COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Croatia Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Croatia, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 17 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Croatia Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)  Third River Basin Management Plans Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 21 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Croatia 

ENVIRONMENT 

 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, member state characterisation ............................................................................................................. 4 

2. Horizontal aspects ................................................................................................................................................................... 10 

2.1 Governance ......................................................................................................................................................................... 10 

2.2 Characterization of River Basin District .............................................................................................................. 10 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 16 

3.1 Surface Water: what is their ecological status or potential .................................................................... 16 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 18 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 19 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 19 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 21 

3.6 What Croatia is doing for abstractions and water scarcity ..................................................................... 21 

3.7 Adaptation to climate change .................................................................................................................................. 24 

4. Policy elements contributing to zero pollution ........................................................................................................ 25 

4.1 Surface Water: what is their chemical status ................................................................................................. 25 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 28 

4.3 What Croatia is doing to combat pollution from agriculture ................................................................. 29 

4.4 What Croatia is doing to combat pollution from other sectors ............................................................ 30 

4.5  What  Croatia  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 31 

5. Exemptions and economics ............................................................................................................................................... 31 

5.1 To what extent are exemptions applied in Croatia ....................................................................................... 31 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 32 

6. WFD recommendations ........................................................................................................................................................ 33 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 36 

7. Flood risk management under floods directive (FD) ............................................................................................ 37 

7.1 Flood hazard and risk maps ...................................................................................................................................... 37 

7.2 Flood risk management plans .................................................................................................................................. 38 

8. FD recommendations ............................................................................................................................................................ 39 

2 

 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation 

Croatia, a predominantly mountainous country, encompasses terrestrial and marine areas of over 
56,000km². It comprises the Slavonia lowlands in the interior and the coastal Dinaric Alps, along with 
numerous islands and islets scattered throughout the Adriatic Sea. It has a population of 3.87 million 
inhabitants (9.64% less than in the 2011 census). There are roughly 73 people per km2 which is 
below  EU  average.  Croatia’s  geography  ranges  from  the  lowlands  of  the  Pannonian  basin  to  the 
Dinaric Alps and the Dalmatian coastline, (over 1800 km long). In addition, Croatia has over 1200 
coastal islands. Hence the country features a quite unique geographical situation with a long and 
narrow stretch of land with a long coast and many islands, which makes the interactions between 
freshwater and sea water very prominent. It remains a country with very rich biodiversity and natural 
areas where a very high proportion (38.1%) of the country is covered by protected areas. There are 
three types of climate in Croatia: Mediterranean, Alpine and Continental. 

Croatia has two RBDs: the Adriatic RBD (“HRJ”) and the Danube RBD which is part of the international 

Danube RBD. Croatia’s Adriatic RBD shares four smaller river basins with Bosnia and Herzegovina 
(Cetina,  Neretva,  Trebišnjica  and  Krka)  and  three  river  basins  with  Slovenia  (Dragonja;  Mirna  and 
Rječina). 

The Croatian territory is administratively divided into 20 counties and the City of Zagreb, as well as 
128 cities, 428 municipalities and 6.755 settlements.  The spatial  distribution of the population is 
very uneven. The north-west is the most populated part of Croatia, where 15% of the total population 
is situated in 15% of the territory. Eastern Slavonia, Istria, Croatian Littoral and Southern Dalmatia 

4 

 
have  an  above-average  and  average  population  while  the  remainder  of  Croatia  has  a  sparser 
population.1 

Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By  September  2023  Croatia  submitted  full  electronic  reporting  and  therefore  the  assessment  is 
based on this dataset. 

Despite the cut off dates for the production of this report, reporting continued and, for the State of 
Water  report,  the  EEA  aggregated    the  results  available  by  July    2024  in  their  products  and 
dashboards available at WISE Freshwater web portal. 

1 https://climate-adapt.eea.europa.eu/en/countries-regions/countries/croatia  

5 

 
 
 
 
 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies  

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

ECOLOGICAL 
STATUS 

CHEMICAL 
STATUS 

The number of SWB in good ecological status decreased from 50% (1st RBMP) to 42% (2nd RBMP) and 33% (3rd RBMP).  It is not entirely 
clear whether this continuous decrease is due to better knowledge (improved monitoring) and/or due to more pollution or both. The re-
delineation of SWBs between the 2nd and 3rd RBMP makes direct comparisons also difficult. Diffuse source pressures from discharges, 
agriculture, transport and physical alterations exert pressures on > 50 % SWB, water abstractions on 7.9 % SWB. Nutrient pollution (41%) and 
morphological changes (40 %) are the most relevant impacts. No improvements are expected until 2027. Croatia's programme of measures 
lacks a cost effectiveness analysis for prioritising and leaves open if funding is secured. Croatia invoked Article 4(4) WFD in relation to 105 
SWB (5.3 %) on grounds of natural conditions and for 1406 SWB (71.7 %) for disproportionate cost.  

Due to the uPBTs mercury, PBDEs and PFOS, about 20% of SWB fail good chemical status. Without these uPBT, 7% SWB would fail the 
objective, only. It is not entirely clear whether the decrease from 92 % to 80 % represents a genuine deterioration since the 2nd RBMP or 
rather us due to a re-delineation of SWBs as well as better knowledge about the pollution. It is of concern that 100% of coastal waters and 
100% transitional waters faill a good chemical status and that Croatia fails to identify the sources of anthropogenic pressures on these 
surface water bodies. Croatia does not expect that the chemical status will improve by 2027. Croatia continues to bring its water 
management in full alignment with the WFD and UWWTD: most basic measures deal with investments in water infrastructure, monitoring 
network and data management and amending the regulatory framework. Croatia mapped KTM1: Alignment with standards for wastewater 
discharge and KTM14: Developing a methodology for assessing waste water emissions.  For the ca. 20% SWBs, Croatia invoked Article 4(4) 
exemptions. More specifically, it invoked technical feasibility in relation to 158 SWB (8%) and disproportionate cost in relation to 216 SWBs 
(10.9 %). 

6 

 
 
 
Ground 
Water 
Bodies  

Trend (% good 
status/potential) 

Main Pressures & Changes & Exemptions 

QUANTITATIVE 
STATUS 

CHEMICAL 
STATUS 

The slight change between 2015 and 2021 seems due to the re-delineation of Ground Water Bodies. The 3rd RBMP identifies only one 
Ground Water Body in the Adria River Basin District to be in poor quantitative status. Since 2016, total water abstractions have increased 
(4.8 %), due potentially to the increase in electricity generation while decreasing trends were observed in households and services (5.9 %) 
and industry (9.4 %). 5 GWBs (9.8 %) are reported to be at risk of losing their good quantitative status by 2027. Croatia invoked Article 4(4) 
exemptions for 1 GWB (2 %) on grounds of technical feasibility, natural conditions and disproportionate costs. 

In the 3rd RBMP, 47 out of 51 GWBs (i.e., 92.2 %) were reported to be in a good chemical status with 4 GWBs (i.e. 7.8 %) being in a poor 
chemical status in 2021 (one in the Danube RBD and four in the Adriatic RBD). These GWBs fail to achieve good chemical status due to the 
general water quality assessment (3 GWBs) and regional saline or other intrusions resulting from anthropogenically induced sustained 
changes in flow direction (1 GWB). Pollutants causing failure of good chemical status are nitrates, saline intrusion and water temperature. 
The 4 GWBs failing good status in 2021 are also at risk of failing good chemical status in 2027.  Croatia has significantly improved 
monitoring of priority substances in GWBs since the 2nd RBMP. In the 3rd RBMP, 95.3 % of the total GWB area has chemical monitoring. No 
measures were mapped for pressures of saline intrusion and water temperature, but measures were mapped for nitrate pollution. Croatia 
invoked Article 4 (4) WFD for 4 GWBs failing good chemical status. More precisely, Croatia invoked natural conditions in relation to 1 GWB (2 
%) and technical feasibility and disproportionate cost in relation to 3 GWB (5.9 %).  

7 

 
 
 
 
2. Horizontal aspects 

2.1 

Governance 

In the Republic of Croatia, three authorities are competent for managing water and elaborating the 
RBMPs:  the Ministry  of  Economy  and  Sustainable  Development,  the  national body  responsible  for 
water  management  Croatian  Waters  and  the  Josip  Juraj  Strossmayer  Water  Institute  (a  public 
research institution created in 2020 and responsible for monitoring water bodies). Croatia’s Flood 
Risk Management Plan is an integral part of the RBMP: the preparation of Croatia’s RBMP and the 
FRMP ran jointly, and there was a joint consultation for both plans. The RBMP and FRMP have separate 
programmes  of  measures,  however,  some  of  the  RBMP  measures  (mainly  measures  related  to 
hydromorphological issues) refer to flood risk management among the relevant sectors.  

Regrettably, given the very strong link between freshwater and marine areas in the country, there 
does not seem to be any evidence that Croatia’s 3rd RBMP and the Programmes of measures under 
the Marine Strategy Framework Directive (MSFD) have been developed in an integrated manner and 
the objectives do not appear to be streamlined. 

The draft and final RBMP were available for public consultation for at least six months. Interested 
members of the public could provide comments and ask questions to the re 

2.2 Characterization of River Basin District 

It is striking that the number of delineated waterbodies has increased very considerably compared 
to the previous 2nd cycle. The number of delineated surface water bodies increased from 1572 to 
1978 SWBs (+26 %) and groundwater bodies increased from 33 to 51 GWBs (+55 %). The new GWBs 
– not yet included in Croatia’s electronic reporting - belong to various types of geological formations, 
e.g.  fissured  and  karstic  aquifers,  fractured  aquifers  and  porous  aquifers.  The  review  of  the  GWB 
delineation affected mainly the first type, the fissured and karstic aquifers, which increased from 19 
in the 2nd RBMP to 33 in the 3rd RBMP. 

The number of river water bodies has increased by 268 (18 % increase). The number of lakes has 
increased by 72 which amounts to a near tripling in their number (195 % increase). The number of 
transitional water bodies has increased by 10 (40 % increase). The number of coastal water bodies 
has increased by 55, more than tripling their number (212 % increase). The changes in the number 
of water bodies are a result of new monitoring data, so due to new and better information. A reason 
for  the increase in  the  number  of  river  water bodies  is  due  to  a  changed  river  typology in  which 
certain biotic types have been further divided according to abiotic characteristics. 

