotiations, 28 January 2024 https://uhs.hr/archives/40270. 

Centre for Democracy and Law Miko Tripalo and Croatian Journalists’ Association (2024), Research 
Fighting SLAPP in Croatia, May 2024. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2024),  Media  pluralism  monitor  2024  –  country 
report on Croatia. 

Civicus, Monitor tracking civic space – Croatia https://monitor.civicus.org/country/croatia/.  

Coalition  Against  SLAPPs  in  Europe  (2022),  Shutting  Out  Criticism:  How  SLAPPs  Threaten 
European 
https://www.the-case.eu/wp-
content/uploads/2023/04/CASEreportSLAPPsEurope.pdf. 

Democracy, 

Coalition  Against  SLAPPs  in  Europe  (2023),  SLAPPS:  A  Threat  to  Democracy  Continues  to  Grow 
https://www.the-case.eu/wp-content/uploads/2023/08/20230703-CASE-UPDATE-REPORT-2023-
1.pdf. 

Council of Europe: Platform to promote the protection of journalism and safety of journalists. 

Court  of  Justice  of  the  European  Union  (2024),  Judgment  of  11  July  2024,  Joined  Cases  C-554/21 
Hann-Invest,  C-622/21  Mineral-Sekuline  and  C-727/21  Udruga  Khl  Medvešcak  Zagreb 
https://curia.europa.eu/juris/documents.jsf?num=C-554/21.  

CRC  (2021),  Opinion M-136-21,  29  October  2021  https://www.sukobinteresa.hr/hr/misljenja/robert-
sveb-m-136-21-misljenje.  

CRC  (2022),  Opinion  M-19-22,  21  January  2022  https://www.sukobinteresa.hr/hr/misljenja/robert-
sveb-m-19-22-misljenje.  

CRC  (2023),  Systemic  overview  of  provisions  on  conflict  of  interest,  8  December  2023 
https://www.sukobinteresa.hr/hr/priopcenja/sustavni-prikaz-odredbi-o-sukobu-interesa. 

Croatian Government (2023), Report for 2022 on the implementation of the Action Plan for the period 
from 2022 to 2024 accompanying the Strategy for the prevention of Corruption for 2021- 2030, 17 
August 
2023 
https://mpu.gov.hr/UserDocsImages/dokumenti/Antikorupcija/Izvjesce%20o%20provedbi%20Akcijs
kog%20plana%20za%202022..pdf.  

32 

 
Croatian  Government  (2024),  Press  release:  Government  adopts  Regulation  for  implementing  the 
Law 
2024 
https://savjetovanja.gov.hr/vijesti/vlada-donijela-uredbu-za-provedbu-zakona-o-instrumentima-
politike-boljih-propisa/1236.  

Instruments, 

Regulation 

February 

Policy 

Better 

on 

15 

Croatian  Government  (2024),  Press  release:  Plenković:  We  are  in  the  largest  investment  cycle  in 
education 
2024 
of  Croatia,  worth  EUR 
https://vlada.gov.hr/vijesti/plenkovic-nalazimo-se-u-najvecem-ciklusu-ulaganja-u-obrazovanje-u-
povijesti-hrvatske-vrijednom-2-5-milijarde-eura/42371.  

2  May 

billion, 

history 

2.5 

the 

in 

Croatian  Government  (2024),  Press  release:  There  is  no  pressure  on  the  EPPO.  We  stand  for  the 
legal  spending  of  European 
for,  11  March  2024 
https://vlada.gov.hr/vijesti/ne-postoji-pritisak-na-eppo-zalazemo-se-za-zakonito-trosenje-europskih-
sredstava-za-koja-se-vlada-izborila/42095. 

the  Government 

fought 

funds 

that 

Croatian Journalists’ Association (2023), Public consultation: HND strongly opposes Article 307a of 
the  Criminal  Code  (Javno  savjetovanje:  HND  oštro  protiv  članka  307.a  Kaznenog  zakona),  31 
https://www.hnd.hr/javno-savjetovanje-hnd-ostro-protiv-clanka-307-a-kaznenog-
October 
zakona. 

2023 

Croatian  Journalists’  Association  (2023),  Working  document  of  new  Media  Act  –  unacceptable,  20 
July 2023, https://www.hnd.hr/eng/cja-working-document-of-new-media-act-unacceptable. 

