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HIGH-RISK AI SYSTEMS UNDER THE EU AI ACT

Introduction to the topic Under Article 6 of the EU Artificial Intelligence Act (Regulation (EU) 2024/1689*), an AI system is classified as high-risk if it either (1) forms part of a product regulated by EU harmonised legislation—such as medical devices, vehicles, or industrial machinery—or (2) performs a function listed in Annex III, including use in areas like education, law enforcement, employment, and biometric identification. The Act also mandates that any AI system used for profiling natural persons—automated evaluation or prediction of individuals' traits, preferences, or behaviour—is automatically classified as high-risk. Even when a provider believes a system does not pose serious risks, its profiling function alone triggers this classification. Providers of such systems must either conduct a formal risk assessment to justify otherwise and still register the system in the EU database, or they must comply with the full framework of regulatory obligations, including documentation, transparency, testing, and human oversight. This high-risk classification ensures that AI systems which can significantly impact people’s lives, safety, or rights are subject to stricter scrutiny and accountability—ultimately promoting trust and lawful innovation across the EU.

EUROPE’S HISTORIC LEAP TOWARD REGULATING ARTIFICIAL INTELLIGENCE: EU AI ACT

Introduction: a series of 13 articles on the EU AI Act We bring you a series of 13 articles on the EU AI Act and its application in law, including an analysis of the Act through 13 different topics covering various chapters of the regulation – with one article published each day. Perhaps 13 really is a lucky number – at least for those eager to learn!

NOT ALL AI IS HIGH-RISK: WHAT THE EU AI ACT SAYS ABOUT CHATBOTS, SPOTIFY, GOOGLE TRANSLATE AND SIRI?

In our previous two articles, we explored the categories of prohibited AI systems and high-risk AI systems as defined by the EU Artificial Intelligence Act (Regulation (EU) 2024/1689, hereinafter: the Act*). While much of the public and legal discourse has focused on these areas, an important and widely applicable category—limited-risk AI systems—deserves closer examination. These systems, which comprise the majority of AI applications in daily commercial and public life, are not banned or heavily regulated. Instead, the Act introduces a light-touch framework of transparency obligations aimed at fostering accountability, user awareness, and trust without stifling innovation.

MERGERS & ACQUISITIONS IN CROATIA: LEGAL DUE DILIGENCE AND COMMON PITFALLS FOR FOREIGN BUYERS

Key Considerations for Foreign Investors When Acquiring Croatian Companies Introduction The Croatian market, as part of the EU single market, continues to attract foreign direct investment across a range of industries—particularly tourism, real estate, energy, ICT, and manufacturing. According to the World Bank and the American Chamber of Commerce (AmCham), foreign investment in Croatia is experiencing strong growth since 2024, with a notable shift in its structure — capital is increasingly moving away from the banking sector and into tourism and the IT industry. In the first quarter of 2024, foreign investors injected over one billion euros into the Croatian economy. If this trend continues, it is expected to surpass the 2021 record of approximately four billion euros. From 1993 to date, Croatia has received more than 46 billion euros in foreign capital, primarily in finance, manufacturing, and real estate — and over time, the country is increasingly perceived as an attractive investment destination.

ARE FOREIGN FOUNDERS AND MANAGEMENT BOARD MEMBERS LIABLE FOR A COMPANY’S OBLIGATIONS IN CROATIA?

Civil and Criminal Liability in the Context of Piercing the Corporate Veil Introduction Although company members and management board members are generally not liable for the obligations of the company, there are legal provisions in place to protect creditors from the abuse of this rule. Both company members and management board members may be held liable for the company’s obligations, albeit on distinct legal grounds. Liability applies equally, irrespective of whether the individuals are domestic or foreign persons, as their residency status has no bearing on the scope or nature of their potential liability. Creditors have at their disposal additional legal remedies beyond the liabilities provided for in the Companies Act and the Criminal Code. Notably, various forms of security instruments can be used to prevent or mitigate malicious conduct by debtor companies and their members or management. Furthermore, creditors may initiate legal proceedings to annul legal transactions made to their detriment, thereby effectively reversing certain forms of abuse by company members or management board members. In conclusion, creditor protection in the Republic of Croatia is broad and comprehensive, offering multiple legal instruments to safeguard against malicious and fraudulent conduct within companies. It is also evident that the limitation of liability for company members and management board members is not absolute.

LATEST AMENDMENTS TO THE CROATIAN FOREIGNERS’ ACT, PART II – STRICTER RULES ON THE EMPLOYMENT OF THIRD-COUNTRY NATIONALS

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.

LATEST AMENDMENTS TO THE CROATIAN FOREIGNERS ACT - PART I (ARTICLES 1-87): ENHANCED ALIGNMENT WITH THE EU ACQUIS

In recent days, one of the key legal developments in Croatia has been the adoption of amendments to the Foreigners Act. The Croatian Parliament has amended the existing Foreigners Act (Official Gazette Nos. 133/20, 114/22, and 151/22), following a proposal submitted by the Government of the Republic of Croatia last year. The revised Act entered into force on 15 March 2025 (hereinafter: the Act). The amendments primarily aim to improve the management of residence and employment of third-country nationals in Croatia and to align national legislation with EU law—particularly Directive (EU) 2021/1883 of the European Parliament and of the Council, which governs the admission and residence conditions for highly qualified workers (the so-called EU Blue Card). The Act also introduces stricter criteria for employers hiring foreign workers, in response to the continuous rise in the number of third-country nationals working and residing in Croatia.