Aida HR 2022 Update

Country Report: Croatia
2022
Update
Acknowledgements & Methodology
This report was written by Lana Tučkorić at the Croatian Law Centre, and was edited by ECRE.
The temporary protection section of the report was written by Lucija Koren and Dora Palić.
This report draws on information gathered through the practice of the Croatian Law Centre, data and
information provided by Administrative Courts, the High Administrative Court, the Croatian Employment
Service, Civil Protection Directorate of the Ministry of Interior, IOM, UNHCR, attorneys at law and
relevant organisations, including the Are you Syrious, Croatian Red Cross, the Centre for Peace
Studies, Civil Rights Project Sisak, Centre for Missing and Exploited Children Croatia, Civis Mundi, D
kolektiv, Doctors of the World (MdM), Rehabilitation Centre for Stress and Trauma, Society for
Psychological Assistance- Centre for children, youth and family –Modus, SVOJA association, as well as
from other publicly available sources.
The information in this report is up-to-date as of 31 December 2022, unless otherwise stated.
The Asylum Information Database (AIDA)

The Asylum Information Database (AIDA) is coordinated by the European Council on Refugees and Exiles
(ECRE). It aims to provide up-to date information on asylum practice in 23 countries. This includes 19 EU
Member States (AT, BE, BG, CY, DE, ES, FR, GR, HR, HU, IE, IT, MT, NL, PL, PT, RO, SE, SI) and 4
non-EU countries (Serbia, Switzerland, Türkiye, United Kingdom) which is accessible to researchers,
advocates, legal practitioners and the general public through the dedicated website
www.asylumineurope.org. The database also seeks to promote the implementation and transposition of
EU asylum legislation reflecting the highest possible standards of protection in line with international
refugee and human rights law and based on best practice.
This report is part of the Asylum Information Database (AIDA), funded by the European Programme for
Integration and Migration (EPIM), a collaborative initiative by the Network of European Foundations, and
the European Union’s Asylum, Migration and Integration Fund (AMIF). The contents of this report are the
sole responsibility of ECRE and can in no way be taken to reflect the views of EPIM or the European
Commission.
2
Table of Contents
Glossary & List of Abbreviations ..........................................................................................6
Statistics .................................................................................................................................7
Overview of the legal framework ...........................................................................................9
Overview of the main changes since the previous update ................................................16
Asylum Procedure ................................................................................................................20
A. General ................................................................................................................................... 20
1. Flow chart ............................................................................................................................ 20
2. Types of procedures ............................................................................................................ 21
3. List the authorities that intervene in each stage of the procedure .......................................... 21
4. Determining authority ........................................................................................................... 22
5. Short overview of the asylum procedure ............................................................................... 23
B. Access to the procedure and registration ............................................................................ 25
1. Access to the territory and pushbacks .................................................................................. 25
2. Registration of the asylum application .................................................................................. 37
C. Procedures ............................................................................................................................. 40
1. Regular procedure ............................................................................................................... 40
2. Dublin .................................................................................................................................. 47
3. Admissibility procedure ........................................................................................................ 53
4. Border procedure (border and transit zones) ........................................................................ 56
5. Accelerated procedure ......................................................................................................... 57
D. Guarantees for vulnerable groups of asylum seekers ......................................................... 60
1. Identification......................................................................................................................... 60
2. Special procedural guarantees ............................................................................................. 66
3. Use of medical reports ......................................................................................................... 68
4. Legal representation of unaccompanied children .................................................................. 68
E. Subsequent applications ....................................................................................................... 72
F. The safe country concepts .................................................................................................... 74
1. Safe country of origin ........................................................................................................... 74
3
2. Safe third country ................................................................................................................. 75
3. First country of asylum ......................................................................................................... 77
G. Information for asylum seekers and access to NGOs and UNHCR ..................................... 77
1. Provision of information on the procedure............................................................................. 77
2. Access to NGOs and UNHCR .............................................................................................. 80
H. Differential treatment of specific nationalities in the procedure ......................................... 80
Reception Conditions ...........................................................................................................82
A. Access and forms of reception conditions........................................................................... 82
1. Criteria and restrictions to access reception conditions ......................................................... 82
2. Forms and levels of material reception conditions ................................................................. 83
3. Reduction or withdrawal of reception conditions ................................................................... 84
4. Freedom of movement ......................................................................................................... 84
B. Housing .................................................................................................................................. 86
1. Types of accommodation ..................................................................................................... 86
2. Conditions in reception facilities ........................................................................................... 87
C. Employment and education................................................................................................... 91
1. Access to the labour market ................................................................................................. 91
2. Access to education ............................................................................................................. 92
D. Health care ............................................................................................................................. 94
E. Special reception needs of vulnerable groups ..................................................................... 99
F. Information for asylum seekers and access to reception centres .................................... 103
1. Provision of information on reception .................................................................................. 103
2. Access to reception centres by third parties ........................................................................ 104
G. Differential treatment of specific nationalities in reception ............................................... 104
Detention of Asylum Seekers ............................................................................................105
A. General ................................................................................................................................. 105
B. Legal framework of detention ............................................................................................. 107
1. Grounds for detention......................................................................................................... 107
2. Alternatives to detention ..................................................................................................... 109
3. Detention of vulnerable applicants ...................................................................................... 110
4. Duration of detention .......................................................................................................... 110
C. Detention conditions ........................................................................................................... 111
4
1. Place of detention .............................................................................................................. 111
2. Conditions in detention facilities ......................................................................................... 112
3. Access to detention facilities............................................................................................... 117
D. Procedural safeguards ........................................................................................................ 119
1. Judicial review of the detention order.................................................................................. 119
2. Legal assistance for review of detention ............................................................................. 120
E. Differential treatment of specific nationalities in detention ............................................... 120
Content of International Protection ...................................................................................121
A. Status and residence ........................................................................................................... 128
1. Residence permit ............................................................................................................... 128
2. Civil registration ................................................................................................................. 129
3. Long-term residence .......................................................................................................... 130
4. Naturalisation ..................................................................................................................... 131
5. Cessation and review of protection status........................................................................... 133
6. Withdrawal of protection status ........................................................................................... 134
B. Family reunification ............................................................................................................. 135
1. Criteria and conditions........................................................................................................ 135
2. Status and rights of family members ................................................................................... 137
C. Movement and mobility ....................................................................................................... 138
1. Freedom of movement ....................................................................................................... 138
2. Travel documents............................................................................................................... 138
D. Housing ................................................................................................................................ 139
E. Employment and education................................................................................................. 141
1. Access to the labour market ............................................................................................... 141
2. Access to education ........................................................................................................... 143
F. Social welfare ....................................................................................................................... 146
G. Health care ........................................................................................................................... 147
ANNEX I – Transposition of the CEAS in national legislation .........................................150
5
Glossary & List of Abbreviations
Asylee Person granted refugee status

Dismissal Rejection of an application as inadmissible
Reception Centre for Pre-removal detention centre
Foreigners
CES Croatian Employment Service | Hrvatski zavod za zapošljavanje

CJEU Court of Justice of the European Union
CPS Centre for Peace Studies | Centar za mirovne studije
CRC Croatian Red Cross | Hrvatski crveni križ
EASO European Asylum Support Office
ECHR European Convention on Human Rights
ECtHR European Court of Human Rights
EUAA European Union Agency for Asylum
IOM International Organisation for Migration
JMBG Unique Identification Number | Jedinstveni matični broj građana
JRS Jesuit Refugee Service | Isusovačka služba za izbjeglice
LGBTI Lesbian, gay, bisexual, transsexual and intersex
LITP Law on International and Temporary Protection | Zakon o međunarodnoj i
privremenoj zaštiti
MdM Doctors of the World | Médecins du Monde
OIB Personal Identification Number | Osobni identifikacijski broj
SGBV Sexual and gender-based violence
SPA Society for Psychological Assistance | Društvo za psihološku pomoć
UNHCR United Nations High Commissioner for Refugees
UNICEF United Nations Children Fund
UNVFVT United Nations Voluntary Fund for Victims of Torture
6
Statistics
Overview of statistical practice
Applications and granting of protection status at first instance: 2022
Limited asylum statistics for 2022 can be found on the website of the Ministry of Interior (MOI).1 However, MOI did not provide a breakdown on the outcome of the
procedure. According to the Ombudsman report,2 10,087 intentions to apply for international protection were expressed in border police stations and 137 in airport
police stations. During 2022, 21 refugee statuses were granted, while 82 applications for international protection were rejected (63 males and 19 females). They were
nationals of Türkiye (29), Iran (9), Russia (8), Cuba (7), Morocco (7), India (5) and other (17).3
Applicants in Pending at end Subsidiary

Refugee status Rejection Refugee rate Sub. Prot. rate Rejection rate
2022 of 2022 protection
Total 12,872 N/A 21 0 82
Breakdown by countries of origin of the total numbers
Iraq 2,434 N/A N/A 0 N/A

Russian
2,064 N/A N/A 0 8
Federation
Burundi 2,051 N/A N/A 0 N/A
Türkiye 1,572 N/A N/A 0 29
Afghanistan 1,390 N/A N/A 0 N/A
Cuba 1,065 N/A N/A 0 7
Syria 628 N/A N/A 0 N/A
Iran 450 N/A N/A 0 9
DR Congo 193 N/A N/A 0 N/A
Pakistan 156 N/A N/A 0 N/A
India 107 N/A N/A 0 5
Morocco 41 N/A N/A 0 7
1
Ministry of Interior, Statistics 2022, available at: https://bit.ly/3z5R6YA.
2
Report of the Ombudsman for 2022, available in Croatian at: https://bit.ly/439X3kT.
3
Croatian Law Centre, The Croatian Asylum System in 2022- National Report. The report was prepared as part of the project “Legal Assistance and Capacity Building for Access to
Territory and Asylum in Croatia“, with financial support of the UNHCR Croatia: available in English at: https://bit.ly/434T7RL.
7
Gender/age breakdown of the total number of applicants: 2022
Number Percentage
Total number of applicants 12,872 -
Men (including children) 7,660 59.5%
Women (including children) 5,212 40.5%
Children 4,773* 37.1%
Unaccompanied children 436 3.4%
Source: Ministry of Interior, Statistics 2022, available at: https://bit.ly/3C0HJuR.
*The number of children was indicated in Ombudsman for children report for 2022, available in Croatian at: https://bit.ly/45Dzl1W.
Comparison between first instance and appeal decision rates: 2022
First instance Appeal

Number Percentage Number Percentage
Total number of decisions N/A 36
Positive decisions 21
 Refugee status 21
 Subsidiary protection 0
Negative decisions N/A 30
Source: Ministry of Interior, Statistics 2022, available at: https://bit.ly/3z5R6YA; Administrative Court of Zagreb, 23 January 2023; Administrative Court of Split, 30 January 2023.
8
Overview of the legal framework
Main legislative acts relevant to asylum procedures, reception conditions, detention and content of protection
Title (EN) Original Title (HR) Abbreviation Web Link

Law on International and Temporary Protection Zakon o međunarodnoj i privremenoj zaštiti LITP http://bit.ly/1hIaq3Q (HR)
http://bit.ly/2ln4y6c (EN)
Official Gazette 70/2015 NN 70/2015, 127/2017, 33/2023
https://bit.ly/2pPntru (HR)
Amended: Official Gazette 127/2017
https://bit.ly/43iu0Mc (HR)
Law on General Administrative Procedure Zakon o općem upravnom postupku Law on General http://bit.ly/1J7BRAh (HR)
Official Gazette 47/2009 NN 47/2009, 110/2021 Administrative

Procedure https://bit.ly/36ZLaFZ (HR)
Amended: Official Gazette 110/2021(in force since

1 January 2022)
Law on Administrative Disputes Zakon o upravnim sporovima Law on http://bit.ly/1Gm4uTj (HR)
Official Gazette 20/2010 NN 20/2010, 143/2012, 152/2014, 94/2016, 29/2017, Administrative

110/2021 Disputes
Amended: Official Gazette 143/2012 http://bit.ly/1K1I8fv (HR)
Amended: Official Gazette 152/2014 http://bit.ly/1Bs4ZiO (HR)
Decision of the Constitutional Court of the Republic

of Croatia U-I-2753/2012 and others, September https://bit.ly/2uyfHXR (HR)
27. 2016., Official Gazette 94/2016
Amended: Official Gazette 29/2017 https://bit.ly/2pWu82v (HR)
Amended: Official Gazette 110/2021 https://bit.ly/3LXKHn4 (HR)
Zakon o strancima Law on Foreigners https://bit.ly/2OLg8ZC (HR)

Law on Foreigners, NN 133/2020, 114/2022, 151/2022
Official Gazette 133/2020
https://bit.ly/3ILqMXi (EN)
9
Amended: Official Gazette 151/2022 http://bit.ly/3lGAZ0z (HR)
http://bit.ly/3LOEeOf (HR)
Law on Mandatory Health Insurance and Health Zakon o obveznom zdravstvenom osiguranju i Law on Mandatory http://bit.ly/1Gm4KSp (HR)
Care for Foreigners in the Republic of Croatia zdravstvenoj zaštiti stranaca u Republici Hrvatskoj Health Insurance and
https://bit.ly/2uzuZLN (HR)
Health Care
Official Gazette 80/2013 NN 80/2013, 15/2018, 26/2021, 46/2022
Amended: Official Gazette 15/2018 https://bit.ly/3uJOYl6 (HR)

http://bit.ly/3lJaYxE (HR)
Law on Free Legal Aid Zakon o besplatnoj pravnoj pomoći Law on Free Legal http://bit.ly/1IojGRf (HR)
Official Gazette 143/2013 NN 143/2013, 98/2019 Aid

https://bit.ly/3bDiHD5 (HR)
Main implementing decrees and administrative guidelines and regulations relevant to asylum procedures, reception conditions, detention and content of
protection
Title (EN) Original Title (HR) Abbreviation Web Link

Ordinance on the forms and data collection in the Pravilnik o obrascima i zbirkama podataka u postupku Ordinance on http://bit.ly/2lndEjr (HR)
procedure for international and temporary protection odobrenja međunarodne i privremene zaštite Forms
Official Gazette 85/2016 NN 85/2016
Decision on the amount of financial assistance Odluka o visini novčane pomoći tražiteljima Decision on http://bit.ly/2lQKkmi (HR)
provided to applicants for international protection međunarodne zaštite Financial
Official Gazette 135/2015 NN 135/2015, 155/2022 Assistance http://bit.ly/3z7hTnn (HR)

Ordinance on the realisation of material reception Pravilnik o ostvarivanju materijalnih uvjeta prihvata Ordinance on http://bit.ly/2lYZIsM (HR)
conditions NN 135/2015, 61/2019 Material Reception
Official Gazette 135/2015 Conditions
Amended: Official Gazette 61/2019 https://bit.ly/3bxCHa9 (HR)
10
Ordinance on the content of the medical examination Pravilnik o sadržaju zdravstvenog pregleda tražitelja Ordinance on http://bit.ly/1K1I9zT (HR)
of asylum seekers, asylees and foreigners under azila, azilanata, stranaca pod privremenom zaštitom i Medical
subsidiary protection stranaca pod supsidijarnom zaštitom Examination
Ordinance on health care standards for applicants for Pravilnik o standardima zdravstvene zaštite tražitelja Ordinance on https://bit.ly/3sbArNC (HR)
international protection and foreigners under međunarodne zaštite i stranca pod privremenom health care
temporary protection zaštitom standards
Ordinance on the manner of implementing the Pravilnik o načinu provođenja programa i provjeri znanja Ordinance on http://bit.ly/1Gm5yGG (HR)
programme and tests of knowledge of asylum tražitelja azila, azilanata, stranaca pod privremenom Knowledge Tests
seekers, asylees, foreigners under temporary zaštitom i stranaca pod supsidijarnom zaštitom, radi
protection and foreigners under subsidiary protection, pristupa obrazovnom sustavu Republike Hrvatske
for the purpose of joining the education system of the NN 89/2008
Republic of Croatia
Decision on the Programme of Croatian language, Odluka o programu hrvatskog jezika, povijesti i kulture Decision on http://bit.ly/1SuZQLq (HR)
history and culture for asylum seekers and asylees za tražitelje azila i azilante Croatian Language
Official Gazette 129/2009 NN 129/2009 Programme
Decision on the Programme of Croatian language, Odluka o programu učenja hrvatskoga jezika, povijesti i Decision on http://bit.ly/1FXstO8 (HR)
history and culture for asylees and foreigners under kulture za azilante i strance pod supsidijarnom zaštitom Croatian Language,
subsidiary protection for inclusion into Croatian radi uključivanja u hrvatsko društvo History and Culture
Society NN 154/2014 Programme for
Official Gazette 154/2014 Inclusion
Decision on the programme of Croatian language for Odluka o nastavnom planu i programu hrvatskoga jezika Decision on http://bit.ly/1yuPG7Y (HR)
asylum seekers and asylees and aliens under za tražitelje azila, azilante i strance pod supsidijarnom Croatian Language
subsidiary protection who are over 15 years of age zaštitom starije od 15 godina radi pristupa Programme above
for the purpose of joining the secondary-school srednjoškolskom obrazovnom sustavu i sustavu the Age of 15
education system and the adult education system obrazovanja odraslih
Decision on establishing the price of passport issued Rješenje o utvrđivanju cijene putovnice izdane sukladno Decision on the http://bit.ly/2kOXEmP (HR)
in accordance with the 1951 Convention relating to Konvenciji o statusu izbjeglica od 28. srpnja 1951. Price of Refugee
the Status of Refugees godine Passports
Official Gazette 98/2016 NN 98/2016 http://bit.ly/2kvoBjf (HR)
Corrigendum
11
Official Gazette 102/2016 Ispravak Rješenja o utvrđivanju cijene putovnice izdane
sukladno Konvenciji o statusu izbjeglica od 28. srpnja
1951. godine http://bit.ly/3FKQNXg (HR)
NN 102/2016
Amended: Official Gazette 155/2022 Rješenje o izmjeni Rješenja o utvrđivanju cijene

putovnice izdane sukladno Konvenciji o statusu
izbjeglica od 28. srpnja 1951. godine
NN 155/2022
Decision on the costs of accommodation in the Odluka o troškovima smještaja u Prihvatilištu za Decision on the http://bit.ly/2lTyx3i (HR)
Reception Centre for Asylum Seekers tražitelje azila Costs of
Official Gazette 47/2016 NN 47/2016 Accommodation http://bit.ly/3JZaWey (HR)
Amended: Official Gazette 155/2022 Odluka o izmjenama Odluke o troškovima smještaja u

prihvatilištu za tražitelje azila
NN 155/2022
Ordinance on free legal aid in the procedure of Pravilnik o besplatnoj pravnoj pomoći u postupku Ordinance on Free http://bit.ly/2kXPLhy (HR)
granting international protection odobrenja međunarodne zaštite Legal Aid
Official Gazette 140/2015 NN 140/2015, 155/2022
http://bit.ly/40xbm0W (HR)
Decision on relocation and resettlement of third Odluka o premještanju i preseljenju državljana trećih Decision on http://bit.ly/2kDTnBH (HR)
country nationals or stateless persons who meet the zemalja ili osoba bez državljanstva koje ispunjavaju Relocation and
conditions for approval of international protection uvjete za odobrenje međunarodne zaštite Resettlement
Decision on the establishment of the Odluka o osnivanju Međuresorne radne skupine za Decision on the http://bit.ly/2lQNEgT (HR)
Interdepartmental Working Group for the provedbu Odluke o premještanju i preseljenju državljana Relocation and
Implementation of the Decision on relocation and trećih zemalja ili osoba bez državljanstva koje Resettlement
resettlement of third country nationals or stateless ispunjavaju uvjete za odobrenje međunarodne zaštite Working Group
persons who meet the conditions for approval of NN 78/2015
international protection
12
Decision on resettlement of third country nationals or Odluka o preseljenju državljana trećih zemalja ili osoba Decision on https://bit.ly/2GVUWHW (HR)
stateless persons who meet the conditions for bez državljanstva koje ispunjavaju uvjete za odobrenje Resettlement
approval of international protection međunarodne zaštite
Decision on resettlement of third country nationals or Odluka o preseljenju državljana trećih zemalja ili osoba Decision on https://bit.ly/2JdqcXL (HR)
stateless persons who meet the conditions for bez državljanstva koje ispunjavaju uvjete za odobrenje Resettlement for
approval of international protection for 2019 međunarodne zaštite za 2019. godinu 2019
http://bit.ly/40bzypZ (HR)
Odluka o stavljanju izvan snage Odluke o preseljenju
Decision to revoke the Decision on resettlement of
državljana trećih zemalja ili osoba bez državljanstva koje
third country nationals or stateless persons who meet ispunjavaju uvjete za odobrenje međunarodne zaštite za
the conditions for approval of international protection 2019. godinu
for 2019

Decision on relocation of the third country nationals https://bit.ly/3JGMZHl (HR)
Odluka o premještanju državljana trećih zemalja ili osoba
or stateless persons who meet the conditions for
bez državljanstva koje ispunjavaju uvjete za odobrenje
approval of international protection međunarodne zaštite
NN 88/2022
Ordinance on participation of asylees, foreigners Pravilnik o sudjelovanju azilanata, stranaca pod Ordinance on https://bit.ly/2Y115uv (HR)
under subsidiary protection and foreigners under supsidijarnom zaštitom i stranaca pod privremenom participation in the
temporary protection in the payment of zaštitom u plaćanju troškova smještaja payment of
accommodation costs NN 59/2018 accommodation
Official Gazette 59/2018 costs
Decision on determination of the price of residence Rješenje o utvrđivanju cijene dozvole boravka za Decision on the http://bit.ly/2kvB0Un (HR)
permit for asylees and foreigners under subsidiary azilanta i stranca pod supsidijarnom zaštitom Price of Residence
protection NN 98/2016 Permits
Ispravak Rješenja o utvrđivanju cijene dozvole boravka http://bit.ly/2kXSmb6 (HR)
Corrigendum za azilanta i stranca pod supsidijarnom zaštitom

http://bit.ly/3lE9Ewb (HR)
13
Rješenje o izmjeni Rješenja o utvrđivanju cijene dozvole
boravka za azilanta i stranca pod supsidijarnom zaštitom
NN 155/2022
Decision on the list of safe countries of origin in the Odluka o listi sigurnih zemalja podrijetla u postupku Decision on the List http://bit.ly/2lcRePz (HR)
procedure of granting International Protection odobrenja međunarodne zaštite of Safe Countries of
NN 45/2016 Origin
Ordinance on treatment of third country nationals, Pravilnik o postupanju prema državljanima trećih Ordinance on https://bit.ly/3MfvLl0 (HR)
Official Gazette 136/2021 zemalja treatment of third
country nationals
NN 136/2021
Detention Centre
Ordinance on accommodation in the Reception Pravilnik o boravku u Prihvatnom centru za strance Ordinance https://bit.ly/35NIA5r (HR)
Centre for Foreigners and the method of calculating i načinu izračuna troškova prisilnog udaljenja
the costs of forced removal; Official Gazette http://bit.ly/4067W5E (HR)
145/2021 NN 145/2021, 155/2022
Action plan for the Integration of beneficiaries of Akcijski plan za integraciju osoba kojima je odobrena Action plan for https://bit.ly/2GMCkNL (HR)
international protection for the period 2017-2019 međunarodna zaštita za razdoblje 2017. do 2019. Integration https://bit.ly/2IHO40C (EN)
godine
Decision on the Establishment of a Permanent Odluka o osnivanju Stalnog povjerenstva za provedbu Decision on the https://bit.ly/2wCNTTX (HR)
Commission for the Implementation of the Integration integracije stranaca u hrvatsko društvo Establishment of a
of Foreigners into Croatian Society NN 110/2019, 119 /2020 Permanent
Official Gazette 110/2019 Commission for
Amended: Official Gazette 119 /2020 Integration https://bit.ly/3wXxALF (HR)
Protocol on the treatment of unaccompanied children Protokol o postupanju prema djeci bez pratnje https://bit.ly/2UnJmLc (HR)
https://bit.ly/2DEgBEu (HR)
Ordinance on stay of third country nationals in the https://bit.ly/3HIvjYR (HR)

Republic of Croatia: Official Gazette 20/2022
14
Amended: Official Gazette 155/2022 Pravilnik o boravku državljana trećih zemalja u Republici http://bit.ly/42x6g6W (HR)
Hrvatskoj NN 20/2022, 155/2022
Decision on the establishment of the http://bit.ly/3JZIIQW (HR)