8 

 
 
 
 
According  to  the  3rd  RBMP  and  other  publicly  available  sources,  the  methodological  changes  are 
explained  by  the  need  to  update  the  specific  water  classification  system  based  on  the  results  of 
implemented intercalibration. Due to late accession of Croatia to the EU in 2013, the intercalibration 
process  was  started  for  the  first  time  in  the  late  phases  of  2nd  RBMP  implementation,  only.  The 
methodological changes led to an amendment of SWB and GWB because of new monitoring results 
and  various  research  findings  where  new  data  on  chemical  and  ecological  status  were  used  for 
characterisation, along with the size. As a result, some river SWBs were split or merged. For GWB 
separate studies for the assessment of background concentrations and limiting values were prepared 
for Pannonian part of Croatia and for karstic areas that provided more precise information. In addition, 
small water bodies were assigned to a provisional type. 

Table 1. Number and area / length of delineated surface water bodies in Croatia in 2nd RBMP (2015) and 
3rd RBMP (2021) 

Rivers 

Lakes 

Transitional 

Coastal 

Territorial 

Year 

RBD 

Number 
of water 
bodies 

Total 
length 
(km) 

Number 
of water 
bodies 

Total 
area 
(km2) 

Number 
of water 
bodies 

Total 
area 
(km2) 

Number 
of water 
bodies 

Total 
area 
(km2) 

Number 
of water 
bodies 

Total 
area 
(km2) 

2021 

HRC 

1365 

15651 

79 

181 

0 

0 

0 

0 

0 

0 

2021 

HRJ 

387 

2937 

30 

90 

35 

129 

81 

13755 

1 

17712 

2021 

Total 

1752 

18588 

109 

271 

35 

129 

81 

13755 

1 

17712 

2015 

HRC 

1126 

16095 

33 

125 

0 

0 

0 

0 

2015 

HRJ 

358 

2979 

4 

41 

25 

150 

26 

13747 

2015 

Total 

1484 

19074 

37 

166 

25 

150 

26 

13747 

Likewise, the number of groundwater bodies increased due to a re-delineation from 33 to 51 GWB. 
At the time the 3rd RBMP was established, chemical monitoring results were still outstanding for the 
18 newly delineated GWBs.  

Table 2. Number and area of delineated groundwater bodies in Croatia in 2nd RBMP (2015) and 3rd RBMP 
(2021)  

Year 

RBD 

Groundwater 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Number of 
water bodies 

Total area 
(km2) 

2021 

2021 

2021 

2015 

2015 

2015 

HRC 

HRJ 

Total 

HRC 

HRJ 

Total 

37 

14 

51 

20 

13 

33 

Source: 3rd RBMP e-reporting 

37812 

20745 

58557 

35084 

20718 

55802 

The largest users of freshwater in Croatia are public water supply (440million m3), followed by the 
energy sector (167 million m3), agriculture (30 million m3)2 and the manufacturing industry (25.07 
million m3).3  

It is positive that Croatia has significantly improved the establishment of physico-chemical quality 
elements for lakes, which are now established for 100 % of lake types compared to 40 % in the 2nd 
RBMP. However, there remain still gaps in Croatia’s type-specific reference conditions. In particular for 
transitional  and  coastal  surface  water  bodies,  Croatia  has  failed  to  set  any  hydromorpholgical4 
reference  conditions  (see  table  4).  The  absence  of  hydromorphological  reference  conditions  for 
Croatia’s coastal and transitional waters may hamper the identification of anthropogenic pressures 
that degrade the ecological status of Croatia’s coastal water bodies (e.g.: construction of hotels and 
tourism etc). 

Table 3. Percentage of surface water body types in Croatia with reference conditions established for all, 
some and none of the biological, hydromorphological and physicochemical quality elements. 

Established reference conditions for: 

Surface water 
category 

Surface water 
types 

Biological quality 
elements 

Hydromorphologic
al quality elements 

Physicochemical 
quality elements 

Rivers 

Lakes 

Transitional 

All 

Some 

None 

All 

Some 

None 

All 

73% 

27% 

79% 

21% 

80% 

99% 

1% 

98% 

2% 

84% 

16% 

100% 

2 Note, however, that Croatia still estimates abstractions in agriculture rather than measuring it, which also explains that 
the figure of 30 million m3 stayed the same since 2015. 
3 Source Eurostat 2021. 
4 Such conditions would for instance include the depth variation, structure and substrate of the coastal bed, both the 
structure and condition of the inter-tidal zones etc. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Some 

None 

All 

Some 

None 

Coastal 

Source: 3rd RBMP e-reporting 

Pressures 

20% 

78% 

22% 

100% 

100% 

80% 

20% 

78% 

22% 

The 3rd RBMP of Croatia also establishes the main pressures on surface water bodies (SWB) which 
appear similar to those in the 2nd RBMP. Namely, the most significant pressures are, in declining order 
of  relevance,  diffuse  discharges  not  connected  to  the  sewage  network,  diffuse  pressures  from 
agriculture, diffuse pressures from the transport sector, and finally also physical alterations.  

Figure 1. Map of the monitoring points showing eutrophication assessment in  Croatia, according to the 
reporting of the Nitrates Directive 

Source:  Joint  Research  Center  of  European  Commission  (n.d.).  JRC  NITRATES  DIRECTIVE  -  Reporting  Period 7  (2016-

2019) 
water.jrc.ec.europa.eu. 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa  

[online] 

Trophic 

Status. 

Available 

at: 

Note : 1% of the monitoring stations are above the threshold of 50mg/l  

11 

 
 
 
 
 
 
 
 
 
Figure  2.  he  most  significant  pressures  on  surface  water  bodies  in  Croatia  by  2021  (expressed  as 
percentages of numbers of water bodies affected) 

Note that Croatia’s Accession Treaty to the EU derogates from Articles 3, 4, 5, 6 and 7 of the Urban 
Waste Water Treatment Directive such that the requirements for collecting systems and treatment 
of urban waste water applies in Croatia only since very recently, namely from 1 January 2024, only. 
Now that Croatia must fully comply with the UWTD, this should normally accelerate the process of 
cleaning Croatia’s surface water bodies from pollution coming from urban sources (“discharges not 
connected  to  sewerage  network”).  From  data  published  under  the  Urban  Waste  Water  Treatment 
Directive, it appears that waste water is in particular still collected without appropriate treatment or 
not collected at all in the region of Split-Solin, a coastal town in the Adriatic RBD.  

Table 4. Waste water treatment in big cities without treatment (2020) 

Source: Country reporting under UWWTD 

For groundwater bodies (GWB), the most significant pressures are abstractions (public water supply, 
alteration of water level or volume, for agriculture) and diffuse pressures from agriculture, together 
causing ca. 8 % GWB to fail good status. The pressures on 18 newly delineated GWBs remains to be 
reported. 

12 

 
 
 
 
 
Figure 3. The most significant pressures on groundwater water bodies in Croatia by 2021 (expressed as 
percentages of numbers of water bodies affected) 

Source: 3rd RBMP e-reporting 

Significant impacts affecting the highest percentage of SWB are shown below in Figure 3. Nutrient 
pollution affects 41% of SWB, a slight decrease from 43 % in the 2nd RBMP. While organic pollution 
has seemingly slightly decreased since the 2nd RBMP, the percentage of SWB affected by altered 
habitats due to morphological and hydrological changes has increased. Only 24 % SWB are reported 
to be affected by no significant impact and for more than 10% the impacts remain unknown. It is, 
however, unclear whether these changes since the 2nd RBMP are the result of re-delineation of water 
bodies, or genuine change. 

Figure  4.  The  most  significant  impacts  on  surface  water  bodies  (SWB)  in  Croatia  2021  (expressed  as 
percentages of numbers of water bodies) 

As can be seen in table 6 below, Croatia considers that a large majority (86 %) of its groundwater 
bodies have been spared from significant pressures. Yet, it is recognised that 10% are affected by 
abstractions, nutrient pollution, and to a limited extent also saline (or other) intrusion. This is roughly 
comparable to the 2nd RBMP, when less than 10 % of GWBs were reported to be affected by nutrient 
pollution,  saline  pollution  /  intrusion  and  abstractions.  The  impacts  on  18  newly delineated  GWBs 
remains to be reported. 

13 

 
 
 
Figure  5.  The  most  significant  impacts  on  ground  water  bodies  (GWB)  in  Croatia  2021  (expressed  as 
percentages of numbers of water bodies) 

Source: 3rd RBMP e-reporting 

Croatia is a highly biodiverse country. Currently, 38.1% of Croatia’s terrestrial territory is designated 
as protected areas, which is significantly above the EU value of 26.4%. Croatia counts approximately 
200  terrestrial  invertebrate  species,  220  freshwater  invertebrate  species,  20  marine  invertebrate 
species, and over 10 new freshwater fish species. 

Croatia is predominantly characterised by two main types of ecosystems: forest ecosystems, which 
cover 51.8% of the country, followed by agroecosystems occupying 39.2% of the land area. While 
urban  areas  account  for  4.5%  and  heathlands  contribute  to  3.4%,  Croatia  has  relatively  smaller 
proportions of rivers and lakes (0.8%) and wetland ecosystems (0.2%). 

Farming in Croatia is done largely on small farms. However, the share of organic farming is around 
7%, which is lower than the EU average. Besides abstractions, agriculture also exerts strong pressures 
on  surface  waters  through  nutrient  pollution.  The  most  significant  impacts  affecting  the  highest 
percentage of surface water bodies are actually nutrient pollution (affecting 41 % SWB).   

Croatia has 28 hydropower plants. They are distributed in three production areas: North, West and 
South and they constitute a significant part of their energy mix.  

