Who NN 89/2025 actually binds
Most Croatian micro-businesses are outside the act entirely. Art. 4(2) of NN 89/2025 states plainly that it does not apply to micro-enterprises providing services, and Art. 5(18) draws that line at fewer than ten employees on average annually and either annual income up to EUR 2m or total assets up to EUR 2m.
Read that grouping carefully. It is headcount AND (income OR assets) - not three conditions in a row. A business with six people and EUR 3m of income still falls under the exemption if its total assets are below EUR 2m.
What the act covers
The act is the Croatian transposition of the European Accessibility Act, Directive (EU) 2019/882. It came into force on 28 June 2025.
E-commerce is explicitly in scope. Art. 3(2)(6), defined in Art. 5(25), covers a service provided at a distance through a website or a mobile device, for consumer contracts.
Who enforces it
Art. 25(9) puts market surveillance of e-commerce services with the market inspectors of the Državni inspektorat.
What it costs to ignore
Art. 36 sets the fines.
| Who | Range |
|---|---|
| Legal person | EUR 6,630 – 132,720 |
| Responsible person within a legal person | EUR 2,650 – 6,630 |
| Self-employed provider (obrtnik) | EUR 2,650 – 6,630 |
If you are exempt, is there any reason to act
The exemption is from the statute, not from your customers. Roughly one in four people has some form of impairment, and an inaccessible checkout loses those orders whether or not an inspector ever calls.
There is also a commercial argument that has nothing to do with disability: the same work that makes a site usable with a keyboard and a screen reader makes it faster, more legible on a phone, and easier for a search engine to parse. Conformance is a floor, not a ceiling.
This is information, not legal advice. Where a decision matters, check the current text of the law or ask a lawyer.