Croatia (Hrvatska) – Valuation for lending purposes

Data as of October 2026

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I. THE VALUATION

I.1 Regulatory Framework

a) Is there a legal framework in your Member State for the valuation of real estate for lending purposes (loan origination)? If yes: • Is this framework specifically for the valuation of real estate for lending purposes or are provisions enshrined in a broader piece of legislation? • Is it limited to the transposition of European or International Standards or is it broader in nature? • Please provide references and indicate whether it applies to both residential and commercial property. If there are differences between both property types, please explain.	The legal framework for real estate valuation is regulated by the Law on Real Estate Valuation (Official Gazette 78/2015) and the Rules on Real Estate Valuation Methods (Official Gazette 105/2015). Previously mentioned Law on Real Estate Valuation and Rules on Real Estate Valuation Methods are specifically intended for the valuation of real estate, regardless of the purpose or reason for which the property is being valued. The legal framework does not provide for the use of European or International valuation standards. The legal framework applies to all types of real estate.
b) If there is no specific legal framework, is the valuation of real estate for lending purposes covered by other means, e.g. self-regulation, sector recommendations or supervisory guidance?
c) Do national valuation standards exist? Is there any cross-reference to European and/or International Valuation Standards (EVS/IVS)?	There is a national valuation standard in Croatia. It is regulated by the Law on Real Estate Valuation and Rules on Real Estate Valuation Methods.
d) How has the regulator in your Member State transposed Article 19(1) of the MCD regarding “reliable standards” for the valuation of residential property (into legislation or delivered through a professional body)? Indicate whether and how “reliable standards” are defined and whether and how the content of those standards are prescribed.	The provisions of Article 19(1) of the MCD, which refer to “reliable standards“ for the valuation of residential property have been transposed into national legislation through the following acts: 1. Law on Real Estate Valuation (Official Gazette 78/2015) – which represents the fundamental legislative framework for carrying out real estate valuations in Croatia; 2. Rules on Real Estate Valuation Methods (Official Gazette 105/2015) – which sets out in detail the procedures, methods, and manner of preparing valuation reports; 3. Law on Residential Consumer Credit (Official Gazette 101/2017, 128/2022, 156/2023) – which transposes the MCD into national law, including provisions on the valuation of real estate used as collateral. The reliable standards are implemented through these legislative and regulatory acts, which define: • who is authorised to carry out valuations (certified valuers registered with the Ministry of Justice, Public Administration and Digital Transformation); • which valuation methods can be used (comparison, income, and cost approach); • the form and content of the valuation report (mandatory elements, documentation, data sources, valuation conclusion, valuer’s signature and seal); • the principles of objectivity, independence, and transparency in the valuation process. This ensures in practice that property valuations are conducted on the basis of reliable, consistent, and verifiable standards, in line with the European principles set out in Article 19 of the MCD.

I.2 Valuation Bases & Methodology

a) What valuation bases (Market Value, Mortgage Lending Value, etc.) are typically used in your Member State for the valuation of property for lending purposes (please disregard at this stage the specific requirements of Art. 229 CRR considering that the Property Value is not an independent basis of value).	In the Republic of Croatia, the market value is used for the valuation of properties for lending purposes. The mortgage lending value is currently not formally defined or prescribed under Croatian legislation as a separate basis of value.
b) Based on what definition? Please provide the definition and reference to where it can be located.	The Market Value is used for the valuation of property, which is understood as the estimated amount at which a property could be exchanged as of the valuation date between a willing buyer and a willing seller, in a transaction according to market conditions, after appropriate advertising, wherein each party has acted in an informed and reasonable manner, without any compulsion.1
c) In case other valuation bases are used in your Member State for the valuation of property for lending purposes, please specify the effect, if any, on the final valuation.	Other valuation bases are not used in Croatia. Alternative valuation bases may be determined for specific purposes, but the lending (collateral) value is always derived from market value, and other bases have no effect on the final value used for lending decisions. From 01st July 2025. according to the CNB decision, all banks in Croatia for lending with purpose of buying real estate, lower value (market or sales value) has to be taken as base for LTV approval calculation.
d) Depending on the valuation base used, which valuation approaches or methods (comparison, income, cost, etc.) are typically applied in your Member State to value properties for lending purposes in each category?	In the Republic of Croatia, all three main valuation approaches — comparison (market), income, and cost — are prescribed by national legislation and all are permitted, depending on the type and purpose of the property. Specifically: According to the Real Estate Valuation Act (Official Gazette 78/2015) and the related Regulations on Real Estate Valuation Methods, all three approaches are recognized and defined: The comparison approach is applied when sufficient comparable market transactions are available. The income approach is used for properties that generate income (e.g. commercial, rental, or investment properties). The cost approach is applied when there is insufficient market data or when valuing specific types of properties (e.g. special-purpose buildings). Therefore, all three valuation approaches are allowed and applied depending on the type of property, available data, and the purpose of the valuation, in accordance with Croatian legislation and professional valuation standards.