Odluka o osnivanju Međuresornog povjerenstva za
Interdepartmental Commission for the Protection of
zaštitu djece bez pratnje NN 3/2022
Unaccompanied Children
Decision on the appointment of the president, deputy http://bit.ly/3LLpsbg (HR)
Rješenje o imenovanju predsjednice, zamjenice
president, secretary, members and deputy members
of the Interdepartmental Commission for the predsjednice, tajnice, članova i zamjenika članova
Protection of Unaccompanied Children, Official Međuresornog povjerenstva za zaštitu djece bez pratnje
Gazette 52/2022 NN 52/2022
15
Overview of the main changes since the previous update
The report was previously updated in April 2022.
International protection
Asylum procedure
 Access to the territory: Reports of push backs and violent police practices at the border were
documented in 2022. According to the Danish Refugee Council (DRC), 3,461 persons were
pushed back from Croatia to Bosnia and Herzegovina (BiH) in 2022,4 while UNHCR data further
indicates that 289 persons were pushed back from Croatia to Serbia in 2022.5 The Ombudsperson
for Children reported that at least 120 children were pushed back in 2022 according to data
provided by the Border Violence Monitoring Network's. The actual number is however likely
higher.
 Relevant case law on access to the territory: In 2022, a Rohingya child submitted complaints
against Croatia and Slovenia at the UN Child Rights Committee for multiple violations of the
Convention on the Rights of the Child (CRC).6 The child spent over a year in Bosnia and
Herzegovina (BiH) from 2020 to 2021. During this time, he was pushed back five times from
Croatia to BiH and subjected to violence. In Slovenia, he was subjected to a “chain” pushback,
forcibly returned first to Croatia by Slovenian authorities and then onwards to BiH by Croatian
authorities. In April 2022, in the case M.H. and Others v. Croatia,7 the request for referral was
rejected by the Grand Chamber panel of five judges and the judgement become final.8 In October
the Action plan in the case was published9.
 Key statistics on the asylum procedure: The number of applicants for international protection
increased significantly throughout 2022, going from 3,039 in 2021 to 12,872. Although detailed
statistics were not made available by national authorities, the recognition rate remained low, as
only 21 persons were granted asylum in the course of 2022.10 According to the Ombudsman’s
report,11 10,087 intentions to apply for international protection were expressed in border police
stations and 137 in airport police stations. In 2022, apart from 21 refugee statuses being granted,
according to the Ombudsman report, 81 applications for international protection were rejected
and 3,406 were suspended. Croatia continues to be a transit country as the majority of applicants
for international protection leave Croatia to other countries. In the second half of 2022 further
intensification of transit migration levels was observed as during August and September 2022
applicants were staying in the Reception Centre for Applicants for International Protection for an
average of only 3 days.12 According to the report of independent monitoring mechanism covering
the period June 2021-June 2022, approximately 80% of persons who applied for international
protection and were therefore accommodated in the Reception Centre for Applicants for
4
Danish Refugee Council (DRC): Border Monitoring Factsheets January- December 2022, available in English
at: http://bit.ly/42BEYfK.
5
UNHCR, Serbia- Snapshots January- December 2022, available at: https://bit.ly/3FJF7E1.
6
European Center for Constitutional and Human Rights (ECCHR): Rohingya child challenges Croatia and
Slovenia over violent pushbacks, available at: https://bit.ly/3IKK0yf.
7
EctHR, Judgment in the case of M.H. and others v. Croatia (Applications nos. 15670/18 and 43115/18),
available at: https://bit.ly/43wOzE9.
8
ECtHR: Grand Chamber Panel's decisions - April 2022, Press Release - Referrals to Grand Chamber,
published on April 4, 2022, available at: https://bit.ly/3WCvyhe.
9
ECtHR: Communication from Croatia concerning the case of M.H. and Others v. Croatia (Application No.
15670/18).
10
Ministry of Interior, Statistics 2022, available at: https://bit.ly/3C0HJuR.
11
12
Information provided by MdM, 14 February 2022.
16
International Protection in Zagreb had left the Reception Centre and their proceedings were
suspended.13
Reception conditions
 Reception centres: During 2022, the renovation of the Reception Centre for applicants of
international protection in Kutina was completed and the capacity for accommodation of
applicants was increased to 140 persons.14
Detention of asylum seekers
 Relevant case law: In January 2023, the European Court on Human Rights (ECtHR) published
its ruling on the case Daraibou v. Croatia,15 application no. 84523/17. The case concerned a
Moroccan applicant, Daraibou, who was detained in a border police station together with three
other migrants. In March 2015, the border police found the applicant and three other persons, in
a truck with Croatian license plates. It was established that the migrants had entered Croatia
clandestinely, avoiding border control. They were taken to the nearest police station in Bajakovo.
While waiting readmission to Serbia, they were placed in the premises for the detention of
irregular migrants in the border police station. One of them allegedly set fire to the facility, which
caused death of three migrants and serious injuries to the applicant. The ECtHR found a violation
of the material and procedural aspect of Art. 2. of ECHR due to the fact that the domestic
authorities did not take sufficient measures to protect the life and limb of the applicant, and due
to the failure to conduct a sufficiently detailed and effective investigation following the event,
according to the Conventional standards. At present, the judgment is not final.
Content of international protection
 Inclusion: A new Integration Action Plan was not adopted in 2022, even if the previous Integration
Action Plan had expired at the end of 2019. Although the integration policy is still being developed
to a large extent at the national level, progress can be observed at the local level as well. In
January 2022, the Assembly of the City of Zagreb adopted the Action Plan of the City of Zagreb
for the integration of applicants for international protection and persons granted international
protection for the year 2022,16 making the City of Zagreb the first unit of local and regional self-
governments in the RoC which adopted such a strategic document.17
Other relevant developments
 Schengen access: As of January 1, 2023, Croatia joined Schengen and Eurozone. The Law
on State Border Control was amended in 2022, with the aim of adapting that act to the
Schengen Acquis which apply as of 1 January 2023 after border controls at Croatian internal
borders were abolished.
 Immigration Policy: In December 2022,18 the Government of the Republic of Croatia adopted
a Proposal for a Decision on the establishment of an Interdepartmental Working Group for
13
Annual report of the Independent Mechanism of monitoring the actions of police officers of the Ministry of the
Interior in the area of illegal migration and international protection- June 2021 – June 2022; available at:
https://bit.ly/3qhkuKB.
14
Ministry of Interior, Successful completion of the project "Renovation of the Reception Center for Applicants
of International Protection in Kutina", available at: https://bit.ly/3OGR6Y7.
15
EctHR, judgment in the case of Daraibou v. Croatia; Application no. 84523/17, available at:
https://bit.ly/3THBvbb; Press Release: Judgment Daraibou v. Croatia - fatal fire in police-station basement
room used to detain illegal migrants, available at: https://bit.ly/3lFUYfS.
16
Action Plan of the City of Zagreb for the integration of applicants for international protection and persons
granted international protection for the year 2022, available at: https://bit.ly/3Zbg9o0.
17
For more, see: https://bit.ly/40cXQjw.
18
Government of the Republic of Croatia: 178 Session, available at: https://bit.ly/44aQ2k2.
17
drafting a proposal for a document on the immigration policy of the Republic of Croatia.19 The
Ministry of Interior coordinates the work of the Interdepartmental Working Group.
Temporary protection
The information given hereafter constitute a short summary of the annex on Temporary Protection to
this report. For further information, see Annex on Temporary Protection.
Temporary protection procedure
 Registration for temporary protection: On March 7, 2022, the Government of the Republic of
Croatia20 adopted the decision on introducing temporary protection on the basis of Council
Implementing Decision (EU) 2022/382 of 4 March 2022, which establishes the existence of a
mass influx of persons in accordance with Article 5 of Directive 2001/55/ EC. Applications for
temporary protection need to be submitted at police stations, while the competent authority for
recognising the temporary protection status lies with the Ministry of Interior. The application can
be submitted in person at the police station or administration based on place of residence of
applicant or via online form available at the e-platform Croatia4Ukraine.21 An exception was
foreseen for those persons who were accommodated in collective accommodation, at times of
increased arrivals of persons displaced from Ukraine to Croatia.22 These persons did not have to
go personally to the police station/administration, but could submit the application directly to the
officials of the Ministry of the Interior who visited the collective accommodations in order to speed
up the process of receiving and further processing of the applications.
 Scope of temporary protection: Pursuant to the Government’s Decision, Croatia shall grant
temporary protection to Ukrainian nationals and members of their families residing in Ukraine on
24 February 2022 and who left Ukraine from 24 February 2022 onwards; stateless persons and
third country nationals who were under international or equivalent national protection in Ukraine
on 24 February 2022 and members of their families who were granted residence in Ukraine on
24 February 2022 and who left Ukraine since 24 February 2022; third country nationals who had
a valid permanent stay in Ukraine on 24 February 2022 in accordance with Ukrainian regulations
and who cannot return to their country or region of origin in safe and permanent conditions and
who left Ukraine since 24 February 2022. Regarding those who had fled Ukraine before 24
February 2022, temporary protection shall also be granted to the displaced citizens of Ukraine
and members of their families who left Ukraine immediately before 24 February 2022 due to the
security situation and cannot return to the country because of the armed conflict. According to the
official statement of the Ministry of Interior,23 ‘immediately before’ is to be considered as starting
from 1 January 2022.
Content of temporary protection
 Residence permit: After the person has been granted the status of temporary protection, the
police administration, i.e. the police station competent based on the place of residence of the
applicant, or officials of the Ministry of Interior or of the police administrations or police stations
who are present in collective accommodation facilities issue the identity card of a foreigner under
temporary protection to the person. The card is proof of having been granted TP status,
represents the residence permit and serves as a valid document for exercising all the rights that
19
Government of the Republic of Croatia: Proposal for a Decision on the establishment of an Interdepartmental
Working Group for drafting a proposal for a document on the immigration policy of the Republic of Croatia,
available at: https://bit.ly/3Nj373B.
20
Croatian Government, Decision on the Introduction of Temporary Protection in the Republic of Croatia for
Displaced Persons from Ukraine, available in Croatian at: https://bit.ly/37ylO2c.
21
Ministry of Interior, web page, Croatia for Ukraine: https://croatia4ukraine.mup.hr/Pages/Zahtjev.
22
The Ministry of Interior, web page Croatia for Ukraine: https://hrvatskazaukrajinu.gov.hr/informacije/status-
privremene-zastite/152.
23
Information provided by Ministry of Interior on 10 November 2022.
18
beneficiaries are entitled go under the scope of protection status. Given the fact that the
circumstances related to the introducing of temporary protection did not change over the course
of one year, decision about prolongation of temporary protection has been made. Temporary
protection has been prolonged until 4 March 202424, as well as all the rights of beneficiaries of
temporary protection within the scope of protection status. In order to extend temporary protection
(i.e. the validity of the card of a foreigner under temporary protection), beneficiaries of temporary
protection were requested to present themselves to the police administration/police station
according to their place of residence in the period from 15 February 2023 to 30 April 2023.
However, persons who applied for a card extension after 30 April 2023 did not lose their temporary
protection status. It is not necessary to submit an application for an extension of temporary
protection as the extension is recorded in the existing card of a foreigner under temporary
protection.
 Access to rights: Beneficiaries of temporary protection enjoy a wide range of rights in the
Republic of Croatia, and no significant obstacles to their realization have been observed due to
the fast reaction of the authorities and early establishment of an effective reception and care
system. By amending the Law on Social Welfare,25 beneficiaries of temporary protection gained
the right to receive all social services and benefits provided for by law under the same conditions
as Croatian citizens.
 Access to the labour market: Beneficiaries of temporary protection have unrestricted access to
the labour market, as do Croatian citizens. What represents a difficulty is the insufficient
knowledge of Croatian language (and the lack of official language courses organised by the state)
and the lengthy and expensive procedure of recognition and evaluation of foreign qualifications
(especially for professions regulated by law). Therefore, options for employment in certain
professions are significantly limited.
 Access to education: Access to primary and secondary education is fully facilitated and
accessible. As for admission to higher education institutions, only some universities or their
constituents decided to facilitate enrolment or continuation of studies, while the rest kept the quota
system for third country nationals, which implies high tuition fees.
 Housing: Persons who cannot afford to live in private accommodation have two options available:
accommodation in a collective centre where they are provided with free accommodation and food,
and accommodation in private units that meet the prescribed conditions, for which a contract is
concluded between the landlord and the state.
 Health care: Within the framework of exercising the right to health care, beneficiaries of
temporary protection face problems that represent a general feature of the health care system in
the Republic of Croatia - long-term waiting for specialist examinations. In addition, they are not
entitled to contract supplementary health insurance. They enjoy the right to health care to the
extent enjoyed by persons who are compulsorily insured, but at the same time they are not
insured and the costs of their health care are covered directly from the budget of the Republic of
Croatia. As a result, they are not able to contract supplementary insurance, except in the case of
employment, which would avoid additional (and large) health care costs that exceed the scope of
protection provided by compulsory insurance.
24
Information provided by the Ministry of Interior on 2 February 2023.
25
The Law on Amendments to the Law on Social Welfare (OG 46/22), available at: https://bit.ly/3TIJc1a.
19
Asylum Procedure
A. General
1. Flow chart
Intention to apply Intention to apply Intention to apply Intention to apply

on the territory at the border at a police in the Reception
administration / Centre for
station Foreigners
Dublin procedure
Detention in
Reception Centre
Dublin transfer for Foreigners
Accepted
Examination
(regular or
accelerated)
Regular procedure Accelerated

Ministry of Interior procedure
Ministry of Interior
Rejected Accepted
Refugee status
Appeal
Subsidiary protection
(judicial)
Suspensive (free legal aid)
Administrative
Court
Appeal
allowed
Non-suspensive
Onward Appeal
(judicial)
High Administrative Court
20
2. Types of procedures
Indicators: Types of Procedures

Which types of procedures exist in your country?
 Regular procedure: Yes No
 Prioritised examination: 26
Yes No
 Fast-track processing:27 Yes No
 Dublin procedure: Yes No
 Admissibility procedure: Yes No
 Border procedure: Yes No
 Accelerated procedure: Yes No
 Other:
Are any of the procedures that are foreseen in the law, not being applied in practice? Yes No
The border procedure foreseen by the Law on International and Temporary Protection (LITP) is not being
applied in practice. According to the information provided by the Ministry of Interior at the beginning of
2019, no decision has been taken on the implementation of the border procedure or the procedure in
transit zones.28 According to the CLC’s knowledge, this has not changed in the course of 2022.
3. List the authorities that intervene in each stage of the procedure
Stage of the procedure Competent authority (EN) Competent authority (HR)
Intention to apply
 At the border Border Police, Ministry of Interior Granična policija
 On the territory Police administration or Police station Policijska uprava

Policijska stanica
Registration of application Reception Centre for Applicants for Prihvatilište za tražitelje
International Protection, Ministry of međunarodne zaštite,
Interior Ministarstvo unutarnjih poslova
Dublin (responsibility Department for Dublin procedure, Odjel za dublinski postupak,
assessment) Ministry of Interior Ministarstvo unutarnjih poslova
Refugee status Department for international protection Odjel za postupak međunardne
determination procedure, Ministry of Interior zaštite, Ministarstvo unutarnjih
poslova
Appeal
 First appeal Administrative Court Upravni sud
 Onward appeal High Administrative Court Visoki upravni sud
Subsequent application Department for international protection Odjel za postupak
procedure, Ministry of Interior međunarodne zaštite,
Ministarstvo unutarnjih poslova
26
For applications likely to be well-founded or made by vulnerable applicants. See Article 31(7) recast Asylum
Procedures Directive.
27
Accelerating the processing of specific caseloads as part of the regular procedure.
28
Information provided by the Ministry of Interior, 28 January 2019.
21
4. Determining authority
Name in English Number of Ministry Is there any political interference
staff responsible possible by the responsible
Minister with the decision making
in individual cases by the
determining authority?
Department for
international protection N/A Ministry of Interior Yes No
procedure
Reception Centre for
applicants for
N/A Ministry of Interior Yes No
international protection
in Zagreb and Kutina
Following the entry into force of the amendments of the Decree on the internal structure of the Ministry of
Interior in March 2019,29 changes have been introduced to the internal organisation of the Ministry of
Interior. Asylum matters are now under the responsibility of the Directorate for immigration, citizenship
and administrative affairs, under which the Sector for foreigners and international protection is divided
into following organisational units dealing with asylum matters:30
1. Service for international protection

- Department for international protection procedure
- Department for Dublin procedure
- Department for integration
2. Service for reception and accommodation of applicants for international protection
- Reception centre for applicants of international protection in Zagreb
- Reception centre for applicants of international protection in Kutina
The Department for international protection procedure of the Ministry of Interior is an administrative
authority responsible for examining applications for international protection and competent to take
decisions at first instance. In September 2020, a new Decree on the internal structure of the Ministry of
Interior entered into force,31 and was amended in 2022.32 The same organisational units were
responsible for asylum related matters in the course of 2022.
In 2021, eight new staff members were employed by the Service for International Protection Procedure
and, at the beginning of 2022, a new vacancy was announced for three more positions in the Department
for International Protection Procedure. Two new employees were also employed in the Department for
Dublin Procedure. An internal workflow for staff responsible to conduct procedures and take decisions
was prepared. The workflow includes all procedures relating to administrative proceedings in international
protection procedure. The employees of the Service for Reception and Accommodation and the Service
for International Protection participated in over 50 seminars, conferences, webinars, lectures and
educational workshops in 2021. The employees of the Service for the Reception and Accommodation of
Applicants, which is responsible for managing reception centres for applicants for international protection
in Zagreb and Kutina, attended different workshops in the field of reception and accommodation, with
29
Decree amending the Decree on the Internal Organisation of the Ministry of the Interior, Official Gazette
24/2019, available in Croatian at: https://bit.ly/2WIbhdd.
30
This Sector further includes unites responsible for other migration-related matters e.g. citizenship, legal
residence of foreigners, visas etc.
31
Decree on the internal structure of the Ministry of Interior, Official Gazette 97/2020, available in Croatian at:
https://bit.ly/2Rrj1zK.
32
Amendments of Decree on the internal structure of the Ministry of Interior, Official Gazette 7/2022 available
in Croatian at: https://bit.ly/3n6iDGG; Amendments of Decree on the internal structure of the Ministry of
Interior, Official Gazette 149/2022 available in Croatian at: https://bit.ly/3TCOKKi.
22
special emphasis on the reception of persons with special reception and procedural guarantees in the
course of 2021.33
In 2022, employees of the Service for International Protection, attended two national workshops organized
under the curriculum of European Agency for Asylum (EUAA). Furthermore, 13 employees of the Service
for Reception and Accommodation attended various workshops in the field of reception and
accommodation with special emphasis on the vulnerable groups in need of special reception/procedural
guarantees (e.g. unaccompanied children, GBV survivors). Workshops were organized by EUAA,
UNHCR, Council of Europe, UNICEF, Croatian Red Cross, Frontex, Judicial Academy and State school
for public administration.34
According to the Ombudsman’s report for 2022,35 due to the high number of applicants for international
protection and the complexity of the asylum procedure, it would be necessary to increase the number of
officials who conduct procedures and prepare decisions.
Croatia has a single procedure for international protection. The Department for international protection
procedure examines whether the applicant fulfils the eligibility criteria for refugee status and, failing that,
subsequently examines whether the applicant is eligible for subsidiary protection. The civil servants
working in the Department for international protection procedure conduct interviews with applicants for
international procedure and, on the basis of all the relevant facts and circumstances arising from the
application, the applicant’s position and personal circumstances (including sex and age) based on the
testimony presented during the interview, the evidence submitted and available country of origin
information, as well as the activities of the applicant after leaving the country of origin to assess whether
these activities might expose him/her to persecution or serious harm if they are returned to that country,
issue a decision on the application for international protection. The existence of an internal protection
alternative in the country of origin, and the possibility for the applicant to obtain the protection of his or her
alleged country of nationality, are also considered when taking a decision.36
When deciding on the credibility of the applicant’s statements, the person conducting the procedure
should abide by the principle of the benefit of the doubt.37
As far as the Croatian Law Centre is aware, the Head of the Department for international protection
procedure reviews all decisions in order to ensure the quality of decisions.
5. Short overview of the asylum procedure
The procedure for granting international protection in Croatia is an administrative procedure regulated by
the Law on International and Temporary Protection (LITP). Additionally, the Law on General
Administrative Procedure is applied in the procedure, unless otherwise provided by the LITP.
The implementation of asylum policies in Croatia falls under the responsibility of the Ministry of Interior,
which is also responsible for the determining authority in charge of examining applications for international
protection (see: Determining authority).38
The Service for reception and accommodation of applicants for international protection is in charge of two
reception centres located in Zagreb and Kutina respectively. Officials of the determining authority are
33
Croatian Law Centre: The Croatian Asylum System In 2021 - National Report, The report was prepared as
part of the project “Access to the territory and the asylum system in Croatia - legal support and capacity
building” with the financial support of the UNf the UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and
in English at: https://bit.ly/3NBvVpC.
34
Croatian Law Centre, The Croatian Asylum System in 2022 - National Report. The report was prepared as
part of the project „Legal Assistance and Capacity Building for Access to Territory and Asylum in Croatia“, with
financial support of the UNHCR Croatia: available in English at: https://bit.ly/434T7RL.
35
36
Articles 27 and 28 LITP.
37
Article 29 LITP.
38
Article 32(1) LITP.
23
thus not only responsible for conducting interviews but also for ensuring access to reception of applicants
for international protection.
Registration
The procedure officially begins from the lodging of the application for international protection. Before this
stage, a foreigner must express the intention to seek international protection. Immediately following the
expression of the intention to apply for international protection, the applicants have access to reception
and police officers or officials from the Reception Centre for Applicants for International Protection shall
take the applicant's fingerprints and shall photograph him or her, establish his or her identity, how he or
she entered the Republic of Croatia, the travel route from the country of origin to the Republic of Croatia,
and personal circumstances of importance for assessing the special reception and procedural
guarantees. 39
Border officers, the police station, police administration or the Reception Centre for Applicants for
International Protection shall register the applicant in the records of the Ministry of Interior no later than 3
working days from the day the applicant expressed the intention to apply for international protection. If the
intention was expressed before some other body, the Reception Centre shall register the applicant in the
records of the Ministry within 6 working days from the day when he or she expressed his or her intention.40
The authority which undertook registration shall issue a certificate of registration of the applicant in the
records of the Ministry, and, as necessary, shall set a time limit in which the applicant must report to the
Reception Centre for Applicants for International Protection to lodge an application.41
Applicants shall be permitted to lodge an application within the shortest possible time and no later than
within 15 days from registration of their status in the records of the Ministry of Interior.42
First instance procedure
After the application has been lodged, the Department for international protection procedures of the
Ministry of Interior shall arrange the personal interview with the applicant as soon as possible,43 and shall
issue a decision within 6 months of a duly completed application or a duly completed and admissible
subsequent application.44 The 6-month time limit may be extended for a further 9 months under certain
circumstances and, exceptionally, the procedure may last up to 21 months. The Department for the Dublin
procedure is responsible for examining the Dublin criteria and carrying out Dublin transfers to another
Member State.
The procedure for international protection in Croatia is a single procedure, given that applications for
international protection cover both requests for asylum and the subsidiary protection, thus allowing the
Department for international protection procedures to determine ex officio the existence of conditions for
granting subsidiary protection status where the conditions for granting refugee status are not met. An
application may also be processed under an accelerated or border procedure, although the latter is not
used in practice according to Croatian Law Centre’s knowledge. The decision rejecting the application for
international protection also states that the person is obliged to leave the European Economic Area within
a certain period of time or will be forcibly removed.
Accelerated procedure
According to the LITP the Ministry shall render a decision in an accelerated procedure within 2 months
from the day the application or an admissible subsequent application is lodged. There are ten grounds for
39
Article 33(8) LITP.
40
Article 33(9) LITP.
41
Article 33(10) LITP.
42
Article 34(2) LITP.
43
Article 35(1) LITP.
44
Article 40(1) LITP.
24
applying the accelerated procedure. The deadline for lodging an appeal according to the LITP is 8 days
from the day the decision is delivered, but the appeal has no suspensive effect.45
Border procedure
Procedures at the border or in transit zones are regulated by the LITP. However, according to the Ministry
of Interior’s information from the beginning of 2019 they are not applied in practice.46 The border
procedure was still not applied in 2022 according to the Croatian Law Centre’s knowledge.
Appeal
Negative decisions may be appealed before the Administrative Court within 30 days in the regular
procedure, and 8 days in the case of Dublin decisions, inadmissibility decisions or the accelerated
procedure. Appeals have automatic suspensive effect in the regular procedure, Dublin cases and some
inadmissibility cases, but not in the accelerated procedure.
As regards onward appeals, besides the possibility to lodge a non-suspensive appeal to the High
Administrative Court, there is also a possibility to lodge a complaint before the Constitutional Court in
case the applicant claims a violation of a right guaranteed by the Croatian Constitution. In that case, a
foreigner would have to regularise their stay in Croatia in accordance with the Law on Foreigners, as stay
under the LITP is not foreseen once the administrative dispute is over. However, it is not feasible in
practice for rejected applicants to easily regularise their stay under the Law on Foreigners, as the majority
of them would not meet the conditions prescribed by the Law on Foreigners to obtain a residence permit.
This renders it very difficult in practice to appeal against a negative decision from the Administrative Court
on constitutional grounds.
B. Access to the procedure and registration
1. Access to the territory and pushbacks
Indicators: Access to the Territory

1. Are there any reports (NGO reports, media, testimonies, etc.) of people refused entry at the
border and returned without examination of their protection needs? Yes No
2. Is there a border monitoring system in place? Yes No

