Croatia’s sweeping overhaul of its gambling laws has drawn a formal complaint to the European Commission, with the European Gambling and Amusement Federation (EUROMAT) accusing Zagreb of bypassing mandatory EU notification procedures — a move that could render key provisions of the new Gambling Act unenforceable.
The Notification Failure
EUROMAT lodged an official complaint with the European Commission under Directive (EU) 2015/1535, known as the TRIS Directive, in October 2025. The complaint centres on Croatia’s failure to notify Brussels of amendments to its Gambling Act and four associated implementing regulations before they took effect.
Under EU law, member states must notify the Commission of any draft legislation that restricts market access or imposes technical requirements on service providers. The notification window allows the Commission and other member states to scrutinise measures for compatibility with Single Market principles. Croatia did neither.
EUROMAT President Jason Frost was direct about the consequences: “The notification procedure exists to ensure that national measures are compatible with the principles of the Single Market. Croatia’s decision to ignore this obligation not only breaches EU law; it also threatens legal certainty for businesses across Europe. The Commission must act decisively to uphold the integrity of the internal market.”
It is not the first time Croatia has faced this issue. In 2014, the European Commission intervened and Croatia was forced to withdraw a previous gambling law following scrutiny over the same notification requirement. Croatia did notify the Commission of a separate 2023 gambling-adjacent law — making the omission here harder to attribute to oversight.
What the Law Contains
The amended Gambling Act, backed by Prime Minister Andrej Plenković as a central mandate of his third term, introduces some of the most far-reaching gambling reforms Croatia has seen in over a decade. Measures include mandatory player identification at both land-based venues and online platforms, a national self-exclusion register (Registar Igrača, now live and managed by the Croatian Institute of Public Health), a near-total ban on gambling advertising across television, radio, print, and digital channels between 6am and 11pm, and a prohibition on the use of celebrities, athletes, and influencers in gambling promotions.
Self-service betting terminals — known locally as kladomati — must be removed from cafes, restaurants, and other public hospitality venues. The law also introduces minimum distance requirements between gambling venues and schools or religious buildings, with the government estimating up to 60% of existing shops could be forced to relocate or close.
On taxation, the reforms replace a flat system with a tiered structure. Gambling winnings are taxed from 10% on amounts up to €1,500 up to 30% on winnings exceeding €70,000. Licensing fees rise sharply across the board: online casino licences increase 50% to €398,168, land-based casino fees rise 50% to €600,000, and land-based betting shop fees increase to €200,000. The government expects the changes to generate between €50m and €70m in additional annual revenue, with at least 11% earmarked for addiction prevention and treatment.
Uneven Playing Field
EUROMAT’s complaint goes beyond the procedural breach. The federation argues the amended law also grants exemptions and regulatory privileges to certain operators — widely understood to refer to state-run lottery Hrvatska Lutrija — while imposing the full burden of new requirements on private licensed operators. This, EUROMAT contends, creates an uneven playing field in breach of EU competition principles.
“The Croatian Government has deliberately sidelined both stakeholders and EU institutions. By failing to notify, it has prevented scrutiny of measures that fundamentally distort competition and harm different segments of the gaming sector. We urge the Commission to carefully assess EUROMAT’s complaint and intervene without delay to ensure that the rule of law and fair market conditions are upheld.”
That statement came from Filip Jelavić, Secretary General of the Croatian Gaming Association (HUPIS), which has been critical of the law throughout its development. HUPIS has warned that in its current form, the law could force the closure of more than 70% of physical gambling locations and put 15,000 jobs at risk — figures that include indirect employment across the wider hospitality and retail sectors.
Industry Impact Warnings
HUPIS and EUROMAT have both pointed to the black market risk. Where legal operators face rising costs and tighter restrictions, the concern is that unlicensed platforms absorb displaced demand — reducing tax revenues and undermining the player protection objectives the law is designed to serve.
Ozren Kronja of the Digital Publishers Association raised a related concern specific to advertising: the law’s restrictions on Croatian media do not apply to major international digital platforms. “While Croatian media are being strangled with restrictions, Big Tech platforms are left to self-regulate,” Kronja said. “The unintended consequence may be to push gambling adverts further into unlicensed, untraceable channels.”
Marko Tomic, a partner at Croatian law firm Siketić & Tomić, noted that the new gambling law represents the first significant legislative change to the Croatian gambling framework in over a decade. He argued the government’s two core objectives — protecting minors and defending legal operators from black market competition — are broadly sound, but that the execution carries structural risks if the EU process is not resolved cleanly.
The Lithuanian Precedent
The timing of EUROMAT’s complaint is not coincidental. Earlier in 2025, the Court of Justice of the European Union ruled that Lithuania’s gambling promotion restrictions were unenforceable against operator Unigames because the Lithuanian government had failed to comply with the same TRIS notification requirements. The court found the procedural defect constituted grounds for unenforceability — a ruling EUROMAT explicitly cited as a precedent applicable to Croatia.
If the European Commission accepts EUROMAT’s complaint and opens infringement proceedings, Croatia faces the prospect of key provisions being suspended pending review. The Commission is understood to have already made contact with Zagreb on the matter. EUROMAT President Frost noted in November 2025: “We understand that the European Commission is in touch with the Croatian Government on this issue and I hope that the outcome of this is respect for EU law.”
The outcome will be watched closely across Central and Eastern Europe. Croatia’s reforms are seen as a potential model for gambling law modernisation in the Balkans, where Serbia, Montenegro, and Bosnia face comparable regulatory pressures. If Zagreb is forced to revise or suspend measures, it will add procedural complexity to reform efforts already under political pressure across the region.
For operators active or seeking licences in Croatia, the immediate question is whether the law as currently enacted can be enforced. Until the Commission concludes its assessment, that remains an open question.
Source: EUROMAT