Croatian Journalists’ Association (2024), HND's open letter to citizens about the dangers of changes 
to the Criminal Code (Otvoreno pismo HND-a građanima o opasnostima izmjena Kaznenog zakona), 
11  March  2024  https://hnd.hr/otvoreno-pismo-hnd-a-gradanima-o-opasnostima-izmjena-kaznenog-
zakona. 

Croatian  Journalists’  Association  (26  September  2023),  Croatian  Government  proposes  a  law  of 
dangerous intentions, 26 September 2023 https://www.hnd.hr/eng/cja-croatian-government-proposes-
a-law-of-dangerous-intentions. 

Draft  amendments  to  the Law  on  implementation  of  the  Council  Regulation (EU)  2017/1939  of  12 
October  2017  implementing  enhanced  cooperation  on  the  establishment  of  the  European  Public 
Prosecutor’s  Office 
2024 
(‘the  EPPO’),  Deputies’ 
https://sabor.hr/sites/default/files/uploads/sabor/2024-02-29/175001/PZ_634.pdf.  

group  Možemo, 

29  February 

EPPO  (2024),  Press  release:  Croatia:  Former  Deputy  Minister  arrested  in  investigation  involving 
University of Zagreb, 2 May 2024 https://www.eppo.europa.eu/en/media/news/croatia-former-deputy-
minister-arrested-investigation-involving-university-zagreb.  

Euromedia  Ownership  Monitor 
ownership.eu/findings/countries/croatia/.  

(2023),  Croatia  –  Country 

report  2023,  https://media-

European Commission (2022), 2022 EU Justice Scoreboard. 

European Commission (2022), 2022 Rule of Law Report, Country Chapter on the rule of law situation 
in Croatia. 

European Commission (2023), 2023 Rule of Law Report, Country Chapter on the rule of law situation 
in Croatia. 

European Commission (2024), 2024 EU Justice Scoreboard. 

European Parliament: Flash Eurobarometer: News & Media Survey 2023. 

European  Public  Prosecutor’s  Office  (2023),  Press  release  –  Croatia:  29  suspects  arrested  in 
investigation 
2023 
of 
https://www.eppo.europa.eu/en/news/croatia-29-suspects-arrested-investigation-involving-university-
zagreb. 

November 

University 

involving 

Zagreb, 

8 

33 

 
investigation 

European Public Prosecutor’s Office (2024), Press release – Croatia: EPPO conducts new searches 
in 
2024 
https://www.eppo.europa.eu/en/news/croatia-eppo-conducts-new-searches-investigation-university-
zagreb.  

University 

February 

Zagreb, 

into 

16 

of 

Forbes  (2024),  How  to  fix  the  public  procurement  system,  through  which  10  billion  euros  pass 
annually?,  23  February  2024  https://forbes.n1info.hr/aktualno/kako-popraviti-sustav-javnih-nabava-
kroz-koji-godisnje-prode-10-milijardi-
eura/?utm_source=onesignal&utm_medium=webpush&utm_campaign=2024-02-23-NAJEI-OBLICI-
KO.  

GONG  (2023),  Press  release:  Gong  to  the  Commission:  Check  the  highest  level  officials  first,  22 
December 
https://gong.hr/2023/12/22/gong-povjerenstvu-prvo-provjeravajte-najvise-
duznosnike/  

2023 

GRECO (2018), Fourth Evaluation Round, Second Compliance Report – Croatia, 7 December 2018, 
GrecoRC4(2018)14 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-
members-of/1680920114.  

High  Criminal  Court,  Press  release:  The  Council  of  Judges  of  the  High  Criminal  Court  made  a 
decision on a complaint to initiate a procedure for violation of the Code of Judicial Ethics, 23 May 
2024  https://sudovi.hr/hr/vksrh/priopcenja/sudacko-vijece-visokog-kaznenog-suda-donijelo-odluku-o-
prituzbi-za-pokretanje. 

HND  (2024),  Press  release:  ‘At  least  752  active  lawsuits  weighing  EUR  4.1  million,  and  in  1 333 
cases  adjudged  – 40%  were  pure  SLAPP’,  24  May  2024  https://www.hnd.hr/hnd-aktivne-najmanje-
752-tuzbe-teske-4-1-milijun-eura-a-u-1333-presudena-predmeta-40-posto-je-bio-cisti-slapp.  

Index  (2023),  Indictment  filed  against  Mamić  and  the  Osijek  judges,  7  December  2023 
https://www.index.hr/vijesti/clanak/podignuta-optuznica-protiv-mamica-i-osjeckih-
sudaca/2469722.aspx.  

