Last year, the Croatian Regulatory Agency for Network Activities (HAKOM) received 52 complaints, 45 of which related to very large Internet platforms and search engines, but in these cases no violations of obligations from the Digital Services Act (DSA) were established, HAKOM reported. Also, last year only seven complaints were filed against Internet service providers with business establishments in Croatia, but none of them led to the initiation of a formal procedure and possible monetary punishment of the provider.
The HAKOM report clarifies that the Digital Services Act established harmonized rules for a safe, predictable and reliable internet environment when using the so-called mediation services that include internet platforms and rules that include additional transparency requirements on how internet platforms moderate content.
Prevent illegal content on the Internet
DSA also aims to prevent illegal content on the Internet, protect minors and prevent the spread of misinformation. At the same time, providers of very large Internet platforms (VLOP) and very large Internet search engines (VLOSE) are subject to additional supervision, including the obligation of transparent advertising and publication of systemic risk assessments.
However, as pointed out in the report, after conducting a preliminary evaluation based on 52 complaints, no specific circumstances were identified that would point to a violation of the obligations from the Act on Digital Services.
In the majority of cases, it was determined that the complaints were reduced to dissatisfaction with the individual decision of the platform in the specific case – removal of content, limitation of reach or suspension of the account, while the elements of DSA violation were also not determined.
For example, the user did not previously contact the platform to challenge the decision, the platform provided a justification for moderating the content, or the available internal complaint resolution mechanisms were not used, according to HAKOM.
He adds that in a small number of cases, users have mistakenly estimated that these are complaints to which the DSA applies, for example, submissions related to monetary transactions between the recipient of the service and the merchant.
On the other hand, from the report, it can also be seen how the Croatian institutions that are responsible for issuing orders to act against illegal content on the Internet and issuing orders to provide information are also reacting.
In the case of illegal content that constitutes a criminal offense or misdemeanor, it is the State Attorney’s Office and the Ministry of Interior, in the case of a violation of personal data protection, it is the Personal Data Protection Agency (AZOP), in the case of theft of intellectual property, the Customs Administration, and within its competences, it is also the State Inspectorate, the Ministry of Health and the Agency for Electronic Media.
Facebook and Whatsapp service
In particular, last year the MUP submitted only two requests for information to the Meta platform – for Facebook in connection with an offense against public order and peace, and for WhatsApp in connection with criminal acts of unauthorized access and exploitation of children for pornography.
“Meta refused both requests with the reasoning that it is necessary to send a request for international legal assistance,” the report states.
The State Inspectorate, on the other hand, submitted four orders in 2025 for violations of the DSA. The market inspection filed an order against Facebook that included two Facebook profiles and related to three advertisements with violations of the provisions of the Trade Act, the Electronic Trade Act and the Consumer Protection Act. The platform fully complied with the order and the illegal content was removed, according to HAKOM.
The Tourist Inspection submitted two orders to the platforms Booking.com and Airbnb.com, in order to remove illegal content related to the advertising of unregistered performance of hospitality activities, i.e. accommodation. Booking.com complied and removed the ad, while Airbnb.com did not.
As part of criminal investigations in Croatia, the Ministry of Internal Affairs 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 the service providers and the police and were outside the scope of the legal provisions of the DSA, it is emphasized in the HAKOM report.
In the reporting of illegal content on the Internet, in addition to the competent institutions, there are also reliable reporters – responsible for detecting potentially illegal content and warning Internet platforms.
Strengthen dialogue with civil society
As experts in identifying certain types of illegal content on the Internet, such as hate speech, terrorist content, counterfeit products or child pornography, they should report such content to online platforms.
They must process them as a matter of priority, since it is assumed that they are more accurate than the applications of average users, HAKOM also added that their rulebook for granting status in public consultation is open until April 13.
The status of a reliable applicant is granted for a specific type of illegal content, with proof of the necessary professional knowledge and appropriate competencies, it will be emphasized in HAKOM’s response to Hina.
It was also confirmed that individual inquiries have been sent to HAKOM so far, and a preliminary interest has been expressed in acquiring the status of a reliable reporter, including the Center for Missing and Abused Children.
During the awarding of the first reliable applicant status, special attention will be paid to strengthening the dialogue with civil society organizations on the implementation of DSA, HAKOM adds, concluding that there is a visible increase in public interest in DSA and users’ rights.
“In the first two months of 2026, 26 complaints were received, which is about half of the total number of complaints in the whole of 2025. This trend confirms the importance of continuing to inform users and stakeholders,” HAKOM said.
Miroslav Edvin Habek
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