On 7 March 2025, the Croatian Parliament adopted comprehensive amendments to the Aliens Act. This marks the third major reform of the legislative framework governing migration policy since 2020. The new amendments consist of 96 articles and bring far-reaching consequences for the legal status, employment, residence, and rights of third-country nationals in the Republic of Croatia.
With these changes, Croatia adopts a proactive migration policy – aligned with European Union law yet tailored to the specific challenges of the national labour market. The Act simultaneously liberalises access for qualified workers (particularly in the IT sector), strengthens oversight of employers, enhances protection of foreign workers’ rights, and supports the return and reintegration of Croatian emigrants.
The implementation of these measures is expected to significantly affect the structure of the labour market, the quality of integration of foreign workers, and the overall migration management system in Croatia.
EMPLOYMENT OF THIRD-COUNTRY NATIONALS UNDER THE LATEST AMENDMENTS TO CHAPTER VI OF THE CROATIAN ALIENS ACT
Legal Grounds for Employment of Third-Country Nationals in Croatia
A third-country national may legally work in the Republic of Croatia, and an employer may employ or engage the work of such a person, based on:
a residence and work permit,
a certificate of work registration, or
without a permit or certificate, in specific cases provided by law.
Employment is strictly limited to the job position, employer, and conditions specified in the permit or certificate. Employers are prohibited from engaging workers who are illegally residing in the country.
Exceptions Allowing Work Without a Residence and Work Permit or Certificate of Work Registration
The law provides several exceptions under which a third-country national may work without a residence and work permit or certificate of work registration, provided they have been granted one of the following legal statuses in Croatia:
Temporary residence for family reunification with a Croatian citizen or a third-country national holding long-term or permanent residence, asylum, or subsidiary protection.
Temporary residence based on life partnership with a Croatian citizen or a third-country national with the above statuses.
Temporary residence for family reunification or life partnership with a holder of an EU Blue Card or an intra-corporate transfer permit.
Temporary residence based on family reunification with a third-country national who holds long-term residence in another EEA country.
Temporary residence for humanitarian reasons.
Autonomous residence.
Temporary residence as a posted worker.
Temporary residence for research (Article 74 of the Act).
Temporary residence based on family reunification with a researcher under Article 74.
Temporary residence for study purposes, with the right to work or be self-employed up to 20 hours per week, unless the activity is part of the official study programme.
Status of regular pupil, engaging in work through authorised intermediaries up to 20 hours per week without an employment contract.
Temporary residence as a person holding long-term residence in another EEA country.
Asylum or subsidiary protection, or pending application for international protection.
Long-term residence.
Permanent residence.
Temporary residence for immigration and return of Croatian emigrants.
Additionally, third-country nationals participating in sports events or competitions in Croatia as members of foreign teams or national delegations are exempt from obtaining a permit or registration. Likewise, students may work or be self-employed up to 20 hours per week without the obligation to obtain a residence and work permit or work registration certificate.
Opinion of the Croatian Employment Service (HZZ)
A positive opinion of the Croatian Employment Service (HZZ)—when required by the Aliens Act as a precondition for issuing a residence and work permit—shall be provided to the competent police administration or station only if the employer meets the following conditions:
A work contract with the third-country national has been submitted.
The contract must not contain discriminatory provisions placing the third-country national in a less favourable position than Croatian or EU workers.
The salary offered must not be lower than that received by workers in similar roles in Croatia, in accordance with applicable laws and collective agreements.
A document proving that the job requirements were fulfilled in the labour market test has been submitted.
This includes education level, qualifications, work experience, and all other employer requirements.
A recognition decision of a foreign professional qualification has been submitted (if the job falls under regulated professions as per the official list in Croatia).
The employer actively conducts business in a registered activity within Croatia.
The employer has settled all tax obligations, as confirmed by the Ministry of Finance.
For the past 12 months, the employer has employed at least one Croatian, EEA, or Swiss national continuously, full-time and on a permanent basis.
The employer has not been convicted of criminal offences related to labour law, social security, or public safety.
The employer has not received final administrative sanctions for serious labour violations or breaches of social security and occupational safety.