 If so, who is responsible for border monitoring? National authorities NGOs Other
 If so, how often is border monitoring carried out? Frequently Rarely Never
In 2022, besides continuation of the spread of COVID-19, the main challenge continued to be a strict
border regime that limits access to the territory and to the procedure for international protection in Croatia,
raising serious concerns for the protection of human rights of applicants for international protection.
1.1. Illegal border practices, push-backs and ill-treatment
According to the Ministry of Interior, there were 50,624 irregular border crossings in 2022, thus marking
an increase of 190.9% compared to 2021 when 17,404 irregularly border crossing cases were recorded.
The main countries of origin of persons apprehended while irregularly crossing the border were
Afghanistan, Iraq, Burundi, Pakistan, Türkiye and Bangladesh. Out of this number, 34,492 persons were
found in the depths of the territory, while 12,071 were apprehended near the border.47
45
Article 41(5) and 51(1)(1) LITP.
46
47
Ministry of Interior, Statistical overview of the fundamental safety indicators and work results in 2022, available
at: https://bit.ly/3JCs8VW.
25
Illegal crossing of the border
Location of interception
(persons)
Citizenship
Border Near the Deep into Accepted by
2021. 2022. Trend in the police of
% crossing border the territory another state
point
Afghanistan 4,824 14,877 +124.5 537 2,488 11,346 506
Bangladesh 1,998 3,237 +62.4 55 443 2,310 429
Bosnia and 124 89 -29.1 20 28 30 11
Herzegovina
Burundi 5,465 0 2,554 2,898 13
India 165 1,766 +1192.6 149 325 1,060 232
Iraq 614 6,334 +843.8 23 1,526 4,574 211
Iran 559 1,914 +275.6 11 344 1,458 101
Congo 3 692 +15666.7 1 146 537 8
Kosovo 678 870 51.0 89 222 455 104
Cuba 145 1,777 3373.7 1 625 1,135 16
Nepal 189 858 529.8 3 217 427 211
Pakistan 3,278 4,429 24.1 55 725 3,262 387
Syria 643 1,594 63.7 12 552 990 40
Serbia 145 60 -60.0 22 11 21 6
Türkiye 2,446 4,110 96.1 206 1,045 2,606 253
Other 1,593 2,552 46.2 200 820 1,383 149
Total 17,404 50,624 190.9 1,384 12,071 34,492 2,677
Source: Ministry of Interior, Statistical overview of the fundamental safety indicators and work results in 2022,
available at: https://bit.ly/3JCs8VW.
Pushback practices reported by national and European NGOs and other actors
Pushback practices persisted throughout 2022, as reported by many organisations such as the Danish
Refugee Council (DRC), PRAB initiative, the Border Violence Monitoring Network (BVMN), Save the
Children, Are You Serious? (AYS), the Centre for Peace Studies (CPS) and Welcome! Initiative’.
According to the Danish Refugee Council (DRC), 3,461 persons were pushed back from Croatia to Bosnia
and Herzegovina (BiH) in 2022,48 compared to 9,114 in 2021.49 UNHCR data further indicates that 289
persons were pushed back from Croatia to Serbia in 2022,50 compared to 928 in 2021.51
In 2022, Save the Children and the Centre for Interdisciplinary Studies at the University of Sarajevo
published a report analysing52 the level and types of violence that children experience while attempting to
reach Western Europe via the Balkans route. Based on the interviews realised with migrant children, most
of the interviewees reported having tried to cross the border from Bosnia and Herzegovina to Croatia
more than three times, with the largest number of attempts recorded being nine.
The Ombudsperson for Children reported that at least 120 children were pushed back in 2022 according
to data provided by the Border Violence Monitoring Network's. The actual number is likely higher, as it is
not possible to determine the exact number of children present within the large groups that were subjected
to pushbacks despite expressing their intention to apply for international protection. Civil society
48
Danish Refugee Council (DRC): Border Monitoring Factsheets January- December 2022, available in English
at: http://bit.ly/42BEYfK.
49
According to DRC the number of persons reporting pushbacks does not necessarily represent the number of
unique individuals, as the same individual(s) may experience repeated pushbacks to BiH.
50
UNHCR, Serbia- Snapshots January- December 2022, available at: https://bit.ly/3FJF7E1.
51
UNHCR, Serbia- Snapshots January- December 2021, available at: https://data2.unhcr.org/.
52
Save the Children: Report “W h e r e v e r w e g o , S o m e o n e d o e s u s H a r m : V i o l e n c e a g a i n s t
r ef u g ee and m i gr ant chi l dr en ar r i vi ng i n Eur op e t hr oug h t h e Bal kan s“ , avai l abl e at :
http://bit.ly/3Z5N6Sx.
26
organizations warn that younger children were exposed to psychological and verbal violence, and older
to physical violence. Nevertheless, some non-governmental organizations reported having received
significantly less calls concerning children in 2022.53
Are You Syrious (AYS), as a part of the Border Violence Monitoring Network (BVMN), reported that BVMN
collects data on pushbacks. According to their data in 2022, BVMN collected 123 testimonies of expelled
groups, which included at least 1,100 victims. The majority of persons (93.5%) were expelled from Croatia
to Bosnia and Herzegovina. Among the interviewed groups who experienced pushback, at least 53 groups
(43.1%) included minors, and at least 73 groups (59.35%) declared having tried to request asylum. The
most common forms of violence recorded were: beating, theft and destruction of personal belongings
(money, mobile phones and portable batteries). AYS also reported that according to BVMN data, violent
acts were observed against all groups of people, including towards pregnant women, children,
unaccompanied children and elderly persons.54
The Centre for Peace Studies (CPS) also reported that push backs practices and denying access to
asylum continued in 2022.55
In 2022, Common report of CPS and PRO ASYL on systematic human rights violations at Croatian
borders was published. 56 This report provides an overview of the unlawful and illegal practices of Croatian
authorities in the past six years, especially during 2020 and 2021, as well as the alleged change of the
pushback practice in 2022. In 2022, CPS noticed the change in approach of the police towards migrants
as police has started issuing more return decision, through the so-called 7-days papers ordering
applicants to leave European Economic Area.
Protection Rights At Borders (PRAB) initiative,57 which focuses on human rights violations at the EU’s
external and internal borders and in particular on the illegal practice of pushbacks, also reported on
pushbacks from Croatia specifying that victims of the pushback cases reported being denied access to
the asylum procedure in 2022.58
Following repeated allegations in previous years, the European Committee for the Prevention of Torture
and Inhuman or Degrading Treatment or Punishment (CPT) organised an ad hoc visit to Croatia in August
2020. Upon publication of the report at the end of 2021, the Croatian Ministry of Interior responded the
following:
“During 2021, the MoI’s Internal Control Department processed 13 cases related to the treatment
of migrants by police officers. The actions of the Internal Control Department relate to the
preliminary collection of information on events and the collection of evidence of possible
disciplinary responsibility of police officers, while other investigations are conducted by
specialized services - the criminal police. In connection with the above, disciplinary proceedings
have been initiated against 6 police officers - against three for misconduct in the service or outside
the service when the reputation of the police is severely damaged - proceedings are underway,
while disciplinary proceedings against three police officers have been terminated for non-
compliance, negligence, untimely or careless performance of official duties and fines were
imposed on them. Criminal investigations in cases from 2021, which have been completed so far
(12 cases in total), have not established facts or evidence that would indicate suspicion of
committing criminal offences or misdemeanours committed to the detriment of illegal migrants by
police officers. However, two procedures are in progress and the decision of competent judicial
authorities is pending.”59
53
Ombudsman for children report for 2022, available in Croatian at: https://bit.ly/45Dzl1W.
54
Information provided by AYS. 3 February 2023.
55
Information provided by the Centre for Peace studies, 18 January 2023.
56
Centre for Peace Studies: Common report of Centre for Peace Studies and PRO ASYL on systematic human
rights violations at Croatian borders, available in English: https://bit.ly/3lINSat.
57
Danish Refugee Council (DRC), Protecting Rights at Borders (PRAB), available at: https://bit.ly/3hCiEfw.
58
Initiative PRAB: Beaten, punished and pushed back, Report January – December: available at:
https://bit.ly/3n9bnK9.
59
Response of the Croatian Government to the report of the European Committee for the Prevention of Torture
and Inhuman or Degrading Treatment or Punishment (CPT) on its ad hoc visit to Croatia from 10 to 14 August
2020, available in English: https://rm.coe.int/1680a5acfc, and Croatian: https://rm.coe.int/1680a5acfd.
27
During the year 2022, reports of injured and dead migrants were also reported.
In April 2022, following an alert from the Slovenian police, police officers found several foreign nationals
on inaccessible terrain along the banks of the river Kupa. One of them was unconscious suffered from
hypothermia, and died despite attempts at resuscitation made by police officers. The next day, another
dead body was found in the river.60 Also in April, after a call from an unknown person who asked for help
as one person from their group had drowned, the police found two bodies in the river Mrežnica, during
the search for a drowned person. 61 In December, the body of a foreign citizen was found in the Sava
river.62 In its annual report, the Independent Monitoring Mechanism recommended the introduction of
mortality monitoring for irregular migrants.63
During the year, the police rescued migrants on several occasions.

In June, police officers rescued nine foreign nationals, including five children, from the wagon of a cargo
train.64
Police officers from police administration Brodsko-posavska rescued migrants on several occasions. in
September, four people were rescued from the swollen Sava river – on the country’s Bosnian border -
by some police officers and local citizens,65 while during October migrants were rescued from the river
in two occasions.66
In December, police officers rescued migrants from an overturned boat in the same river.67
During 2022, UNHCR Croatia continued to carry out its activities, in cooperation with its partners,
monitoring of the asylum procedure and advocating for access to territory and asylum, capacity building
events aimed at strengthening the asylum procedure and promoting local integration prospects and
positive attitudes towards forcibly displaced and stateless people. UNHCR undertook a range of advocacy
and operational activities to promote respect for international law and safeguard access to territory and
the right to seek asylum. This includes protection monitoring, the provision of information on how to seek
asylum, and capacity building of border police and asylum officials.68
Push-back practices reported by the media
In 2021, Lighthouse Reports further recorded a footage of a pushback at the border with Bosnia
Herzegovina.69 Forensic examination of the video demonstrated that the masked men had equipment and
uniforms consistent with the Croatian police’s riot control branch, called the Intervention Police. Three of
the four police officers were using a so-called Tonfa, i.e. a baton that is only issued to the Intervention
Police. The research team contacted six police officers who wished to remain anonymous and confirmed
that “there is no official order which was officially issued by the Ministry of the Interior. However, internally
there is an order that migrants found in Croatia must be returned across the green border. Therefore, the
police are not guilty of anything as it is their duty to carry out orders.“70 This case was followed by
independent monitoring mechanism (IMM). By conducting unannounced monitoring and analysing other
primary and secondary data sources relating to the video recording broadcast on RTL television on 6
October 2021 (i.e. Lighthouse Reports footage), the IMM established that the members of the riot police
acted illicitly by returning irregular migrants from Croatia to Bosnia and Herzegovina outside the scope of
permitted national and international law, which was also confirmed by the MoI. Based on this case,
60
Novi list, available at: http://bit.ly/3JFzQ1n.
61
Available at: http://bit.ly/3JCcGc9.
62
Available at: https://bit.ly/3JnvYmy.
63
Annual Report of the Independent Mechanism of Monitoring the actions of police officers of the Ministry of the
Interior in the area of illegal migration and international protection, June 2021 – June 2022, available in
Croatian at https://bit.ly/3FKhkDQ and in English at: https://bit.ly/3FMRcbD.
64
Police administration vukovarsko- srijemska, available at: https://bit.ly/3CBWJzB.
65
Police administration brodsko-posavska, available at: https://bit.ly/3piwECz.
66
Police administration brodsko-posavska, available at: https://bit.ly/3Xe5vgN.
67
Jutarnji list, available at: https://bit.ly/3JKKEfJ.
68
Croatian Law Centre, The Croatian Asylum System in 2022- National Report ; The report was prepared as
69
Lighthouse Reports, Unmasking Europe’s shadow armies, available at: https://bit.ly/3HR6tGF.
70
INDEX, Police officers: Yes, we use force against migrants. It is illegal, but these are the orders, available at:
https://bit.ly/3C7L9v4.
28
disciplinary proceedings as well as criminal proceedings have been initiated against police officers before
the competent state’s attorney office.71
In January 2022, police officers recorded in the Lighthouse Reports footage retuned to work in their
previous work positions.72
In February 2022, the INDEX portal published news in relation to the instruction that was sent to police
officers regarding migrants’ treatment. According to the portal, the Office of the Ombudswoman has
therefore opened the procedure and will request from the Ministry of Interior to deliver the order or
guidelines as well as their statement.73
Reactions from UN bodies and European human rights bodies
This situation at Croatian’s borders has further drawn attention from the EU ombudsman as well as the
Council of Europe.
The EU Ombudsman opened an inquiry in 2020 concerning how the European Commission (EC) monitors
and ensures respect for fundamental rights by the Croatian authorities in the context of border
management operations supported by EU funds. An Ombudsman inquiry has identified significant
shortcomings related to how the EC monitors respect for fundamental rights by Croatian authorities in
border management operations supported by EU funds. In closing the inquiry, the Ombudsman suggested
a number of improvements to the Commission (including that the Commission should provide up-to-date
information on how the monitoring mechanism is working in Croatia, whether it is independent and
effective; the EC should also ask for information to Croatian authorities on how it investigated reports of
mistreatment of migrants and asylum seekers).74
In August 2020, the Council of Europe Committee for the Prevention of Torture (CPT) completed a five-
day rapid reaction visit to Croatia to examine the treatment of persons attempting to enter the country and
apprehended by the police.75 The delegation visited several temporary reception centres and informal
migrant settlements in north-west Bosnia and Herzegovina, where it interviewed and medically
examined many migrants who claimed they were apprehended by Croatian law enforcement officials
within the territory of Croatia and forcibly returned to Bosnia and Herzegovina. In Croatia, beside the
Reception Centre for Foreigners in Ježevo, the delegation visited the Cetingrad Border Police Station,
the Donji Lapac Border Police Station, the Korenica Border Police Station, the Intervention Police Unit
of the Karlovac Police Administration (Mali Erjavec).
The preliminary observations of the delegation were presented to the Croatian authorities at the end of
the visit. According to the Croatian Ombudsperson, the report on the CPT visit was adopted in November
2020 and the CoE Commissioner for Human Rights urged to Croatia to publish it, as it is common practice
for CPT reports to be made public, with very few exceptions.76 In October 2021, representatives of the
CPT met with officials of the Ministry of Interior led by the Minister and the State Secretary for European
and International Affairs inter alia to discuss why Croatia refused to publish the report. According to the
procedure of the Council of Europe, the country to which the report refers must express its consent to its
71
72
H-Alter: Foundations of the police state; available at: https://bit.ly/3MZgF5s.
73
INDEX.
74
EU Ombudsman: Delay in setting up monitoring mechanism for Croatian border management
regrettable available at: https://bit.ly/40vVnk4.
75
Council of Europe, ‘Council of Europe anti-torture Committee carries out rapid reaction visit to Croatia to
examine treatment of migrants’, 18 August 2020, available at: https://bit.ly/32gXsEs.
76
Ombudsman, Annual report 2020, available in Croatian at: https://bit.ly/3aaQXar.
29
publication, which usually takes place within three months of its adoption.77 The report on the visit to
Croatia carried out by CPT from 10 to 14 August 2020 was finally published in December 2021.78
According to the report there were cooperation difficulties i.e. the list of establishments provided to the
CPT’s delegation concerning the places where foreign nationals may be deprived of their liberty was
incomplete, the police officers met in the police establishments visited by the CPT’s delegation were
poorly informed about the mandate of the Committee, especially as regards the CPT’s right of access to
all documentation containing information relevant to its mandate. (See AIDA Country Report on Croatia –
2021 Update)
In March 2022, the CPT published the response of the authorities to the report on the Committee’s ad
hoc visit to Croatia.79 In relation to the fulfilment of recommendations formulated by the CPT report, some
of the authorities’ responses included the following:
- The Ministry of Interior reported that, on 2 December 2021, “the General Police Directorate of the
Ministry of Interior sent a letter to police administrations and stations familiarising police officers once
again with the CPT’s mandate in the part regarding immigration administrative detention and other
actions towards foreign nationals.”
- Regarding the CPT’s recommendation that individuals must be accorded the fundamental safeguards
against ill-treatment the Ministry of Interior argued that “just because a person was transported in a
police vehicle or because of any other treatment of a person by the police, it cannot be assumed that
the freedom of movement of the person is restricted. The Croatian police often transports various
categories of persons (Croatian and foreign nationals, migrants) in police vehicles and according to
such a provision, for foreigners who are legally staying, the transport would also represent detention
by the police - which is not true, nor is it really the case. Injured and pregnant migrants are transported
to hospitals, migrants who expressed the intention to apply for international protection are transported
to reception centres, unaccompanied minors are transported to initial medical examinations and in
institutions for children, while migrants who were found on the streets or who registered with the police
to express the intention for applying for international protection or for any other reason, are
transported to a police station for identity verification and collecting information, which does not
always imply that they have all been detained by the police “against their own will”. In addition, if it is
necessary to assess the voluntary element of a migrant being transported or being treated in a
different way, the police will assess it in each concrete case and take measures to formally restrict
movement. Furthermore, the Ministry of the Interior stressed that they apply a “zero tolerance for
illegal use of coercive means towards any population, as well as zero tolerance for failure to prosecute
any criminal offence or misdemeanour committed by police officers which we strongly condemn and
do not support in any way.”
- Regarding the CPT's recommendation for the Croatian police to record every “interception”,i.e.
“diversion” of migrants (location, description of the action undertaken, names of officers involved,
means used for these purposes etc.), the MoI stressed that migrants who are deterred from attempting
to illegally enter the Republic of Croatia are located in the state territory of the neighbouring countries
- Bosnia and Herzegovina and Serbia where the Croatian police has no jurisdiction. More precisely,
deterrence measures are applied in open and inaccessible terrains (forests, mountains), by day and
by night and in all weather conditions which is why it is not possible to obtain personal information
from migrants, conduct official hearings etc. Although it is not possible to identify migrants when
applying deterrence measures, police officers are obliged to profile (identify) migrants in need of
77
Novosti, Moi v. Council of Europe, available at: https://www.portalnovosti.com/mup-protiv-vijeca-europe;
Euroactive, Croatia slammed by Council of Europe anti-torture committee over migrants, available at
https://bit.ly/3CcMMb6.
78
Council of Europe, Report to the Croatian Government on the visit to Croatia carried out by the European
Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 10
to 14 August 2020, available at: https://rm.coe.int/1680a4c199.
79
2020, available in English: https://bit.ly/3KHFrDu.
30
assistance and protection and provide them with it, taking into account the circumstances of each
individual case. We would like to point out that police officers are especially trained to recognize such
persons. After noticing the measures applied for deterrent purposes, in the majority of cases migrants
give up on the attempt to illegally enter the Republic of Croatia and return to the depth of the territory
of the neighbouring country in which they are located.
- Regarding the CPT’s recommendation that the Croatian authorities restore the capacity of the NPM
to carry out unimpeded monitoring work in all police establishments, which should include the
possibility of undertaking unannounced visits and having access to all relevant information in paper
or electronic format, the MoI reported that Article 5(1) of the Act on the National Preventive
Mechanism (ANPM) “contains a provision on unannounced visits stipulating that “persons who
participate in the performance of activities of the National Preventive Mechanism shall have the
following powers: perform unannounced visits to bodies or institutions and inspect premises occupied
by persons deprived of liberty” and the crucial part, “or potentially occupied by persons deprived of
liberty”, stipulated in Article 3 of the ANPM, is omitted at the end of the sentence. As this provision is
the only provision in the entire Act mentioning unannounced visits, we consider it to represent a lex
specialis regarding unannounced visits and in relation to all other provisions of the ANPM and that an
unannounced visit based on the ANPM is authorised only if foreign nationals whose freedom of
movement is restricted are located in a police station”. The MoI further stressed that based on this
single provision which is vague and ambiguous (Article 5(1) of the ANPM), unannounced visits have
become a rule because the Ombudswoman did not announce any of her visits to police stations. In
this way, she deliberately made it seem as if information were not given to her because, at the time
of the visit to the police station, only police officers who do not have the requested information are
most often on operational duty. Due to this, police officers for illegal migration from the headquarters
of the police administration have to be called to find case files that the Ombudswoman wants to
inspect immediately because the files are not in the information system and are not accessible
immediately, which is another fact not mentioned by the Ombudswoman. On the contrary, she tries
to imply that, considering she has indirect access to the information system (using requests), she
does not obtain information which are not even in the information system (notes, certificates,
orders...). In this way, a practice has been created according to which the exception as provided by
law has become a rule. As regards access to the information system of the MoI, the Ombudswoman
was answered on several occasions that it is strictly under the personal authority of police officers in
line with the Instructions for assigning passwords and responses issued by the IT Department of the
MoI, police officers are not allowed to give their passwords and responses to other persons nor are
they allowed to enable access to the system to other unauthorised persons. The violation of this
instruction is considered to be a serious breach of official duty in line with the Police Act.
- Regarding the CPT’s recommendation on the conditions of detention for large groups of “intercepted”
migrants who need to be processed at a police station, the Ministry of Interior replied that they are
aware that the premises for persons deprived of liberty in individual police stations do not fully meet
the prescribed standards. However, they are of the opinion that the possible accommodation in such
premises should not be considered a degrading act because it refers to a short-term detention lasting
up to 24 hours and the rooms are heated, the persons are given food as well as access to sanitation
facilities. On 26 March 2020, the General Police Director sent instructions to all police administrations
and stations concerning the recommendation of the Ombudswoman, that if an arrested alien needs
to be detained at a police station in accordance with the Aliens Act for a period longer than 24 hours,
the prolonged detention must be implemented at the nearest police station which has premises for
detention for up to 72 hours.
- As for the CPT recommendation on police transportation, the MoI reported that on 5 January 2022,
the General Police Directorate of the Ministry of the Interior sent a letter to all police administration
and police stations informing and instructing police officers on the orderly manner of transporting
migrants using police vehicles.
31
In February 2022, the President of the CPT, met with Croatian Deputy Prime Minister and Minister of the
Interior, in Strasbourg, further to their previous meeting in October 2021 to continue their discussions on
the treatment of migrants deprived of their liberty. The talks focussed on the implementation of the
recommendations contained in the CPT’s report on the 2020 ad hoc visit to Croatia, published on 3
December 2021.80
Litigation on pushback practices and relevant complaints
The case M.H. and others v. Croatia concerned an Afghan family of 14, in which the ECtHR found Croatia
to have violated several articles of the ECHR. According to the complainants, the mother and her six
children were pushed back by Croatian authorities in November 2017 after crossing the border from
Serbia. The group was intercepted by Croatian police officers when resting in a field and despite
expressing the wish to seek asylum they were taken back to the border and told to return to Serbia by
following a train track in the area. As a train passed, it hit one of the children, a six-year-old girl that died
following the incident. On 21 March 2018, Croatian authorities apprehended the applicants who had
attempted a second crossing. Despite expressing a wish to apply for asylum they were detained in a
transit immigration centre in Tovarnik. In its judgment the ECtHR found several violations of the ECHR
including ineffective investigation into the child’s death (article 2 procedural), degrading treatment of child
applicants detained for a period above two months (article 3 substantive), failure to demonstrate required
assessment, vigilance and expedition in proceedings in order to limit family detention as far as possible
(article 5 § 1), restriction of contact with the chosen lawyer, pressure placed on the lawyer aimed at
discouraging pursuit of case (article 34), and collective expulsion by Croatian police outside official border
crossing and without prior notification of Serbian authorities (article 4 para 4). In April 2022, in the case
M.H. and Others v. Croatia,81 the ECtHR’s Grand Chamber panel of five judges rejected the Croatian
request for referral and the judgement became final.82
The organisation Centre for Peace Studies – who intervened in the case – and activist alliance Are You
Syrious called for the interior minister and others responsible within the police to be dismissed in light of
the ruling. In December 2022, the Action plan was published.83 The plan concerns measures that the
authorities have taken aimed at bringing the violations to an end and redressing the applicants.
The Centre for Peace Studies and the Human Rights House Zagreb prepared recommendations for the
execution of the judgment of M.H. and Others against Croatia.84
In 2022, a Rohingya child submitted complaints against Croatia and Slovenia at the UN Child Rights
Committee for multiple violations of the Convention on the Rights of the Child (CRC).
After many years looking for protection, he spent over a year in Bosnia and Herzegovina (BiH) from 2020
to 2021, having to survive without state support or medical care, sleeping rough in forests and squatting
in abandoned buildings. During this time, he was pushed back five times from Croatia to BiH. In Slovenia
he was subjected to a “chain” pushback, by which he was forcibly returned first to Croatia by Slovenian
authorities and then onwards by Croatian authorities to BiH. The child faced beatings by Croatian border
officers, had his belongings burnt and his shoes confiscated.
The applicant’s complaints argue violations of the CRC, in relation to his expulsions and ill-treatment, and
states’ failure to assess his age or apply any of the relevant safeguards under articles 3, 8, 20(1), and 37
CRC. The child corroborated his accounts with a range of digital evidence. The complaints were filed
against Croatia and Slovenia with the support of ECCHR and Blindspots. 85
80
European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment:
Council of Europe anti-torture Committee (CPT): President holds high-level talks with Deputy Prime Minister
and Minister of the Interior of Croatia on migration issues, available in English at: http://bit.ly/3TAHVZP.
81
ECtHR, Judgment in the case of M.H. and others v. Croatia (Applications nos. 15670/18 and 43115/18),
available at: http://bit.ly/3yWYBRT.
82
ECtHR: Grand Chamber Panel's decisions - April 2022, Press Release - Referrals to Grand Chamber,
published on April 4, 2022, available at: https://bit.ly/3z0PoI9.
83
ECtHR: Action Plan-Communication from Croatia concerning the case of M.H. and Others v. Croatia
(Application No. 15670/18), available at: http://bit.ly/3LLlVJH.
84
Recommendations of the Centre for Peace Studies and the Human Rights House Zagreb for the execution of
the judgment of M.H. and Others against Croatia, available at: https://bit.ly/42Rajdg.
85
ECCHR, Rohingya child challenges Croatia and Slovenia over violent pushbacks, available at:
https://bit.ly/3PDQ0wG.
32
1.2. Criticism and accountability
In December 2022, environmental protection organization “Zelena akcija” reported that the police illegally
entered one of their premises, without identification or a warrant, looking for "migrants and persons of
lower financial status". Only later, they found out that this was the criminal police.86
1.3. Border monitoring
The CPT in its report on ad hoc visit to Croatian in August 2020, stated that there were no effective
accountability mechanisms nor effective monitoring mechanism capable of examining push-backs.
An independent monitoring mechanism (IMM) for border monitoring was established in Croatia in summer
2021.87
According to the PRAB, the mechanism has not been effective in preventing and limiting pushback
practices.88
The independent monitoring mechanism was established for a one-year period with the possibility of
extension, while activities were planned to be carried out at the Croatian border (border crossings / police
stations / police administrations) with Bosnia and Herzegovina, Montenegro and the Republic of Serbia
and in the reception centres for foreigners.
A second agreement was signed in November 2022. It will be implemented for a period of 18 months with
automatic extension, through announced and unannounced visits to police stations, police
administrations, the external border, including the green border, at the border crossings with Bosnia and
Herzegovina, Montenegro and Serbia, as well as and in Reception Centre for Applicants of International
Protection and in reception centres for foreigners.89
The activities of the Independent Monitoring Mechanism include 20 visits (announced and unannounced)
in order to monitor police officers' treatment of irregular migrants and applicants for international protection
in the implementation of regulations governing state border surveillance and international protection,
announced visits to green border and access to case files regarding complaints of alleged illegal treatment
of irregular migrants and applicants for international protection. The direct activities of the Independent
Monitoring Mechanism are carried out by two representatives of civil society organizations.
Within seven (7) days after the monitoring visits, monitors shall jointly compile an individual report and
submit it to the Coordinating Committee. The first semi-annual report of the Independent Monitoring
Mechanism for the period June - December 2021 was published at the end of 2021 and is available
online.90
86
Jutarnji list: Police officers in in civilian clothes illegally entered our premises, available in Croatian at:
http://bit.ly/3JEINrV.
87
European Commission: Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions on the Report on Migration and
Asylum, September 2021, available at: https://bit.ly/3C86iFs.
88
Initiative PRAB: Beaten, punished and pushed back, Report January – December: available at:
https://bit.ly/3n9bnK9.
89
Ministry of Interior: A cooperation agreement was signed for the implementation of an independent monitoring
mechanism for the protection of fundamental human rights in the conduct of police officers of the Ministry of
Interior in the field of border protection, illegal migration and international protection; available at:
http://bit.ly/3JGyjbs.
90
Independent Monitoring Mechanism, The first semi-annual report of the Independent Monitoring Mechanism
for the period June- December 2021, available at: https://bit.ly/3KbMgfX.
33
The first annual IMM’s report covering period June 2021 - June 2022 was published in July 2022. 91
The report presents the activities and findings of the IMM, as well as cases of established irregularities
and examples of good practices.
The monitoring visits conducted in the framework of the IMM were both announced and unannounced.
According to the first Agreement, 20 monitoring visits were foreseen during the 1-year period. According
to annual report, out of 20 monitoring visits, 3 were announced and 17 unannounced. Direct “activity
providers” visited the green border on 5 occasions as part of observations of border police stations
accompanied by police officers in the areas of Border police station (BPS) Donji Lapac, Police station
(PS) Dvor, BPS Stara Gradiška, BPS Trilj and BPS Korenica. When sampling cases/locations of
observations, the IMM was guided by the key selection criteria of the size/number and the degree of
vulnerability of persons/groups of migrants, estimated urgency of the observation, assessment of the
scale/severity of potential illegalities and geographically unified distribution of conducted observations in
correlation with incidence and prevalence of irregular migrations in individual locations. In addition to
aggregate statistical data and reports of the Ministry of Interior, the IMM also based the sampling of
cases/locations of observations on daily notifications of the Ministry of Interior on persons encountered
as irregular migrants (location, number of people in the group, presence of vulnerable persons in the
group, origin of group members, etc.) also making sure that observations in BPSs and PSs cover the
entire eastern border of the Republic of Croatia.
According to the annual report, no irregularities regarding the right to seek asylum and access to the
asylum procedure were registered at border police stations.
The powers of the IMM do not include unannounced visits to the green border nor gaining insight into the
Information System of the Ministry of Interior, so the IMM could not observe the actions at the green
border of the Republic of Croatia, except during announced visits to the green border conducted in the
presence of authorized officers of the Ministry of Interior and in line with their instructions.
Based on the insight into documentation and interviews at border police stations and announced
observations of the green border, apart from the cases mentioned below, cases of forcible return of
irregular migrants, which would lead to collective expulsions, were not established.
By monitoring, the IMM established that the police conducts, without registering them, permissible
deterrence in line with Article 13 of the Schengen Borders Code, as well as illicit deterrence in mine-
suspected areas in isolated cases. The IMM further established that the Ministry of Interior misinterprets
relevant regulations in situations when irregular migrants know that police officers do not conduct physical
control of mine-suspected areas, take full advantage of that circumstance by crossing the state border in
these dangerous/(potentially) mined locations and upon crossing and being encountered by police officers
claim that they entered the Croatian territory and apply for asylum. However, the interpretation of the
border police is that these persons did not in fact enter the Croatian territory, as these areas are
considered not “under the actual control of the Republic of Croatia”. Instead they are, “deterred from
crossing/entering” in a way that they are returned in harmless locations, without determining whether they
are indeed in need of international protection, and should as such be protected from refoulement from the
moment they come under the jurisdiction of the Republic of Croatia, let alone on its territory, which is the
case in the situation described.
By conducting unannounced monitoring and analysing other primary and secondary data sources relating
to the video recording broadcast, the IMM established that the members of the riot police acted illicitly by
returning irregular migrants from Croatia to Bosnia and Herzegovina outside the scope of permitted
national and international law, which was also confirmed by the MoI. Based on this case, disciplinary
proceedings as well as criminal proceedings were initiated against police officers before the competent
state’s attorney office.
91
available in Croatian at https://bit.ly/3FKhkDQ and in English at: https://bit.ly/3FMRcbD.
34
Among the difficulties faced by irregular migrants, the annual report states that illegal acts of members of
the Croatian police towards migrants (e.g. use of force) with the aim of forced return have been recorded.
In describing cases of illegal use of force, irregular migrants stated that force was applied by persons in
dark uniforms without markings, with "phantoms" on their heads, equipped with batons.
For the duration of the IMM (from June 2021 to June 2022), based on claims from various sources
(requests of the Ombudswoman, Ombudswoman for Children, Office for the Prevention of Corruption and
Organized Crime (USKOK), State Attorney’s Office, media, individual complaints, nongovernmental
organisations etc.), thirty-five cases were initiated in the Internal Control Department of the Ministry of
Interior, which monitors the actions of the border and riot police regarding possible violations of rights of
refugees and migrants irregularly entering the Republic of Croatia. Fifteen of these cases were finalised
and in seven of them sanctions were imposed. Three out of the said seven sanctions refer to police
officers from the RTL report. They were sanctioned due to improper conduct and abuse of power.
According to the information presented in the Action plan concerning the case of M.H v. Croatia, in 2022,
among other topics, trainings on the topic of protection of fundamental rights regarding treatment of
migrants were conducted for (border) police officers.92
Under the Agreement with the Ministry of Interior, CLC organised training for border police officers -
multipliers in the field of asylum in April 2022.
In addition, in 2022, UNHCR and the Croatian Law Centre in cooperation with the Ministry of Interior
organised and held 3 workshops on the subject “Protection of human rights and access to the system of
international protection” for police officers. In total 57 police officers participated at workshops. The
following topics were discussed at the workshop: human rights of migrants, protection and identification
of vulnerable groups, access to asylum system and the responsibility of police officers regarding the
prevention of irregular migration in the light of the ECtHR judgment - M.H. v. Croatia.
1.4. Legal access to the territory
Based on the 2015 Decision on relocation and resettlement of third-country nationals or stateless persons
who meet the conditions for approval of international protection, Croatia has committed to accept 150
people through resettlement. Due to the high number of people who withdrew from the process during the
selection missions, this quota was filled in October 2018 following four selection missions. By way of
illustration, another mission took place in February 2019, during which 141 Syrian refugees identified by
UNHCR were interviewed and 103 selected for resettlement.93 In addition, Croatia continued to implement
the 2017 Decision on resettlement of third-country nationals or stateless persons who meet the conditions
for approval of international protection, which requires Croatia to accept up to 100 persons.
A Decision on resettlement of third-country nationals or stateless persons who meet the conditions for
approval of international protection for 2019 entered into force in February 2019.94 The Decision foresees
that Croatia will accept up to 150 persons through resettlement or shall participate in other forms of
solidarity with EU Member States. However, in 2022 a Decision to revoke the Decision on resettlement
of third country nationals or stateless persons who meet the conditions for approval of international
protection for 2019 was issued. 95
In addition, a new Decision on relocation of the third country nationals or stateless persons who meet the
conditions for approval of international protection was adopted in July 2022.96 In accordance with the
aforementioned decision, Croatia will participate in the relocation of 60 third-country nationals or stateless
92
Action Plan (01/12/2022) - Communication from Croatia concerning the case of M.H. and Others v. Croatia
(Application No. 15670/18; available at: http://bit.ly/3ZizCCZ, page 18 and 19.
93
SHARE, Integration Magazine, April 2019, available in English at: https://bit.ly/2xyKwOm.
94
Official Gazette 16/2019.
95
Official Gazette 88/2022, available at: http://bit.ly/3lLCA5g.
96
Ibid.
35
persons who meet the conditions for granting international protection from Greece, Cyprus, Italy, Malta
and Spain.
In May 2019, in the framework of the Croatian resettlement programme, 50 Syrian citizens arrived in the
Reception Centre of Kutina. Four representatives of the Ministry of the Interior participated in the study
visit from 24-28 June 2019 as part of the resettlement programme. The study visit aimed to exchange
experiences and best practices with Portuguese colleagues while Portugal was conducting a selection
mission in Türkiye, Ankara.97
According to the Ministry of Interior, the seventh group of refugees from Türkiye arrived in Croatia as part
of the European Resettlement Program on 21 August 2019. The group consisted of 8 families i.e 41
citizens of the Syrian Arab Republic, of whom 24 are minors.98 7 Syrian nationals (2 families) arrived on
30 August 2019. As a result, Croatia has fulfilled its pledge within the EU resettlement scheme to
effectively resettle 250 Syrian refugees from Türkiye, according to the Decisions on Relocation and
Resettlement of Third-country Nationals or Stateless Persons Eligible for International Protection from
2015 (150 persons) and 2017 (100 persons). 99
In 2020, Croatia decided to take part in the relocation of unaccompanied children from Greece.100 It was
expected that relocation will take place in the course of 2021. Although the Croatian government originally
planned to accept ten children, after the fire at the Moria camp in Greece, it was decided that 12 children
would be relocated to Croatia.101 However, Croatia’s efforts to relocate 12 asylum-seeking
unaccompanied children (all girls) from Greece failed, as all of them applied for international protection
while transiting at the Amsterdam International Airport.102 Their transfer to Croatia was thus cancelled as
the competent Dutch court designated the Netherlands as the state responsible for examining their
applications for international protection.103
In 2021, Croatia responded to the call of the European External Action Service (EEAS) on evacuations
from Afghanistan and decided to accept 20 people whose lives and security were endangered by the
arrival of the Taliban regime. In August 2021, 19 Afghan nationals arrived, namely three families with
children and one single person. 104 Other Afghan nationals came to Croatia by the end of 2021. A total of
41 Afghan citizens were admitted from August to December 2021, three of whom left the Republic of
Croatia to reunite with their families, while the rest were granted asylum.105 Out of total number, 16 were
children.106
Although the Ministry of Interior reported in previous years that they do not keep statistics on the average
duration of the resettlement process, they stated that the procedure from the receipt of the file from
UNHCR to the transfer of refugees to Croatia lasts around 6 months on average.
In January 2022, Croatian Law Centre started the implementation of the project "Complementary
pathways for Southeast Europe - COMP4SEE". The project aims to contribute to the development of
complementary pathways by creating new models of private sponsorship and by making and advocating
recommendations for improving national systems in the area of family reunification.
97
EMN, Bulletin, July 2019, available at: https://bit.ly/2xQ8zrO.
98
Ministry of Interior, ‘The arrival of the seventh group of Syrian refugees from Turkey’, 21 August 2019, available
at: https://bit.ly/3c181hL.
99
EMN, Bulletin, November 2019, available at: https://bit.ly/34iMWN8.
100
Telegram, 'Confirmed to the Telegram: seven EU countries will accept 1,600 refugee children, including
Croatia', 12 March 2020, available in Croatian at: https://bit.ly/3ato5KA.
101
Telegram, 'Telegram finds out: After the terrible fire in the migrant camp, the Government is preparing to
accept 12 children', 12 September 2020, available in Croatian at: https://bit.ly/3n6F36E.
102
FRA, Migration: Key fundamental rights concerns- January- June 2121, Quarterly bulletin, available at:
https://bit.ly/3HQapaz.
103
Ministry of Interior, Decision on revocation of the decision on the allocation of funds for the implementation of
the project "New Home", available in Croatian: https://bit.ly/3KmMkcV.
104
Ministry of Interior: 19 Afghan citizens arrived in Croatia, available at: https://bit.ly/3Ciow7r.
105
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/3v5TsVi.
106
Ombudsperson for Children: Report on the work of the Ombudsman for Children in 2021, available in Croatian:
https://bit.ly/3KzksTm.
36
2. Registration of the asylum application
Indicators: Registration
1. Are specific time limits laid down in law for making an application? Yes No
 If so, what is the time limit for lodging an application?
2. Are specific time limits laid down in law for lodging an application? Yes No
 If so, what is the time limit for lodging an application? 15 days
3. Are registration and lodging distinct stages in the law or in practice? Yes No
4. Is the authority with which the application is lodged also the authority responsible for its
examination? Yes No
5. Can an application be lodged at embassies, consulates or other external representations?

