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Does July 2026 Bring Full Professionalization and Greater Security to the Market?

The real estate market in the Republic of Croatia is undergoing its most significant regulatory changes in recent years. On June 19, 2026, the Croatian Parliament passed the new Real Estate Brokerage Act, published in the Official Gazette (Narodne novine) No. 69/2026, which entered into force on July 7, 2026. The Act introduces stricter operating rules, a higher degree of professionalization, advanced digitalization, and significantly enhanced consumer protection.

The goal of this legislative solution is clear: the elimination of unfair competition, the suppression of the gray economy, and the creation of a transparent and legally secure environment for all participants in real estate transactions.

As an agency that has been operating according to the highest professional standards in Croatia and abroad for more than two decades, we can conclude that for all brokers who adhered to the previous law on real estate brokerage and the code of ethics, nothing significant will change. Below we bring you an overview of the key news and obligations that came into effect on 7 July 2026.

1. Professionalization of the Industry and Stricter Status of Agents

The Act sets high standards for conducting brokerage business, aiming to ensure that clients are represented exclusively by qualified and fully dedicated professionals:

• Qualifications and Examination: Every agent must have completed at least secondary education (or an undergraduate university or professional study program) and have passed the professional examination administered by the Croatian Chamber of Economy (HGK).

• Enrollment in the Directory and Exclusive Employment: An agent must be enrolled in the Directory of Real Estate Agents maintained by the HGK and may perform brokerage activities exclusively on the basis of an employment contract, and with only ONE broker (agency). An agent is not permitted to work for multiple brokers during the same period, nor provide services identical or similar to brokerage outside of their employer.

• Mandatory Full-Time Agent: Every broker (agency or craft/trade business) must employ at least one qualified agent on a full-time basis. For other agents, the Act mandates an employment contract, but does not explicitly require full-time hours.

• Ethical Business Practices: The HGK, upon the proposal of the Real Estate Business Association and with the prior approval of the Ministry, adopts a general act on the ethical business practices of brokers, the provisions of which must be respected by all brokers and agents. The HGK supervises its implementation.

• Good Reputation: The broker, its legal representatives, owners, and founders must maintain a good reputation. A person does not possess a good reputation if criminal proceedings are being conducted against them or if they have been legally convicted of specific criminal offenses precisely enumerated by law—primarily financial and economic crimes (money laundering, terrorist financing, tax evasion, economic fraud, counterfeiting, etc.). Loss of a good reputation is a ground for revoking the operating license and deletion from the Register.

2. The End of the "External Associate" Model in Brokerage

One of the most important changes concerns the legal status of agents. The previous practice in which agencies engaged agents as external associates (for instance, through their own flat-rate tax crafts/trades) is no longer possible for agents:

• Mandatory Employment Contract: The Act explicitly prescribes that an agent may perform brokerage activities only on the basis of an employment contract concluded with a single broker. An agent who performs brokerage activities for multiple brokers or without enrollment in the Directory commits an offense and shall be deleted from the Directory.

• Crafts/Trades as Brokers: A craft/trade business (obrt) can still be registered as a broker, but like any other broker, it must have at least one agent registered on a full-time basis, which is proven by an electronic record from the Croatian Pension Insurance Institute (HZMO).

• Note on Tax Supervision: Independently of this Act, the Tax Administration, within the framework of general tax regulations, conducts audits regarding the characteristics of independent vs. dependent work (the so-called NR Questionnaire). Engagements that formally look like a collaboration with a craft/trade business, but in reality bear the hallmarks of classic employment, can be reclassified in tax proceedings as dependent work, resulting in the calculation of associated contributions. It is important to emphasize that this is not a provision of this Act, but rather an existing tax regulation and practice.

3. Digitalization and Faster Administration via the START Plus System

As part of the modernization of public administration, the entire licensing procedure is moving into the digital sphere:

• Applications for issuing decisions to perform brokerage activities and for enrolling agents into the Directory are submitted to the Ministry exclusively electronically, through the START Plus e-service, accessed via the e-Građani system, using a credential with a substantial level of security.

• The Ministry retrieves part of the documentation (e.g., the certificate of passing the professional exam) automatically from official records, thereby speeding up the process and reducing the administrative burden.

• Data Updates Within 30 Days: Brokers and agents are obliged to report any change of data to the HGK within 30 days of the occurrence of the change.

• Annual Proof of Compliance: The broker is obliged to submit documentation to the HGK once a year proving that they continue to meet the legal requirements. If they fail to do so, the Ministry issues a decision revoking their operating license, after which the HGK deletes them from the Register.