The employer has demonstrated minimum revenue over the past six months:
Legal entities: at least €10,000 per month
Natural persons: at least €15,000 total over the observed period
The employer is not listed among those identified for undeclared work, according to relevant labour regulations.
In addition to the above, the HZZ will issue a positive opinion if:
At the time of application, at least 16% of full-time employees are Croatian, EEA, or Swiss nationals, relative to third-country nationals.
For shortage occupations, this threshold is lowered to 8%.
On request by the HZZ, the Croatian Pension Insurance Institute (HZMO) is obliged to provide data on the employment status of the employer’s staff.
Vrh obrasca
Labour Market Test
Except in cases explicitly exempted by law, before submitting an application for a residence and work permit, the employer is obliged to request the implementation of a labour market test from the Croatian Employment Service (CES). The test includes checking the status of unemployed persons registered in the database and conducting mediation procedures aimed at employing domestic labour force.
The requirements listed in the labour market test for a particular job position cannot exceed the standards applied to comparable job positions, nor can the proposed salary be lower than the wage paid to employees in similar or related occupations in Croatia, in accordance with relevant laws and collective agreements.
If the CES finds suitable candidates, it will facilitate the hiring process. If no suitable candidates are available or relocation within the country is not feasible, the CES will issue a report, and the employer can submit an application for a residence and work permit within 90 days from the date of the issued report.
Number of Work Permit Applications
An employer hiring up to 50 Croatian/EEA/Swiss nationals may submit up to 50 applications. An employer hiring between 51 and 250 such workers may submit up to 250 applications. If the allowed number is exceeded, the CES will not issue a positive opinion.
Longer Validity of Residence and Work Permits
Residence and work permits can now be issued for up to three years, depending on the employment contract duration — a significant reduction of administrative burden compared to the previous one-year limitation.
EU Blue Card: A New Standard for Highly Qualified Workers
In line with Directive (EU) 2021/1883, Croatia has redefined the issuance rules for the EU Blue Card, which serves as both residence and work authorization for highly skilled foreign workers.
Extended validity: The Blue Card is now valid for four years (previously two).
IT sector inclusion: Candidates without formal education but with at least three years of IT experience may be eligible.
Salary requirement: Applicants must earn at least 1.5 times the average gross wage in Croatia.
Stricter Employer Obligations and Responsibilities
1. Financial Guarantee – Promissory Note
Employers must pay one average monthly gross salary into the state budget (based on the latest statistics) if:
i. The third-country national fails to start work as per the employment contract,
ii. The employment contract is terminated within three months (except in cases of employee misconduct).
iii. To secure this liability, the employer must issue a promissory note to the Ministry of the Interior and submit it within five days of receiving the work approval confirmation.
2. Adequate Accommodation
If the employer provides or intermediates in housing, the accommodation must:
i. Ensure an adequate living standard for the foreign worker,
ii. Be reported to the police within eight days of any change,
iii. Allow rent payments that are fair and not automatically deducted from wages,
iv. Be formalized with a rental agreement stating terms clearly,
v. Comply with Croatia’s health and safety regulations.
Greater Flexibility for Foreign Workers
The law now allows change of occupation, change of employer, and supplementary employment without issuing a new permit, as long as changes occur within the validity of the existing permit.
Temporary Residence & Incentives for Return of Croatian Emigrants
A new purpose of temporary residence has been introduced: immigration and return of Croatian emigrants. These individuals will no longer be treated as foreigners under migration law and can:
- Work or be self-employed without a permit,
- Enrol in education and training programmes,
- Study at higher education institutions,
- Apply for Croatian citizenship immediately after receiving their residence permit.
Validity: Up to two years, with no proof of income or health insurance required.
Penalties for Illegal Employment
To deter unlawful employment practices and enhance worker protection, high penalties are prescribed for employers who employ third-country nationals:
- Legal entities: €5,000 – €20,000
- Natural persons: €2,000 – €6,000
LEGAL SOURCE:
- Foreigners Act ("Official Gazette" Nos. 133/20, 114/22, 151/22, 40/25)
Anja Juršetić Šepčević, managing director
LAW FIRM JURŠETIĆ & ALEKSOVSKI Ltd