Yes No
1.1. Making and registering the application
Although no time limit is specified in the LITP, a foreigner is in practice expected to seek international
protection (i.e. express the intention to lodge an application) at a police administration, a police station, at
border crossing points, in Reception Centre for Foreigners or in the Reception Centre for Applicants for
International Protection within a reasonable time after entering the country.
In 2022, in total 12,872 intentions to lodge applications for international protection were expressed. Out
of the total number of intentions, the largest number of intentions was expressed at border police stations
(10,087). The rest were expressed at police stations (2,318), the Reception Centre for Foreigners in
Ježevo (138), Pleso Airport police station (137), police administrations (112), the Transit Reception Centre
for Foreigners in Tovarnik (50) and the Transit Reception Centre for Foreigners in Trilj (30).107
As soon as a foreigner expresses the intention to seek protection during a border control at a border
crossing point,108 competent officials will refer him or her to the Reception Centre for Applicants for
International Protection,109 and if necessary determine the time period within which he or she must report
to the Reception Centre to lodge the application.
In practice, a person may express such an intention even after having been found irregularly crossing the
state border or at a later stage, during further proceedings related to irregular border crossing. After the
foreigner has been apprehended and transferred to a police administration or station, the police officer
makes a report and hands the person over to officers in charge of irregular migration for further
proceedings. These police officers will conduct an interview with the foreigner in the police station to
determine the person's identity, perform a security check and conduct an informative interview. If the
foreigner expresses the intention to seek international protection at any stage of this procedure, the
procedure should be suspended and the person will have the right to stay in Croatia until a final decision
is taken on the application for international protection. However, many problems have been reported since
2017 in accessing the territory and the asylum procedure (see Access to the Territory).
Border officers, the police station / police administration or the Reception Centre for Applicants for
International Protection shall register the applicant in the records of the Ministry of Interior no later than 3
working days from the day the applicant expressed the intention to apply for international protection. If the
intention was expressed before some other body, the Reception Centre shall register the applicant in the
107
108
Article 33(1) LITP.
109
The Reception Centre is also the place where asylum seekers have to report themselves after expressing
their intention to lodge an asylum claim and where interviews are conducted.
37
records of the Ministry within 6 working days from the day when he or she expressed his or her intention. 110
The authority which undertook registration shall issue a certificate of registration of the applicant in the
records of the Ministry.
The Border Directorate reported in 2018 that, according to Standard Operational Procedure (SOP) for
police in relation to the asylum procedure, police officers are not competent for assessing the reasons
why international protection is sought.111 In addition, in an official note which is sent to the competent
organisational unit of the Ministry, the police transmits information on the circumstances of irregular
migration as well as personal data referred to in Article 15 LITP which are essential for assessing if there
is a need for special reception and procedural guarantees e.g. for pregnant women, elderly, disabled
persons, unaccompanied children.
After having expressed the intention to seek international protection, the applicant is given a registration
certificate (potvrda o registraciji) which contains the following details: authority issuing the certificate; date
of issuance; name; date, place and country of birth; nationality; sex; place, address and time the person
is required to report to the Reception Centre for Applicants for International Protection to lodge the
application; signature of the official; and stamp.112
The certificate proves that the person is registered in the information system of the Ministry of Interior as
the applicant for international protection. The certificate shall be issued by the competent police
administration or police station and the Reception Centre for Foreigners if they registered a person as an
applicant in the information system. Exceptionally, the certificate may be issued by the Reception Centre
for Applicants for International Protection if they conducted registration.113
1.2. Lodging the application
After reporting to the Reception Centre for Applicants for International Protection, an applicant shall be
enabled to formally lodge an application as soon as possible and no later than 15 days from the
registration of his or her status in the records of the Ministry of Interior.114 The authority conducting
registration indicates in the registration certificate the time and place where the applicant has to report.
In certain cases, involving vulnerable persons or for other humanitarian reasons, applicants will be
accompanied by police officers to the Reception Centre for applicants for international protection.115
If, after having expressed the intention to apply for international protection, a foreigner does not report to
the Reception Centre for Applicants for International Protection without a justified reason, the Ministry of
Interior will ex officio discontinue the procedure;116 according to LITP it shall be deemed that the applicant
has withdrawn the application if he or she does not appear at the Reception Centre or avoids lodging an
application and fails to justify this within 2 days of the time limit set for appearing at the Reception Centre,
or for lodging an application.117
If the person is apprehended in an irregular situation once the deadline for an appeal has passed as well
as the deadline to leave the European Economic Area, the provisions of the Law on Foreigners will apply.
In particular, this means that the person will be considered to be an irregular migrant and will be detained
for the purposes of removal.
110
Article 33(9) LITP.
111
Information provided by the Border Directorate, 17 August 2018.
112
Article 3(2) Ordinance on the forms and data collection in the procedure for international and temporary
protection.
113
Article 3(3)-(5) Ordinance on the forms and data collection in the procedure for international and temporary
protection.
114
Article 34(2) LITP.
115
Information provided by the Ministry of Interior, 10 August 2018.
116
Information provided by the Ministry of Interior, 13 February 2018.
117
Article 39(2)(1) LITP.
38
The Reception Centre for Applicants for International Protection is the competent authority for conducting
interviews for the purpose of receiving applications for international protection. The application is usually
lodged at the Reception Centre for Applicants for International Protection, and only exceptionally outside
the Reception Centre within an appropriate period, depending on personal circumstances of the
applicant,118 for example where he or she is detained in the Reception Centre for Foreigners (pre-removal
detention centre), the Transit Reception Centre for Foreigners or in prison.
The procedure for international protection is initiated by lodging the application.119 In practice this means
that the application is submitted orally by the person seeking protection in front of the state officials of the
Reception Centre for Applicants for International Protection’. Officials will draft minutes of the interview.
The civil servants of the Reception Centre conduct a short interview to collect the following information:
personal data of the applicant, information on military service, family and other relations, information on
the journey from country of origin (type of transportation and route) and the reasons (in short) why they
fled their country of origin. All documents, including the minutes of the first interview, are then sent to the
Department for international protection procedure within the Ministry of Interior, which is responsible for
conducting a further substantive interview and examining the application.
Besides that, civil servants in the Reception Centre for Applicants for International Protection take
fingerprints and photos of the applicants, provide them with information on the procedures, their rights
and obligations, and issue the applicants’ identity card.
The Ministry of Interior informed the Croatian Law Centre that delays in the organisation of interviews for
the purpose of lodging applications for international protection occurred in 2018, in situations where
guardians were not appointed to unaccompanied children on time. According to the Ministry, the most
common cases where delays occurred were those where the competence of the Social Welfare Centre
had changed.120 No further information on this topic was provided by the Ministry for the period between
2019 and 2022.
After the application has been lodged, the applicant receives an international protection applicant card
(iskaznica tražitelja). The card shall be issued within three days from the lodging of the application and
confirms the right of residence in the Republic of Croatia until the completion of the procedure. An
applicant’s card does not constitute proof of identity.121 The card is not issued if the person applies at the
border.122 In 2022, applicants’ cards were issued to 2,520 persons.123
However, Croatia is still a transit country as it is estimated that majority of applicants for international
protection leave the country approximately very soon after expressing intention to apply for international
procedure. In 2020, the Ministry of Interior suspended a total of 1,674 cases for that reason. The trend
has continued in 2021 and 2022.
Out of the total number of expressed intentions to apply for international protection (12,872) in 2022, only
2,727 persons submitted application for international protection.124
High percentages (approximately 80% in the period June 2021-June 2022) of applicants leaving Croatia
soon after entering asylum system were reported by the independent monitoring mechanism.125
118
Article 34(3) LITP.
119
Article 34(1) LITP.
120
121
Article 62(1) LITP.
122
Article 62(2) LITP.
123
124
Croatian Law Centre, The Croatian Asylum System in 2022 - National Report; The report was prepared as
part of the project “Legal Assistance and Capacity Building for Access to Territory and Asylum in Croatia“, with
125
Interior in the area of illegal migration and international protection, June 2021 – June 2022, available in in
39
C. Procedures
1. Regular procedure
1.1. General (scope, time limits)
Indicators: Regular Procedure: General

1. Time limit set in law for the determining authority to make a decision on the asylum application
at first instance: 6 months
2. Are detailed reasons for the rejection at first instance of an asylum application shared with the
applicant in writing?126 Yes No
3. Backlog of pending cases at the end of 2022: Not available
4. Average length of the first instance procedure in 2022: Not available
The first instance decision can be a decision by which the Ministry of Interior:
- Grants asylum;
- Grants subsidiary protection;
- Rejects the application if the applicant does not meet the conditions for asylum and subsidiary
protection;
- Rejects the application if the conditions are met for exclusion;
- Rejects the application as manifestly unfounded;
- Dismisses an asylum application as inadmissible; or
- Suspends the procedure.
The Ministry of Interior’s Department for international protection procedure has the obligation to take a
decision on the application for international protection within 6 months from its lodging. If no decision can
be rendered within 6 months, the applicant shall be informed of this in writing and at his or her request
shall be provided with information about the reasons for the failure to respect the time limit and about the
time needed before which he or she may expect a decision. The 6-month time limit may be exceptionally
prolonged for additional 9 plus 3 months. It may be extended for a further 9 months if:
(a) The application includes complex facts and/or legal issues;
(b) A large number of third-country nationals or stateless persons are requesting international
protection at the same time; or
(c) The applicant, through his or her actions, contrary to his or her obligations as applicant, causes
the time limit to be extended.
However, this time limit may be extended for a further 3 months exclusively in order to ensure the complete
consideration of the application.127
At the beginning of 2019, the Ministry of Interior informed the Croatian Law Centre that they do not have
exact data on the duration of the first instance procedure as the Ministry does not keep such records, but
stressed that most of the cases are processed within the prescribed deadlines, which vary from 6 to 21
months according to the LITP. The Ministry also indicated that they do notify applicants when the decision
can be expected.128 In practice, procedures exceeding the 6-month period were observed in previous
years, but no information is available since 2019.
If it is justifiably to be expected that no decision will be rendered on the application within the time limits
referred above on account of the temporary unsafe situation in the country of origin, the Ministry shall
periodically verify the situation in the country of origin and inform the applicant and the European
126
Except for exclusion cases.
127
Article 40 LITP.
128
40
Commission within a reasonable time of the reasons for failure to render a decision. In that case, a
decision must be rendered no later than within 21 months from the day the application is lodged.129
1.2. Prioritised examination and fast-track processing
Applications by unaccompanied children are prioritised as specified by the LITP.130 Additionally, an

application which may be approved on the basis of the established facts also has priority in decision-
making.131
According to the Ministry of Interior, priority in the decision-making process is given unaccompanied
children and persons with special procedural or reception needs.
1.3. Personal interview
Indicators: Regular Procedure: Personal Interview

1. Is a personal interview of the asylum seeker in most cases conducted in practice in the regular
procedure? Yes No
 If so, are interpreters available in practice, for interviews? Yes No
2. In the regular procedure, is the interview conducted by the authority responsible for taking the
decision? Yes No
3. Are interviews conducted through video conferencing? Frequently Rarely Never
4. Can the asylum seeker request the interviewer and the interpreter to be of a specific gender?
Yes No
 If so, is this applied in practice, for interviews? No information
After a short initial interview conducted by the officials from the Reception Centre for Applicants for
International Protection for the purpose of lodging an application, a substantive interview is conducted by
the Department for international protection procedure of the Ministry of Interior. According to the LITP,
when the application has been lodged, the Ministry of Interior shall, as soon as possible, interview the
applicant. During the interview, the applicant is obliged to present all circumstances relevant to the
application for international protection, truthfully answer all questions, and submit all available evidence
to support the application, i.e. give credible and convincing explanations of all the reasons behind the
application for international protection.132
If possible, applicants shall be provided ex officio with a translator/interpreter of the same sex in order to
ensure a full explanation of the reasons for the application or for other justified reasons.133 However, there
is no information to what extent is this implemented in practice.
The interview may be omitted:

- When a positive decision on application may be taken on the basis of the available evidence;
- In cases when an applicant is unfit or unable to be interviewed, owing to enduring circumstances
beyond his or her control; or
- When the admissibility of a subsequent application is being assessed. 134
The Ministry of Interior reported at the beginning of 2019 that they do not keep records on cases in which
a decision was taken without an interview. This practice is likely to have continued, although official
information is not available.
129
Article 40 LITP.
130
Article 17(9) LITP.
131
Article 38(2) LITP.
132
Article 35(2) LITP.
133
Article 14(3) LITP.
134
Article 35(8) LITP.
41
The LITP provides that the applicant shall give reasons if they refuse to cooperate with the official
conducting the interview. The Ministry shall consider the reasons and shall inform the applicant orally for
the record of its decision.135
All interviews are conducted by the caseworkers of the Department for international protection procedure
within the Ministry of Interior, who are also responsible for taking decisions on the application.
1.3.1. Interpretation
Most applicants are interviewed in practice. According to the LITP, the presence of an interpreter during
the personal interview is required in case an applicant does not understand the language in which the
procedure is conducted.136 In practice this means that the interpreter is present in all cases, with the only
exception of those in which the applicant understands Croatian (for example when applicants were
nationals of a neighbouring country such as Bosnia and Herzegovina).
There is no specific code of conduct for interpreters in the context of procedure for international protection,
nor were standards prescribed in the past with regard to the qualifications of interpreters in the procedure
for international protection. The LITP prescribes conditions that have to be fulfilled in order for a contract
to be signed between the Ministry of Interior and an interpreter.137 The Ministry shall conclude an
agreement with a translator/interpreter if:
(a) It is assessed that he or she has good knowledge of the Croatian language in writing and speech;
(b) It is assessed that he or she has good knowledge of the language for which he or she is being
engaged;
(c) It is established that no circumstances exist that could represent a hindrance to employment in
the civil service pursuant to the regulations on employment in the civil service;
(d) It is established that no security hindrances exist after the conducting of a basic security check
pursuant to the regulations on security checks.
In addition, the interpreter must be reliable, impartial and must interpret truthfully and accurately. He or
she is obliged to act pursuant to the regulations governing the protection of personal data, and especially
may not disclose the data such as personal and other information collected during the procedure.
If for objective reasons it is not possible to provide an interpreter for a specific language, the Ministry of
Interior shall request assistance from another Member State of the European Economic Area.
Up to now, interpreters were not professionally trained and interpretation is not done by accredited
interpreters in the majority of cases. Many of them are native speakers, however some of them are not
fluent in the Croatian language. Usually, persons who simply possess the requested language skills are
contracted by the Ministry of Interior. Nevertheless, there is a lack of interpreters, especially for some
specific languages (such as Kurumanji and Tamil). In addition, applicants from African countries are often
interviewed in English or French, languages they are considered as being able to understand. Applicants
are asked at the beginning of the interview if they understand the interpreter.
Within the AMIF fund, in July 2020, the Directorate for European Affairs, International Relations and
European Union Funds adopted a Decision on the allocation of funds for the implementation of the project
"Interpretation and expansion of the network of interpreters in the procedure for granting international
protection".138
The LITP prescribes that interpretation can be provided by means of electronic telecommunications or
audio-visual equipment.
135
Article 35(6) LITP.
136
Article 14(2) LITP.
137
Article 13 LITP.
138
Decision on the allocation of funds for the implementation of the project "Interpretation and expansion of the
network of interpreters in the procedure for granting international protection", 13 July 2020, available in
Croatian at: https://bit.ly/3x39GyF.
42
1.3.2. Recording and transcript
During the interview, verbatim minutes of the interview are drafted. Once the interview is finished, the
interpreter translates the minutes to the applicant who then has a possibility to make corrections,
interventions, as well as to add information if needed. Generally, in practice, the quality of the minutes is
not considered problematic, although there were cases in the past in which minutes were not considered
to be of sufficient quality by the applicants. It also depends on the interpreter whether he or she
summarises the answers (which they should not do), or translates each sentence of the applicant (which
is how they should translate). By signing the minutes, the applicant agrees with the content of the
transcript.
1.4. Appeal
Indicators: Regular Procedure: Appeal