Index  (2023),  Investigation 
https://www.index.hr/vijesti/clanak/uskok-usao-u-hep-zbog-goleme-plinske-afere/2478524.aspx.   

the  huge  gas  affair,  11  July  2023. 

into  HEP  because  of 

Index  (2023),  The  High  Criminal  Court  takes  an  important  decision  in  favor  of  Plenković's  former 
ministers,  7  December  2023  https://www.index.hr/vijesti/clanak/visoki-kazneni-sud-donio-vaznu-
odluku-u-korist-bivsih-plenkovicevih-ministara/2519026.aspx.  

Information 
content/uploads/2024/03/Izvjesce-o-provedbi-ZPPI-za-2023.pdf?x57830.  

Commissioner 

(2024), 

Report 

2023 

for 

https://pristupinfo.hr/wp-

Jutarnji list (2024), The EU prosecutor's office for Jutarnji: 'We have conducted a thorough analysis: 
Croatia 
2024 
https://www.jutarnji.hr/vijesti/hrvatska/eu-tuziteljstvo-za-jutarnji-proveli-smo-temeljitu-analizu-
hrvatska-se-ne-pridrzava-nacela-15431673. 

principles...', 

January 

comply 

does 

with 

not 

the 

24 

Mapping  Media  Freedom  (2023),  Minister  of  Culture  and  Media  Nina  Obuljen  Koržinek  attacks 
Telegram journalist Dora Kršul, 8 November 2023 https://www.mapmf.org/alert/30839. 

Mapping Media  Freedom (9  January  2024),  N1 journalist told  by  Prime Minister  Andrej  Plenković 
N1 is "semi-legal", https://www.mapmf.org/alert/31100. 

N1  (2024),  Supreme  Court 
https://n1info.hr/english/news/daily-supreme-court-is-requesting-documentation-on-turudic/. 

is  requesting  documentation  on  Turudić,  5  February  2024 

N1  news  portal  (2024),  Chief  European  prosecutor  for  N1:  “I  believe  that  the  Croatian  prime 
minister  does  not  aim 
January  2024 
https://n1info.hr/vijesti/glavna-europska-tuziteljica-za-n1-vjerujem-da-hrvatskom-premijeru-nije-cilj-
mijesati-se-u-istrage-eppo-a/. 

investigations”,  20 

in  EPPO 

interfere 

to 

34 

 
Osservatorio Balcani Caucaso Transeuropa (2024), Croatia, the assault on the local press, 12 January 
2024 
https://www.balcanicaucaso.org/eng/Areas/Croatia/Croatia-the-assault-on-the-local-press-
229297. 

Ombudsperson 

People’s 
https://www.ombudsman.hr/hr/download/izvjesce-pucke-pravoraniteljice-za-2022-
godinu/?wpdmdl=15489&refresh=659e7e3a9150d1704885818. 

(2023), 

Report 

2022, 

for 

4 

April 

2023 

Ombudsperson 

People’s 
Report 
https://www.ombudsman.hr/hr/download/izvjesce_pucke_pravobraniteljice_za_2023_godinu/?wpdm
dl=18399&refresh=6628e234b27ec1713955380. 

(2024), 

March 

2023, 

for 

29 

2024 

(2024),  Croatian 

Politico 
https://www.politico.eu/article/croatia-journalists-hrvoje-zovko-slam-andrej-plenkovic-catastrophic-
new-legislation-press-freedom/. 

‘catastrophic’  anti-leaks  bill,  31  January  2024 

journos  decry 

Reporters Without Borders (2023), 2023 World Press Freedom Index. 

State  Attorney’s  Council  (2024),  Press  release:  Four  applications  to  the  public  call  received,  5 
January 2024 https://dov.hr/hr/priopcenja/zaprimljene-cetiri-prijave-na-objavljeni-javni-poziv.  

State  Attorney’s  Office  (2024),  2023  Report,  28  April  2024  https://dorh.hr/hr/izvjesca-o-
radu/izvjesce-o-radu-drzavnih-odvjetnistava-u-2023-godini.  

Supreme Court (2023), Guidelines for communication of the judiciary with the public in line with the 
Action  plan  for  2022-2024  based  on  the  Strategy  for  the  Prevention  of  Corruption  2021-2030,  25 
September 
https://www.vsrh.hr/EasyEdit/UserFiles/normativni-akti/2023/smjernice-za-
komuniciranje-pravosudja-s-javnoscu.pdf. 