Invasive alien species 

Morphological changes affect 40 % of Croatia’s surface water bodies. As regards other pressures, 
such as invasive alien species, they proliferate steadily in some of Croatia’s Surface Water Bodies 
including  for  instance  the  bivalve  species  zebra  mussel  (Dreissena  polymorpha),  and  the  plant 
Canadian waterweed (Elodea canadensis).5 Moreover, the invasive signal crayfish has spread from 
Austria through the Mura river into Slovenia and from there to Croatia. Also, the spiny-cheek crayfish 
has spread into Croatia from the Hungarian part of the Danube River.6 While these invasive crayfish 
species still appear to be present in Northern Croatia7, only, experience in other EU Member States 
suggest that they procreate very quickly. The invasive North American crayfish are resistant to the 
crayfish plague, which they carry, and gradually replace local crayfish species. They also endanger 
local fish populations.  

5 See The Nature Protection Strategy and Action Plan of the Republic of Croatia for the period 2017-2025, page 29, 
available at https://www.cbd.int/doc/world/hr/hr-nbsap-v3-en.pdf .  
6 (PDF) Update on the distribution of freshwater crayfish in Croatia (researchgate.net).  
7 These data form 2011 may, however, meanwhile be outdated. (PDF) Update on the distribution of freshwater crayfish in 
Croatia (researchgate.net) 

14 

 
 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

Article 8(1) of the WFD requires Member States to establish monitoring programmes to assess the 
status of surface water and groundwater, in order to provide a coherent and comprehensive overview 
of  water  status  within  each  RBD.  The  WFD  distinguishes  between  surveillance  and  operational 
monitoring.8  

Due to Croatia’s late accession to the EU, the 2nd RBMP was still based on incomplete monitoring. 
Extensive investigative monitoring has been carried out in the period from 2016 to 2021 on about 
195  new  measuring  sites  providing  data  for  a  revision  of  the  classification  system  of  ecological 
status, biological quality elements, for the implementation of intercalibration procedures, as well as 
for development of a classification system of ecological potential for heavily modified and artificial 
water bodies. Hydromorphological monitoring was also carried out for the first time during the 2nd 
RBMP. In addition, the analysis of pressures and impacts improved and for the first time monitoring 
was revised in an intercalibration process.  

This all resulted in a very different methodology and results. For example, the number of biotic types 
of rivers has increased from 28 to 35. As a result, the determination of ecological status in the 3rd 
RBMP is more akin to the approach used in other Member States and data now come closer to the 
real situation than the 2nd RBMP suggested.  

Despite the significant improvements to monitoring, only 17.3% of the total length of Croatia’s rivers 
and only 18.5% of the total length of Croatia’s lakes are so far subject to surveillance monitoring to 
determine  the  ecological  and  chemical  status.  This  is  because  most  of  Croatia’s  “smaller”  water 
bodies are still not subject to any monitoring of ecological (or chemical) status. This is of concern as 
Croatia has an unusually large number of such smaller surface water bodies, that is rivers with a 
catchment area of less than 10 km2 and lakes with a surface area that is less than 0.5 km2. These 
smaller surface water bodies, however, make up 80 % of the total length of all recorded rivers and 
about 98 % of the total area of all recorded lakes.  

8 Surveillance monitoring is carried out for one year, once per six-year cycle and is mainly aimed at assessing impacts and 
long-term changes in natural conditions or resulting from anthropogenic pressures and is used for the purpose of designing 
future monitoring programmes. Operational monitoring is carried out throughout the cycle and aims mainly at establishing 
the status of bodies identified as being at risk of failing to meet their environmental objectives and assessing any changes 
in  status  resulting  from  the  Programmes  of Measures.  All  water  bodies  must  be  classified  for ecological  “status”  or  (if 
heavily modified) ecological “potential”. 

15 

 
 
 
 
Table 5. Coverage of surveillance or operational monitoring 

Source: 3rd RBMP e-reporting 

Where monitoring takes place, a comprehensive set of quality elements is being measured.  

Table 6. Monitoring of quality elements for ecological status (per water body) 

Gap to Target 

Croatia’s  gap  to  reach  good  ecological  status,  however,  remains  substantial,  namely  66.9%  SWB. 
Croatia does not expect that more than 33.1 % of its SWB will reach good ecological status already 
by 2027. By 2021, the number of SWB in good ecological status has dropped from 50% (1st RBMP) 
to 42% (2nd RBMP) and in the 3rd RBMP of 2021 to only 33.1%. The reasons for this deterioration 

16 

 
 
 
appear  largely  due  to  the  methodological  changes  and  stricter  monitoring  after  the  2nd  RBMP  as 
opposed to a genuine decrease of water quality.  

Figure 5. Ecological status or potential of surface water bodies in the 1st, 2nd and 3rd RBMPs 

 Source: 3rd RBMP e-reporting 

Regrettably, the ecological status of surface water bodies in Croatia has continued to deteriorate 
steadily since the 1st RBMP (50%) and 2nd RBMP (42%). In the 3rd RBMP, merely 33% SWB are reported 
to meet the objective of good (or better) status and Croatia does not expect major improvements by 
2027. As in the 2nd RBMP, main pressures remain discharges not connected to sewerage network, 
agricultural, transport and physical alterations (>50 % SWB) and the ecological status of SWB is also 
under pressure from water abstractions (7.9% SWB).  

It is of concern that 100% of transitional water bodies and 100% of coastal water bodies failed 
the objective of good ecological status in 2021 with no prospect for improvement by 2027. Little 
progress has been achieved since the 2nd RBMP when it comes to identifying the “unknown” 
anthropogenic (man-made) pressures on coastal and transitional surface water bodies: pressures 
remain “unknown” for 23 of 35 transitional and for 77 of 81 coastal waterbodies although 
monitoring of transitional waters and coastal waters has improved since the 2nd RBMP. 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

Table 7. Modifications of surface water bodies (2021)  

Modifications 

Rivers 

Lakes 

Transitional 

Coastal 

Heavily modified 

11% 

57% 

Artificial 

11% 

28% 

3% 

N/A 

5% 

N/A 

Equally striking is that, compared to the previous cycle, the number of heavily modified water bodies 
has almost doubled from 135 (2nd RBMP) to 256 (3rd RBMP).   This is particularly evident for lakes 
from 0 (0%) to 62 (57 %) and less prominent but still significant for rivers from 120 (8 %) to 189 

17 

 
 
(11 %). On the contrary, the number of heavily modified transitional water bodies decreased from 
11 (44 %) to 1 (3%), only heavily modified coastal water bodies remained 4 (5 %). 

According to the 3rd RBMP and other publicly available sources, the methodological changes to the 
designation as HMWB are explained by the need to improve the methodology and consequently the 
designation  of  HMWBs,  as  the  2nd  RBMP  still  contained  (due  to  late  EU  accession)  only  proposed 
HMWB,  based  on  the  assessment  of  hydromorphological  status,  biological  status  and  a  limited 
analysis of the anthropogenic activities. The methodological changes led to an increase of HWMB 
because  of  more  thorough  analysis  -  a  technical  study  for  on  the  influence  of  the  existing 
hydroelectric  power  plants  on  the  hydromorphological  state  of  the  waters  and  consequently  on 
designation of HMWBs and AWBs was made, a more thorough consideration of flood protection issues 
was  performed  and  data  on  navigation  use  were  used.  However,  more  detailed  information  on 
agricultural use (irrigation, drainage) were not considered yet, thus further amendments of the HMWB 
methodology are to be expected.  

Hydromorphological characteristics of surface water bodies concern the quantity and dynamics of 
water flow, the connection of surface water bodies to groundwater bodies, continuity of rivers, as 
well as river depth, river width and their variation in structure as well as the substrate of the riverbed 
structure of the riparian zone.  

In Croatia, the regulation of watercourses and changes in the water regime represent a key threat to 
water-dependant  habitat  types  such  as  river  gravels,  sand  shores  and  muddy  shores,  karst 
watercourses with tufa-creating communities and tufa barriers, as well as all types of wet grasslands 
and floodplain forests. Coastal habitats are under strong pressures due to expanding construction 
areas.9 

In the 3rd RBMP, Croatia defined 189 river bodies (11 %) and 62 lakes (57 %) as “heavily modified”. 
It  is  positive  that  Croatia  successfully  established  a  classification  for  the  ecological  potential  of 
artificial  and  heavily  modified  water  bodies.  Croatia  should  now  require  operators  of  plants  to 
implement projects that achieve this good ecological potential of artificial and heavily modified water 
bodies.  

For all other water bodies, that is 56% SWB, the target remains “good ecological  status”. Croatia 
must reduce pressures from all significant hydromorphological pressures reported in the 3rd RBMP 
for both RBDs (main drivers are agriculture, flood protection and hydropower).  

The percentages of natural,  heavily modified and artificial  water bodies are shown Table 9 below. 
There have been overall increases in the number of surface water bodies since the 2nd RBMP. Due 
to the increases in the number of surface water bodies overall, a direct comparison of the distribution 
of numbers of water body designations since the 2nd RBMP is complex. Overall, very few lakes in 
Croatia are natural while comparatively few rivers have been heavily modified. 

9 Section 2.5.2. of Croatia’s Nature Protection Strategy and Action Plan for the period 2017-2025, available at 
https://www.cbd.int/doc/world/hr/hr-nbsap-v3-en.pdf. 

18 

 
 
Figure 6. Percentage of surface water bodies in Croatia designated as natural, heavily modified or artificial 
in 2nd (2015) and 3rd (2021) RBMPs, per water category 

Source: 3rd RBMP e-reporting 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

The number of monitoring sites for quantitative monitoring has increased from 143 in the 2nd RBMP 
to 217 in the 3rd RBMP. Furthermore, the number of groundwater bodies with quantitative monitoring 
has increased in absolute number, from 22 GWBs in the 2nd RBMP (out of 33 groundwater bodies in 
total) to 33 groundwater bodies in the 3rd RBMP (out of 51 groundwater bodies in total). Therefore, 
all  previously  delineated  GWBs  by  the  2nd  RBMP were  covered  with  quantitative monitoring  until 
2021. The overall confidence in the assessment of the quantitative status of groundwater bodies has 
increased significantly since the 2nd RBMP. Hence, it can be concluded that Croatia’s knowledge of 
the quantitative status of groundwaters has much improved. 