I.3 Valuation Report: Form & Content

a) Does the legal or professional framework in your Member State specific to the valuation of properties provide minimum requirements in terms of the form and content of the valuation report? If yes, please indicate what these minimum requirements are.	The minimum content is prescribed by Article 68 of the Rules on Real Estate Value Appraisal Methods. Reports must include details of the property, methodology, market analysis, calculations and a conclusion of value. Form and content of the valuation reports should contain the following: ■ A cover page with an identification number of the report, general data on the property being valued, (property type, address stated in the manner that unambiguously identifies the property), identity of the commissioning party with the exact address, the identity of the potential user (loan applicant/borrower) with the exact address, the identity of the valuer and the date the report is drawn up (month and year). ■ A brief statement specifying the most important assumptions or restrictions and a valuation statement in EUR, indicating the valuation date. ■ Specification of all persons responsible for preparing the valuation, certified by an authorized valuer and /or a person authorized to represent him/her. ■ Authorization of the valuer. ■ Important data: valuation date (day, month, year); date of on site visit; commissioning party – full name and address; property – type; property address – full address; data from the Land Registry Office; data from the Cadastral Office; property description – location, and condition, access to public road; existence of acts that prove the legality of the property or that would ensure its legality provided administrative procedures are carried out and detail of all possible restrictions on the property concerning its legality. ■ Statement of the property’s surface. ■ Analysis of market data necessary to calculate the value of property with the adopted method. ■ The calculation of property value with one of the methods (the second method can be an ancillary method, i.e. control of the stated value with a previous description of the method and the reason of its choice. ■ Photo evidence. ■ Documentation.
b) Should the form and content of valuation reports be prescribed, are there differences between residential and non-residential properties? Please describe as appropriate.	The content of valuation for lending purposes is strictly prescribed by regulator. Residential and commercial reports share the same structure, differing mainly in analytical depth.
c) If the form or content of the valuation report are not prescribed, what form does the valuation report typically take? Please specify differences between residential and commercial property valuation reports.	The content of valuation report is strictly prescribed by regulator.

I.4 Technology & Valuation

a) Does the legal or professional framework in your Member State provide specific rules/guidance on the use of digital valuation tools (AVMs, Artificial Intelligence etc.)? If yes, what does this consist of and is it restricted to a particular type of property? Please specify whether there is a correlation with the requirements of Article 208(3a) CRR and of section 7.4 of GLOAM or whether the latter provisions are of stand-alone application in your Member State.	The legal and professional framework currently does not contain specific rules or guidance explicitly regulating the use of digital valuation tools (AVMs or AI) for property valuation in lending purposes. The Law on Real Estate Valuation (Official Gazette 78/2015) and the Rules on Real Estate Valuation Methods define the methodology, procedures, and content of valuations, but do not specifically address digital or automated methods. In practice, AVM tools are used as a supplementary aid – for example, for internal checks or indicative analyses – however, the final valuation must be carried out by a certified valuer, in accordance with the law and professional standards.
b) For what purpose are digital tools and/or AI employed in your Member State? - Mortgage origination, monitoring and review of property values, revaluation etc. - Capital requirements, covered bond funding, securitisation transactions, mortgage portfolio risk management etc.
c) Scope of digitisation: Please determine the scope of automated and digitised tools in your Member State. Are they confined to data collection, do they deliver reliable property values or are they even used to produce full or partial valuation reports including description of locations, infrastructure, building characteristics etc.? If the latter is the case, is internal data used or it is permitted to purchase data from an external data provider?
d) Quality requirements: How are the reliability of the tools and their outputs assessed, e.g. by controlling the inputs, back-testing, supervision and/or plausibility checks by valuers etc.?
e) Do you foresee an increase in the use of automation and digitisation of property valuation processes in the future? Please describe potential technological developments which could impact the valuation profession and accelerate its transformation, notably through the use of AI.	An increase in the use of automation and digitalisation in property valuation processes is expected in the coming period, particularly through the development and application of AI and AVMs. Several important technological trends are anticipated that could significantly impact the valuation profession and accelerate its transformation, including: • The development of advanced AVM systems • The application of artificial intelligence and machine learning • The digitalisation of data collection and verification processes (e.g. automatic retrieval of data from registries, land registry books, and market databases).

