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Module 22

Regulation, law and the Croatian market

ITU, EU law, GDPR, roaming, spectrum, numbering, and the Croatian market.

On this page · 7 sections

Telecom is one of the most regulated industries: spectrum is a limited public resource, numbers are national property, and networks carry private communications. This module covers who decides what, with the EU and Croatian context.

Note on facts: figures such as market shares and prices change every quarter. The values below come from the public HAKOM and EU sources listed in References and carry the date they were checked; always confirm current data at the source.

1. Who regulates whom

Level Body Role
Global ITU (International Telecommunication Union, UN agency) Radio Regulations, spectrum allocation in three Regions, numbering plans (E.164, E.212), standards (ITU-T), IMT definitions (ITU-R); WRC (World Radiocommunication Conference, every 3–4 years)
Europe CEPT / ECC Harmonised spectrum use across 48 countries; ECC decisions
ETSI European standards (also hosts 3GPP partner functions)
EU European Commission (DG CONNECT) Directives and regulations; RSPG (Radio Spectrum Policy Group); BEREC (Body of European Regulators for Electronic Communications)
Croatia HAKOM — Hrvatska regulatorna agencija za mrežne djelatnosti (Croatian Regulatory Authority for Network Industries) Telecom, post and rail regulator: spectrum licences, numbering, market analyses, consumer protection, quality-of-service monitoring
Ministry of Sea, Transport and Infrastructure Policy; telecoms law drafting
AZOP Data-protection authority (GDPR)
CARNET, CERT, ZSIS, SOA, HNB, etc. Academic network, cyber-security and other authorities
Industry GSMA Operators' association: roaming, fraud, IMEI database, MWC
O-RAN Alliance, 5GAA, LoRa Alliance, Wi-Fi Alliance, Bluetooth SIG Technology alliances

2. Main laws and rules (EU framework)

Instrument What it does
European Electronic Communications Code (EECC), Directive (EU) 2018/1972 Single framework for networks and services: spectrum, market regulation, universal service, consumer rights, emergency communications (112, reverse 112), number-independent services (OTT). Transposed nationally by Dec 2020 (Croatia: new Electronic Communications Act, ZEK, 2022)
GDPR, Regulation (EU) 2016/679 General personal-data protection: legal basis, consent, DPO, breach notification within 72 h, fines up to 4% of global turnover
ePrivacy Directive 2002/58/EC (revision pending as "ePrivacy Regulation") Confidentiality of communications, location and traffic data, cookies, spam
Data retention EU Directive 2006/24/EC was annulled in 2014 (CJEU Digital Rights Ireland); national retention rules must be targeted and proportionate (later CJEU decisions Tele2 Sverige, La Quadrature du Net)
Open Internet / Net Neutrality, Regulation (EU) 2015/2120 No blocking or throttling; limits on zero-rating; basis for BEREC guidelines
EU Roaming Regulation (EU) 2022/612 "Roam like at home" extended to 30 June 2032; wholesale price caps fall over time (data caps from €2/GB in 2022 to €1/GB from 2027; voice and SMS caps fixed at about €0.019 per minute and €0.003 per SMS from 2025). The 2017 start of free roaming applied to all EU/EEA
NIS2 Directive (EU) 2022/2555 Cyber-security duties for "essential" entities including telecom operators; incident reporting, risk management, management accountability
EU 5G Toolbox (2020) Risk-mitigation measures on vendors and supply chain
Radio Equipment Directive (RED) 2014/53/EU Rules for radio devices placed on the EU market, including cyber-security delegated act in force since 2025
Gigabit Infrastructure Act (2024) Faster, cheaper fibre/5G build-out (shared ducts, permits)
Digital Markets Act / Digital Services Act Platform regulation affecting OTT messaging interoperability
EMF limits Council Recommendation 1999/519/EC (ICNIRP), national ordinances usually stricter
Lawful interception National criminal procedure and security-agency laws; ETSI TS 102 232 handover interfaces
Universal service Minimum affordable access to voice + broadband

3. Spectrum management

Concept Explanation
Frequency plan National table of allocations: which band for mobile, broadcast, military, satellite, Wi-Fi
Licensing models Individual licences (auctioned to operators), general authorisation / licence-exempt (Wi-Fi, SRDs), light licensing/shared (e.g. private networks)
Auction types Simultaneous multiple-round ascending (SMRA), combinatorial clock (CCA), sealed-bid
Licence conditions Duration (15–20 years), coverage obligations, roll-out milestones, technology neutrality
Spectrum caps Limit per operator to avoid hoarding
Refarming Moving a band from old tech (2G/3G) to new (LTE/5G)
Sharing/pooling Licensed Shared Access (LSA), dynamic spectrum sharing, CBRS (US)
Digital dividend 700/800 MHz freed by digital TV switch-over
EU harmonised bands for 5G ("pioneer bands") 700 MHz (coverage), 3.4–3.8 GHz (core capacity), 26 GHz (mmWave)
SRD Short-range devices (Wi-Fi, Bluetooth, RFID, key fobs) under harmonised power limits
Cross-border coordination Neighbouring countries coordinate to avoid interference (important on the Adriatic with Italy, Bosnia, Slovenia, Montenegro)
Interference enforcement Regulator investigates jammers and illegal transmitters