Recharge of groundwater bodies has so far not been a problem in Croatia. While there were 1 out of 
33 in the previous cycle, in the 3rd RBMPs, only 1 out of 51 groundwater bodies (i.e., 2.0 % of total 
groundwater bodies) fails to achieve good status. This difference emanates rather from a change in 
typology and delineation performed to achieve a more focused management of the waterbody found 
in poor quantitative status. It is worth noting that Croatia invoked an Article 4(4) exemption for this 
groundwater body which is also to two Natura 2000 areas, for which conservation objectives have 
not been set, because good status pursuant to the WFD was considered sufficient. 

However, 5 groundwater bodies, that is roughly 10% of total groundwater bodies, are at risk of failing 
to achieve good quantitative status by 2027. This comprises four in the Danube RBD and one in the 
Adriatic RBD. The reasons quoted for this failure are: excessive water abstractions for the four GWB 
in the Danube RBD and saline intrusion for the one GWB in the Adriatic. 

Hence there is an upward trend on pressures from abstractions affecting groundwater bodies. While 
in  2021  only  1 GWB  (connected to  Natura  2000 preserves)  fails  good  quantitative  status  due  to 
abstractions, there is now a risk that this number will further increase to 5 GWB (9.8%) by 2027. 
4 GWB (7.8%) also missed the objective of good chemical status in 2021. Pollutants causing failure 
of groundwater to meet good chemical status are mainly nitrates but also saline intrusion. Croatia 
mapped measures to tackle nitrate pollution. 

19 

 
 
 
3.4 Protected Areas (identification, monitoring, objectives and measures) 

Since the 2nd RBMP the number of protected areas in Croatia has changed. While Natura 2000 sites 
have increased, drinking water protected areas have slightly decreased. Croatia reported the following 
protected areas under the 3rd RBMP:  

Table 8. Number of water bodies associated with protected areas in Croatia (2022) 

Surface water and groundwater protected areas have been identified for all relevant Directives in 
Croatia.  This  includes  protected  areas  under  the  WFD  Article  7  drinking  water  protection  zones, 
Bathing Water Directive, Natura 2000 sites (including Birds and Habitats Directives), Urban Waste 
Water Treatment Directive and economically significant aquatic species (under the now repealed Fish 
and Shellfish Directives). Croatia also identified Nationally Designated Areas (CDDA).  The table below 
summarises the information reported by Croatia in the 3rd RBMP electronic reporting. Given the very 
large area under protection in the country and the rich biodiversity, Croatia has a particularly high 
number of surface water bodies whose quality has direct repercussions on the status of Natura 2000 
sites, namely 1130 river water bodies and 76 lake water bodies.  

Croatia  has  made  progress  with  the  monitoring  of  protected  areas.  Monitoring  sites  for  surface 
waters associated with protected areas are reported for bathing waters, drinking water protection 
areas, freshwater fish designated waters, nationally designated areas (CDDA), Natura 2000 areas, 
nitrate  vulnerable  zones  and  sensitive  areas.  Monitoring  sites  reported  for  groundwater  bodies 
include those associated with drinking water protection areas, nationally designated areas (CDDA), 
Natura 2000 sites. When compared with the monitoring sites identified in the 2nd RBMP it is apparent 
that the 3rd RBMP monitoring includes for the first time monitoring for bathing waters, freshwater 
fish designated waters, and for nationally designated areas (CDDA).  

20 

 
 
Regrettably,  the  number  of  surface  water  bodies  connected  to  protected  areas  that  feature  good 
ecological  status  has  decreased  since  the  2nd  RBMP.  While  in  the  2nd  RBMP  almost  20%  of  SWB 
connected to protected areas reached good ecological status, the 3rd RBMP reports less than 10% of 
SWB connected to protected areas to reach this objective. In a similar vein, the percentage of SWB 
linked to protected areas in “poor” status almost doubled from ca. 20% to slightly more than 40%. It 
is uncertain whether this decline is due to more accurate monitoring (and/or a change in the number 
of protected areas), or whether there has been an actual deterioration due to stronger pressures. The 
chemical  status  of  SWB  and  GWB  linked  to  protected  areas  is  much  closer  to  target  (see  below 
Figure 7). 

Figure 7. Status of water bodies (SWB and GWB) linked to protected areas.  

2022

0%

20%

40%

60%

80%

100%

Ecological status/potential SWB

e
p
y
T
s
u
t
a
t
S

Chemical status SWB

Chemical status GWB

Quantitative status GWB

% of water bodies associated with PAs

High

Good

Moderate

Poor

Bad

Unknown

Source: 3rd RBMP e-reporting 

3.5 What is being done to prevent/reduce hydromorphological pressures 

In  respect  of  surface  water  bodies  that  are  subject  to  morphological  pressures,  Croatia  reports 
operational measures in both RBDs.  

These operational measures include KTM 5 - "Improving longitudinal continuity (e.g. establishing fish 
passes,  demolishing  old  dams)", KTM7  -  “Improvements  in  flow  regime  and  / or  establishment  of 
ecological flows”, KTM 14 - "Research, improvement of knowledge base reducing uncertainty" and 
KTM 23 - “Natural water retention measures”.   

It is noteworthy that the large bulk of these measures still focuses on research of underlying issues 
and on improved monitoring. There are still relatively few technical measures that actually implement 
changes  to  reduce  pressures  (e.g.:  creation  of  retention  basins  to  capture  the  rainwater  runoff  in 
urban areas, measures to reduce impact on fish populations, limiting the potential alteration of water 
flow where permits are in place and the impacts of changes in flow regime). Yet, in view of Croatia’s 
accession date, this backlog was to be expected. It is, however, regrettable that Croatia’s measures 
will not go beyond improving longitudinal continuity only (i.e.: KTM 96 but not KTM6).  

21 

 
 
 
3.6 What Croatia is doing for abstractions and water scarcity 

The  3rd  RBMP  does  not  specifically  elaborate  on  issues  of  water  scarcity.  Water  abstraction  is, 
however, a significant pressure affecting 7.9 % of SWB failing to achieve good ecological status or 
potential. Most water is abstracted for public water supply, followed by the manufacturing sector. 
Table 16 shows the trends since 2000 (EEA data 2020).10  

Figure 8. Water abstraction in Croatia by economic sector 2000-2019  

Source: EEA Water abstraction index 

Figure 9 . Source of water abstraction in Croatia (2000-2019) 

Source: EEA Water abstraction index 

10 Conventional statistic abstraction data of Eurostat, EEA and OECD exclude water disappearing after abstraction via 
leakages or evaporation from the surfaces of reservoirs and canals. Leakage and evapotranspiration losses can however 
be significant in MSs with many reservoirs and/or older distribution systems, as is illustrated by French data. Page 14, 
French analytical note on total water consumption (incl. evapotranspiration and losses) adding up to 54.000 million m3 
abstracted, instead of 30.000 million m3 used: https://www.strategie.gouv.fr/sites/strategie.gouv.fr/files/atoms/files/fs-
2024- 
na_136_enjeux_et_usages_de_leau_avril.pdf 

22 

 
 
 
 
According to Croatia’s 3rd RBMP and reporting under the Drinking Water Directive, a significant volume 
of freshwater is lost between the point of abstraction and the point of use. The water losses in the 
public water supply system are estimated around 50 %. The average leakage rate for drinking water 
networks is 23% in the EU (2018).  Croatia must significantly improve its water transportation and 
distribution network.  

According to the Article 169 of Croatia’s Water Act, a permit is required for any use of water going 
beyond  personal  needs/consumption,  which  is  defined  in  Article  88  as  “household  use”,  “bathing”, 
“sports” and “recreation”. Users holdings abstraction permits are also obliged to keep records and 
must regularly report to Croatian Waters.11 Water rights permits shall be reviewed and harmonised 
within a RBMP planning cycle, that means every 6 years and can then be cancelled or revised as 
appropriate. The Water Act contains clear rules on the modification of permits. Permits for industrial 
water use/water rights define the location, place, method, conditions and scope of water use and are 
issued for a definite period, with the possibility to modify/restrict the approved conditions, if that is 
in public interest due to water regime modifications.  

Permits for abstractions to drain land are for a period of 3 to 5 years. Permits for “public irrigation 
services” are equally for 3 to 5 years. Permits for “works” in public irrigation activities shall be for a 
maximum period of 20 years. “Public” irrigation services are activities for abstraction groundwater 
and surface water for the purpose of irrigating agricultural land through irrigation structures owned 
by regional self-governing bodies or mixed structures owned by the Republic of Croatia.12  

Funded by Croatia’s national Recovery & Resilience Plan 2021-2026, devices for measuring water 
abstractions at wells are gradually being implemented. However, it appears that so far mainly water 
abstraction sites in the public water supply sector carry such measuring devices, not necessarily also 
wells for agricultural irrigation. As far as the latter are concerned, Croatia estimates the quantities 
of water abstracted using as a proxy the size of agricultural land and an assumed water consumption 
per hectare per year.  

Croatia has not yet defined let alone implemented ecological flows. Croatia, however, plans to develop 
e-flows as part of its measures under the 3rd RBMP. Ecological flows are considered within the context 
of  the  WFD  as  “an  hydrological  regime  consistent  with  the  achievement  of  the  environmental 
objectives of the WFD in natural surface water bodies as mentioned in Article 4(1)”. 13 The lack of 
established e-flows is not only problematic for the ecological status of surface water bodies (as fish 
and  invertebrates  need  sufficient  flows  to  survive), but  also  matters  as  e-flows  in  surface  waters 
depend  on  the  quantitative  status  of  groundwater  bodies.14  Prior  to  granting  water  abstraction 
permits from surface and ground water bodies, Croatia must therefore know the e-flows for surface 
water  bodies,  to  assess  whether  the  permission  to  abstract  water  could  endanger  the  ecological 
status of surface water bodies.  

The  respect  of  e-flows  will  also  ensure  that  Croatia  is  better  prepared  to  address  future  water 
scarcities, by anticipating the need to timely adapt water abstraction permits for surface and ground 

11 RBMP until 2027, page 422. 
12 The Water Act also foresees that companies, cooperatives and associations can be formed for the construction, 
management and maintenance of irrigation systems which are in the interest of multiple stakeholders. OG 66/19, 84/21, 
47/23; Zakon o vodama (nn.hr). 
13 See CIS Guidelines no 31 Ecological flows in the implementation of the Water Framework Directive 
14 The long-term annual average rate of abstraction from groundwater must not exceed the ”available groundwater 
resource”. The “available groundwater resource” (Articles 1 (27) WFD) is defined by reference to the “long-term annual 
rate of flow” required “to achieve the ecological quality objectives for associated surface water bodies”. 