• Transitional Period: Agents with existing licenses have a deadline of 30 days from the entry into force of the Act (July 7, 2026) to submit documentation proving that they still meet the requirements for enrollment in the Directory; anyone who fails to submit the documentation will be deleted from the Directory.

4. Stricter Advertising Rules and Business Premises Standards

The Act puts an end to unverified and misleading real estate advertising:

• Mandatory Contract for Advertising: Advertising a property is not permitted without a previously concluded brokerage contract with the owner of the property.

• Transparency of Advertisements: Every advertisement must contain the company name and registered office address of the broker, as well as the addresses of its branches (or a link to them).

• Requirements for Business Premises: The broker must operate in a space suitable for office business, which is entirely separated from spaces intended for other purposes, and must have a separate area for confidential conversations with clients. Branch offices and separate facilities outside the main registered office must be declared in the application to the Ministry.

5. New Rules for Charging the Brokerage Fee

One of the most frequent questions in the market—the charging of agency commission—is now precisely defined:

• Right to the Fee: The broker acquires the right to the fee only after the conclusion of the contract (the main contract of sale or lease) for which they brokered, unless the brokerage contract stipulates that this right arises upon the conclusion of a preliminary contract (predugovor).

• Prohibition of Advance Payments: It is strictly forbidden to demand partial or full payment of the brokerage fee in advance, before the conclusion of the contract or preliminary contract.

• Prohibition of Charging a Party Without a Contract: The broker may not charge a fee to a third party (buyer, lessee) who has not concluded a brokerage contract with them.

• Charging Both Sides Under a Strict Cap: The broker may charge a fee to both the seller and the buyer only if they have a separate brokerage contract concluded with each party. The total sum of both fees for the same property may not exceed the maximum amount specified by the valid price list at the time of concluding the contract.

• When Only One Party Pays: If the broker has contracts with both parties, and it has been agreed that the fee is paid by only one of them, they may charge that party a maximum of half the fee amount specified by the valid price list.

Legal Guide for Buyers and Sellers: Know Your Rights

The new law places a strong emphasis on consumer protection:

• Viewing Properties Without a Contractual Obligation: Agencies are no longer allowed to condition the viewing of a property on the signing of a brokerage contract. During the viewing, only a Property Viewing Certificate (Potvrda o razgledavanju nekretnine) is signed, by which the agent proves to their principal (nalogodavac) that they showed the property. The certificate is not considered a brokerage contract and must not contain any provisions regarding the payment of a brokerage fee by the signer.

• Transparent Costs and Price List: The valid price list of the agency, with a specified date, is an obligatory integral part of the brokerage contract. Before signing, the agency is obliged to inform the contracting parties in writing of the amount of individual fees and their total sum.

• Drastically Higher Financial Security (Insurance Policies): The law prescribes mandatory professional liability insurance with minimum coverages of:

  • €100,000 per single damage event,

  • €300,000 for all compensation claims during one insurance year.

• Protection of Agencies Against Abuse: The law equally protects brokers. If, after the termination of the brokerage contract, the principal concludes a legal transaction that is a direct consequence of the broker's actions prior to the termination of the contract (for example, by waiting for the contract to expire to close the deal directly), they are obliged to pay the broker the full agreed fee.

Inspection Supervision and Rigorous Penalties

The implementation of the Act is supervised by market inspectors of the State Inspectorate of the Republic of Croatia (DIRH), while administrative supervision is carried out by the Ministry:

• For most offenses (advertising without a contract, conditioning viewings, failure to keep records, inadequate premises, exceeding the fee limit, etc.), fines ranging from €3,000 to €6,000 are prescribed for the broker, and from €1,000 to €3,000 for the responsible person.

• For the most severe offenses—performing activities without a decision from the Ministry or ceasing to meet the legal requirements—fines for the broker range from €15,000 to €30,000, along with an immediate measure prohibiting further business activities, which is executed by sealing the business premises.

• For agents as natural persons, fines ranging from €3,000 to €6,000 are prescribed (working without being enrolled in the Directory, working for multiple brokers, failing to report changes).

Conclusion: How to Do Business Safely?

The enactment of the new Real Estate Brokerage Act represents a turning point that will clean the market of unprofessional individuals in the long run and guarantee European standards of business. Citizens and investors are advised to check the broker in the official, publicly available Register and Directory kept by the HGK before entering into any business relationship.

The agency PROAGENT d.o.o. operates fully in line with all legal regulations of the Republic of Croatia and international standards. Our licensed agent is enrolled in the HGK Directory, and our high-coverage insurance policies along with transparent contractual relations are the ultimate guarantee for the security of your investment.

Vlatko Mrvoš

Sources: Real Estate Brokerage Act (Official Gazette - NN 69/2026); Ministry of Economy of the Republic of Croatia