2023 

Supreme Court (2023), Letter from President of Supreme Court to the Prime Minister, 26 June 2023 
https://www.vsrh.hr/dopis-predsjednika-vrhovnog-suda-republike-hrvatske-predsjedniku-vlade-
republike-hrvatske-u-svezi-strajka-sluzbenika-i-namjestenika-u-pravosudnim-tijelima.aspx.  

Supreme  Court  (2023),  Press release: Judicial system  on  the verge  of  collapse  -  mass  departure  of 
officials,  3 
July  2023  https://www.vsrh.hr/pravosudni-sustav-pred-slomom-masovni-odlazak-
sluzbenika.aspx. 

Supreme Court (2023), Press release: The Supreme Court has ruled - the strike of court officials and 
employees  is  legal,  20  June  2023  https://www.vsrh.hr/vrhovni-sud-presudio-strajk-sluzbenika-i-
namjestenika-u-sudovima-je-zakonit.aspx. 

Supreme Court (2024), Contribution to the 2024 Rule of Law Report. 

Supreme  Court  (2024),  Instruction  of  the  President  of  the  Supreme  Court,  22  January  2024 
https://www.vsrh.hr/EasyEdit/UserFiles/priopcenja/2024/su-v-9-2024-1-uputa.pdf. 

Supreme Court (2024), Press release of 15 February 2024 https://www.vsrh.hr/predsjednik-visokog-
kaznenog-suda-uz-suglasnost-predsjednika-vrhovnog-suda-podnio-prituzbu-zbog-povrede-kodeksa-
sudacke-etike-protiv-suca-ivana-turudica.aspx. 

Telegram (2024), Fantastic HRT. The supervisory board confirmed Telegram's scandalous revelations 
about director Šveb but blamed the former administration for everything (Fantastičan HRT. Nadzorni 
odbor potvrdio Telegramova skandalozna otkrića o ravnatelju Švebu, ali za sve krive bivšu upravu) 
22 February 2024 https://www.telegram.hr/politika-kriminal/fantastican-hrt-nadzorni-odbor-potvrdio-
telegramova-skandalozna-otkrica-o-ravnatelju-svebu-ali-za-sve-krive-bivsu-upravu/.  

Telegram  (2024),  Plenković  threatens  from  the  Government  session:  'It  is  unacceptable  that  no  one 
answers  because  the  media  write  about  interesting  cases'  (Plenković  prijeti  sa  sjednice  Vlade: 
'Neprihvatljivo je da nitko ne odgovara jer mediji pišu o interesantnim predmetima'), 31 October 2024 
https://www.telegram.hr/politika-kriminal/plenkovic-i-nakon-ublazavanja-lex-ap-a-prijeti-
neprihvatljivo-je-da-nitko-ne-odgovara-jer-mediji-pisu-o-interesantnim-predmetima/. 

35 

 
Telegram  (2024),  The  Commission  for  Conflict  of  Interest  confirmed  Telegram's  discovery:  the 
scandalous head of HRT paid himself fees that did not belong to him (Povjerenstvo za sukob interesa 
potvrdilo Telegramovo otkriće: skandalozni šef HRT-a isplaćivao si naknade koje mu ne pripadaju), 8 
March  2024  https://www.telegram.hr/politika-kriminal/povjerenstvo-za-sukob-interesa-potvrdilo-
telegramovo-otkrice-skandalozni-sef-hrt-a-isplacivao-si-naknade-koje-mu-ne-pripadaju/. 

Telegram (2024), This is unreal. Media racket exposed, and the Government assures the EU that state 
advertising  in  the  media  is  great  for  us  (Ovo  je  nestvarno.  Razotkriven  medijski  reket,  a  Vlada 
uvjerava  EU  da  nam 
je  državno  oglašavanje  u  medijima  super),  16  January  2024 
https://www.telegram.hr/politika-kriminal/ovo-je-nestvarno-razotkriven-medijski-reket-a-vlada-
uvjerava-eu-da-nam-je-drzavno-oglasavanje-u-medijima-super/. 