1. Does the law provide for an appeal against the first instance decision in the regular procedure?
Yes No
 If yes, is it Judicial Administrative
 If yes, is it suspensive Yes Some grounds No
2. Average processing time for the appeal body to make a decision: 181139
1.4.1. Appeal before the Administrative Court
Decisions of the Ministry of Interior may be challenged before the Administrative Court.140 According to
the law, the time limit for an applicant to lodge the lawsuit to the Administrative Court (which refers to the
“appeal”) in the regular procedure is 30 days after the delivery of the decision of the Ministry of Interior.141
In the Croatian Law Centre’s experience, there is no information specifying that applicants face obstacles
to appealing a decision in practice, although some issues arise with regard to legal assistance (see Legal
assistance).
Each asylum case is examined by a single judge. Judges are not specialised on asylum neither
specifically trained in asylum law, although from time to time some trainings are organised for judges
(usually by UNHCR and NGOs). As documented in the previous updates of this AIDA country report,
several trainings have been organised by the Croatian Law centre with the financial support of UNHCR
since 2016.
In 2022, the training of Administrative court judges, financially supported by UNHCR, was held. The topic
of the training was Administrative judicial protection of selected rights of applicants for international
protection and persons granted international protection. A total of 15 judges and judicial advisors from the
Administrative courts in Zagreb, Osijek and Rijeka and High Administrative Court participated at the
training.
The court holds a hearing in the presence of the applicant in the majority of cases. Exceptions may occur
when the applicant’s whereabouts are unknown. Interpreters are provided and paid by the state and
available during the administrative dispute. The hearings are not public. In 2021, the Law on
Administrative Disputes was amended introducing inter alia the possibility for the court to carry out the
hearing remotely through the use of appropriate audio-visual devices.142
139
This refers only to the average processing time at the Administrative Court of Zagreb in 2022. Waiting times
may vary at other Courts. Nevertheless, in 2022, 35 out of the 36 lawsuits were dealt by the Administrative
Court of Zagreb.
140
Article 32(2) LITP.
141
Article 24(1) Law on Administrative Disputes.
142
Article 37 paragraph 2 of the Law on Administrative Disputes prescribes that the hearing is, as a rule, held in
the court building. The court can determine that the hearing be held at a distance. No appeal is allowed against
this decision.
43
The Court can freely assess the evidence and establish the facts (requesting also further evidence if
needed) – without being bound by the facts established in the procedure of the Ministry of Interior – while
determining refugee status, although it takes them into account when deciding. Evidence, in terms of Law
on Administrative Disputes, includes in this case documents, interviews of the parties, experts' opinions
and findings and other means of collecting evidence, and the court presents it according to the rules for
presenting evidence in the civil procedure.143 In general, there is no time limit set in law for the
Administrative Court to make a decision in the regular procedure.
The outcomes of the administrative dispute can be that the lawsuit is dismissed as inadmissible (and
therefore not decided on the merits), rejected (i.e. decided negatively on the merits), or allowed. If the
lawsuit is allowed, the Court can either refer the case back to the Ministry of Interior for the review
procedure or it can change the decision by itself, meaning that the result is granting refugee or subsidiary
protection status. The court decisions are not publicly available.
Administrative Courts reported the following decisions in 2022:
Second instance decisions by Administrative Courts: 2022

Category Zagreb Rijeka Osijek Split Total
Accepted 0 0 0 0 0
Accepted - cases referred back to 4 0 0 0 4
the Ministry of Interior
Rejected 29 0 0 1 30
Suspended 1 0 0 0 1
Incompetence 0 1144 0 0 1
Case referred by other 1 0 0 0 1
Administrative court due to
incompetence
Total 35 1145 0 1 36146
Source: Administrative Court of Zagreb, 23 January 2023; Administrative Court of Rijeka, 31 January 2023;
Administrative Court of Osijek, 30 January 2023; Administrative Court of Split, 30 January 2023.
As indicated above, almost all appeals are dealt with by the Administrative Court of Zagreb and the large
majority of them were rejected in 2022.
The average processing time for asylum cases before Administrative Court in Zagreb was 77 days in
2021 and 181 days in 2022.
1.4.2. Onward appeal before the High Administrative Court
Applicants may lodge a further appeal against the Administrative Court decision before a High
Administrative Court. According to the Law on Administrative Disputes, the High Administrative Court
shall reject the appeal as unfounded and uphold the first-instance judgment (i.e. the judgment of the
Administrative Court) when determined that there are no reasons for the judgment to be challenged or
that the reasons do not affect the adoption of a different decision. In addition, the High Administrative
Court shall annul the first-instance judgment and shall solely remedy the deficiencies and resolve the
matter by issuing a judgment if it determines that the administrative court has committed a substantial
violation of the rules of court procedure, has erroneously or incompletely determined the factual state or
143
Article 33 Law on Administrative Disputes.
144
Administrative court in Rijeka reported that one case was received in 2022, but due to lack of jurisdiction, it
was referred to the competent Administrative Court in Zagreb for further proceedings.
145
This case is counted under 35 cases listed for Administrative Court in Zagreb.
146
The total number is reduced to 1 due to fact that Administrative Court in Rijeka referred the case to Zagreb.
44
has inaccurately applied the substantive law.147 This means that the High Administrative Court can decide
on the merits and can grant international protection.
This appeal, however, does not have suspensive effect.148 During 2022, the High Administrative Court
received 19 appeals in international protection cases:
Onward appeal statistics: 2022

Category Number
Appeals received 19
Appeals rejected 15
Accepted 3
Suspended 1
Total decisions 19
Source: High Administrative Court, 13 January 2023
As indicated above, the large majority of appeals were also rejected by the High Administrative Court.
1.5. Legal assistance
Indicators: Regular Procedure: Legal Assistance

1. Do asylum seekers have access to free legal assistance at first instance in practice?
Yes With difficulty No
 Does free legal assistance cover: Representation in interview
Legal advice
2. Do asylum seekers have access to free legal assistance on appeal against a negative decision
in practice? Yes With difficulty No
 Does free legal assistance cover Representation in courts
Legal advice
The right to free legal assistance in procedures is regulated by LITP. There is also a general procedure
and system of free legal aid which is regulated by the Law on Free Legal Aid, but applicants for
international protection can only benefit from this law in some procedures for which legal aid is not
provided for by the specific law (for example LITP).
1.5.1. Legal assistance at first instance
The LITP provides for the possibility of legal information and counselling at first instance procedure before
the Ministry of Interior.149 The LITP specifies that applicants should, at their request, be provided with legal
and procedural information on the approval of international protection, taking into account the
circumstances of the specific case, in a language which it may be reasonably be presumed that they
understand and in which they are able to communicate. The right to counselling should be provided by
organisations working to protect the rights of refugees or by attorneys with whom the Ministry shall
conclude an agreement on the provision of legal counselling. An applicant who has no financial resources
or things of significant value that enable him or her to have an appropriate standard of living shall have
the right to legal counselling.
A public call under the AMIF fund for legal aid providers was published by the Ministry of Interior in
September 2021.150 The Croatian Law Centre (CLC) was selected in 2022 as organisation responsible for
providing legal counselling at first instance until the end of 2022. The legal counselling activities entailed
147
Article 74 (1) (2) Law on Administrative Disputes.
148
Article 51(3) LITP.
149
Article 59(3)-(5) LITP.
150
Public call in Croatian available at: https://bit.ly/3pBuqeK.
45
provision of: general legal information related to the procedure for granting international protection, legal
information on the right to work and the right to free legal aid to applicants for international protection, legal
and procedural information on the granting of international protection related to the specific application for
international protection, information on stage of submitted application for international protection, the
explanation of reasons why the application for international protection was rejected and the possibility of
using a legal remedy. Under the project informative materials and brochures on the ways and conditions
of exercising the right to legal counselling were prepared, and a mobile application on the main features
of the procedure for granting international protection in the Republic of Croatia and the ways of exercising
the rights of applicants for international protection in practice was developed. The same information as in
mobile application, are available on web: https://rhprotection.mup.hr/hr/.
In 2022, CLC implemented the project "Legal Assistance and Capacity Building for Access to Territory
and Asylum in Croatia" with the role of implementing partner and with the financial support of the UNHCR.
The provision of legal information to targeted groups of beneficiaries including applicants for international
protection, was usually provided by telephone, mobile applications (WhatsApp) and e-mail or in CLC's
office.
In 2020 and 2021, CLC implemented the project “Croatian Lawyers Asylum Network (CALN), aimed at
building a network of lawyers who are working in the field of asylum and migration, financed through the
project “STEP UP Fond–capacity-building for NGO on refugee protection and inclusion” and led by the
Dutch Council for Refugees. The project ended on 31 May 2021. Within the mentioned project, an online
platform was launched with the aim of connecting all actors who provide legal assistance and support to
applicants for international protection and beneficiaries of international protection. The aim of the platform
is to use it as a virtual space for the exchange of legal opinions, practical challenges and problems
observed in legislation.
Centar for Peace Studies (CPS)151 also provided legal support to applicants for international protection
by telephone, mobile and e-mail or in CPS 's office.
1.5.2. Legal assistance in appeals
According to the LITP, free legal aid includes assistance in the preparation of a law suit to the
Administrative Court and representation before the Administrative Court i.e. in the first instance
administrative court disputes,152 if requested by the applicant and foreigner under transfer, under the
condition that they do not have sufficient financial resources or possessions of significant value.153 Legal
assistance may be provided by attorneys at law and lawyers from organisations registered for providing
legal assistance.154
In practice there are no obstacles to accessing attorneys, as applicants are informed about their right to
free legal assistance. In practice when a decision is delivered to applicants, they are also given the list of
providers of free legal aid from which they can choose an attorney or lawyer from NGO, who are then
notified by the Ministry of Interior. Attorneys and lawyers from NGO organise the interpreter for the
appointment and then inform the Ministry of Interior.
The Administrative Court shall decide on the right to free legal assistance, and the amount of costs of
legal assistance.155 According to the Ordinance on free legal aid, the Administrative Court decides on the
right to free legal assistance and takes into account the evidence on the financial status of the applicant,
which is obtained ex officio by the Ministry of Interior during the first instance procedure on the one side
and by compiling the form by the applicant on the other side. In practice that means that at the beginning
151
Information provided by Centre for Peace Studies, 18 January 2023.
152
Article 60(2) LITP.
153
Article 60(1) LITP.
154
Article 60(4) LITP.
155
Article 60(3) LITP.
46
of the first instance procedure, the applicant has to specify, by completing a form provided to them, if they
carry any valuables with them, which is rarely the case.
In previous years it was emphasised that this system of granting the right to legal aid at the end of the
procedure is unfair as the full burden and risk is shifted to the provider of free legal aid. If, for any reason,
the court does not endorse free legal aid, the provider will not receive anything and has completed the
work without payment. This is still considered problematic in 2020 as reported by one attorney,156 however
no such observations were reported in 2021 and 2022.
The High Administrative Court took the view that free legal aid under the LITP covers only the composition
of the lawsuit and the hearing, and not the composition of any further submissions which are sometimes
needed, which also means that for such legal actions attorneys are not reimbursed. 157 There is no
information available whether this practice has changed in the course of 2022.
Moreover, the appeal to the High Administrative Court is not covered by free legal aid under the LITP,
although it is a logical next step. In addition, the Attorneys Act requires from attorneys to continue
representing clients up to 30 days after the termination of the power of attorney, if there is a risk that a
client may be harmed. So since there is a contradiction between the provisions of the Attorneys Act and
the provisions of the LITP which regulate free legal aid, attorneys have to deal with this in a way that
prevents possible harm for a client and to proceed according to the Attorneys Act, which means that they
are writing and submitting appeals to the High Administrative Court, without being paid for their work.158
The LITP also states that the providers of free legal aid must inform the Ministry of Interior without delay
of the bringing of a lawsuit before the Administrative Court and the date of delivery of the Court’s judgment.
If a provider of legal assistance does not act in line with this obligation, the provider shall be deleted from
the List of Providers of Free Legal assistance.159 The Ordinance on free legal aid prescribes that the
provider should be first warned in writing and then deleted for the list if he or she has not complied with
this obligation.160
2. Dublin
2.1. General
In 2022, Croatia received 11,931 incoming Dublin requests according to the following categories: 8,636
request for re-acceptance (take back), 1,882 requests for the acceptance of responsibility (take charge),
618 requests for information, 743 requests for the reconsideration of requests for re-acceptance and 51
requests for reconsideration of requests for the acceptance of responsibility. The majority of incoming
requests came from Germany (5,054), Slovenia (2,687), Switzerland (1,212), France (1,121) and Belgium
(1,100). As for outgoing requests, in 2022, Croatia submitted 2,272 outgoing requests under the Dublin
Regulation in the following categories: 1,718 requests for reacceptance (take back), 241 requests for the
acceptance of responsibility (take charge), 254 requests for information, 36 requests for the
reconsideration of applications for reacceptance and 23 requests for reconsideration of requests for the
acceptance of responsibility. Most of the outgoing requests were sent to Greece (1,654), Bulgaria (188),
Germany (164) and Hungary (36).161
In 2022, only 1 outgoing Dublin transfer was carried out to Sweden, while Croatia received a total of 167
incoming transfers mainly from Germany (89), Austria (36), Switzerland (18), Slovenia (8) and France (5).
156
Information provided by an attorney-at-law, 26 January 2021.
157
158
159
Article 60(5) LITP; Article 11(8)-(9) Ordinance on free legal aid in the procedure of granting international
protection.
160
Article 11(8)-(9) Ordinance on free legal aid in the procedure of granting international protection.
161
financial support of UNHCR Croatia, available in English at: https://bit.ly/434T7RL.
47
Dublin statistics: 1 January – 31 December 2022
Outgoing Dublin transfers from Croatia Incoming Dublin transfers to Croatia

Total 1 Total 167
Sweden 1 Austria 36
Belgium 2
Denmark 2
France 5
Germany 89
Norway 4
Poland 1
Slovenia 8
Sweden 2
Switzerland 18
Source: Ministry of Interior, available at: https://bit.ly/3C0HJuR.
Application of the Dublin criteria
Croatia does not use any national legislation to incorporate the Dublin III Regulation, as it is directly
applicable, but refers to it in Articles 2 and 43 LITP, specifying that the application will be dismissed if the
responsibility of another Member State has been established. In that respect, the LITP does not establish
criteria to determine the state responsible, but the Ministry of Interior, when deciding on a case, simply
refers to the criteria listed in the Dublin Regulation. The Dublin procedure is applied whenever the criteria
listed in the Dublin Regulation are met.
In 2022,the most common criterion for both incoming and outgoing requests was Art. 18, para. 1, item
b) of the Dublin Regulation.162
In June 2020, a meeting was held between representatives of the Ministry of Interior and representatives
of the Ministry of Labour, Pension System, Family and Social Policy to improve cooperation in the
implementation of family reunification within the Dublin procedure.163 Following that, a standard operative
procedure (SOP) has been drafted to contribute to the coordination in process of family reunification of
unaccompanied minors.164 There is no information available as to whether it has been implemented in
practice in 2021 and 2022.
2.2. Procedure
Indicators: Dublin: Procedure

1. Is the Dublin procedure applied by the authority responsible for examining asylum applications?
Yes No
2. On average, how long does a transfer take after the responsible Member State has accepted
responsibility? Not available
Within the Department for international protection procedure, officials working within the Unit for Dublin
Procedure conduct Eurodac and Dublin procedures.
According to the information provided by the Ministry of Interior in January 2019, there are eight stationery
LiveScan machines for taking fingerprints for Eurodac purposes, two new and one old in the Reception
162
financial support of UNHCR Croatia, available in English at: https://bit.ly/434T7RL.
163
At the time of the meeting the name of the Ministry was still the Ministry for Demography, Family, Youth and
Social Policy
164
EMN, Bulletin number 31, August 2020, available at: https://bit.ly/3dy8fR4.
48
Centre for Applicants for International Protection in Zagreb (1 currently at Border Police Station in
Cetingrad in Police administration Karlovačka), one in the Reception Centre for Applicants for
International Protection in Kutina, one old and one new in the Reception Centre for Foreigners in Ježevo,
one in the Transit Reception Centre in Trilj, and one in Transit Reception Centre in Tovarnik. There are
also 24 portable devices: two in the Reception Centre for Applicants for International Protection in Zagreb
(1 currently at the Police station Donji Lapac in Police administration ličko-senjska), one in the Reception
Centre for Foreigners in Ježevo, one in the Transit Reception Centre in in Tovarnik, while other devices
are located in various police administrations and police stations on the Croatian territory. Since October
2017 fingerprinting is done through Eurodac LiveScan machines, which was the reason why portable
devices were located in all police administration centres. Only when an applicant or irregular migrant
cannot be brought to the police station or the device cannot be brought to the police station where the
person is located are fingerprints taken on paper and then scanned to Eurodac LiveScan or are
fingerprints taken by the officials in the Reception Centre for Applicants for International Protection once
person arrives there.165
Where fingerprinting is temporarily impossible due to medical or other reasons, fingerprints of an applicant
shall be taken as soon as those impediments cease to exist.166
The applicant who refuses to be fingerprinted without justified cause shall have his or her fingerprints
taken by police officers without his or her consent.167 This can also be a reason for the Ministry of Interior
to render a decision in an accelerated procedure (see section on Accelerated Procedure).168
According to the Ministry of Interior, applicants are informed about Dublin and Eurodac when they express
the intention to apply for international protection and during the interview for the purpose of lodging the
application for international protection.169 Information is available in Arabic, English, Farsi, French,
Croatian, Somali, Turkish, and Urdu.170 The Ministry of Interior does not provide a written translation of
the Dublin decision, but the decision is explained orally by the interpreter during its delivery in a language
that the applicant for international protection understands.
According to the Ministry of Interior, there have been changes in the practice in relation to the CJEU ruling
in Case C-670/16 Mengesteab. Authorities apply the Dublin procedure before application for international
protection is lodged i.e. from the registration of the intention to apply for international protection171 and the
3-month deadline for issuing a “take charge” request starts running from the moment they receive the
notification of registration of intention to apply for international protection by the police station (see
Registration), not from the moment the application is lodged. The deadline for a “take back” request is 2
months from the Eurodac “hit”.
Transfers
In practice, if another EU Member State accepts responsibility for the applicant, the time for the transfer
to the responsible Member State will depend on the circumstances of each case. According to the
information provided by the Ministry of Interior in 2018, the time between the day when another Member
State accepts responsibility and the transfer being made is approximately 2 months. 172 More recent
information is not available. Nevertheless, Dublin transfers were postponed due to COVID-19 in 2020.173
165
166
Article 33(6) LITP.
167
Article 33(7) LITP.
168
169
170
171
172
Information provided by the Ministry of Interior, 10 August 2018..
173
EMN, Special Annex to the 30th EMN Bulletin EU Member States & Norway: responses to COVID-19 in the
migration and asylum area, January – March 2020, available at: https://bit.ly/3sypjKV; Ombudsman, Annual
report 2020, available in Croatian at: https://bit.ly/3aaQXar.
49
As of 1 June 2021, incoming and outgoing transfers were re-established under the Dublin Regulation, the
implementation of which had been suspended in the previous period due to the COVID-19 pandemic.174
The transfer to the responsible Member State is organised by the Unit for Dublin procedure of the Ministry
of Interior, in cooperation with the receiving Member State. According to the Ministry of Interior, the
transfer is usually under escort of two police officers, or in cases of voluntary transfer of a minor it could
be arranged that a staff member of the Dublin Unit escorts the minor.175
On 13 April 2022, the Dutch Administrative Jurisdiction Division of the Council of State ruled that the IND
is obliged to do further research on the situation of applicants for international protection being transferred
to Croatia under the Dublin III Regulation. This is due to reports of frequent pushbacks (including of
applicants who are transferred to Croatia from another EU member state), which may result in a violation
of the principle of non-refoulement. On 30 May 2022, the Minister for Migration announced that until this
research is concluded, no Dublin transfers to Croatia will be carried out.176
In 2022, German Administrative Court of Stuttgart upheld an appeal against a Dublin transfer to Croatia
due to systemic deficiencies in the asylum procedure, characterised by the fact that applicants who have
withdrawn their application before an assessment on substance are treated as subsequent applicants
upon their return, which entails a risk of refoulement. The Court also suggested there may be systemic
deficiencies because of the frequent indications both of violent pushbacks and chain deportation of Dublin
returnees. 177
The Belgium Council of Alien Law Litigation in its two decisions in 2022 - 278 106178 and 278 108179
suspended Dublin transfers to Croatia due to structural deficiencies identified for what concerned the
asylum procedure and reception conditions, namely, absence of legal aid for part of the procedure and
absence of a screening process for torture victims.
In Switzerland, in the course of 2022, the Federal Administrative Court rejected several appeals against
Dublin transfers to Croatia .180 The Court considered that reception conditions, although not perfect, were
acceptable and that in case they were not applicants could revert to NGOs and courts for help. Cases of
mistreatment by border guards were considered as individual isolated acts rather than proof of patterns
of violation of international law by Croatia or of a general will to mistreat migrants; medical infrastructure
was considered similar to that of Switzerland and any deficiencies could be mitigated thanks to support
from NGOs and by the fact that Swiss authorities would inform Croatia of medical needs of the applicants.
Indicators: Dublin: Personal Interview

Same as regular procedure
1. Is a personal interview of the asylum seeker in most cases conducted in practice in the Dublin
procedure? Yes No
There is no special interview conducted in the Dublin procedure, since questions relevant to that
procedure are part of the interview when expressing the intention to apply for international protection
174
EMN Bulletin Number 35, April – June 2021, available at: https://bit.ly/3IEjUup.
175
Ibid.
176
EMN, Bulletin n.39, April-June 2022, available at: https://bit.ly/4047pBf.
177
Administrative Court of Stuttgart :Decision A 16 K 360/22,available at: https://bit.ly/3NgKDlT.
178
Available at: https://bit.ly/3qnlZa3.
179
Available at: https://bit.ly/3ONIgIc.
180
Federal Administrative Court: F-3903/2022 available at: https://bit.ly/3MCrVU4; F-5089/2022 available at:
https://bit.ly/42mmE8W; E-4341/2022 available at: https://bit.ly/3IPdavY.
50
before the police, and also of the first interview that is conducted by the officials of the Reception Centre
for Applicants for international protection upon the lodging of the application.
If there are elements in connection with the Dublin procedure which were not mentioned in the application,
for instance there is a Eurodac hit and the applicant has not mentioned that he or she was in another
Member State, an additional interview can be conducted.
The same procedural rules as for the regular procedure apply during this part of the procedure, and the
same guarantees as for the first interview in the regular procedure will apply (see section on Regular
Procedure: Personal Interview).
2.4. Appeal
Indicators: Dublin: Appeal

1. Does the law provide for an appeal against the decision in the Dublin procedure?
Yes No
 If yes, is it suspensive Yes No
The decision on the transfer includes the grounds for the application of the Dublin Regulation and
information on how to lodge a lawsuit against the decision. The lawsuit, for which applicants receive free
legal assistance, must be lodged before the Administrative Court within 8 days from the delivery of the
decision.181
The courts and their judges are not specialised in asylum cases. The court examines the lawfulness of
the Dublin decision. A personal hearing can be omitted on the decision of the judge: therefore in some
cases the oral procedure is conducted in absentia (with only the legal representative present). In Dublin
cases, it happens when the complainant disputes only the application of the law and not the facts of the
case, and the parties have not made a request for a hearing to be held. However according to the
knowledge of the Croatian Law Centre, in practice hearings are held in Dublin cases as well.
Complaints have suspensive effect. According to the information available to the Croatian Law Centre, in
the past the courts did not always take into account the level of reception conditions, 182 the procedural
guarantees and the recognition rates in the responsible Member State when reviewing the Dublin
decision. In 2021, there was one case in which the Administrative Court referred the case back to the
Ministry of Interior as it failed to take into account the individual circumstances of the client in the
administrative procedure, and it did not thoroughly assess the situation in Greece to which the transfer
was ordered. 183
There is no publicly available data on how many Dublin decisions on transfers to other Member States
were actually challenged before the Administrative Court since Croatia became an EU Member State.
Therefore, no conclusions can be drawn on whether the Administrative Court takes into account the
conditions and guarantees in the responsible Member state when reviewing the Dublin decision. The
Administrative Court in Zagreb reported that information on Dublin cases should not be entered in the
“eSpis” application (an application used by courts), so no information is available on Dublin Cases before
the Administrative Court in Zagreb in 2021 and 2022. 184
181
Article 43(3) LITP.
182
Information provided by the attorney at law, 21 January 2020.
183
Information provided by the attorney at law, 11 January 2022.
184
Information provided by the Administrative Court in Zagreb, 31 January 2022.; 23 January 2023.
51
Indicators: Dublin: Legal Assistance