23 

 
 
water bodies under pressure. This will be particularly important for the Adriatic RBD which is drier 
than the Danube RBD and is more vulnerable to droughts. 

Although  the  3rd  RBMP  includes  measures  to  improve  metering,  monitoring,  control  and  use  of 
rainwater,  there  is  no  consideration  of  temporary  restrictions  to  abstractions.  Furthermore,  no 
definition of water scarcity is offered, nor any indication that modelling of future water scarcity is 
taking place.  

Due to climate change, water scarcity conditions may also aggravate in the country, as indicated by 
the Danube Climate Change Adaptation Strategy developed and updated by ICPDR. It is therefore 
welcome that Croatia plans to develop of a Drought Management Plan in the future. 

3.7 Adaptation to climate change 

As regards flood risks, climate change impacts on flooding were not yet considered in Croatia’s first 
FHRMs due to unreliable data. Over the last few years, however, there has been significant progress 
in climate change modelling. This has resulted in the inclusion of climate change impacts in Croatia’s 
flood modelling of coastal areas which are recognised as most endangered regarding climate change. 

Croatia’s  FRMP  identifies  two  key  challenges  of  climate  change:  sea-level  rise  and  increased 
frequency of urban flooding due to storms. The plan moreover identifies key areas expected to face 
a significant increase in flood risk due to climate change, and provides a map of these areas15. All 
areas at increased risk are located in the Adriatic UoM (HRJ). It also provides estimates of the total 
square kilometres of area facing a significant increase of flood risk16. The second FRMP indicates that 
the remaining areas of the country face a moderate increase of flood risks. Consequently, there is no 
area where climate change impacts on flood risk can be ignored. The plan identifies responses to 
address  the  two  climate  challenges,  including:  capacity-building  in  research  and  management; 
development  of  structural  and  non-structural  measures;  implementation  of  integrated  water 
management  measures;  and  strengthening  the  protection  of  freshwater  and  marine  systems  to 
protect  them  from  climate  impacts  and  for  adaptation  purposes.  The  first  FRMP  assessment 
recommended integrating ongoing studies of potential  impacts of climate change into new FRMP. 
That recommendation has been fulfilled. The second FRMP also takes a more in-depth approach to 
addressing climate change impacts, building on Croatia’s 2020 Climate Change Adaptation Strategy 
and  the  2019  interpretation  of  climate  change  analysis  for  water  management  planning  and 
incorporating some of their measures. 

As  regards  droughts  and  water  scarcity,  Croatia’s  3rd  RBMP  builds  upon  the  conclusions, 
recommendations and measures of Croatia’s national  Climate Change Adaptation Strategy 2020-
2040.  However,  there  are  limited  details  on  how  the  national  strategy  has  informed  the  RBMP’s 
development  (the  selection  of  measures  relevant  for  climate  change  adaptation  and  how  any 
analyses on the impacts of climate change on water bodies have been utilised).  

Climate change adaptation measures have been included in the RBMP, building upon the conclusions, 
recommendations and measures for the water sector from the Climate Change Adaptation Strategy 
2020-2040 (with a perspective to 2070). The Strategy was used to assess against climate change 
impacts under four scenarios. 17 

15 Section C.5, Figure C.14. 
16 Section C.5, Table C.21. 
17 Ministry of Economy and Sustainable Development (2020) Climate Change Adaptation Strategy in the Republic of 
Croatia for the Period Until 2040, With a View to 2070. https://www.voda.hr/sites/default/files/dokumenti/PUVP3%20-
%20OUE%20-%200008.pdf 

24 

 
 
Climate change adaptation measures included in the RBMP include research18, monitoring (upgrades 
of monitoring of groundwaters in Danube RBD and Adriatic RBD in order to improve monitoring of 
climate change impacts), and educational aspects (spatial planners and civil engineers specialised 
for  water  infrastructure  on  new  trends  and  climate  change  adaptation  solution  of  urban  water 
systems). In addition, measures to improve water retention capacity to reduce pressures on sewage 
systems (nature-based solutions) are included. A climate proofing of measures is foreseen during 
implementation.  

Croatia does not define the concept of “water scarcity” or “droughts” in the RBMP or a DMP which 
makes planning ahead more difficult. However, a drought management plan is under development. 

Studies undertaken by the United Nations suggest that a sea level rise of more than 80 cm would 
have  a  pronounced  effect  on  Croatia’s  coastal  areas  by  increasing  risks  of  inundation  and  surge 
flooding, affecting in particular islands and coastal areas where erosion is taking place. For instance, 
existing  sand  and  gravel  beaches  could  be  inundated.  In  some  locations,  projected  sea-level  rise 
might also affect the groundwater supply for agricultural irrigation.19 

It is welcome and  good  practice that Croatia considers climate adaptation measures which imply 
hydromorphological changes to surface or groundwater bodies only after an environmental Impact 
assessment. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring 

Croatia  successfully improved  the  scale  of  its monitoring  network to  support  the  chemical  status 
assessment since the 2nd RBMP. The 3rd RBMP suggests that the monitoring network now covers 
around 40 % of all water bodies nationally, including much greater coverage of both rivers and lakes. 
Croatia in particular booked progress as the 3rd RBMP now reports that all 45 priority substances are 
included  in  monitoring,  whereas  in  the  previous  reporting  cycle  only  29 out  of  (then)  33  priority 
substances  were  included,  with  polybrominated  diphenyl  ethers  (PBDEs),  short-chain  chlorinated 
paraffins, tributyltin, and trifluralin being missing substances. All four missing substances along with 
the  12  new  substances  added  to  the  priority  substances  list  in  2013  have  been  added  to  the 
monitoring programme for the 3rd RBMP.  

Croatia also takes credit for including more priority substances in the inventories of each RBD. While 
in the 2nd RBMP, only 6 of the 41 Priority Substances were included in inventories of each RBD, the 
electronically  reported  data  for  the  3rd  RBMP  now  contain  emissions  inventories  for  53  chemical 
substances in the Danube RBD and for 54 chemical substances in the Adriatic RBD.  

Croatia has, however, made comparatively less progress with identifying the source of pressures on 
transitional  and  coastal  water  bodies.  Regrettably,  anthropogenic  (man-made)  pressures  remain 
unknown for 23 out of 35 transitional water bodies and for 77 out of 81 coastal water bodies.  

18 Modelling of the relationship between climate groundwater status; modelling of the relationship between groundwater 
and sea level rise; assessment of climate change impact on change of abiotic and biotic characteristics of water 
ecosystems in Protected Areas and Natura 2000 network). 
19 See Potential Implications of Sea-Level Rise for Croatia by Ante Baric, Branka Grbec, and Danijela Bogner Institute of 
Oceanography and Fisheries, Split, Croatia available at untitled (unizd.hr).  

25 

 
 
Status 

The 3rd RBMP reports an increase in the number of water bodies failing to achieve good chemical 
status across all categories. It appears that chemical status results steadily decreased as Croatia’s 
monitoring  improved.  There  is  notably  a  pronounced  deterioration  of  the  chemical  status  of 
transitional and coastal waters, where the precise anthropogenic pressures remain unknown.  

Figure 10. Chemical Status SWB in Croatia 1st, 2nd and 3rd RBMP 

26 

 
 
 
 
 
 
Figure 11. Number of SWB in Croatia in good status 1st, 2nd and 3rd RBMP  
blue = good status; red = not in good status (including unknown status) 

Source: WISE electronic reporting.  

Croatia reported that - in addition to other sources of pollution – it is agricultural pollution that causes 
1112  out  of  1978  surface  water  bodies to  fail  good  chemical  status  in the 3rd  RBMP  (see  below 
section 4.3.).  

Compared to the 2nd RBMP, the lower values for good status of rivers and lakes are apparently due 
to  Croatia’s  ability  of  measuring  now  also  ubiquitous  persistent  bioaccumulative  and toxic (uPBT) 
substances,  namely  polybrominated  diphenyl  ethers  (PBDEs)  and  perfluorooctane  sulphonic  acid 
(PFOS), which had apparently not been monitored in previous RBMP cycles.  

Similarly, the pronounced deterioration of the chemical status of transitional and coastal waters is 
due  to  these  uPBTs  as  well  as  due  to  the  uPBT  Tributyltin  (TBT),  a  biocide  in  anti-fouling  paint, 
commonly known as bottom paint, applied to the hulls of oceangoing vessels to poison organisms 
that otherwise end up settling. When TBT accumulates in sediments, its half-life is about 2 years. 
However, TBT often bonds to suspended material and sediments, where it can remain and be released 
for up to 30 years. TBT was globally banned on ship hulls from 2003 onwards, only.  

While Croatia’s biodiversity assessment under the Marine Strategy Framework Directive (MSFD) is 
still evolving, the Good Environmental Status (GES) Decision for Croatia of 2018 adopted under the 
MSFD reported some values for birds. These data seem to suggest that around 2/3 of surface feeding 

27 

 
 
birds in Croatian territorial waters are not in a good environmental status.20 This could be due to the 
bad chemical status of Croatia’s transitional and coastal waters, as reported in this RBMP cycle.  

Croatia does not expect that more SWB can achieve a good chemical status until 2027. 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

64.7% of Croatia’s GWBs are subject to chemical monitoring (33 out of 51) which compares to 84.8 
% GWBs in the 2nd RBMP. Note, however, that the numbers for the 3rd RBMP do not yet include the 
18 newly created GWB.  

Status 

In the 3rd RBMP, 47 out of 51 GWBs reported in total (i.e., 92.2 % of total groundwater bodies) have 
been in good chemical status and 4 GWBs (i.e., 7.8 % of total GWBs) have been in poor chemical 
status by 2021 (see Figure 12). Croatia does not expect improvements until 2027. In the 2nd RBMP, 
3 out of 33 GWBs reported in total (i.e., 9.1 % of total GWBs) were in poor chemical status by 2015. 
Note that the number of GWB increased significantly  between the 2nd  and 3rd RBMP and that the 
assessment of 18 GWBs was outstanding at the time of reporting the 3rd RBMP.  