I.5 ESG, climate risk, transformation risk

a) How are ESG factors and climate risk taken into consideration in the valuation process? Do Market Values and/or Mortgage Lending Values reflect the ESG characteristics of properties?	ESG factors and climate risks are currently not formally incorporated into the legal framework governing real estate valuation. The Law on Real Estate Valuation and the related Rules on Real Estate Valuation Methods do not prescribe any obligation for separate assessment of ESG aspects. Elements of ESG factors are taken into consideration through market analysis and the technical characteristics of properties, such as: • energy efficiency and possession of an energy performance certificate, • use of sustainable materials and construction technologies, • location-related factors associated with climate and environmental risks (floods, seismic activity, fire, drought, etc.). In real life, the market value reflects ESG characteristics to the extent that the market recognizes and values them through higher demand and prices for “green” or energy-efficient properties.2
b) Are there rules in your Member State requiring assessment of EU Taxonomy alignment of a property in the valuation report and the subsequent impact of compliance/non-compliance on property values?	Rules requiring an assessment of a property's compliance with the EU Taxonomy in the valuation report, or any obligation to reflect the impact of compliance/non-compliance on the assessed value, are currently not formally mandatory.
c) Are digitised tools and AI applied in order to capture and/or measure the impact of ESG factors and climate risk on property values?	There are digitised tools and AI solutions that assess ESG factors and climate risks of a property. These tools are not publicly available, as they were developed by private companies.

I.6 Market Initiatives

a) Please describe any market initiatives which have been undertaken in your Member State (including cross border initiatives) and which have promoted market best practices and/or transparency of valuation practices.

II. THE VALUER

II.1 Regulatory Framework

a) Is property valuation a regulated profession in your Member State (through legal, regulatory or statutory rules)?	Property valuation is a regulated profession. According to the Law on Real Estate Valuation, the valuation report is a document that clearly and transparently presents the valuation of a property in written form, and it may be prepared by certified court experts or certified court valuers.
b) Is the use of the title of valuer protected in your Member State? If yes, by whom?	The profession of certified court experts and certified court valuers is regulated by the Judiciary Act (Official Gazette 28/13, 33/15, 82/15, 82/16, 67/18, 60/22, 21/22, 16/23, 155/23 and 36/24) and the Regulation on Certified Court Experts (Official Gazette 38/14, 123/15, 29/16, 61/19).
c) If the title of valuer is not protected in your Member State, how do lenders ensure that they work with ‘qualified’ valuers? Are there ‘professional’ certifications for property valuers in your Member State? If yes, please name them.
d) Is the regulatory or professional framework the same for all valuers, whether they value residential and/or commercial property? Or are there differences? Please describe as appropriate.	The regulatory and professional framework is the same for all valuers, regardless of the type of property being valued.