Yes With difficulty No185
Legal advice
2. Do asylum seekers have access to free legal assistance on appeal against a Dublin decision in
practice? Yes With difficulty No
Legal advice
The same rules as in the regular procedure apply for access to free legal assistance during the Dublin
procedure, meaning that free legal aid includes assistance in the preparation of the lawsuit and
representation before the Administrative Court,186 if requested by the applicant.
2.6. Suspension of transfers
Indicators: Dublin: Suspension of Transfers

1. Are Dublin transfers systematically suspended as a matter of policy or jurisprudence to one or
more countries? Yes No
 If yes, to which country or countries?
After accessing the EU, Croatia suspended transfers of applicants for international protection to Greece.
Where there was no responsible Member State other than Greece, in previous years Croatia took
responsibility for the examination of the asylum application. However, from data provided by the Ministry
of Interior, it can be inferred that this changed in 2017. The Ministry of Interior reported that, according to
the Commission Recommendation of 8 December 2016, the Dublin Unit began sending requests to
Greece in cases where, under the conditions of the Dublin Regulation, it was found out that Greece is
responsible for examining an application for international protection. According to their information until
August 2018, all received answers were negative and no transfer has been carried out since 15 March
2017.187 Although, no such information is available for 2022, in 2022 the highest number of outgoing
requests were sent to Greece (1.654). 188
As for transfers to Croatia, the Swiss Federal Administrative Court issued a reference judgment ordering
the determining authority to examine the existence of systemic deficiencies and the general situation in
Croatia in 2019. Since then, some cases were sent back to the determining authority for further
clarification, e.g. regarding access to healthcare for single men, while other cases involving families with
health issues were rejected. The Swiss Court generally takes into consideration reports of push-backs, in
particular in the context of ”take charge” cases because the applicant needs to have access to the asylum
procedure. In the context of “take back” requests, i.e. where an application for international protection has
already been lodged, it is generally assumed that the applicant will not be pushed back. Diverging opinions
have also been reported in the Netherlands. While the Regional Court Den Bosch ruled in 2020 that the
principle of mutual trust no longer stands with Croatia due to extensive evidence of push-backs, the
Council of State considered in July 2021 that the principle of mutual trust should apply to transfers to
Croatia.189
185
State funded free legal aid for applicants for international protection before the Ministry of Interior ended on 31
March 2020.
186
Article 60(2) LITP.
187
188
189
ECRE, The implementation of the Dublin III Regulation in 2020, September 2020, available at:
https://bit.ly/3xfv1an.
52
On 13 April 2022, the Dutch Administrative Jurisdiction Division of the Council of State ruled that the IND
is obliged to do further research on the situation of applicants for international protection being transferred
to Croatia under the Dublin III Regulation. This is due to reports of frequent pushbacks (including of
applicants who are transferred to Croatia from another EU member state), which may result in a violation
of the principle of non-refoulement. On 30 May 2022, the Minister for Migration announced that until this
research is concluded, no Dublin transfers to Croatia will be carried out.190
2.7. The situation of Dublin returnees
Applicants who are returned from other Member States in principle do not face any obstacles in accessing
the procedure for granting international protection in Croatia. However, those who had left Croatia before
the end of procedure and therefore had their case suspended, have to re-apply for international procedure
(if they wish) once they return to the country, and thereby re-enter their initial procedure, in line with Article
18(2) of the Dublin III Regulation. On the other hand, persons whose application was explicitly withdrawn
or rejected before leaving Croatia are considered subsequent applicants upon return, contrary to the
requirements of the Regulation.191
According to the report prepared by the Swiss Refugee Council, Dublin returnees are transferred to
Zagreb airport. No NGO is available at the airport, even though for very serious cases, a psychologist
may be made available. Normally, an official from the Ministry of the Interior is assigned to collect arriving
people at the airport. Asylum seekers are placed in a Reception centre for applicants for international
protection. There is no different treatment or procedure for persons with special vulnerabilities. In
reception centres, Dublin returnees are in general subjected to initial health examination and screening,
during which basic screening of mental health difficulties are assessed. This is conducted through MdM.
According to their information, the outcome of this assessment may be shared with the Ministry of Interior,
if the patient agrees with it. This is the case especially if special needs regarding the accommodation
become apparent.192
As for the transfers to Croatia, national courts developed different practices in the evaluation of the
conditions that returnees would face in the country (see more above under: Suspension of transfers).193
3. Admissibility procedure
3.1. General (scope, criteria, time limits)
No specific procedure is designated as “admissibility procedure” in Croatia. However, it is possible for the
Department for International Protection procedure to take a decision without entering into a further in-
depth examination of the application (i.e. an examination on the merits) when the grounds for the dismissal
of the application are met.
An application will be dismissed where:194

(1) The applicant has been granted international protection in another member state of the European
Economic Area;
(2) The applicant has been granted international protection in a third state whose rights he or she
still enjoys, including the guarantees stemming from non-refoulement, provided that he or she will
be received back into that state;
(3) It is possible to apply the concept of Safe Third Country;
(4) It is possible to apply the concept of European safe third country;
190
EMN, Bulletin n.39, April-June 2022, available at: https://bit.ly/4047pBf.
191
ECRE, Balkan route reversed, December 2016, 30.
192
Swiss Refugee Council, Situation of asylum seekers and beneficiaries of protection with mental health
problems in Croatia, available at: https://bit.ly/3DZ09MS.
193
ECRE, The implementation of the Dublin III Regulation in 2020, September 2020, available at:
https://bit.ly/3xjuHYr.
194
Article 43(1) LITP.
53
(5) The responsibility of another member state of the European Economic Area is established to
consider the application; or
(6) The application was lodged by a national of a member state of the European Union.
There are no specific time limits that must be respected by the Ministry of Interior in the first instance
procedure for delivering a dismissal decision, and the rules governing the regular procedure are
applicable.
In case of a subsequent application,195 the admissibility of the application shall be assessed on the basis
of the facts and evidence it contains, and in connection with the facts and evidence already used in the
previous procedure. If it is established that the subsequent application is admissible, a decision shall be
rendered once again on the merits of the application, and the previous decision would be revoked.
The subsequent application would be dismissed if it is established that it is inadmissible i.e. if the
subsequent application is not understandable and does not contain relevant facts and evidence which
arose after decision became final or which the applicant for justified reasons did not present during the
previous procedure relating to establishing the meeting of the conditions for approval of international
protection (see section on Subsequent Applications).
In 2021, the Ministry of Interior dismissed the cases of 105 applicants on the basis of Art. 43, para. 1, item
1 of the LITP (granted international protection in another EEA Member State), for 82 applicants based on
Art. 43, para 1, item 5 of the LITP (established responsibility of another EEA Member State to consider
the application), for one applicant on the basis of Art. 43, para. 1, item 6 of the LITP (application submitted
by a national of an EU Member State) and for 28 applicants based on Art. 43, para. 2 of the LITP (dismissal
of a subsequent application if it is determined that such an application is inadmissible in accordance with
Article 47, para. 6 of the LITP).196
In 2022, the cases in which the Ministry of Interior dismissed the applications on the grounds of
inadmissibility are as follows: for one applicant, the decision was made on the basis of Art. 41, para. 2 of
the Law on General Administrative Procedure (lack of legal preconditions to initiate the proceeding), for
35 applicants on the basis of Art. 43, para. 1, item 1 of the LITP (granted international protection in another
EEA Member State), for 29 applicants based on Art. 43, para 1, item 5 of the LITP (established
responsibility of another EEA Member State to consider the application), and for 10 applicants on the
basis of Art. 43, para. 2 of the LITP (dismissal of a subsequent application if it is determined that such an
application is inadmissible in accordance with Article 47, para. 6 of the LITP, i.e. that the subsequent
application is not comprehensible or does not contain the relevant facts and evidence which arose after
the finality of the decision or which the applicant for justified reasons did not present during the previous
procedure relating to establishing the meeting of the conditions for approval of international protection. 197
195
Article 47 LITP.
196
building” with the financial support of the UNf the UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and
in English at: https://bit.ly/3NBvVpC.
197
54
Indicators: Admissibility Procedure: Personal Interview

1. Is a personal interview of the asylum seeker in most cases conducted in practice in the
admissibility procedure? Yes No
 If so, are questions limited to identity, nationality, travel route? Yes No
The interview is conducted by the Ministry of Interior (i.e. by decision makers from the Department for
International Protection Procedure). According to the LITP, the personal interview would not be
undertaken if the admissibility of a subsequent application is being assessed. 198 In such cases, usually
only the applicant makes the application in writing i.e. fills in form stating the reasons for subsequent
application and explaining why those reasons were not mentioned in the previous procedure.
3.3. Appeal
Indicators: Admissibility Procedure: Appeal

1. Does the law provide for an appeal against an inadmissibility decision?

Yes No
According to the LITP the deadline for appealing a dismissal decision before the Administrative Court is
8 days after the delivery of the decision of the Ministry of Interior.199
As for suspensive effect, the LITP provides all lawsuits with suspensive effect, except for lawsuits against
dismissal decisions on “first country of asylum” grounds where the applicant has refugee status in another
country or when a subsequent application is dismissed. 200
Indicators: Admissibility Procedure: Legal Assistance

Legal advice
2. Do asylum seekers have access to free legal assistance on appeal against an inadmissibility
decision in practice? Yes With difficulty No
Legal advice
Regarding free legal assistance in “inadmissible” cases, the general provisions about the right and access
to free legal assistance apply, meaning that free legal aid in terms of representation is not foreseen in the
first instance procedure, but only in the preparation of a lawsuit to the Administrative Court, including
198
199
Article 43(3) LITP.
200
Article 51(1)(2)-(3) LITP, citing Article 43(1)(1)-(2) and Article 43(2) LITP.
55
representation before the Administrative Court,201 if requested by the applicant (see section on Regular
Procedure: Legal Assistance).
4. Border procedure (border and transit zones)
4.1. General (scope, time limits)
Indicators: Border Procedure: General

1. Do border authorities receive written instructions on the referral of asylum seekers to the
competent authorities? Yes No
2. Where is the border procedure mostly carried out? Air border Land border Sea border
3. Can an application made at the border be examined in substance during a border procedure?
Yes No
4. Is there a maximum time limit for a first instance decision laid down in the law? Yes No
 If yes, what is the maximum time limit? 4 weeks
5. Is the asylum seeker considered to have entered the national territory during the border
procedure? Yes No
The LITP foresees a border procedure. Two Transit Centres for Foreigners were built and opened in 2017,
one in Tovarnik at the border with Serbia and another in Trilj near the border with Bosnia and
Herzegovina.
At the moment, the border procedure provided under the LITP does not take place in those two centres.
According to information provided by the Ministry of Interior at the beginning of 2019, it was still not clear
when the implementation of the border procedure would start.202 However, no information is publicly
available on whether this has changed from 2019 to the end of 2022. Thus, there is currently no border
procedure in Croatia according to the knowledge of the Croatian Law Centre.
According to the LITP, the border procedure would be applicable for the foreigner who expresses intention
of lodging an application or make subsequent application at a border crossing point or in a transit zone of
an airport, sea port or internal water port, provided that the following conditions are met:
- The applicant is provided with material reception conditions; and

- The application or subsequent application may be rejected as manifestly unfounded if the
applicant does not meet the conditions for asylum or subsidiary protection and conditions are met
for the accelerated procedure to be conducted, or the application or subsequent application may
be dismissed as inadmissible.203
However, if a decision concerning the application is not issued within the period of 28 days from the day
of the lodging of the application for international protection, the applicant would be permitted entry to the
Republic of Croatia with a view to conducting the regular procedure.204
As it is unclear whether border procedures are conducted at the moment, no information can be provided
on personal interviews.
201
Article 60 LITP.
202
Information provided by the Ministry of Interior, 2 March 2017; 13 February 2018; 28 January 2019.
203
Article 42(1) LITP.
204
56
4.3. Appeal
Indicators: Border Procedure: Appeal

1. Does the law provide for an appeal against the decision in the border procedure?
Yes No
The border procedure is foreseen by the LITP, but is unknown whether it is applied in practice. By law
lawsuits against decisions in the border procedure have suspensive effect,205 and are subject to shorter
time limits: a lawsuit to the Administrative Court against a decision of the Ministry of Interior made in the
border procedure must be lodged within 5 days from the day of the delivery of the decision. The Ministry
shall deliver the case file no later than 8 days from the day of receipt of the decision by which the
Administrative Court requests the case file. The Administrative Court shall render a judgment within 8
days from the day of receipt of the case file.206
Indicators: Border Procedure: Legal Assistance

Legal advice
Legal advice
According to the LITP, applicants in all types of procedures shall have access to free state funded legal
aid in the preparation of a lawsuit to the Administrative Court, including representation before the
Administrative Court where requested by the applicants. However, this could be restricted, as the LITP
allows the possibility to temporarily restrict access to those locations (and therefore to applicants
accommodated there) for the applicant’s legal representative or a representative of an organisation
engaged in the protection of refugee rights, other than UNHCR, when it is necessary for the protection of
the national security and legal order of the Republic of Croatia.207
5. Accelerated procedure
5.1. General (scope, grounds for accelerated procedures, time limits)
According to the LITP the Ministry shall take a decision in an accelerated procedure where:208
1. The applicant has presented only facts which are irrelevant to an assessment of the merits of the
application;
2. The applicant has consciously misled the Ministry by presenting false information or unreliable
documents, or by not providing relevant information or by concealing documents which could
have had a negative effect on the decision;
3. The applicant in bad faith has probably acted and destroyed documents that establish identity
and/or nationality with the aim to provide false information about his or her identity and/or
nationality;
205
Article 51(1) LITP:
206
Article 42(6) LITP.
207
Article 42(3) LITP.
208
Article 41(1) LITP.
57
4. The applicant has presented inconsistent, contradictory, manifestly inaccurate or unconvincing
statements contrary to the verified information on the country of origin, rendering his/her
application unreliable;
5. A subsequent application is admissible;
6. The applicant has already resided for a longer period of time in the Republic of Croatia and for
no justifiable reason failed to express his or her intention to apply for international protection
earlier;
7. The applicant expressed the intention to apply for international protection for the clear purpose of
postponing or preventing the enforcement of a decision which would result in his or her expulsion
from the Republic of Croatia;
8. The applicant represents a risk for the national security or public order of the Republic of Croatia;
9. It is possible to apply the concept of Safe Country of Origin; or
10. The applicant has refused to give fingerprints.
The Department for International Protection Procedure within the Ministry of Interior is responsible for
taking decisions in accelerated procedures. The LITP has set a 2-month deadline for completing the
accelerated procedure, failing which the claim is transferred to the regular procedure.209
In 2021, a total of 57 applicants for international protection whose applications were processed in an
accelerated procedure were registered (Morocco - 24, Tunisia - 17, Algeria - 10, Bosnia and Herzegovina
- 2, Albania - 1, Kosovo - 1, Türkiye - 1, United Arab Emirates - 1).210
In 2022, a total of 14 applicants for international protection whose applications were processed in an
accelerated procedure were registered (nationals of Morocco, Albania, Kosovo, Serbia and Türkiye). In
13 cases MoI rejected them as clearly unfounded.211
Indicators: Accelerated Procedure: Personal Interview

1. Is a personal interview of the asylum seeker in most cases conducted in practice in the
accelerated procedure? Yes No
 If so, are questions limited to nationality, identity, travel route? Yes No
The same provisions from the LITP on the personal interview in a regular procedure apply to the one in
accelerated procedures. That means that the interview in accelerated procedure is not held only in specific
cases prescribed by the LITP, i.e. when:
- A positive decision on application may be taken on the basis of the available evidence;
- In cases when an applicant is unfit or unable to be interviewed, owing to enduring circumstances
beyond his or her control; or
- The admissibility of a subsequent application is being assessed.212
The Department for International Protection Procedure of the Ministry of Interior is responsible for
conducting the interviews and taking a decision.
209
Article 41(1) LITP.
210
building” with the financial support of the UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and in English
at: https://bit.ly/3NBvVpC.
211
212
Article 35(8) LITP.
58
5.3. Appeal
Indicators: Accelerated Procedure: Appeal

1. Does the law provide for an appeal against the decision in the accelerated procedure?
Yes No
The Administrative Court is the competent appeal body in the accelerated procedure, so there is no
difference in the authority responsible for handling the lawsuit compared to regular procedure. However,
time limits are shorter: a lawsuit may be lodged to the Administrative Court within 8 days from the delivery
of the decision of the Ministry of Interior.213
Moreover, lawsuits against negative decisions in the accelerated procedures do not have suspensive
effect.214 The applicant can apply for suspensive effect, which the Court has to decide on within 8 days
from the receipt. However, lawsuits against decisions in cases where the applicant has already resided
for a longer period of time in the Republic of Croatia and for no justifiable reason failed to express his or
her intention to apply for international protection earlier never have suspensive effect i.e. there is no
possibility to request suspensive effect.215
Indicators: Accelerated Procedure: Legal Assistance

