If your organization operates in the Croatian market or provides consumer credit to customers in Croatia, a significant regulatory change is approaching.
Croatia’s new Consumer Credit Act (Official Gazette 86/2026) enters into force on 20 November 2026, bringing consumer credit and residential consumer credit under a single regulatory framework. Certain provisions will apply at later dates, including requirements concerning creditors and credit intermediaries that have not previously been covered by the existing legislation, which enter into force on 1 June 2027, while some provisions related to instalment payments by payment service users will apply from 1 January 2028.
For banks, fintech companies, leasing providers and other organizations operating in Croatia’s lending market, some of the most relevant changes concern creditworthiness assessments, the sources and quality of data used in those assessments, and automated data processing.
This raises an important operational question:
How can organizations operating in the Croatian market build a digital credit journey that provides a simple customer experience while enabling reliable identity verification, access to relevant financial data and digital contracting?
Identyum services can support individual stages of such a process.
Creditworthiness assessment starts with quality data
One of the key areas addressed by the new Act is the assessment of a consumer’s creditworthiness before entering into a credit agreement.
The Act requires creditors to conduct a detailed assessment based on relevant and accurate information regarding the consumer’s income, expenses and other financial and economic circumstances.
Depending on the particular case, this may include evidence of income or other sources of repayment, information about financial assets and other financial obligations. Information may be obtained from relevant internal or external sources and must be appropriately verified.
This is precisely where access to high-quality, verifiable data can significantly improve a digital lending process.
FinCheck: financial data supporting creditworthiness assessment
Identyum FinCheck enables access to bank account and transaction data with the user’s consent.
This can provide creditors with relevant financial information that may serve as one of the data sources used within their own creditworthiness assessment process.
Instead of relying exclusively on information and documents manually provided or entered by the customer, digital access to financial data can help create a more comprehensive picture of the customer’s financial circumstances.
However, it is important to distinguish between technology that enables access to and processing of relevant data and the creditworthiness assessment itself.
The creditor remains responsible for assessing creditworthiness and meeting the associated legal obligations. FinCheck does not replace that assessment; it can support the
→ Learn more about Identyum Fincheck
More data does not necessarily mean a better assessment
The new regulatory framework also establishes boundaries regarding the types of data that can be used.
Special categories of personal data under Article 9 of the GDPR may not be used for creditworthiness assessments, while the Act explicitly states that social networks are not considered an external data source for this purpose.
This further emphasizes the importance of data relevance, proportionality and reliability.
For digital lending, therefore, the objective should not be to collect as much information about a customer as possible, but to enable the use of appropriate and reliable data for a clearly defined purpose.
A digital credit journey starts with reliable identity verification
Before financial information can be assessed, the identity of the person applying for credit needs to be reliably established.
In a fully digital customer journey, this does not necessarily require a visit to a physical branch.
Identyum Identify enables remote identity identification and verification and can be integrated into a digital customer onboarding process.
This allows two important stages of the digital journey to be connected:
Identify → verify the customer’s identity
FinCheck → access relevant financial data
The creditor can then use the available information within its own creditworthiness assessment and decision-making process.
→ Learn more about Identyum Identify
What happens when creditworthiness assessment is automated?
Another particularly relevant aspect of the new Croatian Act concerns automated processing of personal data in creditworthiness assessments.
Where an assessment involves automated processing of personal data, the Act introduces additional consumer rights and corresponding obligations for creditors.
Among other requirements, consumers must be informed about the automated processing and about their right to human assessment. The framework also provides rights relating to receiving a clear and understandable explanation of the assessment and how the automated processing works, expressing their point of view, and requesting a review of the creditworthiness assessment and decision.
For financial service providers, the message is important:
Automating the process does not mean automating responsibility.
Technology can accelerate identity verification, data collection and processing while reducing manual work, but creditors still need to design processes that respect consumer rights and applicable regulatory requirements.
Creditworthiness assessment is not necessarily a one-time step
From a digitalization perspective, another relevant requirement is that creditors establish, update, document and apply procedures for assessing creditworthiness, as well as document and retain relevant information.
The Act also addresses monitoring creditworthiness during the contractual relationship and reassessment in certain circumstances, such as before a significant increase in the total amount of credit.
This demonstrates that effective financial data management may be relevant beyond the initial credit application and can form part of the broader credit lifecycle.
Technologies enabling secure and controlled access to relevant financial data can therefore potentially play a role beyond initial onboarding, depending on the specific business process and appropriate legal basis.
From credit approval to digital contracting
Once the creditworthiness assessment has been completed and the creditor has made its decision, the process moves to contracting.
The new Croatian Act requires credit agreements and their amendments to be made in writing, either on paper or on another durable medium.
Within a digital business process, contracting can also be connected with electronic signature solutions.
Identyum Sign enables documents to be signed electronically and remotely and supports simple (SES), advanced (AdES) and qualified electronic signatures (QES), depending on the requirements of the particular business process.
The solution also supports fully remote and automated issuance of the required signing certificate for all signature levels directly within the signing process, without requiring additional devices, applications or the physical presence of the signer.
The appropriate electronic signature level should always be determined according to the specific legal and business context.
→ Find out more about Identyum Sign
What could a connected digital credit journey look like?
Individual technology components can be connected into a more integrated customer journey:
IDENTIFY
Verify identity
↓
FINCHECK
Access relevant financial data
↓
CREDITOR
Assess creditworthiness and make the decision
↓
SIGN
Digitally sign the documentation
This approach enables several stages of the credit journey to be digitalized while responsibility for the creditworthiness assessment, the lending decision and compliance with applicable legal obligations remains with the creditor.
Where does the ID Wallet fit in?
The next stage in the evolution of digital financial services goes beyond simply digitizing individual forms and processes.
The market is moving towards reusable digital identity, allowing users to reuse certain verified identity data and credentials and share them in a controlled manner when required.
The Identyum ID Wallet provides a separate identity and data layer through which users can store and selectively share their data.
In future digital financial processes, this creates opportunities for customer journeys in which certain information does not need to be entered and verified from scratch every time.
The ID Wallet should not be presented as a solution that by itself meets the requirements of Croatia’s Consumer Credit Act. Instead, it represents part of the broader digital identity infrastructure.
→ Read more about Identyum ID Wallet
If you operate in Croatia, how ready is your digital credit journey?
Croatia’s new Consumer Credit Act can primarily be viewed as a regulatory change. For established financial institutions, it is also an opportunity to review existing processes and the way they use data and technology.
For organizations that will become subject to the new framework for the first time, the impact may be considerably greater — potentially requiring the establishment of creditworthiness assessment, identity verification and contracting processes that have not previously formed part of their operations.
Rather than digitizing each step separately, organizations operating in the Croatian market can look at the entire customer journey:
verify identity → access relevant financial data → assess creditworthiness → make a decision → complete the agreement digitally
Identyum Identify, FinCheck and Sign, together with the ID Wallet as part of the broader digital identity infrastructure, can support individual stages of this journey.
With the new regulatory framework approaching, the key question for organizations providing consumer credit in Croatia is therefore not only what the new Act requires.
The question is: how ready is your digital credit journey for Croatia’s new regulatory reality?
Do you operate in the Croatian market and want to digitalize identity verification, access to financial data or electronic signing within your lending process? Talk to the Identyum team about integrating these capabilities into your existing customer journey.