II.2 Qualification and Independence

a) The qualified valuer • How has the regulator in your Member State transposed the requirements of Article 19(2) of the MCD, of Articles 229(1) and 208(3b) of the CRR regarding the instruction of “professionally competent valuers” or valuers who possess the “necessary qualifications, ability and experience” (transposition through legislation or by self-regulation)? Indicate how professional competence and qualification requirements are prescribed.	Pursuant to Article 3(2) of the Real Estate Valuation Act, real estate valuations shall be carried out by court experts and court valuers, whose authority derives from specific provisions regulating court and expropriation procedures. The requirements and conditions for appointing valuers are prescribed by the Judiciary Act (Official Gazette 28/13, 33/15, 82/15, 82/16, 67/18, 60/22, 21/22, 16/23, 155/23, and 36/24). As court experts, the Ministry of Justice, Public Administration and Digital Transformation may appoint persons who, during the nomination procedure, have been found to meet the following criteria: • are citizens of the Republic of Croatia, of a Member State of the European Union, or of a state that is a signatory to the Agreement on the European Economic Area; • have completed an undergraduate and graduate university study, an integrated undergraduate and graduate university study, or a specialist graduate professional study, or have completed an undergraduate university or undergraduate professional study corresponding to the field of expertise for which they are being appointed; • have at least eight years of professional experience after completing a graduate or integrated study programme, or ten years after completing an undergraduate study programme; • are proficient in the Croatian language; • are medically fit to perform the duties of a permanent court expert; • have successfully passed a knowledge test on the structure of the judicial system, public administration, and legal terminology; • have concluded a professional liability insurance contract for performing the duties of a permanent court expert, with a minimum coverage of EUR 25,000; • hold a valid authorization for independent professional practice (license) or have passed a professional or specialist examination required for the performance of that profession, if such a requirement exists under special regulations. A person subject to ongoing criminal proceedings or convicted by a final judgment for a criminal offense prosecuted ex officio — except for traffic safety offenses for which no unconditional prison sentence was imposed — may not be appointed as a permanent court expert. Before appointment, candidates for permanent court experts must successfully complete professional training, the content and procedure of which are prescribed by the Minister of Justice. Appointed permanent court experts are required to undertake continuous professional development in the field for which they have been appointed and to submit proof of such training to the Ministry of Justice at least once every two years.
a) The qualified valuer • If professional competence, qualification, ability and experience requirements are not prescribed, what is general practice with regard to professional qualifications?	Competence requirements are regulated by law as described above. 3
b) The independent valuer • How has the regulator in your Member State transposed the provision in Article 19(2) of the MCD or in Articles 229(1) and 208(3)(b) of the CRR regarding “sufficient independence from the credit underwriting process” or “independence from the loan processing and loan decision process” (through legislation or delivered through self-regulation)? Indicate whether and how the requirement is defined and whether and how it is prescribed.	Pursuant to the Real Estate Valuation Act, the valuer is obliged to carry out the activities in respect of which he has been authorised in a professional, manner, independently and impartially, and he/she must present all the circumstances that bring into question his/her impartiality or a possible conflict of interest. The valuer shall sign a statement on impartiality and independence which is an integral part of the valuation report. If characteristics of the real estate in question exceed the competence limits of the valuer, he/she shall include, in the preparation of the valuation report, a professional with specific competences. The valuer shall draw up a valuation report in a correct manner and in line with regulations and rules of the profession. 4
b) The independent valuer • If “sufficient independence” is not prescribed, what is general practice to ensure the valuer is unbiased and not subject to undue pressure?	Sufficient independence is prescribed.

II.3 External vs. Internal

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties? • If yes, do credit institutions have the possibility to employ both internal and external valuers? • Is one type of valuer typically employed more frequently than the other?	Credit institutions may use only qualified and certified valuers who meet the legal requirements of professional competence, independence, and professional liability. Credit institutions have the option to employ both internal and external valuers, depending on their chosen or preferred operating model. External valuers are used more frequently than internal ones.
b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice?	It is common practice for credit institutions to use the services of both external and internal valuers, depending on their needs.