Legal advice
Legal advice
The same provisions from the LITP as regards access to free legal assistance for applicants in the regular
procedure for international protection apply for access to free legal assistance during an accelerated
procedure, meaning that free legal aid includes assistance in the preparation of a lawsuit to the
Administrative Court and representation before the Administrative Court, if requested by the applicant
(see section on Regular Procedure: Legal Assistance).
213
Article 41(5) LITP.
214
215
Article 51(1)(2) LITP, citing Article 41(1)(6) LITP.
59
D. Guarantees for vulnerable groups of asylum seekers
1. Identification
Indicators: Identification
1. Is there a specific identification mechanism in place to systematically identify vulnerable asylum
seekers? Yes For certain categories No
 If for certain categories, specify which:
2. Does the law provide for an identification mechanism for unaccompanied children?
Yes No
According to the LITP, vulnerable groups include persons without legal capacity, children, unaccompanied
children, elderly and infirm persons, seriously ill persons, disabled persons, pregnant women, single
parents with minor children, persons with mental disorders and victims of trafficking, as well as victims of
torture, rape or other forms of psychological, physical and sexual violence, such as victims of female
genital mutilation.216
1.1. Screening of vulnerability
The LITP has introduced special procedural and reception guarantees.217 It specifies that appropriate
support must be provided to applicants in relation to their personal circumstances, amongst other things
their age, gender, sexual orientation, gender identity, disability, serious illness, mental health, or as a
consequence of torture, rape or other serious forms of psychological, physical or sexual violence, for the
purpose of exercising the rights and obligations from the LITP. The procedure of recognising the personal
circumstances of applicants shall be conducted continuously by specially trained police officers,
employees of the Ministry of Interior and other competent bodies, from the moment of the expression of
intention to apply for international protection until the delivery of the decision on the application.
At the moment, there is no further detailed guidance available in the law, nor an early identification
mechanism in the form of internal guidance.
Early identification is conducted in accordance with the Article 15 LITP at the moment of the expression
of intention to apply for international protection by the police officers. Police then accordingly inform the
Reception Centre for Applicants for International Protection and further identification during the procedure
for international protection is done by social workers of the Reception Centre as well as employees of
NGOs with which the Ministry has cooperation agreements and who come into first contact with applicants
when they arrive in the centres.218 Less evident vulnerabilities such as those relating to victims of torture
or trauma, victims of trafficking or LGBTI persons are much less likely to be identified in current practice.219
The Rehabilitation Centre for Stress and Trauma (RCT) reported the lack of mental health prevention and
non-availability of psychiatric facilities with an interpreter.220 However, in April 2021, a Standard
Operational Procedure (SOP) in Cases of Sexual and Gender-Based Violence (SGBV) in the Reception
Centres for Applicants of International Protection entered into force. The latter was developed in
cooperation with the Ministry of Interior, UNHCR, IOM, MDM-BELGIQUE, the Croatian Red Cross and
the Croatian Law Centre. SOP contain procedures, roles, and responsibilities of service providers involved
in the prevention and response to SGBV in the reception centres.
Regular meetings of involved organisations and the Ministry of Interior are held few times each year to
discuss current trends, statistical data, actions taken to strengthen prevention of further violence and
ensure adequate support for victims, actions that will be taken in coming period, annual reports on SGBV,
the method of data collection and their purpose, etc.
216
217
Article 15 LITP.
218
219
Ibid, 24.
220
Information provided by Rehabilitation Centre for Stress and Trauma, 18 January 2023.
60
In 2022, three meetings of the Coordination Group for Sexual and Gender-Based Violence were held to
discuss recorded data on the number of cases of sexual and gender-based violence reported in receptions
centres for applicants for international protection and to evaluate the efficacy of the Standard Operating
Procedure for prevention and response in the case of sexual and gender-based violence in reception
centres for applicants for international protection in Croatia.221
The Croatian Red Cross (CRC) provides psychosocial and practical support and assistance to applicants
for international protection in Reception Centres for Applicants for International Protection, based on the
identified needs of individuals and families. CRC identifies vulnerable groups (children, unaccompanied
children, the elderly, single women, people with physical and mental disabilities, people who have
experienced trauma or torture, potential victims of trafficking, victims of domestic violence) and plans work
tailored to their specific needs.222
Unaccompanied children
The Government adopted a Protocol on the treatment of unaccompanied children on 30 August 2018. 223
The protocol aims to improve the position of unaccompanied children, provides a detailed overview of all
procedures and provides guidance for all relevant actors coming in contact and working with this category
of children. The Protocol elaborates in 14 chapters on the various issues in regard to unaccompanied
children. According to the Ministry of Interior, an Interdepartmental Commission for the protection of
unaccompanied children has been established. The Commission was established with the aim to improve
inter-agency cooperation between state administration bodies and other stakeholders involved in the
protection of unaccompanied children. The Commission is composed of representatives of the Ministry of
Labour, Pension System, Family and Social Policy, the Ministry of the Interior, the Ministry of Science and
Education, the Ministry of Health, the Office for Human Rights and Rights of National Minorities and
international organisations dealing with the protection of the rights of the child or refugee rights and, civil
society organisations dealing with the protection of children's rights.
On 1 January 2019, the new Law on Foster Care entered into force, which provides for the possibility of
unaccompanied children staying in a foster family.224 According to the Ombudsperson for Children, this
possibility was not used in 2020,225 while in 2021, 3 unaccompanied children were placed in foster
families226 In 2022, only one accommodation in foster family took place.227
In 2022, 329 unaccompanied children were accommodated in reception centres for applicants of
international protection, and 107 in social care homes.228
In May 2019, the coordinating body of the Interdepartmental Commission for unaccompanied minors held
a meeting that was attended by representatives of the competent central authorities of the State
administration and other stakeholders involved in the protection of unaccompanied children.229 UNICEF
reported that they participated in the work of Commission which met twice during 2019, however without
significant and concrete results.230 In 2020, the Commission met once to discuss the relocation of children
from Greece and to plan future activities relating to the protection of unaccompanied children. However,
that did not result in a significant change in the quality of protection unaccompanied children or in
221
222
Croatian Red Cross, Annual report for 2022, available at: https://bit.ly/3MNYjmG, 77.
223
Protokol o postupanju prema djeci bez pratnje, 30 August 2018, available in Croatian at:
https://bit.ly/2DEgBEu.
224
225
Ombudsperson for Children: Report on the work of the Ombudsman for Children in 2020, March 2021,
available online as of 7 April 2021 at: https://bit.ly/32B5hEQ.
226
It is not clear whether they were applicants for international protection. Ombudsperson for Children: Report
on the work of the Ombudsman for Children in 2021, available in Croatian: https://bit.ly/3jonKNp.
227
Ombudsman for children report for 2022, available in Croatian at: https://bit.ly/43C5ZPL.
228
229
EMN, Bulletin, July 2019 available at: https://bit.ly/39MwSV1.
230
Information provided by UNICEF, 8 January 2020.
61
productive proposals for improving the position of unaccompanied children in Croatia. Also, experts from
institutions where unaccompanied children are accommodated do not participate in the work of the
Commission and they are mostly acquainted with the problems of these children. The cooperation of the
Commission and institutions is only triggered in crisis situations when there is a lack of capacity so it is
necessary to find additional accommodation for unaccompanied children.231 According to the
Ombudsperson for Children, the Commission for unaccompanied minors did not meet in 2021.232 A new
commission was established by a decision of the Government of the Republic of Croatia on 5 January
2022.233 The decision states that the goal of the Commission is to improve the interdepartmental
cooperation of competent authorities and other stakeholders involved in the protection of unaccompanied
children.
At the 115th session of government held on 27 April 2022, the Croatian Government adopted a Decision
on the appointment of a representatives of the Interdepartmental Commission for the Protection of
Unaccompanied Children,234 in accordance with the Protocol on the Treatment of Unaccompanied
Children. The first session was held on 24 May 2022 at the Ministry of Labour, Pension System, Family
and Social Policy.235
According to the Ombudswoman for Children, the new Commission met twice in the course of 2022 to
discuss the following topics: children from Ukraine, difficulties in including unaccompanied children in the
education system, accommodation of children in social care homes for children with behavioural
problems, appointment of special guardians, assessment of children's age and initial health
examination.236
On the World Refugee Day, in 2022, the Ombudsperson for Children and UNHCR organized a joint Round
Table entitled “Protection of Asylum Seeker, Refugee, and Stateless and at-risk Children in Croatia:
Current issues and the way forward,” in Zagreb. The event served to emphasize key positive
developments and areas for improvement in the child protection system in Croatia.237
In 2021, the Ministry of Interior and the Ministry of Labour, Pension System, Family and Social Policy
issued Instruction on the Treatment of Unaccompanied Children, which was disseminated to the MoI
Border Directorate, police administrations and stations and centres for social welfare.238
In 2021, Centre for Peace Studies, Rehabilitation Centre for Stress and Trauma, together with an
independent expert prepared a Policy brief on the protection of unaccompanied children in the Republic
of Croatia.239 Based on the analysis of the current situation, the following recommendations for
improvement of the system of protection of unaccompanied children were given: to develop a new
National Strategy for the Rights of the Child, to develop a Plan for capacity building of alternative care
for unaccompanied children, to establish uniform records and consistent and systematic collection and
recording of data on unaccompanied children in the Republic of Croatia, to encourage and support
advocacy activities of CSOs and the entire professional community, aimed at raising public awareness
on the needs of unaccompanied children and improving cultural competencies and sensitivity of the
professional and general community and to develop a new Migration Policy.
231
Ombudsperson for Children: Report on the work of the Ombudsman for Children in 2020, March 2021,
available online as of 7 April 2021 at : https://bit.ly/32B5hEQ
232
https://bit.ly/3LW66Nf.
233
Government of the Republic of Croatia, Decision on the establishment of the Interdepartmental Commission
for the Protection of Unaccompanied Children, available in Croatian at: https://bit.ly/3JuF1Pu.
234
Decision on the appointment of the president, deputy president, secretary, members and deputy members of
the Interdepartmental Commission for the Protection of Unaccompanied Children, Official Gazette 52/2022,
available at: http://bit.ly/3K4rMIX.
235
EMN, Bulletin n. 39, April - June 2022, available at: https://bit.ly/4047pBf.
236
237
238
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/3rcoPfF.
239
Policy brief on the protection of unaccompanied children in the Republic of Croatia, available at:
https://bit.ly/3E3FpTX.
62
In June 2021, the Croatian Law Centre signed a cooperation agreement with the European Federation
for Missing and Sexually Exploited Children (Missing Children Europe) related to the project on so-called
Miniila application. The purpose of this application is to inform children in simplified language adapted to
them about their rights and explain to them the procedures such as the procedure for granting international
protection and family reunification, and also give them an overview of the organisations in the country,
which they can contact for information and services they need (e.g. information on the asylum system,
support in cases of trafficking and sexual violence, language learning etc.). The application is available in
five languages Farsi, English, Arabic, French and Tigrinya).
According to the report of the Ombudswoman for children, in 2022, 4,773 children requested international
protection, which represented a significant increase compared to 2021. Out of the total number of children
seeking international protection, 436 were unaccompanied. 74 of them were aged 14-15. A total of 104
applications for international protection were submitted by unaccompanied children. Out of that number,
the procedure was suspended for 32 child applicants, two applications were rejected, while 70
applications were pending at the end of 2022. International protection was granted to 17 children, one of
whom unaccompanied. Regardless of the year the application was submitted, in 2022, 121 decisions
were issued for unaccompanied children seeking international protection. Of these, one was positive, 116
procedures were suspended (due to withdrawal of applications), three applications were rejected, and
one was annulled.240
According to report of Ombudswoman for children for 2022, from the data of the Border Violence
Monitoring network, it appears that at least 120 children experienced pushback during 2022. Civil society
organizations warn that younger children were exposed to psychological and verbal violence, and older
to physical violence. Nevertheless, some non-governmental organizations reported to the Ombudswoman
that in 2022 they received significantly less calls concerning children.241
During 2022, the Croatian Red Cross continued the implementation of two projects aimed at supporting
unaccompanied children and experts working with unaccompanied children - "Integrative support for
unaccompanied children”, co-financed by the European Union from the European Social Fund and
"Access to protection for asylum seekers and refugees" financed by UNHCR. CRC provided psychosocial
support and tracing services to unaccompanied children accommodated in social welfare institutions
throughout Croatia and reception centres for applicants for international protection.
Since unaccompanied children accommodated in social welfare institutions often do not have customized
services and interpreters available, CRC mobile team conducted a large number of visits to children
placed in those institutions. A mobile team composed of a psychologist or social worker, an interpreter
and expert from the Tracing Service carried out an initial assessment of the needs of unaccompanied
children.
The initial needs assessment was carried out with each child involved in the projects in order to collect
information about the child, determine the circumstances, needs and priorities. For some of the children
who expressed a desire for further support or needed additional information, the provision of individual
support continued.
CRC activities included provision of individual and group psychosocial support, distribution of
humanitarian aid (clothing and footwear, school supplies and equipment for sports activities, mobile
devices), services of the Tracing Service (enabling contact with family members, distribution of SIM cards
and vouchers for mobile phones, assistance in family reunification process), involvement in activities in
the local community (help with enrolment in sports clubs and paying membership fees, socializing with
fellow volunteers, participation in various social activities (trips, bowling, cinema, amusement parks, etc.)
and other activities depending on the specific needs of the child.
240
241
Ibid.
63
In addition, CRC provided support to their guardians, primarily in the area of family reunification, but also
in matters related to access to the health and education systems.
In 2022, CRC participated in the work of the Interdepartmental Commission for the Protection of
Unaccompanied Children, in which CRC is one of the representatives of the non-governmental sector and
can present observed difficulties and possible examples of good practice in order to work on improving
cooperation and protection of unaccompanied children.242
In the course of 2022, the problems with the inadequate accommodation of unaccompanied children
continued. The Croatian Red Cross (CRC) and Centre for Peace Studies reported continued problems of
inadequate accommodation provided to unaccompanied children.243 CRC reported that most children who
were older than 16, were placed in reception centres for applicants for international protection, together
with adults where they were at risk of potential exploitation and abuse.
CRC stressed that the various accommodation capacities are lacking interpreters and often do not provide
services for children that are adapted to their age and needs.
Victims of sexual and gender-based violence
Between October 2018 and March 2020, IOM implemented the project ”PROTECT - Preventing SGBV
against migrants and strengthening support to victims”.244 The project, that aimed at strengthening the
capacity and coordination of existing national support services for sexual and gender based violence, as
well at facilitating access to such services for refugees, migrants and applicants for international protection
affected by SBGV, ended in March 2020. During the course of the project IOM Croatia organised sixteen
capacity building trainings on SGBV and migration for first responders (i.e. border police, employees of
the Ministry of the Interior and NGOs working in the Reception Centre), specialised service providers (i.e.
social workers, psychologists, social pedagogues working in the Centres for Social Welfare, Home for
Children, NGOs working with the victims of SGBV) and general service providers (i.e. teachers and other
school and kindergarten employees, interpreters, various NGOs working with migrants) and reached 216
people.
The PROTECT project developed country-specific information material on sexual and gender-based
violence tailored to adults and children needs. These include:
1) a two-minute animated film which explains SGBV, designed for migrant audiences, and with subtitles
available in Croatian and other languages (English, Arabic, Farsi, Pashto, Urdu, French, Russian, Italian,
Somali, Albanian, Bulgarian, Spanish, Ukrainian, Tigrinya, Turkish, Kurdish (Kurmanji);245
2) The tailored material presents the services locally available i.e. the leaflet for adults on sexual and
gender-based violence in English Arabic, Pashto, and Farsiand the one for children is also available in
English, Arabic, Pashto and Farsi.246
Moreover, in 2020, as part of the project implemented by MDM-Belgique entitled: "Empowering Women
and Children in the migrant population to take ACTion against sexual and gender-based violence (We
ACT)", guidelines for dealing with cases of sexual violence against women and children was prepared by
the MDM-Belgique Team. The content of guidelines was incorporated in the Standard Operational
Procedure in Cases of Sexual and Gender-Based Violence in the Reception Centres for Applicants of
International Protection”.247 The Standard Operational Procedure was developed in cooperation with the
Ministry of Interior, UNHCR, IOM, MDM-BELGIQUE, the Croatian Red Cross and the Croatian Law
Centre. It entered into force in April 2021.
242
Information provided by Croatian Red Cross ,18 January 2023.
243
Information provided by Croatian Red Cross and Centre for Peace Studies, 18 January 2023.
244
Information on the project available at: https://bit.ly/3at8KcS.
245
The videos are available on YouTube in all mentioned languages here: https://bit.ly/3gqYuG7.
246
The PROTECT project, see the English versions available at: https://bit.ly/3yaMVsW; and for children at:
https://bit.ly/3omPXWB.
247
Information provided by MdM, 17 January 2021.
64
In 2022, UNHCR Croatia also carried out capacity-building activities with key stakeholders dealing with
refugees, more specifically through trainings on gender-based violence, protection from sexual
exploitation and abuse (PSEA), the fight against human trafficking and communication with communities.
The activities involved state and non-governmental employees, members of the Coordination group for
sexual and gender-based violence, operators of the 112-emergency telephone line and the newly
established telephone line run by UNHCR and partner Croatian Law Centre specifically for Ukrainian
refugees. In addition to the above, numerous informative materials on the mentioned areas were created
and their distribution ensured. Furthermore, UNHCR and the Council of Europe (CoE) organized an online
event on the topic 'Preventing, combating and responding to gender-based violence in the context of
asylum and migration', which gathered experts and key stakeholders of the system who encounter
gender-based violence issues in their work.248
In 2022, the Governmental Office for Gender Equality, in cooperation with the Ministry of Interior and
UNHCR, published a leaflet intended to inform victims of gender-based violence about available
protection options and services. The leaflet is intended primarily for female migrants, refugees and
applicants for international protection, although it acknowledges that gender-based violence can be
committed against men, and is available in 8 languages (Arabic, Croatian, English, Farsi, French, Kurdish,
Turkish and Urdu).249
Within the framework of the project financed by UNHCR, in 2022 CRC prepared short guide on gender-
based violence. The document covers the legislative framework for the prevention and suppression of
gender-based violence in Croatia in the context of applicants and beneficiaries of international protection.
The document also contains recommendations that aim to increase the capacities of the competent
ministries, institutions and organizations that deal with the issue of domestic violence.250
Victims of trauma and mental health issues
In 2019, Médecins du Monde (MDM-Belgique) published a study on the mental health of applicants for
international protection in Croatia.251 The aim of this study was to examine the level of psychological
distress, anxiety, depression and post-traumatic symptoms on the sample of applicants accommodated
at the Reception Centre for Applicants for international protection in Zagreb.
In 2020, MdM published the report „Everyone has the right to healthcare - model of healthcare
mediation/support intended for asylum seekers in Croatia”.252 The report presented the healthcare
mediation/support model for applicants for international protection in Croatia which was initiated and set
up in 2016 by the organisation Médecins du Monde ASBL - Dokters van de Wereld VZW (MDM-Belgique)
in partnership with the Ministry of Health and the Ministry of the Interior of the Republic of Croatia. The
report describes the different components of this model as well as its results in terms of improved access
to healthcare for applicants in Croatia, but also different challenges tackled between 1 November 2018
and 31 July 2020.
In May 2023, MdM issued publication “Physical and mental health of applicants for international protection
in the Republic of Croatia - new trends, observations, challenges and recommendations”, developed with
support of the European Union’s Asylum, Migration and Integration Fund and Government of Croatia
(Ministry of Health).253
248
249
Office for Gender Equality: The Office for Gender Equality published a leaflet for female migrants, refugees
and asylum seekers, available at: http://bit.ly/3FNHzte.
250
Croatian Red Cross, Annual report for 2022, available at: https://bit.ly/3MNYjmG
251
MdM, Nearing a point of no return? Mental health of asylum seekers in Croatia, February 2019, available at:
https://bit.ly/2XeDQiD.
252
Médecins du Monde, “Everyone has the right to healthcare - model of healthcare mediation/support intended
for asylum seekers in Croatia”, 2020, available in English at: https://bit.ly/3sHCIA9.
253
MdM Publication Physical and mental health of applicants for international protection in the Republic of Croatia
- new trends, observations, challenges and recommendations available in Croatian at: https://bit.ly/42ZH8F2
and in English at: https://bit.ly/43QN988.
65
In 2021, the Rehabilitation Centre for Stress and Trauma (RCT) reported that the identification of
vulnerable applicants, including victims of torture, is not implemented in accordance with established
standards. 254 Consequently, applicants for international protection who are victims of torture are not
provided with the necessary treatment and access to appropriate medical and psychological rehabilitation
and care. In addition, according to RCT, the health and social care system does not address the rights
and needs of victims of torture as a vulnerable group.
1.2. Age assessment of unaccompanied children
The LITP foresees the possibility of an age assessment procedure if, during the procedure for international
protection, doubt arises regarding the age of an unaccompanied child.255 The assessment of the child’s
age shall be conducted on the basis of the information available on the child, including the expert opinions
of persons involved in work with the child. If the information available is insufficient, a medical examination
shall be conducted, with the prior written consent of the child and the guardian. The medical examination
shall be conducted by means of a physical examination, X-ray of the teeth and/or hands, with full respect
for the dignity of the unaccompanied child. An unaccompanied child shall be informed in writing in a
language which he or she may justifiably be presumed to understand and in which he or she is able to
communicate about the manner of examination and its possible consequences for his or her health, the
consequences of the results of the medical examination for his or her application, as well as the
consequences of unjustified refusal. In the case of unjustified refusal of consent, the unaccompanied child
shall be deemed to be an adult applicant. The application cannot be refused exclusively on the basis of
the fact that consent to perform a medical examination was not given. During the medical examination,
an unaccompanied child who does not understand Croatian shall be provided with a translator/interpreter
for a language which he or she may justifiably be presumed to understand and in which he or she is able
to communicate. The costs of the medical examination shall be borne by the Ministry. If, even following
the results and report on the medical examination undertaken, there is still doubt regarding the age of the
minor, the concept of benefit of the doubt shall be applied.
In relation to appeal to the age assessment outcome, the Ministry stressed that in case of doubt in the
opinion of the doctor, new medical check would be initiated. The Ministry also emphasises that in such
case, the concept of benefit of the doubt shall be applied.256
According to the Ministry of Interior, in 2017 and 2018, the age assessment procedure was not
conducted.257 No information is available for the period from 2019 until the end of 2022.
2. Special procedural guarantees
Indicators: Special Procedural Guarantees

1. Are there special procedural arrangements/guarantees for vulnerable people?
Yes For certain categories No
 If for certain categories, specify which:
2.1. Adequate support during the interview
The LITP regulates that the needs of the applicant who needs special procedural and reception
guarantees shall be taken into account when rights established in the LITP are exercised. 258 The notion
of “adequate support” is understood by the Ministry as meaning that vulnerability should be determined
254
Information provided by the Rehabilitation Centre for Stress and Trauma, 14 January 2022.
255
Article 18 LITP.
256
Information provided by the Ministry of Interior, 2 March 2017.
257
Information provided by the Ministry of Interior, 13 February 2018, 28 January 2019.
258
Article 52(2) LITP.
66
and that the rights related thereto are respected,259 without however specifying what types of guarantees
should be provided.
The Ministry of Interior does not have a special unit dealing with vulnerable groups, but accommodates
their needs in the general system and assesses their cases within the same legislative framework.
Officials of the Ministry of Interior participated in trainings on how to deal with vulnerable cases in 2022.
Namely, 13 employees of the Service for Reception and Accommodation attended various workshops
with special emphasis on the vulnerable groups in need of special reception/procedural guarantees (e.g.
unaccompanied children, GBV survivors). Workshops were organized by EUAA, UNHCR, Council of
Europe, UNICEF, CRC, Frontex, Judicial Academy and State school for public administration.260
There are few specific provisions on how to process and assess the cases of vulnerable applicants, and
with a few exceptions (enumerated below) the same procedural guarantees are in place for vulnerable
categories as for other applicants. There is a general obligation to take into consideration the individual
situation and personal circumstances of the applicant,261 in particular the acts of persecution or serious
harm already undergone.262 The personal interview and decision-making mechanism is the same for all
applicants, regardless of their vulnerability.
It could be concluded that, according to the LITP, vulnerable applicants have the following rights in the
status determination procedure:
- the possibility to be interviewed by a decision-maker of the same sex;263
- to an interpreter of the same sex, if possible;264
- to be interviewed as soon as possible upon the submission of the application for international
protection;265
- in cases where the interview is omitted,266 in particular when an applicant is unfit or unable to be
interviewed, owing to enduring circumstances beyond their control, their relatives shall be
permitted to present evidence and give statements;267
- in case of an application of an unaccompanied child, the application has priority in decision-
making (see section on Regular Procedure: Fast-Track Processing). 268
2.2. Exemption from special procedures
According to the LITP, the Accelerated Procedure would not apply to cases of application lodged by an
unaccompanied child except in cases when a subsequent application is admissible, when the child
represents a risk for the national security or public order of the Republic of Croatia or when it is possible
to apply the concept of safe country of origin.269 According to the Ministry of Interior during 2018
applications lodged by unaccompanied children were not processed under the accelerated procedure.270
However, there is no information available on whether applications lodged by unaccompanied children
were processed under the accelerated procedure in the period from 2019 until the end of 2021.
Procedures at border crossings or in transit zones would not apply to cases of application lodged by an
unaccompanied child.271 However, as mentioned in
Border procedure (border and transit zones), no border procedure is in place in practice.
259
Information provided by the Ministry of Interior, 21 July 2017.
260
261
262
Article 28(3) LITP.
263
Article 35(5) LITP.
264
Article 14(3) LITP.
265
Article 35 LITP.
266
267
Article 35(9 LITP.
268
Article 17(9) LITP.
269
270
271
67
The LITP also prescribes that accelerated procedures and procedures at border crossings or in transit
zones, shall not apply to applicants who are in need of special procedural guarantees, especially victims
of torture, rape or another form of serious psychological, physical or sexual violence, if it is not possible
to provide the appropriate support (“adequate support”).272
3. Use of medical reports
Indicators: Use of Medical Reports

1. Does the law provide for the possibility of a medical report in support of the applicant’s statements
regarding past persecution or serious harm?
Yes In some cases No
2. Are medical reports taken into account when assessing the credibility of the applicant’s
statements? Yes No
In practice, evidence is rarely presented by way of medical reports, although the claims of some applicants
indicate that it is possible that they have been victims of torture or inhuman and degrading treatment. In
most, if not all of the cases where medical reports were provided, this was at the initiative of applicant’s
legal advisor. To the knowledge of the Croatian Law Centre, in those few cases in the past medical reports
were not based on the methodology laid down in the Istanbul Protocol. The LITP does not explicitly
establish the possibility to submit a medical report in the procedure, so in this case the provisions of the
Law on General Administrative Procedure are applied. That means that in the procedure, the case worker
determines the factual situation using any means suitable as evidence and can for this purpose, among
other possibilities, make use of findings and opinions of experts.273
However, expert witnesses are not mandatory according to the law, and that is why they are rarely used
in practice. Even when applicants mention that they are victims of torture, they are still not referred to a
specialist, either during the first instance procedure or even later during the administrative dispute. The
other reason is the lack of public funds from the State budget. Therefore, the Ministry of Interior has the
possibility to order a medical examination; however, this possibility is not used in practice.
The Rehabilitation Centre for Stress and Trauma noted that no appropriate procedures are implemented
in relation to documentation and verification, including medico-legal documentation, of victims of
torture.274
The LITP only introduces the possibility of use of medical records in the age assessment procedure.
4. Legal representation of unaccompanied children
Indicators: Unaccompanied Children

1. Does the law provide for the appointment of a representative to all unaccompanied children?
Yes No
According to the LITP, “unaccompanied child” means a third-country national or a stateless person
younger than eighteen years of age who entered the Republic of Croatia unaccompanied by an adult
person responsible for him or her in the sense of parental care, pursuant to the law of the Republic of
Croatia, until placed under the care of such a person, and includes all children who are left
unaccompanied after they entered the Republic of Croatia.275
In 2021, 195 unaccompanied children sought international protection in Croatia.276
272
Article 15(3) LITP.
273
Article 58(1) Law on General Administrative Procedure.
274
Information provided by the Rehabilitation Centre for Stress and Trauma, 18 January 2019, 7 February 2021.
275
276
Ministry of Interior, Statistics 2021, available in Croatian at: https://bit.ly/3DYJpoY.
68
In 2022, 4,733 children expressed the intention to seek international protection, among them a total of
436 unaccompanied children, of which 337 were boys and 99 were girls. In 2022, 104 unaccompanied
children submitted applications for international protection whereas 32 procedures were suspended, two
dismissed and 70 are ongoing. Regardless of the year when applications for international protection were
submitted, in 2022 one unaccompanied children was granted international protection, 116 procedures
were suspended, three dismissed and one annulled.277
A special guardian should be appointed for each unaccompanied child, with the exception of married
unaccompanied children over the age of 16.
4.1. Time of appointment
According to the Protocol on Procedures for Unaccompanied and Separated Children, as soon as it is
established that a child is unaccompanied or separated, the police officer must take actions to ensure the
procedure of identification, which among others includes obligation to invite a social worker from the
Centre for Social Welfare and an interpreter if the child does not understand Croatian, and to forward a
letter to the competent Centre for Social Welfare requesting a special guardian to be appointed.
The procedure of identification includes:

- Communication, introducing oneself and informing the child about the country of arrival, his or
her guaranteed rights, the appointment of a special guardian, procedures that follow after the
child’s identification;
- Collecting personal data and other information about the child;
- Conducting an initial assessment of the child’s needs by completing the form “Initial Assessment
of Needs of Unaccompanied and Separated Children” in Annex 1 to the Protocol;
- Steps to be followed in the event of an expression of intention to submit an application for
international protection during the identification procedure.
The procedure of identification is conducted by a police officer in the police administration or police station.
An interpreter assigned by the Ministry of Interior, a social worker from the Centre for Social Welfare
and/or a special guardian also participate.
Where the procedure of identification is conducted outside the regular working hours of the competent
Centre for Social Welfare, the expert duty officer of the Centre for Social Welfare takes part in the
procedure. He or she must appoint a special guardian, in an oral ruling, to protect the wellbeing of the
child and to ensure the implementation of further procedures. If it is found out that the child already has a
guardian, the official from the Centre for Social Welfare or the police officer will call the appointed guardian
to take part in further procedures with the unaccompanied or separated child.
Allegations of pushbacks involving children have been a constant in recent years (see previous AIDA
reports). In 2021, the Office of the Ombudsperson for Children continued to receive information on cases
of authorities separating migrant and asylum-seeking children from their families for months. In addition,
the Office of the Ombudsperson for Children reported that children were regularly placed into pre-removal
detention centres, as well as in community service centres in Zagreb and Split which are intended for
children with behavioural issues. 278
Media also reported two cases of parent–child separation by Croatian border guards at the external
borders, with no information about the whereabouts of the parent(s). Are You Syrious reported on family
separation at the borders in 2021: mothers and children are often allowed to enter the territory to seek
asylum while fathers are pushed back to Bosnia and Herzegovina by Croatian police.279
277
278
FRA Quarterly bulletin for the period 1 January to 30 June 2021, available at: https://bit.ly/3O26z2s.
279
FRA Quarterly bulletin for the period 1 July until 30 September 2021. available at: https://bit.ly/3rgwd9A.
69
In 2022, allegations of pushbacks continued (see Access to the territory and pushbacks), including
pushbacks of children.
According to the LITP, the Centre for Social Welfare shall appoint a guardian, who has been trained to
work with children and who does not have a conflict of interest with the child, unaccompanied children
who have expressed the intention to apply for international protection.280 The child must be informed
immediately about the appointment of the guardian. The procedure for international protection must be
conducted by the official from the Ministry of Interior trained to work with children. The guardian has to
prepare, on time, the unaccompanied child for the interview and provide him or her with information on
the significance and consequences of the interview in a language which it may justifiably be assumed that
child understands and in which he or she is able to communicate. The costs of interpretation shall be
borne by the Ministry of Interior. However, to the Croatian Law Centre’s knowledge, this possibility is
rarely used in practice as guardians are not using this legal right.
There is no time limit prescribed by the LITP for the appointment of the representative of an
unaccompanied child but it is obvious from the LITP that a guardian has to be appointed before submitting
an application for international protection. From the information provided by the Ministry of Interior
problems with delays in the appointment of legal guardians in practice also existed in 2018.281 According
to the knowledge of Croatian Law Centre this issue persisted in 2020,2021 and 2022 in some cases as
well.
In 2022, the Croatian Red Cross continued the implementation of two projects aimed at supporting
unaccompanied children and experts working with unaccompanied children - "Integrative support for
unaccompanied children”, co-financed by the European Union from the European Social Fund and
"Access to protection for asylum seekers and refugees" financed by UNHCR. (see more under:
Unaccompanied children).
In 2022, the Croatian Law Centre (CLC) implemented the project "Legal counselling in the procedure for
the approval of international protection in 2021". Within the project, the legal advices and/or information
were provided also to unaccompanied children who were applicants for international protection. It was
observed that children often did not receive adequate information about their rights and obligations from
their guardians. In addition, it was observed that unaccompanied children were quickly leaving the
institutions where they were accommodated and consequently Croatia.
During the implementation of the project, CLC published informative material (brochure), visually and
terminologically/linguistically adapted to children, in seven languages: English, Turkish, Arabic, Farsi,
Pashto, Russian and Spanish. The brochures, which contains basic information on the procedure for
international protection and the scope of legal counselling, were sent to social welfare institutions where
unaccompanied children were accommodated and are also available on CLC website.282 Within the
project, CLC organized and held a meeting with the institutions where unaccompanied children were
accommodated and centres for social welfare in order to provide more detailed information about the
project and the importance of legal advice for children and their guardians.
4.2. Qualifications of guardians
Until now, no special qualifications were required for the appointment of guardians. In practice, according
to the information available to the Croatian Law Centre, when workers from Centres for Social Welfare
were appointed as guardians, these were usually lawyers, social workers or social pedagogues who are
working within the Centre for Social Welfare.
The Ombudsperson for Children reported that problems still existed in the guardianship system in 2021.
Some special guardians did not have contact with unaccompanied children, which is why children did not
280
Article 17(1) LITP.
281
282
See: https://bit.ly/3Ppt5Fs.
70
received adequate information about their rights and obligations. Some guardians are reportedly also not
motivated, which stems from the scope of work that they regularly perform.283 In 2022, the Ombudsperson
for Children reached similar conclusions. According to the Ombudsperson for Children, employees of the
Centres for Social Welfare are often not motivated to take special guardianship of unaccompanied
children due to overload of obligations arising from their regular work. Special guardians are often not
available to children neither in regular contact with them. As a result, they do not fully protect their rights
and interests. The Ombudsperson for Children reported that many children do not know who their
guardian is or how to contact them, and they only meet guardian when submitting application for
international protection. Children do not know how to get information about the family reunification
available services and school enrolment. Therefore, there is a need for more frequent and timely
communication with the guardian and their actual, not just formal, availability.284
The Croatian Red Cross reported that in 2022 their mobile team conducted a large number of visits to
institutions where unaccompanied children are accommodated to provide psychosocial support to
children and provide material services (such as clothing and school supplies). 285
The previous updates of the AIDA report on Croatia provide background information on the different
trainings and projects related to the unaccompanied children that were organised since 2016.
In November 2020, on the occasion of the World Children’s Day, Croatian Law Centre (CLC) in
cooperation with UNHCR, held the online conference “Actualities in the Field of the Protection of Rights
of Unaccompanied children”. The topic of the conference was the state of the protection of
unaccompanied children, with the special focus on the expected arrival of unaccompanied children from
Greece.
Since 2016 CLC, as implementing partner of UNHCR,286 started providing free legal aid in places where
unaccompanied children are accommodated (Residential Child Care Institutions in Zagreb, Split, Rijeka
and Osijek, and Child Reception Units), when needed and depending on the number of children
accommodated. The activity continued in 2018. In 2019 the majority of counselling services were
organised in Zagreb. In 2020 and 2021 due to the unfavourable epidemiological situation, legal
counselling with children was mainly provided via phone and WhatsApp/viber, as opposed to an in-person
assistance in childcare institutions. The CLC also provided special guardians with legal information about
protection of rights of unaccompanied children. In 2022, the similar activities (i.e. counselling for
unaccompanied children) were provided by CLC within the project "Legal counselling in the procedure for
the approval of international protection in 2021". Project was co-financed with the funds of the Fund for
Asylum, Migration and Integration, and based on the contract concluded with the Responsible Authority
for the Management of Funds for Internal Affairs, the Directorate for European Affairs, international
relations and European Union funds of the Ministry of Interior.
In the course of 2021, the Croatian Law Centre held 3 online workshops in cooperation with UNHCR on
“The Protection of Unaccompanied Children: Procedure and Exercising Rights After the Accommodation
of Children” for relevant actors working within social welfare system. The following topics were presented
at the workshops: UNHCR standards in the treatment of unaccompanied children, the right and
possibilities of accommodation of unaccompanied children within the social welfare system, the right to
health care and health support for children, the importance of inter-sectoral cooperation in the inclusion
of unaccompanied children in educational system, unaccompanied children in the procedure for granting
international protection, expression of intention in the procedure for international protection, Dublin
283
https://bit.ly/3jxpvaZ.
284
Ombudsperson for Children: Report on the work of the Ombudsman for Children in 2022, available in Croatian
at: https://bit.ly/3p3LZXu.
285
Information provided by the Croatian Red Cross, 18 January 2023.
286
The project Legal Services to Asylum Seekers has been implemented by the Croatian Law Centre from 1
February 2003, with the aim of providing free legal aid to asylum seekers and recognised refugees i.e. asylees
and foreigners under subsidiary protection. The project is being implemented with financial support from and
in close co-operation with the UNHCR Representation in Croatia.
71
procedure and temporary stay for humanitarian reasons and integration of unaccompanied children into
Croatian society.
In 2020, IOM conducted info campaigns on prevention of sexual and gender-based violence for
unaccompanied minors located in children homes in Zagreb, Ivanec, Zadar and Split. 287
4.3. Capacity and performance of functions
Guardians of unaccompanied children were and still are generally appointed among the social workers of
the competent Centre for Social Welfare, although in the Policy brief on the protection of unaccompanied
children in the Republic of Croatia which was prepared by the Centre for Peace Studies, the Rehabilitation
Centre for Stress and Trauma, together with an independent, it is reported that in recent years, they are
being appointed from the ranks of employees of social welfare institutions in which unaccompanied
children are accommodated.288
According to the law, the best interests of children should be considered when implementing provisions
of LITP,289 so also when appointing a person to act as a guardian. The best interests of the child shall be
assessed, taking into account:
- The welfare and social development of the child, and his/her origin;
- The protection and safety of the child, especially if the possibility exists that he or she is a victim
of trafficking in human beings;
- The child's opinion, depending on his or her age and maturity; and
- The possibility of family reunification, etc.
The guardian of an unaccompanied child shall undertake all the necessary activities, including contact
and cooperation with the competent ministries, other state and foreign bodies, and NGOs, in order to
reunite the child with his or her family if this is in the best interests of the child.
On the other side, the LITP prescribes that a guardian shall not be appointed when an unaccompanied
child is over 16 years of age and is married,290 which can be understood that persons from the age of 16
have the capacity “to perform procedural acts” on their own behalf in procedures for international
protection.
The Centre for Peace Studies reported that unaccompanied children have insufficient or no contact with
guardians in some cases, which leads to inadequate support and access to information and services.291
E. Subsequent applications
Indicators: Subsequent Applications

