The Croatian Regulatory Authority for Network Activities (HAKOM) received 52 complaints last year, of which 45 pertained to very large online platforms and search engines, but no violations of obligations under the Digital Services Act (DSA) were established in these cases, HAKOM reported.
Additionally, only seven complaints were filed against internet service providers based in Croatia last year, but none led to the initiation of formal proceedings or potential monetary penalties for the providers.
HAKOM’s report clarifies that the Digital Services Act established harmonized rules for a safe, predictable, and reliable online environment when using so-called intermediary services, which include online platforms, as well as rules that include additional transparency requirements regarding how online platforms moderate content.
Preventing illegal content on the internet
The DSA also aims to prevent illegal content on the internet, protect minors, and prevent the spread of misinformation. In this context, very large online platform (VLOP) and very large online search engine (VLOSE) providers are subject to additional oversight, including the obligation for transparent advertising and the publication of systemic risk assessments.
However, as emphasized in the report, after conducting a preliminary assessment based on the 52 complaints, no circumstances were found that would indicate a violation of obligations under the Digital Services Act.
In most cases, it was determined that the complaints were based on dissatisfaction with a specific platform decision in a particular case – content removal, reach limitation, or account suspension, where elements of DSA violation were also not established.
For example, the user did not previously contact the platform to contest the decision, the platform provided justification for content moderation, or available internal complaint resolution mechanisms were not utilized, HAKOM points out.
It adds that in a smaller number of cases, users incorrectly assessed that these were complaints to which the DSA applies, such as submissions related to monetary transactions between the service recipient and the merchant.
On the other hand, the report also reveals how Croatian institutions respond that are responsible for issuing orders to act against illegal content on the internet and issuing orders for information provision.
In the case of illegal content that constitutes a criminal offense or misdemeanor, these are the State Attorney’s Office and the Ministry of the Interior (MUP), in the case of violations of personal data protection, it is the Agency for Personal Data Protection (AZOP), in the case of intellectual property theft, it is the Customs Administration, and within their competencies, these also include the State Inspectorate, the Ministry of Health, and the Agency for Electronic Media.
The case of Facebook and WhatsApp
Specifically, last year, the MUP submitted only two requests for information to the Meta platform – for Facebook regarding a violation of public order and peace and for WhatsApp regarding criminal offenses of unauthorized access and exploitation of children for pornography.
– Meta rejected both requests with the explanation that it is necessary to submit a request for international legal assistance – the report states.
The State Inspectorate, on the other hand, submitted four orders for violations of the DSA during 2025. The Market Inspectorate submitted an order to Facebook that covered two Facebook profiles and related to three ads with violations of the provisions of the Trade Act, the Electronic Commerce Act, and the Consumer Protection Act. The platform fully complied with the order, and the illegal content was removed, HAKOM emphasizes.
The Tourist Inspectorate submitted two orders to the platforms Booking.com and Airbnb.com for the removal of illegal content related to advertising unregistered hospitality activities or accommodation. Booking.com complied with the order and removed the ad, while Airbnb.com did not comply with the order.
The MUP, within criminal investigations in Croatia, also sent 719 requests to foreign internet service providers for the delivery of basic subscriber data about users. The requests were based on voluntary cooperation between service providers and the police and were outside the regime of the legal provisions of the DSA, HAKOM’s report states.
In reporting illegal content on the internet, in addition to the competent institutions, reliable reporters are also provided – responsible for detecting potentially illegal content and alerting online platforms.
Strengthening dialogue with civil society
They should, as experts in recognizing certain types of illegal content on the internet, such as hate speech, terrorist content, counterfeit products, or child pornography, report such content to online platforms.
These platforms must process them as a priority, as their greater accuracy is assumed compared to reports from average users, HAKOM emphasizes, adding that their regulation for granting status is in public consultation open until April 13.
The status of a reliable reporter is granted for a specific type of illegal content, with the requirement to demonstrate necessary expertise and appropriate competencies, HAKOM states in response to Hina.
It has also been confirmed that individual inquiries have been sent to HAKOM so far, and preliminary interest has been expressed in obtaining the status of a reliable reporter, including the Center for Missing and Exploited Children.
When granting the first statuses of reliable reporters, special attention will be paid to strengthening dialogue with civil society organizations regarding the implementation of the DSA, HAKOM adds, concluding that there is a visible increase in public interest in the DSA and user rights.
‘- In the first two months of 2026, 26 complaints were received, which is about half of the total number of complaints for all of 2025. This trend confirms the importance of continuing to inform users and stakeholders – emphasizes HAKOM.
