HAKOM reminds: the deadline for submitting notifications by intermediary service providers expires on 29 October 2025

ZAGREB, 27 October 2025 - The Coordinator for Digital Services of the Republic of Croatia (HAKOM) calls on all intermediary service providers to submit a notification of the provision of intermediary services in accordance with the Act on the Implementation of the Digital Services Act (Official Gazette 67/2025). Guidance on how to submit the notification was published on 29 July 2025, and the statutory deadline is three months from the date of publication - 29 October 2025.

What is a notification of the provision of intermediary services?
A notification of the provision of intermediary services is a formal notice that, pursuant to Article 23 of the Act on the Implementation of the Digital Services Act, intermediary service providers submit to HAKOM as the Coordinator for Digital Services of the Republic of Croatia. The purpose of the notification is to ensure transparency in the digital services market, maintain an up-to-date register of entities, and effectively monitor compliance with the rules of the Digital Services Act (DSA).

Who must submit a notification?
Notifications must be submitted by:

• Intermediary service providers with a business establishment in the Republic of Croatia; and
• Intermediary service providers with a business establishment outside the European Union who appoint a legal representative in Croatia.

The DSA has been in force since February 2024 and imposes obligations on all intermediary service providers, including internet access providers (fixed and mobile).

What is the deadline?
The guidance on submitting notifications was published on 29 July 2025. The deadline for submission is three months from publication, i.e., 29 October 2025. As the deadline approaches, we urge all obliged entities to submit their notifications without delay.

Consequences of failing to submit a notification
Failure to submit a notification constitutes an offence under Article 18 of the Act on the Implementation of the DSA. Financial penalties range from €6,630 to €66,360, or up to 6% of the provider’s annual worldwide turnover in the previous financial year, whichever amount is higher.

How to submit a notification
Notifications must be submitted electronically via the e-Provider DSA system, available on HAKOM’s website. Each intermediary service provider must submit a separate notification for each service they provide.

For a practical guide, please refer to the User Instructions available at the following link.
 
Examples: what falls under “intermediary services”

For easier understanding, below are examples of the most common categories of intermediary services:

1. “Mere conduit” services

Examples: internet access providers (fixed/mobile), Internet Exchange Points (IXPs), wireless access points (public Wi-Fi networks), VPN services, DNS services and resolvers, top-level domain registries/registrars (TLDs), certification authorities (CAs), VoIP and person-to-person communication services (e.g., Zoom, Microsoft Teams, WhatsApp, Telegram, Signal), TOR nodes, IP transit.

2. “Caching” services

Examples: CDN networks (e.g., Akamai, Fastly), reverse proxy solutions (Nginx, Varnish), content adaptation proxies (e.g., Opera Turbo).

3. “Hosting” services

Examples: cloud platforms (AWS, Azure, Google Cloud), web hosting providers (Bluehost, SiteGround), paid advertising/referral services (Google Ads, Bing Ads), storage and sharing services (Dropbox, Google Drive, OneDrive).

4. Online platforms

Examples: social networks (Threads, Bluesky, Mastodon), video platforms (Twitch, Vimeo), online marketplaces (including platforms enabling remote contract conclusion - B2C), app stores (Google Play, App Store), review/rating platforms (Trustpilot, Yelp, TripAdvisor), forums, wikis, open channels/chat groups in messaging applications.

5. Online search engines

Examples: Google Search, Bing, Ecosia, Yahoo Search, Startpage, Qwant.

Why is the notification important?
Submitting a notification ensures compliance with the law, reducing the risk of financial penalties and business uncertainty. It also contributes to greater transparency and trust in the market, as an up-to-date register facilitates communication between the competent authority and all market participants. Finally, it allows timely compliance with the Digital Services Act (DSA), which sets standards for user protection and intermediary responsibility. Proper registration supports the consistent application of these standards.

All additional information and instructions are available on HAKOM’s website.

• HAKOM - Coordinator for Digital Services of the Republic of Croatia