Figure 12. Chemical status of ground water bodies in the 2nd and 3rd RBMP 

Source: 3rd RBMP e-reporting 

There are three pollutants (or indicators of pollution) causing failure to achieve good chemical status 
of GWBs, namely nitrates, water temperature and electrical conductivity. Electrical conductivity is the 
indicator of pollution causing failure to achieve good chemical status in the GWB which is affected 
by saline intrusion. Water temperature is the indicator of pollution causing failure to achieve good 

20 These numbers shoud be treated with caution, though, as Croatia’s reporting under the MSFD is still evolving. See the 
MSFD Dashboard at Good Environmental Status (GES) assessments by EU Member State and Descriptor (europa.eu).  

28 

 
 
 
chemical status in one GWB. The 3rd RBMP does not elaborate on the origin of this failure and the 
specific measures taken to address it.  For the other 2 out of these 3 GWBs failing to achieve good 
chemical status due to the general water quality assessment, the failure is caused by pollution with 
nitrates.  

4.3 What Croatia is doing to combat pollution from agriculture 

As set out above, Croatia’s gap to achieve a good ecological status of its surface water bodies is very 
substantial,  namely  66.9%.  Agricultural  pressures  contribute  to  a  significant  amount  to  the 
magnitude of this gap. The 3rd RBMP reports that 2 out of 51 GWBs fail good status due to nitrate 
pollution from agriculture. For surface water bodies, it is reported that 1112 out of 1978 surface 
water bodies fail status due to diffuse agricultural pollution. Croatia’s 3rd RBMP refers in particular 
to agricultural pressures on water quality due to the use of manure and mineral fertilisers as well as 
pesticides; runoff from livestock grazing is also noted.  

The  focus  of  the  3rd  RBMP’s  measures  for  nitrates  pollution  is  on  support  for  investments  for 
compliance (manure storage and its management) and adjusting of the agricultural practices both in 
terms of the technology / techniques used and management practices. Croatia has mapped 12 basic 
measures to reduce nutrient pollution from agriculture as well as 8 supplementary measures. These 
include, for instance, compliance with standards for the storage and use of manure on farms through 
the  construction  of  manure  tanks;  measures to  reduce  the  use  of  mineral  and  organic  fertilisers; 
implementing agrotechnical measures, such as crop rotation and improving the methods of applying 
mineral fertilisers as well as organic fertilisers; intensify the supervision of the implementation of 
Good Agricultural and Environmental Conditions (GAECs) especially in the part related to the reduction 
of the use of mineral and organic fertilisers; In areas with intensive agricultural production, plan and 
encourage the establishment of windbreaks in order to reduce the impact of wind erosion on soil and 
water. Croatia has reported that KTM2 measures should be applied on around 12,000 km² of the 
area, which is about twice the surface area of Croatia’s Nitrates Vulnerable Zones (NVZs). 

Geographically, the focus of the measures in the RBMP is on Nitrates Directive vulnerable zones and 
areas outside where the WFD-objectives are likely not going to be met, with the ambition to later 
expand across the country. There is, however, no information on the gap between the current use of 
pesticides  and  the  reduction  needed  to  achieve  good  status  (electronic  RBMP  reporting  does  not 
include any gap in relation to pesticide pollution).  

The RBMP includes measures to address agricultural pollution, but the 3rd RBMP does not include an 
assessment of the expected  effects of the planned  measures and how far they will  contribute to 
closing  the  gaps.  The  measures  are  generically  described,  and  it  is  reported  that  they  should  be 
applied  to  all  agricultural  areas.  Based  on  the  reported  information,  and  notable  the  lack  of 
information and assessment of the expected effects of the planned measures, it is not possible to 
assess the expected progress of the 3rd RBMP in relation to reducing pollution from agriculture and 
close the gap towards compliance with the WFD objectives. 

4.4 What Croatia is doing to combat pollution from other sectors 

To reduce pressures, Croatia has mapped KTMs for the identified pressures from pollution in sectors 
other than agriculture. These KTMs include:  

•  KTM1 – “Construction or upgrades of wastewater treatment plants”; 
•  KTM14 – “Research, improvement of knowledge base reducing uncertainty”;  

29 

 
•  KTM15  –  “Measures  for  the  phasing-out  of  emissions,  discharges  and  losses  of  Priority 
Hazardous Substances or for the reduction of emissions, discharges and losses of Priority 
Substances”; 

•  KTM16 – “Upgrades or improvements of industrial wastewater treatment plants (including 

farms)”; and  

•  KTM21 – “Measures to prevent or control the input of pollution from urban areas, transport 

and built infrastructure”. 

Basic  measures  to  reduce  point  source  discharges  include  a  multi-year  programme  for  the 
construction  of  urban  wastewater  infrastructure  for  the  period  up  to  2030  with  the  objective  to 
achieve full compliance with the Urban Wastewater Treatment Directive. Agglomerations larger than 
15000 population equivalent regardless of the sensitivity of the receiving waters are identified as 
priority for measures to be implemented, except for agglomerations of 15000 - 50000 p.e. in touristic 
areas where wastewater is discharged into the sea that has not been declared to be a sensitive area. 
In  relation  to  the  pollution  from  industrial  sources,  Croatia  reports  that  12  measures  address 
industrial pollution, including measure 3.OSN.05.13 related to compliance with industrial wastewater 
discharge standards, a measure already foreseen in Croatia’s 2nd RBMP. There are 11 measures (ten 
basic  and  one  supplementary)  which  are  dedicated  in  the  Programme  of  Measures  to  prevent  or 
control the input of diffuse pollution from urban areas, transport and built infrastructure, and forestry. 
Most (six) of these are a continuation of measures from the 2nd RBMP, whilst five measures were 
introduced on the basis of the SEA Report for the RBMP. Overall, 10 of the measures are going to be 
implemented  in  both  RBDs.  The  only  exception  to  this  is  measure  3.OSN.06.13  for  establishing  a 
Registry of Marine Litter, which will be implemented in the Adriatic RBD. There is no information on 
whether Croatia expects these measures to be sufficient for achieving the objectives. 

11 measures aim at preventing and/or controlling the input of pollution from urban areas, transport 
and  built infrastructure.  6  of  these  11 measures  continue measures  of  the  2nd  RBMP,  whilst  the 
following 5 measures are new:  

•  monitoring of pesticides in forestry; 
• 
control of pesticides for forestry in inundation and retention areas; 
•  prepare a methodology for assessing emissions from landfills into water; 
• 
•  encourage  the  implementation  of  green  infrastructures  to  solve  the  problem  of  surface 

control of herbicides and retardants used for maintenance of railway corridors; 

runoff from urban areas21  

The majority of the measures will be implemented in both RBDs, only one measure for establishing 
a registry of marine litter is specific to the Adriatic RBD.  

This all suggests that Croatia is on the right track to tackle pressures on the chemical status of SWB 
and  GWB  from  sources  other  than  agriculture.  A  notable  exception  are  pressures  on  coastal  and 
transitional water bodies. The 3rd RBMP also does not explain to which extent measures can exactly 
close the gap. This all should be improved in the next cycle.  

To reduce pressures at the coast, Croatia must also both look inland (agriculture) and at tourism and 
lack of urban infrastructures. I particular the coastal region around Split has been known to be one 
of the most polluted areas of the eastern coast of the Adriatic. The environmental pollution has been 
a consequence of fast industrialisation and urbanisation without development of appropriate urban 

21 During rain, storms, and other precipitation events, these surfaces (built from materials such as asphalt and concrete), 
along with rooftops, carry polluted stormwater to storm drains, instead of allowing the water to percolate through soil. 

30 

 
 
 
infrastructures.  The  existing  wastewater  treatment  plants  in  this  region  still  do  not  meet  EU 
requirements and lack adequate purification capacity. Discharge of untreated wastewater into the 
sea has been observed.22 

4.5 What Croatia is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

The  overall  assessment  of  Croatia’s  Programem  of  Measures  under  the  3rd  RBMP  is  positive,  as 
Croatia  achieved  a  number  of  significant  improvements  since  the  2nd  RBMP.  In  the  3rd  RBMP  e-
reporting, Croatia mapped measures in both RBDs against all KTMs and basic and specific measures 
are listed in great detail.  

It  is  unclear  why  Croatia  omitted  to  map  KTM  19  (“measures  to  prevent  adverse  impacts  of 
recreation”)  to  reduce  pressures  on  the  ecolgical  status  of  coastal  and  transitional  water  bodies. 
Croatia’s coastline is affected by  mass tourism and this pressure can grow. For instance,  KTM 19 
could address pollution of coastal waters by cruise ships. 100% of Croatia’s coastal and transitional 
water bodies fail good ecological status.  

Gap analyses are presented for all significant pressures, with quantitative pressure indicators and 
measure  indicators  and  gap  values  for  2022,  but  no  gap  analsys  has  been  presented  for  2027. 
Information is also presented for groundwater bodies with pressure indicators, measure indicators 
and gap values for 2022. No gap analysis has been presented for 2027.   

Some  elements  are  still  missing  though,  in  particular  the  use  of  cost  effectiveness  and  the 
prioritisation of measures. Croatia has reported estimated funding requirements from national and 
EU funds for the implementation of measures. However, no details are provided confirming whether 
this funding has been secured. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Croatia 

Croatia  invoked  the  exemption  of  Article  4(4)  WFD  which  allows  Member  States  more  time  if  all 
necessary improvements in the status of bodies of water cannot reasonably be achieved within the 
timescales set out in article 4 (4) WFD for reasons of technical feasibility, disproportionate cost or 
natural conditions of the water body. Croatia used all three reasons to justify non- compliance with 
Article 4 WFD objectives. To the contrary, Croatia did not invoke exemptions according to Article 4(5), 
Article 4(6), 4(7) WFD and Article 6(3) of the Groundwater Directive.  