II.4 Professional Indemnity Insurance

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require: • Valuers to have professional indemnity insurance cover? • Lenders to use only valuers covered by professional indemnity insurance?	Professional liability insurance is mandatory. Proof of renewal of the insurance policy must be submitted to the competent Ministry of Justice, Public Administration and Digital Transformation each year. If a certified valuer does not have valid professional liability insurance, the competent Ministry revokes their licence to operate.
b) If there are no such requirements, how are lenders/valuers covered for the risk? • Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer.	Valuers who work for e.g. banks, investors, companies, etc., operate under a contractual relationship with the client commissioning the valuation. Their liability towards the client is governed by: • Law on Real Estate Valuation (Official Gazette 78/15), • Civil Obligations Act (Official Gazette 35/05, 41/08, 125/11, 78/15, 29/18, 126/21, 114/22, 156/22, 155/23) – in the part relating to liability for damages and the performance of a contract for services. A valuer bears civil/financial liability if : • fails to apply the legally prescribed valuation methods, • provides an incorrect or unprofessional valuation opinion, • causes financial damage to the client due to negligence or omission. The competent Ministry of Justice, Public Administration and Digital Transformation may also initiate supervisory or disciplinary proceedings, and in serious cases revoke the valuer’s authorisation.

a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require:
• Valuers to have professional indemnity insurance cover?
• Lenders to use only valuers covered by professional indemnity insurance?

Professional liability insurance is mandatory. Proof of renewal of the insurance policy must be submitted to the competent Ministry of Justice, Public Administration and Digital Transformation each year. If a certified valuer does not have valid professional liability insurance, the competent Ministry revokes their licence to operate.

b) If there are no such requirements, how are lenders/valuers covered for the risk?
• Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer.

Valuers who work for e.g. banks, investors, companies, etc., operate under a contractual relationship with the client commissioning the valuation.

Their liability towards the client is governed by:
• Law on Real Estate Valuation (Official Gazette 78/15),
• Civil Obligations Act (Official Gazette 35/05, 41/08, 125/11, 78/15, 29/18, 126/21, 114/22, 156/22, 155/23) – in the part relating to liability for damages and the performance of a contract for services.

A valuer bears civil/financial liability if :
• fails to apply the legally prescribed valuation methods,
• provides an incorrect or unprofessional valuation opinion,
• causes financial damage to the client due to negligence or omission.

The competent Ministry of Justice, Public Administration and Digital Transformation may also initiate supervisory or disciplinary proceedings, and in serious cases revoke the valuer’s authorisation.

III. VALUATION & CAPITAL REQUIREMENT

a) Property Value How are the Property Value requirements of Article 229(1) CRR transposed in your Member State: • by calculating the Mortgage Lending Value • by Market Value adjustments ◦ adjustments determined by the valuer on a single property by property basis ◦ adjustments determined by the credit institution on a portfolio level based on internal historic market data series ◦ adjustments determined by the credit institution on a portfolio level based on data provided by external research institutes or data providers	The mortgage lending value is currently not formally defined or prescribed under Croatian legislation as a separate basis of value. Regular annual checking of the non residential real estates done by official appraisers based on official appraisal done by OTP real estate company. Market Value of residential real estates is regularely adjusted using official indexes published by Croatian Bureau of Statistics.
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding "more frequent monitoring where the market is subject to significant changes in conditions"?	No
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding “advanced statistical or other mathematical methods” complying with the technical requirements of Article 208(3a) CRR?	No
b) Monitoring of property values Please provide an overview of the different statistical methods/tools complying with Article 208(3a) CRR applied by lenders in practice.	OTP bank Croatia applies indexes on residential real estates published by Croatian Bureau of Statistics.
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “review” of the property valuation? If so, what are the minimum and maximum periods within which a review must be conducted? Based on which criteria?	No
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “material decline relative to general market prices”? How are ESG-related considerations assessed as an indicator for a material decline?	No
c) Review of property values and revaluation • Please provide a description of how ‘reviews’ are carried out in your Member State, e.g. by a new full-size valuation report, a desk-top valuation, a valuation certificate, a plausibility assessment or alike. What criteria are used to determine how the reviews are to be carried out?	Revaluation of residential real estates is performed using indexes on residential real estates published by Croatian Bureau of Statistics. For non residential real estates desktop valuations are being performed in the 5 year period since original official valuation, so every 5 years we make new official appraisal and in the meantime desktop valuation, except for properties securing exposures above 3 EUR where criteria is set to 3 years. General criteria are 3 years for residential and 1 year for non residential real estates according to the article 208 of CRR.
c) Review of property values and revaluation • For the calculation of average values in accordance with Article 229 (1)(e) CRR in the context of upward revisions of values, are there any guidelines from regulators or lenders addressing the data points to be used and the comparability of properties? Please indicate whether there are requirements from regulators or lenders for ‘sufficient data’ and ‘unequivocal increases of value’.	No