4. Numbering and portability

  • National numbering plan managed by the regulator: country code +385 for Croatia, trunk prefix 0, mobile and geographic ranges, special-service numbers (112, 116 harmonised social numbers e.g. 116 000 missing children, 116 111 child helpline), premium-rate ranges.
  • Number portability for mobile and fixed numbers: customer keeps the number when changing operator; a central database/routing lookup is used before routing calls and SMS (Module 14). Porting time is regulated (days, in many countries one working day).
  • MCC 219 is Croatia; MNCs identify operators. Roaming partners exchange network data in IR.21.
  • E.164 and numbering resource: also short codes for A2P SMS (assigned by operators), alphanumeric sender IDs.

5. Consumer and market rules

Topic Facts
Contracts Contract summary, max initial duration 24 months, switching rules, compensation for outages
Transparency Advertised vs actual speeds (BEREC guidelines; regulators run measurement tools)
Quality of service Regulators publish drive-test comparisons of mobile networks
Roaming and bill shock Notifications, data-cap alerts, EU-wide limits
Wholesale access SMP operators (Significant Market Power) must give access to infrastructure (copper/fibre, bitstream, termination rates, mobile termination rates (MTR))
Mobile termination rates Price one operator charges another for ending a call; EU-wide regulated "Eurorates" for voice termination (mobile 0.2 euro-cent/min, fixed 0.07 euro-cent/min from 2024, Delegated Regulation (EU) 2021/654)
Merger control Competition law (EU Commission or national authority) — e.g. consolidation from 4 to 3 operators
Customer data & marketing Opt-in for electronic marketing, spam fines
Complaints Operator → regulator (HAKOM) → court / ADR

6. The Croatian market in brief

Item Facts (verify the latest at HAKOM)
Country / MCC / code Croatia, MCC 219, +385, EU member since 2013, euro since 2023
Mobile operators (MNOs) Hrvatski Telekom (HT, part of Deutsche Telekom group, T-Mobile brand), A1 Hrvatska (A1 Telekom Austria Group; ex-VIPnet), Telemach Hrvatska (United Group; includes former Tele2)
Market share (users of mobile telephony, Q4 2024, HAKOM) HT about 44.4%, A1 about 34.1%, Telemach the remainder
Penetration Mobile penetration over 120–130% (more SIMs than people, because of M2M, tourists, second SIMs); 2025 HAKOM figures around 128–136%
5G First commercial 5G in Oct 2020 via Dynamic Spectrum Sharing on existing spectrum; spectrum auction August 2021 for 700 MHz, 3.6 GHz and 26 GHz, 15-year licences, about HRK 359 million (≈ €48 million), HT bought the largest share; operators then launched real 5G
Fixed broadband Incumbent HT dominant, fast FTTH build-out by HT, A1 and Telemach; cable TV and IPTV by Telemach, A1, HT (MAXtv)
MVNOs Small segment (e.g. resellers/flanker brands run by the same groups)
Tourism effect Huge summer roaming traffic and capacity peaks on the Adriatic coast; networks are dimensioned for seasonal loads
Regulatory approach HAKOM runs market analyses (SMP designation), quality measurements, spectrum assignments, number portability, consumer complaints
Emergency numbers 112 (unified), 192 police, 193 fire, 194 ambulance
Internet exchange CIX (Croatian Internet eXchange) in Zagreb
Academic network CARNET; .hr domain registry also at CARNET
Data protection AZOP
Cyber National CERT (CARNET CERT / CERT.hr), ZSIS/SOA for state security

7. Compliance obligations inside an operator

Obligation What the engineer sees
Lawful interception (LI) Mediation device, X1/X2/X3 interfaces, secure handover to agency
Data retention / CDR storage Billing and traffic data stored for defined periods and protected
GDPR Access control, pseudonymisation, deletion, DPO, DPIA for new services (e.g. location analytics)
Network security / NIS2 Risk assessments, incident handling, audits, supply-chain rules
Emergency calls Always route 112, provide location, keep PSAP links redundant
Number portability Port-in/port-out processes, SLA
Quality reporting KPIs, outage notifications to regulator
SMS and call fraud measures Cooperating on blocking spoofed numbers, smishing
Net neutrality No unlawful traffic discrimination
EMF compliance Measurements around base stations
Accessibility Services for persons with disabilities (e.g. total conversation)

Remember this: the regulator does not run networks, it rations the scarce things (spectrum, numbers), sets the rules of the market (access, prices, quality) and protects users (privacy, emergency access, roaming). Engineers feel it as licence conditions, LI, GDPR and portability.