As regards surface water bodies, for the ecological status, Article 4(4) exemptions have been applied 
in relation to 105 surface water bodies (5.3 % of surface water bodies) on the grounds of natural 
conditions  and  in  relation  to  1406  surface  water  bodies  (71.7  %  of  SWBs)  on  the  grounds  of 
disproportionate costs. For chemical status, Article 4(4) exemptions have been applied in relation to 
158 surface water bodies (8% of surface water bodies) on the grounds of technical feasibility and in 
relation to 216 SWBs (10.9 % of surface water bodies) on grounds of disproportionate costs.  

22 https://ec.europa.eu/regional_policy/en/projects/croatia/water-infrastructure-in-croatias-split-solin-agglomeration-to-be-
upgraded.  

31 

 
 
 
As regards groundwater bodies, for 1 groundwater body (2 %), Article 4(4) exemptions have been 
applied  in  relation  to  the  failure  to  achieve  good  quantitative  status  on  the  grounds  of  technical 
feasibility,  natural  conditions  and  disproportionate  costs  (same  groundwater  body).  For  chemical 
status, exemptions have been applied in relation to 1 GWB (2 % of GWBs) on the grounds of natural 
conditions and in relation to 3 groundwater bodies (5.9 % of groundwater bodies) on the grounds of 
both technical feasibility and disproportionate costs (same groundwater bodies). 

Regrettably there seems to be no detailed information at the water body level clarifying how each of 
these  exemptions  have  been  justified.  Thus,  the  Commission  cannot  conclude  whether  these 
exemptions have been lawfully applied.  

It is of note that Article 4 (4) c WFD limits exemptions according to Article 4 (4) WFD to “two further 
updates” of the river basin management plans except in cases where natural conditions are such that 
the objectives cannot be achieved.  

Croatia joined the European Union on 1 July 2013 and its first cycle lasted from 2012 – 2015 with 
the first RBMP published in 2016. This is only Croatia’s second cycle of the RBMP (Croatia’s RBMP is 
being referred to as “3rd” RBMP to align with the terminology used for all other MS I the present cycle). 
This means that the possibility for Croatia to exempt from Article 4 objectives according to Article 4 
(4) WFD expires at the very latest with Croatia’s next RBMP, i.e.: by 2033.  

5.2 Use of economic analysis and water pricing – cost recovery 

Croatia’s 3rd RBMP includes a chapter on economic analysis. There is a global presentation of pricing 
schemes.  Price  differences  exist  between  the  two  RBDs  reflecting  differences  in  financial  costs  of 
providing water services. Water fees and tariffs are set and regulated by the Croatian Government. 
Croatian Waters are in charge of calculation and collection of the tariffs.  

Water services as well as uses with significant impact on water bodies have been clearly identified. 
The reporting of financial cost consists of costs totals for the broad water services, drinking water 
supply and sanitation services, as well as for irrigation services, at basin and sub-basin level.  Water 
pricing schemes are presented in a transparent way, but neither adequacy of neither price incentives 
nor of the contribution of different users and polluters is explained.  

The  3rd  RBMP  foresees  two  types  of  investments,  namely  investments  in  water  supply  and 
wastewater  collection  and  treatment  that  could  be  funded  by  economic  instruments23  and 
investments in improvement of costing24. The latter include the introduction of individual metering25 
and  setting  up  various  IT  tools,  such  as  improved  management  benchmarking26,  a  system  for 
economic  analysis  with  clear  reporting  requirements27,  and  setting  up  the  system  for  economic 
analysis that could be used for development for water policy, analysis and projections of “tariffs” of 
users for different governmental decisions28. 

It  remains  generally  uncertain  how  much  funding  has  actually  been  secured  already  and  which 
measures in the 2nd RBMP have meanwhile been implemented. 

23 3rd RBMP chapter on economic analysis, 3rd RBMP, pp. 376-379. 
24 3rd RBMP, summary programme of measures, pp. 405-407. 
25 Measure 3.OSN.01.08 of implementation of the programme of introducing individual water meters, a continuation of a 
measure from 2nd RBMP. 
26 Measure 3.OSN.01.06. 
27 Measure 3.OSN.01.09. 
28 Measure 3.OSN.01.17. 

32 

 
 
 
6. WFD recommendations 

Recommendations: Croatia should 

1.  Accelerate action and enhance the overall level of ambition for restoring to good ecological status 
(natural water bodies) or good ecological potential (heavily modified water bodies) all rivers, lakes, 
transitional and coastal water bodies. This presupposes that Croatia:  

a)  conducts a more comprehensive gap assessment for diffuse pollutant loads from agriculture 
(nutrients, agri-chemicals, sediment, organic matter) across waters in RBDs and links them 
clearly and directly to mitigation measures in the 3rd RBMPs (as per WFD Article 11(3)(h)), to 
facilitate the achievement of WFD objectives; and 

b)  adopts and implements a legally binding standard for establishing the volume and rate of 
flow in surface water bodies (“ecological flows” - see also CIS Guidance Document no. 
31) within the meaning of Article 8 (1) first indent (i) WFD (in coordination with transboundary 
river basin authorities of other neighbouring countries) linking also water abstraction permits 
to the respect of e-flows; and 

c)  adopts  and  implements  a  legally  binding  standard  for  the  ecological  potential  of  river 

stretches that are qualified as “heavily modified” within the meaning of Article 4 (7) WFD;   

d)  maps and commits funding for concrete measures to improve the longitudinal continuity of 
rivers  that  are  under  pressures  from  dams,  physical  alteration  of  channel/bed/riparian 
area/shore, and other forms of hydrological alterations. There should be a concrete timeline 
for  such  measures  with  funding  commitments  following  a  cost  effectiveness  analysis  of 
alternative options.; and 

e)  maps measures under KTM 19 to prevent adverse impacts of recreation (mass tourism, cruise 

ships) affecting Croatia’s coastal and transitional water bodies;  

f)  maps measures to curb pressures from saline intrusion into ground water bodies;  

g)  monitors  and  contains  more  aggressively  invasive  alien  species  and  in  particular  adopt 

measures to constrain the spreading of North American crayfish; and 

h) 

Implements  all  programmed  amounts  for  sustainable  water  management  and  climate 
adaptation under the Cohesion Policy 2021-27.  

2.  Moreover, to reach objectives for the chemical status of Croatia’s surface and groundwater bodies, 

Croatia should increase its ambition to: 

a)  Enhance and upgrade wastewater treatment such that no more wastewater is being released 
into surface or ground water bodies without being processed, and particularly so in the region 
around Split and Solin;  

b)  Reduce nitrates beyond measures required under the Nitrates Directive where necessary to 
meet WFD objectives by adopting more nutrient related measures funded under the Common 
Agricultural Policy such as broader buffer strips for arable land that is being farmed with 
pesticides; and  

c) 

Identify and curb remaining point sources of pollution for ubiquitous PBTs such as mercury 
and brominated diphenylethers as well as PFOS; monitor specifically whether uPBT Tributyltin 
(TBT), a biocide in anti-fouling paint, still originates from the bottom paint of certain ship 

33 

 
hulls and more controls of ships and boats in Croatia’s harbours should be conducted to verify 
if boats still carry TBT on their hulls (and if so order their owners to remove it at their cost); 
pollution from uPBT mercury can be addressed by reducing combustion processes in traffic 
and heating of houses. 

3.  On the use of economic tools, Croatia should apply the polluter pays principle more consistently and 
consider better pricing of water related service according to Article 9 WFD where public funding or 
other WFD tools are not enough to achieve good status or good potential of water bodies; this applies 
in  particular  for  measures  to  enhance  river  continuity  and  wastewaters  and  point  pollution  from 
industrial plants and large agricultural plants.  

4.  As regards adaptation to climate change, it is recommended that Croatia: 

a) 

reduces water abstractions as significant pressure affecting 7.9 % of SWB failing to achieve 
good ecological status or potential by adapting water abstraction permits; reduce remaining 
carve-outs for “non-significant abstractions” from permitting where needed to achieve a good 
status; step up monitoring to curb unauthorised abstractions; 

b) 

reduces water  losses  in the  public  water  supply  system  estimated  at  ca.  50  % 
which is roughly twice as much the average in the European Union,  

c)  Addresses  more  proactively  the  increasing  risk  of  salinisation  of  groundwater  bodies  in 
coastal areas due to sea level rise by curbing abstractions from these ground water bodies; 
it is also recommended to exchange best practices with other EU Member States in similar 
situation like Portugal, Spain or The Netherlands.  

5.  As regards Croatia’s progress with applying the Water Framework Directive, Croatia should in the next 

cycle of River Basin Management Planning in particular  

a)  Analyse and report pressures on the 18 newly delineated Ground Water Bodies  

b)  Step up efforts to identify the originators of anthropogenic pressures which remain “unknown” 
for 23 out of 35 transitional and 77 out of 81 coastal water bodies, which is very problematic 
in view of the fact that 100% of Croatia’s transitional water bodies and 100% of its coastal 
water  bodies  failed  the  objective  of  good  ecological  status  in  2021  with  no  prospect  for 
improvement by 2027; Croatia should amongst others assess the impact of mass tourism 
and of pollution caused by cruise ships as well as pollution caused by insufficient wastewater 
treatment on smaller coastal islands and in touristic coastal regions; measures should then 
be taken to reduce these anthropogenic pressures significantly; 

c)  Link measures more specifically to problems in the gap analysis as regards diffuse pollutant 
loads (nutrients, agri-chemicals, sediment, organic matter) from agriculture and include in 
particular an analysis of pesticides in order to quantify the gap needed to achieve good status 
and add data on the gap to its electronic RBMP reporting;  

d) 

Improve  the  programme  of  measures  by  providing  a  more  thorough  cost  effectiveness 
analysis to prioritise  measures and by clarifying which of the  reported estimated funding 
requirements for the implementation of measures has been secured yet, or not; and provide 
information on which measures announced under the previous programme of measures have 
been implemented and which ones not (yet).   

6.  Use  all  funding  instruments  agreed  in  the  context  of  the  European  Green  Deal  to  join  up 
implementation efforts for the benefit of the Water Framework Directive and increase effectiveness 
and efficiency. 