Telegram  (2024),  We  bring  a  discovery  that  would  make  the  entire  administration  fly  in  every 
regulated country: HRT paid 1.25 million euros to the former company of its boss without a tender 
(Donosimo otkriće zbog kojeg bi u svakoj uređenoj državi letjela cijela uprava: HRT bivšoj tvrtki svog 
šefa  bez  natječaja  platio  1,25  milijuna  eura),  12  February  2024  https://www.telegram.hr/politika-
kriminal/hrt-je-bivsoj-tvrtki-svog-direktora-protuzakonito-platio-125-milijuna-eura-ministrice-
kulture-pomogla-mu-je-to-pravdati/. 

Telegram (2024), We came to a scandalous audit finding on HRT: they illegally pay out millions and 
declare  it  a  business  secret  (Došli  smo  do  skandaloznog  nalaza  revizije  na  HRT-u:  nezakonito 
2024 
isplaćuju  milijune 
https://www.telegram.hr/politika-kriminal/dosli-smo-do-skandaloznog-nalaza-revizije-na-hrt-u-
nezakonito-isplacuju-milijune-i-to-proglasavaju-poslovnom-tajnom/. 

proglašavaju 

poslovnom 

tajnom), 

January 

31 

to 

i 

USKOK (2024), An investigation was launched against the defendant due to suspicion of "extracting" 
money from a TV station (Protiv okrivljenika pokrenuta istraga zbog sumnje na „izvlačenje“ novca s 
jedne  TV  postaje),  29  January  2024  https://uskok.hr/hr/priopcenja/protiv-okrivljenika-pokrenuta-
istraga-zbog-sumnje-na-izvlacenje-novca-s-jedne-tv-postaje. 

USKOK (2024), Press release: USKOK sent a letter to the Office of the European Public Prosecutor 
in  the  Republic of  Croatia,  12  March  2024  https://uskok.hr/hr/priopcenja/uskok-uputio-dopis-uredu-
europskog-javnog-tuzitelja-u-republici-hrvatskoj.  

Venice  Commission,  Opinion  on  the  Act  on  the  Public  Prosecutor's  office  (Poland),  CDL-
https://venice.coe.int/webforms/documents/?pdf=CDL-
AD(2017)028, 
AD(2017)028-e. 

11  December 

2017 

36 

 
 
 
Annex II: Country visit to Croatia 

The Commission services held virtual meetings in January and February 2024 with: 

•  Agency for Electronic Media  
•  American Chamber of Commerce - Croatia 
•  Association of Judges (Judge Damir Kontrec) 
•  Bar Association 
•  Centre for Democracy and Law Miko Tripalo 
•  Centre for Peace Studies 
•  Commission for the Resolution of Conflicts of Interest 
•  Constitutional Court 
•  Croatian Journalists' Association 
•  Croatian Newspaper Publishers' Association 
•  GONG 
•  Government’s Legislation Office 
•  Government’s Office for Cooperation with NGOs  
•  Government’s Office for Human Rights and Rights of National Minorities 
•  HRT – Croatian Radio and Television (Director General Robert Šveb) 
•  Human Rights House 
•  Ministry of Culture and Media 
•  Ministry of Justice and Administration 
•  Office of the Information Commissioner 
•  Office of the Public Ombudsperson 
•  Parliamentary  National  Council 

for  Monitoring  Anti-Corruption  Strategy 

Implementation 

•  PNUSKOK - specialised anti-corruption police 
•  Secretariat of the Parliament 
•  State Attorney’s Council 
•  State Attorney’s Office (including USKOK-specialised anti-corruption prosecution) 
•  State Audit Office 
•  State Commission for Supervision of Public Procurement Procedures 
•  State Judicial Council 
•  Supreme Court (President Radovan Dobronić, LL.M.) 
•  Trade Union of Croatian Journalists 

* The Commission also met the following organisations in a number of horizontal meetings:  

•  Amnesty International EU 
•  Centre for Democracy and Technology Europe 
•  Centre for European Volunteering 
•  Civil Liberties Union for Europe 
•  Civil Rights Defenders 
•  Civil Society Europe 
•  Culture Action Europe 
•  Democracy Reporting International 
•  European Centre for Non-Profit Law 

37 

 
 
International Federation for Human Rights 
International Planned Parenthood Federation 
International Press Institute 
Irish Council for Civil Liberties 

•  European Civic Forum 
•  European Federation of Journalists 
•  European Partnership for Democracy 
•  European Youth Forum 
•  Free Press Unlimited 
• 
• 
• 
• 
•  JEF Europe 
•  Open Society Foundations 
•  Philanthropy Europe Association 
•  PICUM 
•  Reporters Without Borders 
•  SOLIDAR 
•  Transparency International EU 

38