IV. VALUATION OF THE COVER POOL

a) Are valuation rules for cover assets provided at national level in accordance with Article 6(5a) CBD? Are they provided by national covered bond legislation or by professional guidance/standards?
b) What valuation bases apply for the valuation of cover assets (Market Value, Mortgage Lending Value)?
c) In the case of Market Value valuations, are there any prudential or longer term/sustainable features of the property to be considered? If yes, to what extend?
d) How is the requirement that the valuation shall be carried out by a valuer who possesses the necessary qualifications, ability and experience transposed in your Member State (Article 6(5b) CBD)? Are there specific qualification requirements for valuers?
e) How is the requirement that the valuer shall be independent from the credit decision process transposed in your Member State (Article 6(5c) CBD)?
f) Are there differences in valuation rules and/or qualification requirements with regard to the property type (residential vs. commercial properties) or to the loan amount?
g) Are there specific monitoring, review and revaluation requirements for cover pool assets at national level (see Article 129(3) CRR referring to Article 208 CRR)?
h) Do regulators of your Member State provide a waiver from the limitation of calculating average values for cover assets in case of upward revision of values (Article 129(3) second subpar. CRR)?

V. OTHER

REGULATORY HARMONISATION AND NATIONAL DIVERGENCES

1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)?

DATA QUALITY, TRANSPARENCY AND COMPARABILITY

a) What data sources are typically used by valuers in your Member State, and to what extent do they comply with Article 208(3a) of the CRR?	In Croatia, there is a central information system for the real estate market called eNekretnine (managed by the Ministry of Physical Planning, Construction and State Assets), which enables the collection and sharing of data on real estate transactions — purchase prices, types of properties, locations, etc.
b) What measures have been taken to improve transparency and comparability of valuation data within your Member State?	None as far as we know
c) Is there a central database or platform for sharing valuation data in your Member State?

EDUCATION, TALENT PIPELINE AND PROFESSIONAL DEVELOPMENT

a) What training programs or continuing education opportunities are available for property valuers in your Member State?	In the Republic of Croatia, various training programmes and continuing education opportunities are available for real estate valuers. Some of them are: • Croatian Institute of Finance (HIF) – offers preparatory courses for certified valuers, including both theoretical and practical modules followed by a final examination. • Baltazar University of Applied Sciences – provides a professional development programme in “Real Estate Management and Valuation,” offering multidisciplinary knowledge in law, economics, construction, and valuation. • Croatian Valuers Association (HDP) – a professional association that organises training sessions, workshops, and certification exams for property valuers. • Croatian Association of Court Experts and Valuers (HDSVIP) – organises seminars, congresses, and professional lectures for its members and other court experts and valuers. These programmes enable valuers to pursue continuous professional development and stay up to date with new regulations, methodologies, and market practices in the field of real estate valuation.
b) Is there collaboration between universities, professional bodies, and regulators to ensure a sustainable pipeline of qualified valuers?
c) How does the EU regulatory environment influence the development and attractiveness of the valuation profession?	The Law on Real Estate Valuation, adopted in line with the European Union regulatory framework, promotes the application of reliable and harmonised valuation standards, independence and professional competence of valuers, and a stronger link between valuation practices, risk management, and sustainability. As a result, the profession has become more structured, transparent, and professional, which enhances its credibility and attractiveness in both the domestic and European markets.

FUTURE TECHNOLOGICAL AND REGULATORY DIRECTIONS

1. What technological developments are expected to impact valuation processes in your Member State over the next five years?	In the next five years, an increase in the use of automation and digitalisation in property valuation processes is expected, particularly through the development and application of AI technologies and AVMs.