34 

 
SECTION B: 
FLOODS DIRECTIVE 

35 

 
 
 
 
7. Flood risk management under floods directive (FD) 

The Directive requires each Member State (MS) to scan its territory for flood risks, assess the potential 
adverse  consequences  of  future  floods  for  human  health,  the  environment,  cultural  heritage  and 
economic  activity,  identify  the  significant  risks,  map  the  flood  extent  and  the  potential  adverse 
consequences, and take measures to reduce the flood risk. These activities are reflected in (a) the 
preliminary  flood  risk  assessments,  or  PFRAs  (including  the  identification  of  areas  of  potential 
significant flood risk, or APSFRs), (b) the preparation of flood hazard and risk maps, or FHRMs, and (c) 
the establishment of flood risk management plans, or FRMPs. 

Information from the PFRA/APSFR assessment 

There are two Units of Management (UoMs) in Croatia, which are the same as the Water Framework 
Directive’s River Basin Districts (RBD).  Fluvial,  pluvial,  groundwater, sea water, and Artificial  Water 
Bearing Infrastructure types of floods are considered as potentially significant sources of flooding in 
Croatia. Croatia has designated 3 685 Areas of Potential Significant Flood Risk (APSFRs). The impacts 
of climate change on flood risk have been considered in Croatia. It was concluded that the impact of 
climate change on flood risks is relevant throughout Croatia, and climate change should be carefully 
considered in all aspects of flood risk management. The results of the model indicate that, in general, 
the adverse effects of climate change on flood risks increase: (1) from northeast to southwest and 
(2) on the coast where meteorological effects are superimposed with the effects of the sea level rise.  

7.1 Flood hazard and risk maps 

Highlights 

Croatia is using a GIS-based geoportal29 for their FHRMs. FHRMs were prepared at the national level 
and  show  the  whole  country.  Maps  for  floods  with  low  probability  (1/1 000  years),  with  medium 
probability (1/100 years) and with high probability (1/25 years) are provided. Flood extent is shown 
on all maps. Water depth is shown on all maps. Number of inhabitants is shown on all maps. Likewise, 
type  of  economic  activity  is  shown  on  all  maps.  IED  installations  are  shown.  Potentially  affected 
protected  areas  identified  in  Annex  IV(1)(i),  (iii)  and  (v)  to  Directive  2000/60/EC  are  shown  in  the 
FHRMs. 

Changes since the first FHRMs 

Information  on  sectors  of  economic  activity  in  areas  potentially  affected  by  flooding  is  partially 
improved. Another positive change is the mapping of cultural heritage (one of the four focus areas 
of the Floods Directive). The mapping has been improved by including cultural heritage protected on 
the national level (not only by UNESCO). Information of structures for provision of social services is 
also given in more detail (for example homes for the elderly are added). 

Changes of contextual information since the first FHRMs 

It is stated that the maps are created for the public and the entire approach is adjusted accordingly. 
The aim was to include the public in the entire process of risk management in an easier and more 

29 http://korp.voda.hr/ (accessed in July 2023) replaced now by https://preglednik.voda.hr/  

36 

 
 
informative way. There are not many technical details about modelling, limitations or uncertainties 
of the FHRMs. 

Changes in methodologies used to prepare flood hazard maps since the first FHRMs 

No changes have been identified. 

Changes in methodologies used to prepare flood risk maps since the first FHRMs 

Criteria used to select and assess the potential  risk to human health and economic activities are 
developed compared to the first FHRMs – more institutions of social services, and more IED structures 
are included. The criteria used to select and assess the potential risk to WFD protected areas are the 
same. The criteria used to select and assess the potential risk to cultural heritage have significantly 
developed by using more data. In the second FHRMs there is more information about museums and 
other cultural assets from the national Register of Cultural Property. 

As regards the consideration of climate change effects in the preparation of flood hazard and risk 
maps, reference is made to section 3.7 on ‘adaptation to climate change’. 

7.2 Flood risk management plans 

Highlights 

The  combined  FRMP  and  RBMP  can  be  downloaded  from  two  government  webpages30  (on  the 
websites of the Ministry of Economy and Sustainable Development, and Hrvatske vode). The FRMP 
was  developed  along  with  the  RBMP  by  Croatia’s  water  management  authority,  Hrvatske  vode, 
nevertheless,  the  FRMP  provides  few  details  on  that  coordination.  The  second  FRMP  contains  the 
same objectives as the first one. The FRMP sets two main objectives, one strategic objective and two 
aims for flood protection. One of the FRMP’s main objectives is to protect people and material goods 
from floods, implying a reduction in adverse impacts of floods. The objectives do not specifically refer 
to  non-structural  initiatives  (although  non-structural  measures  are  included  in  the  FRMP).  The 
strategic  objective  refers  to  ensuring  acceptable  flood  risk.  The  two  aims  refer  to  improved  flood 
protection. The main objectives refer to the protection of people from floods. The objectives do not 
refer to the environment and cultural heritage, however, the approach for selecting priority APSFRs 
includes environmental and cultural heritage related criteria. The FRMP identifies 72 measures. The 
priority is not directly defined but can be assumed through the completion date. Croatia did not report 
information on the priority of its measures to EIONET and instead opted for including references to 
the  timetable  for  implementation.  The  FRMP  indicates  the  number  of  protection  projects  in  the 
previous  Multiannual  Programme  that  were  completed,  under  construction,  or  abandoned.  Little 
information was found on the progress of non-structural measures.  

The FRMP provides information on the costs of measures and monetary estimates of potential flood 
damages, which could be used to calculate benefits of the measures. Croatian Waters (Hrvatske vode) 
provides the main source of funding for measures in both UoMs, according to the FRMP31. In turn, the 
model of funding used in Croatia for FRM sees water charges paid to HV as the main sources of 
revenue to finance both structural and non-structural measures. Water charges thus finance flood 

30The combined FRMP and RBMP can be found in Croatia’s official national gazette, https://narodne-
novine.nn.hr/clanci/sluzbeni/2023_07_84_1335.html   
https://mingor.gov.hr/o-ministarstvu-1065/djelokrug/uprava-vodnoga-gospodarstva-i-zastite-mora-2033/planski-
dokumenti-upravljanja-vodama/plan-upravljanja-vodnim-podrucjima-2022-2027/5556  
https://voda.hr/sites/default/files/2023-07/PLAN%20UPRAVLJANJA%20VODNIM%20PODRUCJIMA%20DO%202027..pdf  
31 Chapter C.7.2. 

37 

 
 
measures. The FRMP identifies a range of EU funds as possible sources of finance for the measures, 
including Cohesion Policy funds, Recovery and Resilience Funds, the Solidarity Fund, and the CAP. It 
also mentions the possible use of loans from the Council of Europe Development Bank32. The FRMP 
does not mention the use of CBA. The objectives refer to the ecological status of water and the FRMP 
includes ‘win-win’ and ‘no regrets’ measures, such as NWRMs. The FRMP takes natural water retention 
into account and identifies several natural water retention measures. The FRMP includes measures 
to address nature conservation, including nature protection in the maintenance of water courses and 
for water works, as well as measures to address flood management issues in administrative activities 
connected to forestry and hunting. Several measures are related to spatial planning, e.g. including 
NWRMs  in  spatial  planning  documents.  Croatia  reported  26  prevention  measures.  The  FRMP  has 
objectives to improve flood protection systems, and Croatia reported 15 protection measures. Croatia 
reported 50 preparedness measures. 

The  Multiannual  Programme  identifies  whether  each  measure  is  linked  to  the  2023  or  the  2038 
target for flood protection  – and the FRMP includes measures whose purpose is to monitor these 
indicators. The FRMP indicates that there has been progress towards the strategic objectives of the 
previous plan but does not provide details. The FRMP provides some information on the progress of 
measures, identifying protection projects completed, underway and abandoned, and also noting that 
earthquakes in Croatia and global crises have hindered implemented. The plan states, however, that 
the  measures  implemented  under  the  first  FRMP  have  ‘contributed  significantly’  towards  the 
achievement of its strategic objectives.  

Croatia reported  to EIONET that coordination took place at international  level for both UoMs. The 
FRMP and RBMP33  reports that exchanges of information were organised in the framework of the 
ICPDR and the ISRBC, but no specific details are provided. The FRMP and RBMP34 also lists the cross-
border consultations held with neighbouring countries. The plan provides no further information on 
the topics discussed35. 

The  FRMP  explains  that  public  and  interested  parties  were  informed  in  the  two  UoMs  via  media 
(newspapers,  TV,  radio),  internet,  direct  mailing,  invitations  to  stakeholders,  local  authorities  and 
expert meetings. This refers to the joint consultation of the combined RBMP/FRMP document. The 
public  consultation  was  coordinated  by  the  Ministry  of  Economy  and  Sustainable  Development, 
Directorate of Water Management. Consultation on the draft RBMP and FRMP lasted for six months. 

As regards the consideration of climate change effects in the preparation of flood risk management 
plans, reference is made to section 3.7 on ‘adaptation to climate change’. 

8. FD recommendations 

On the basis of the assessment performed and in addition to the progress already achieved, Croatia should: 

• 

consider pluvial flooding in the FHRM; 

32 The Council of Europe Development Bank is a multilateral development bank with an exclusively social mandate, 
https://coebank.org/en/ 
33 In Chapter F, which covers both flood risk and river basin management. 
34 Ibid. 
35 Croatia declares that more information is available in the meeting notes from the meetings. 

38 

 
 
• 

provide detail on how the FHRM was used in the choice of objectives and measures in the FRMP;. 

•  make objectives more specific and where possible linked to quantitative indicators and be timebound. 
An assessment of the progress made towards the achievement of the objectives should be included 
in the FRMP; 

• 

• 

• 

provide the cost for all measures, not just structural measures in the FRMP 

set out in the FRMP the methods used to monitor measures, including non-structural measures; 

link both structural and non-structural measures to the objectives in the FRMP; 

•  where  relevant,  incorporate  Cost  Benefit  Analysis  for  the  prioritisation  of  measures  that  lend 

themselves to it and provide a clear description of the methodology used; 

• 

• 

consider the use of insurance as a measure for adaptation to climate change; 

provide more detail on the public consultation and stakeholder involvement in the FRMP, such as the 
specific stakeholders that participated, the meetings and advisory groups convened, the comments 
received, and how they were taken into account; 

•  where appropriate, consider in the FHRM the flow velocity or relevant water flow and in the FRMP flood 

conveyance routes, as these are relevant to emergency response. 

39