Article 35, paragraph 2 and its single condition
A Croatian online casino comes attached to a casino on premises
The Act puts 1 precondition in front of a Croatian online casino, and it has nothing to do with capital, technology or where the company is seated: it demands a right, already held, to run a casino in a physical venue.
| Casino | Licence | Company | Threshold for checks | Open |
|---|---|---|---|---|
| Vave | Curaçao Gaming Authority | Latcas B.V. | at discretion | Open |
| Vave pays for the single link that leaves this site, and that is the whole of our commercial relationship with it. Its sportsbook and its casino sit on one account, so the same money covers both without a second stake — uncommon among operators that advertise themselves as crypto casinos. We read the licence number ourselves on 2 September 2026 in the Curaçao Gaming Authority register: OGL/2024/1676/0905, held by Latcas B.V., issued 19 May 2025, status active. | ||||
| Rocketpot | Curacao | Danneskjold Ventures B.V. | US$2,500 | Read |
| Bitcasino.io | Curaçao Gaming Authority | Moon Technologies B.V. | 2,500 EUR | Read |
| Wild Fortune | Anjouan Gaming Board | Metlait SRL | at discretion | Read |
| DuckDice | Anjouan Gaming Board | Zentari Limitada | at discretion | Read |
| Empire.io | Anjouan Gaming Board | Pixel Entertainment Limited | 2,000 USDT | Read |
| Metaspins | Curaçao Gaming Authority | 3-102-959384 SRL | at discretion | Read |
| Rainbet | Anjouan Gaming Board | RBGAMING N.V. | at discretion | Read |
| Shuffle | Curaçao Gaming Authority | Natural Nine B.V. | at discretion | Read |
| Wild.io | Curaçao Gaming Authority | Stack Gaming Ltd. | at discretion | Read |
The sentence that sets the whole market
Article 35, paragraph 2: “Trgovačkim društvima koja … imaju pravo na priređivanje igara na sreću u casinima može se odobriti pravo priređivanja … putem interaktivnih prodajnih kanala on-line igranja.” — commercial companies that hold the right to organise games of chance in casinos may be granted the right to organise them through interactive online sales channels.
Read the order carefully.
First comes the right to a venue casino, and only then the possibility of extending it to the internet — as an approval that may be granted, not as a right acquired by ticking off a list of conditions. A company without the first has no route to the second, whatever its capital, technology or country of seat.
A foreign operator therefore stays outside the Croatian system even when it would like to change that.
The first condition comes before article 35
Before the online version comes into view at all, the Act sets a condition that settles the question for most foreign operators.
Article 3, paragraph 1 starts from the position that organising games of chance in Croatia is a right of the Republic of Croatia itself. Paragraph 2 names three instruments that set that right in motion: the Act, a decision of the Government and an approval of the Ministry of Finance. Paragraph 3 transfers the whole right to Hrvatska Lutrija d.o.o.
Paragraph 4 opens up the remainder, subject to a condition written into its closing words:
“Pravo priređivanja igara na sreću iz članka 5. stavka 1. točke 2., 3. i 4. ovoga Zakona mogu na temelju odluke i odobrenja steći i druga trgovačka društva sa sjedištem u Republici Hrvatskoj.”
The right may also be acquired by other commercial companies with their seat in the Republic of Croatia.
A seat in Croatia therefore comes before everything else. A company registered in Curaçao or on Anjouan is out on that condition regardless of what its terms say; how the division is arranged is unpacked on the page about Hrvatska Lutrija.
An approval is not the same thing as a licence
The word the Act uses is “odobrenje”, an approval, and it is a legal instrument with a meaning of its own: an extension of a right somebody already holds, not a public tender open to anyone who meets a set of technical requirements.
That is why comparisons with markets where a licence is obtained by application miss the subject. In Croatia there is no argument about whether a foreign operator passed or failed a procedure.
There is no procedure for it.
From that division also follows why the phrase “Croatian online casino” refers in practice to a very narrow circle of companies, while everything else reachable from Croatia works under a licence issued somewhere else. What comparing those others by their own documents looks like is shown on the page about how the choice is made.
The amendment published in Narodne novine 72/2025 did not touch this mechanism. It changed deadlines, identification at betting counters and the advertising provisions, and left the condition in article 35, paragraph 2 as it was; what it did bring sits on the page about the 2025 amendment.
The same article, in paragraph 2, also mentions standards prescribed by the Minister of Finance. We have not opened the secondary act adopted on that basis, so nothing is claimed here about its content.
Two conditions working together
Now the two conditions can be set one behind the other, and only then is it visible why a foreign operator has nowhere to go in Croatia.
The first wall is the seat in the Republic of Croatia, from article 3, paragraph 4. The second is an existing right to run a casino in a venue, from article 35, paragraph 2. A company that clears the first but has no venue stops at the second.
That double construction also explains why comparisons with other markets do not work here. There the argument is about the conditions of an application; here it is about whether an application exists at all.
Lottery games take their own route
Lottery games in Croatia are run by Hrvatska Lutrija d.o.o. That is a separate branch with its own arrangement and it does not enter the arithmetic about casinos.
Article 9, paragraph 2 gives it the exclusive right to the first point of article 5, that is to lottery games. The other three points — casinos, betting and slots — are not covered by that paragraph, and the more open regime of article 3, paragraph 4 applies to them.
The practical consequence of that split is visible in the offence counts. Point 27 in the chapter on offences speaks precisely about a lottery game and about an operator who “dopusti sudjelovanje”, allows participation, by a person who is not of age, while point 28 covers betting and slots in the same language. The text of both sits on the page about what the Act says.
Who supervises and who issues
There is no separate gaming authority in Croatia. Supervision sits inside the tax system, with the Ministry of Finance and the Tax Administration, whose pages on casinos and on blocking orders anyone can open.
Here is the boundary of what we read. We opened the Tax Administration pages and the text of the Act. We did not read the ministry pages on the mfin.gov.hr domain directly, so we do not name the exact organisational unit responsible for gaming. How we draw that line is described in reading documents.
The blocking measure comes from the same body but under a different statute. A blocking order rests on the General Tax Act rather than on the Gaming Act, which the page about the list of blocked addresses covers.
What this means for the ten operators in our table
None of them holds a Croatian approval, and that is the only thing we can claim about them on the basis of Croatian law. Everything else comes from their own documents.
Nine of the ten state a licence number issued elsewhere: four from Anjouan, four from the Curaçao Gaming Authority and one from the older Curaçao system, marked 1668/JAZ. The tenth has no number, so its row says the fact is not published.
What such a number confirms, and what it leaves open, is set out on the page about foreign licences. The payout and verification terms at those ten operators differ from one another more than they differ from Croatian rules, so we separated them on the page about payout limits.
The condition that stands in front of this one
The right to a casino on premises is the second of two conditions, not the only one.
The first sits in article 3, paragraph 4 and demands a seat in the Republic of Croatia. A company registered outside Croatia drops out under that provision before the question of a venue is even raised, so the two conditions work separately and do not substitute for one another.
The wording of that provision, and the procedure by which a reader can check where a company is registered, is set out on the page about the Croatian operator.