1. Does the law provide for a specific procedure for subsequent applications? Yes No
2. Is a removal order suspended during the examination of a first subsequent application?

 At first instance Yes No
 At the appeal stage Yes No
3. Is a removal order suspended during the examination of a second, third, subsequent application?
 At first instance Yes No
 At the appeal stage Yes No
287
Information provided by IOM, 30 December 2020.
288
Policy brief on the protection of unaccompanied children in the Republic of Croatia, available at:
https://bit.ly/3vsEZTB.
289
Article 10 LITP.
290
Article 17(3) LITP.
291
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When the foreigner lodges a subsequent application, the authority competent to examine the application
is the Department for international protection procedure of the Ministry of Interior, the same authority as
in the regular procedure. The Department for international protection procedure examines the elements
presented in the subsequent application in conjunction with the elements provided in the previous
application and/or lawsuit.
The LITP provides a specific procedure for subsequent applications. A subsequent application for
international protection is defined as the intention to apply for international protection expressed after a
final decision has been taken on a previous application i.e. the previous application was rejected because
the conditions were not met for asylum or subsidiary protection; or conditions were met for exclusion; or
the application was rejected as manifestly unfounded as the applicant did not meet the conditions for
asylum or subsidiary protection or the procedure was discontinued because the applicant withdrew the
application.292
If a person decides to submit a subsequent application,293 an explanation of the subsequent application

should be submitted to the Reception Centre for Applicants of International Protection directly in writing
or orally if the person is illiterate. The Ministry of Interior must decide on the subsequent application no
later than within 15 days from the day of receiving it. This subsequent application must be comprehensible
and contain the relevant facts and evidence which arose after the finality of the decision or which the
applicant for justified reasons did not present during the previous procedure, relating to establishing the
conditions for approval of international protection. The admissibility of the subsequent application should
be assessed on the basis of the facts and evidence it contains, and in connection with the facts and
evidence already used in the previous procedure. If it is established that the subsequent application is
admissible, a decision shall be rendered once again on the substance of the application, and the previous
decision revoked. The subsequent application should be dismissed if it is established that it is
inadmissible. A subsequent application made by a foreigner under transfer shall be considered in the
responsible member state of the European Economic Area, but a subsequent application lodged in the
Republic of Croatia shall be dismissed as inadmissible.
In practice under the LITP, the interview for lodging the subsequent application can be omitted when the
admissibility of a subsequent application is being assessed. 294
Under the LITP,295 if the applicant lodges a subsequent application with the intention of postponing or
preventing the enforcement of the decision on expulsion from the Republic of Croatia, he or she shall
have the right of residence until the decision on the subsequent application becomes final. However, as
at the same time LITP prescribes that the Ministry shall render a decision to dismiss a subsequent
application if it assesses that it is inadmissible,296 and that in that case appeal to Administrative Court
does not have a suspensive effect,297 (which means that the decision is final)298 the above provision
means that the right to residence is applicable only during the first instance procedure. However, there is
also a possibility for the appeal to contain a request for suspensive effect.299 If the applicant brings an
appeal which contains a request for suspensive effect, he or she shall have the right of residence until the
delivery of the judgment on granting suspensive effect.300
However, applicants who lodge a new subsequent application after a decision has already been rendered
on a previous subsequent application do not have the right of residence in the Republic of Croatia.
292
293
Article 47 LITP.
294
295
296
Article 43(2) LITP.
297
298
299
Article 51(2) LITP.
300
Article 53 LITP.
73
If the conditions for the accelerated procedure are met and the subsequent application is admissible, then
the Ministry of Interior must render its decision within 2 months period. The deadline for the appeal in that
case is then 8 days for the delivery of the first instance decision, however it does not have suspensive
effect. Otherwise the 15-day time limit is applicable for the Ministry of Interior to decide on subsequent
applications. As in the regular procedure, the Administrative Court is the competent authority for deciding
upon appeal. If the subsequent application is dismissed as inadmissible, the deadline is 8 days from the
delivery of the first instance decision and does not have suspensive effect.
In 2018, 104 persons lodged subsequent applications, however data from 2019 until the end of 2021 are
not available.
Although the total number of subsequent applications that were submitted in 2021 and 2022 is not
available, it is known that in 2021, 28 subsequent applications were dismissed as inadmissible;301 in
2022, the number of subsequent applications deemed inadmissible was 10.302
F. The safe country concepts

Indicators: Safe Country Concepts
1. Does national legislation allow for the use of “safe country of origin” concept? Yes No
 Is there a national list of safe countries of origin? Yes No
 Is the safe country of origin concept used in practice? Yes No
2. Does national legislation allow for the use of “safe third country” concept? Yes No
 Is the safe third country concept used in practice? Yes No
3. Does national legislation allow for the use of “first country of asylum” concept? Yes No
In Croatia, safe country concepts started being applied in 2016 under the LITP. In 2016, a Decision on
the list of safe countries of origin was adopted.
1. Safe country of origin
According to the LITP,303 a country is considered as a safe country of origin where, on the basis of the
legal situation, the application of the law and the general political circumstances, it can be shown that
there is generally and consistently no persecution, or risk of suffering serious harm, as established on the
basis of information on:
(1) The relevant laws and legislation of the country and the manner in which they are applied;
(2) Respecting the rights and freedoms guaranteed by the ECHR, especially Article 15(2) of the
ECHR, the International Covenant for Civil and Political Rights and the United Nations Convention
against Torture;
(3) Respect for the principle of non-refoulement;
(4) The provision of a system of effective remedies.
The information referred above shall be collected from various relevant sources, especially from other
member states of the European Economic Area, the European Asylum Support Office (EASO), UNHCR,
the Council of Europe and other relevant international organisations.
The Minister competent for internal affairs, with the prior consent of the Minister competent for foreign
affairs, shall render a decision to establish a list of safe countries of origin, and shall inform the European
301
building” with the financial support of the UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and in English
302
303
Article 44 LITP.
74
Commission of this. The Ministry shall regularly verify and as necessary revise the list of safe countries
of origin, taking into account above mentioned information, with the prior consent of the minister
competent for foreign affairs, and shall inform the European Commission accordingly.
It shall be established for each application individually whether the conditions are met for the application
of the concept of safe country of origin. A country included on the list of safe countries of origin may be
considered a safe country of origin in a specific case only if the applicant:
(2) Has the nationality of that country or had his or her previous residence in that country as a
stateless person; and
(3) Has not explained in a credible manner why that country of origin cannot be deemed to be a safe
country of origin for him or her.
The applicant shall be informed timely of the application of the mentioned concept in order to enable
him/her to challenge the use of the concept of safe country of origin, in view of the specific nature of
his/her personal circumstances.
An application shall be rejected in an accelerated procedure if it is possible to apply a safe country of

origin concept (see section on Accelerated Procedure).304 This is also applied to unaccompanied minors,
who are generally exempted from accelerated procedures (see Special Procedural Guarantees).
In 2016, a Decision on the list of safe countries of origin in the procedure of granting international
protection has been adopted.305 The list includes 10 countries:
- Albania
- Bosnia and Herzegovina
- North Macedonia
- Kosovo
- Montenegro
- Serbia
- Morocco
- Algeria
- Tunisia
- Türkiye
According to information provided by the Ministry of Interior in the past to the Croatian Law Centre (CLC),
the concept is not used for applicants from Türkiye.
In 2018, negative decisions based on the concept of safe country of origin were issued in 76 cases. 39 of
those concerned citizens of Algeria, 13 Morocco, 13 Tunisia, 5 Kosovo, 4 Serbia and 2 Bosnia and
Herzegovina.306 No information on decisions based on the concept of safe country of origin is available
for the period from 2019 until the end of 2022.
2. Safe third country
The LITP defines safe third country as a country where the applicant is safe from persecution or the risk
of suffering serious harm and where he or she enjoys the benefits of non-refoulement, and the possibility
exists of access to an effective procedure of being granted protection, pursuant to the 1951 Convention.307
The fact whether the conditions have been met to apply the concept of safe third country is established
separately for each application, by assessing whether a country meets the abovementioned conditions
and whether a connection exists between that country and the applicant, on the basis of which it may
304
305
Official Gazette 45/2016, available in Croatian at: http://bit.ly/2lcRePz.
306
307
Article 45 LITP.
75
reasonably be expected that he or she could request international protection there, taking into account all
the facts and circumstances of his or her application.
The applicant will be informed timely of the application of the safe third country concept, so that he or she
is able to challenge this in view of the specific characteristics of his or her personal circumstances.
The Ministry shall issue an applicant whose application is dismissed with a document in the language of
the safe third country, informing the competent state bodies of that country that his or her application has
not been examined in substance in the Republic of Croatia. If the safe third country refuses to accept the
foreigner, a procedure would be conducted in Croatia i.e. decision shall be rendered on the substance of
the application pursuant to the provisions of LITP.
The Ministry has an obligation to regularly inform the European Commission about the countries to which
the concept of safe third country has been applied. No information is available for 2019 ,2020 and 2021.
The LITP also provides a definition of the concept of safe European third country.308 It defines the latter
as a country that has ratified and applies the provisions of the 1951 Refugee Convention and the
European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR), including
standards on effective remedy, and has established an effective procedure for the approval of protection
pursuant to the 1951 Convention. It shall be determined whether the conditions have been met for the
application of the concept of European safe third country for each application individually, assessing
whether a country meets the above-mentioned conditions. The application of an applicant who entered
Croatian territory unlawfully from a European safe third country shall be dismissed taking into account
respect for the principle of non-refoulement, and the special circumstances of a humanitarian or political
character, as well as the rules of international public law. The applicant must be informed in a timely
manner of the application of the European safe third country concept, so that he/she is able to challenge
this in view of his/her personal circumstances. If the Ministry of Interior dismisses the application of the
European safe third country concept, it shall issue the applicant with a document in the language of the
European safe third country, informing the state bodies of that country that the application has not been
examined in substance in Croatia. In addition, the Ministry of Interior must regularly inform the European
Commission about the countries to which the concept of European safe third country has been applied.
In March 2021, the Constitutional Court has issued a decision in a case concerning an Afghan family
whose cases were dismissed by the Ministry of Interior on the basis of the safe third country concept.309
More precisely, the Ministry of Interior concluded that Serbia, from which the family had entered Croatia,
is a safe third country. In further proceedings before the Administrative Court in Osijek and the High
Administrative Court their appeals were rejected. The applicants' main complaint before the Constitutional
Court was that they would be returned to Serbia from Croatia despite clear indications that they would not
have access to an appropriate asylum procedure in Serbia that could protect them from expulsion or
refoulement.
The Constitutional court upheld the constitutional complaints and annulled the judgments of the High
Administrative Court and the judgments of the Administrative Court in Osijek. The case was thus referred
back to the Administrative Court in Osijek. The Constitutional Court assessed the situation in Serbia to
determine the status of the rights of applicants for international protection in that country but also to
conclude whether the Afghan family would be in serious risk of deportation to a third country without due
process in accordance with the requirements of Article 3 of the ECHR. The Court also pointed out that
the Ministry of the Interior and administrative courts limited themselves to the normative framework and
the number of persons granted international protection in their assessment of the situation in Serbia,
without analysing the relevant reports and determining what is the actual treatment of persons returned
from Croatia to Serbia and whether they face a risk of automatic refoulement. The Constitutional Court
thus accepted the applicant's allegations that during the procedure before the Ministry of Interior and
administrative court proceedings it was not established with sufficient certainty that Serbia is a safe
308
Article 46 LITP.
309
Constitutional Court, Decision U-III-4865/2018, 4 March 2021, available in Croatian at: https://bit.ly/3bQYmMZ.
76
European third country and that Croatia had failed to fulfil its procedural obligations under Article 3 of
ECHR.
3. First country of asylum
While the LITP does not define the concept of first country of asylum, an application may be dismissed
as inadmissible where the applicant has been granted international protection or enjoys sufficient
protection from refoulement in a third country.310 In 2018, no decision was taken based on the concept of
first country of asylum.311 No information on decisions taken based on the concept of first country of
asylum from 2019 until the end of 2022 is available.
G. Information for asylum seekers and access to NGOs and UNHCR
1. Provision of information on the procedure
Indicators: Information and Access to NGOs and UNHCR

1. Is sufficient information provided to asylum seekers on the procedures, their rights and
obligations in practice? Yes With difficulty No
 Is tailored information provided to unaccompanied children? Yes No
The LITP prescribes that the Ministry of Interior is obliged, within 15 days from the expression of the
intention to apply for international protection, to inform an applicant about the procedure for international
protection, about rights and obligations applicants are entitled to in the procedure, and about the possibility
to get free legal aid and to get into contact with UNHCR representatives and representatives of other
organisations dealing with the protection of refugees’ rights.312 This information must be given in the
applicant’s own language or in a language he or she can be reasonably supposed “to be able to
communicate” in.313 The law does not specify whether the information should be provided orally or in
writing. The same type of information is provided with the same modalities to applicants during all types
of procedures except in border procedure where this information should be given by police officers.314
Official information on the procedure
At the beginning of the interview, the applicant is also informed about his or her duties in the procedure
and during the interview. According to the Ministry of Interior, in general, information is provided during
the process of lodging the application for international protection in the presence of interpreter and
information is also given to the person in writing.315 An information sheet, together with the rest of the
documents (House Rules of the Reception Centre, information on Dublin procedure etc) is available in
Albanian, Amharic, Arabic, Bengali, English, Farsi, French, Russian, Tigrinya, Turkish, Pashto and
Urdu.316 According to the Ministry of Interior, if information is not translated in a particular language, then
it is translated from Croatian in the presence of an interpreter.
Applicants are informed about the Dublin procedure when expressing the intention to apply international
protection, and later on when lodging the application for international protection. They are provided with
information explaining the purpose of the Dublin procedure as well as the purpose of taking fingerprints
and of the Eurodac database. Also, information has clarified the procedure to be carried out if the applicant
for international protection is unaccompanied child. The above information is available in 8 language
versions: Urdu, English, French, Arabic, Croatian, Somali, Farsi and Turkish.317
310
311
312
Article 59(2) LITP.
313
Article 14 LITP.
314
Article 59(1) LITP.
315
316
317
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The decision on the transfer that applicants receive include the ground for application of the Dublin
Regulation, and also information on the fact that they can lodge a complaint before the Administrative
Court within 8 days from the delivery of the decision. The Ministry of Interior does not provide a written
translation of the Dublin decision, but they do explain it orally in a language that the applicant understands
during the delivery of the decision itself.
No information is available on whether the common leaflet and the specific leaflet for unaccompanied
children have been created in accordance with Article 4(3) of the Dublin III Regulation.
In 2022, Croatian Law Centre (CLC) implemented the project "Legal counselling in the procedure for the
approval of international protection in 2021". The Project was co-financed with the funds of the Fund for
Asylum, Migration and Integration, and based on the contract concluded with the Responsible Authority
for the Management of Funds for Internal Affairs, the Directorate for European Affairs, international
relations and European Union funds of the Ministry of Interior.
The Project was carried out in cooperation with the Ministry of Interior and targeted applicants for
international protection. During the 2022, several information sessions on legal counselling services were
held in the Reception Centre for Applicants for International Protection in Zagreb. Legal counselling with
interested applicants was provided in CLC’s premises. Within the framework of the project counselling for
unaccompanied children applicants in institutions where children were accommodated and support to
their guardians were also provided.
Among other things, within the project, an informative brochure for applicants for international protection
as well as its simplified version adapted to unaccompanied children applicants was created on the project.
The brochure contains information on who and under which conditions people can access the right to
legal counselling, what legal counselling includes and how to exercise the right to legal counselling.
Brochures are available in several languages. 318
Furthermore, during the implementation of the project, a mobile application was created about the main
features of the procedure for granting international protection and ways of exercising the rights of
applicants in practice. The application is available at multiple languages (Croatian, Arabic, English, Farsi,
Pashto and Turkish).319
Information on the procedure from NGOs
NGOs also provide information on asylum system. Some NGOs have issued leaflets and brochures which
are also available in the Reception Centre for Applicants for International Protection, as well in Reception
Centre for Foreigners. A leaflet prepared in cooperation of UNHCR, Croatian Law Centre and the Ministry
of Interior contains basic information on the procedure and rights and obligations during the procedure
and is available in the both Receptions Centre for Applicants for International Protection and in the
Reception Centre for Foreigners. The leaflet is available in Arabic, Croatian, English, Farsi, French,
Pashto, Somali, Turkish, Ukrainian and Urdu. The leaflet is also available online on the Croatian Law
Centre’s web page. 320
The Centre for Peace Studies (CPS), an NGO also working within the integration of beneficiaries of
international protection, has issued different leaflets dealing with inclusion into society, accommodation,
education, free legal aid, family, religion, health and social care. The leaflets are available in Croatian,
English and French. CPS has also issued a brochure entitled “Welcome to Croatian Society”, containing
318
Croatian Law Centre: The project "Legal counselling in the procedure for the approval of international
protection in 2021"- informative materials for those seeking international protection created and distributed,
available at: https://bit.ly/46rM1JU.
319
See: https://rhprotection.mup.hr/hr.
320
The leaflet may be found at CLC web page in Croatian at: https://bit.ly/3ux3zTR; in English at:
https://bit.ly/3uzy9wk; in Arabic at: https://bit.ly/3E2AEKC; in Somali at: https://bit.ly/3E2Pxwi; in Turkish at:
https://bit.ly/3jsn9Ku; in Pashto at: https://bit.ly/3rkgdn3; in Farsi at: https://bit.ly/3vbDOrh; in French at:
https://bit.ly/3xhYksT; in Urdu at: https://bit.ly/37cZBH1; and in Ukrainian at: https://bit.ly/3KCbpB9.
78
information on Croatian history, the political system of Croatia, cultural differences, information on
detention, a short overview of asylum procedure etc.321
During 2022, the CPS published on its website and printed leaflets on free legal aid. The leaflet is available
in several languages: Arabic, Farsi, Urdu, Pashto, Somali, Turkish, Kurdish (Kurmanji), Tigrinya,
Ukrainian, French, in Spanish, English and Croatian.322 In addition, in 2022, CPS also translated the most
frequently asked questions about the procedure for seeking international protection and the rights of
applicants for and beneficiaries of international protection into Russian and French.
The Centre for Missing and Exploited Children produced and printed leaflets for unaccompanied children,
available in Croatian, English, Arabic and Farsi.323
The Croatian Law Centre, within the project entitled “Improving the protection of the rights of
unaccompanied children”, prepared a leaflet for unaccompanied children. Leaflets are recorded as mp3
format in Arabic, Croatian, English, Farsi and Pashto.324
In 2020, the Centre for cultural activities prepared 6 videos containing the necessary information for
applicants for international protection and foreigners residing in Croatia, and one video contains
information on legal counselling, accommodation and daily life.325
Information at the border
Several years ago, leaflets aligned with the LITP were prepared by the Croatian Law Centre and UNHCR
in cooperation with the Ministry of Interior and distributed by the Ministry of Interior. At some border
crossing points, there is a lack of available interpreters. This prevents effective communication between
foreigners (among whom some are potential applicants i.e. applicants for international protection) and
border officers. However, according to the LITP third-country nationals or stateless persons in a reception
centre, at a border crossing or in a transit zone of an airport, sea port or inland water port who wish to
express their intention to apply for international protection shall be provided by police officers with all
necessary information on the procedure for the approval of international protection in a language which
they may justifiably be expected to understand and in which they are able to communicate.326
In practice, persons may seek international protection at police stations at the border but are not
proactively informed of that possibility, although the authorities have indicated that border guards have
received training on how to recognise indications that a person wishes to seek protection. Interpretation
at the border is also problematic, especially for Afghan and Pakistani nationals.327 Problems regarding
access to the territory and then accordingly to the asylum system which started since the end of 2016 and
are valid up until the end of 2022 (see Access to the territory and pushbacks).
With regard to decisions, these are written only in Croatian and are translated orally by an interpreter to
the applicant during the delivery of the decision. However, due to the legal terms used in the decision, the
level of understanding of that information by applicants is questionable (including the information on the
available legal remedy and its deadline).
321
According to the Centre for Peace Studies, the brochure is available in Arabic, Croatian, Farsi, French, English,
Russian and Turkish.
322
Centre for Peace Studies, Leaflet on free legal aid, available at: https://bit.ly/44cOcie.
323
Centre for Missing and Exploited Children, Welcome to Croatia: Guide for unaccompanied children, available
at: https://bit.ly/2TBXncq.
324
Croatian Law Centre, ‘Izrađen informativni letak za djecu bez pratnje u audio formatu – dostupan i na web
stranici HPC-a’, 17 July 2017, available at https://bit.ly/2H9BpX3.
325
The video is available at: https://bit.ly/32CTDJP.
326
Article 59(1) LITP.
327
ECRE, Balkan route reversed, December 2016, 11-12.
79
2. Access to NGOs and UNHCR
Indicators: Access to NGOs and UNHCR

1. Do asylum seekers located at the border have effective access to NGOs and UNHCR if they
wish so in practice? Yes With difficulty No
2. Do asylum seekers in detention centres have effective access to NGOs and UNHCR if they
wish so in practice? Yes With difficulty No
3. Do asylum seekers accommodated in remote locations on the territory (excluding borders) have
effective access to NGOs and UNHCR if they wish so in practice?
UNHCR has access to all facilities where applicants are accommodated, namely the Reception Centres
for Applicants for International Protection in Zagreb and Kutina and the Reception Centre for Foreigners
in Ježevo and to Transit Reception Centres for Foreigners in Trilj and Tovarnik.
Since the end of March 2020 and the beginning of the COVID-19 pandemic, access for NGOs to
Reception Centre for Applicants of International Protection was restricted; this continued in 2022.
Although the measures related to the pandemic were lifted in 2022, civil society organizations were
prevented from accessing the Reception Centres, and based on their project with the Ministry of Interior,
only the Croatian Red Cross (CRC) and MdM had daily access to the Reception centres.
The CRC staff is present on a daily basis in the Reception Centre for Applicants for International Protection
and can refer applicants to the relevant organisations or institutions which can provide information to
them.
MdM staff is also present in the Reception Centre for Applicants for International Protection in Zagreb.
In 2022, lawyers of the Croatian Law Centre (CLC) held several information sessions on legal counselling
services in the Reception Centre for Applicants for International Protection in Zagreb. Sessions were held
within the project "Legal counselling in the procedure for the approval of international protection in 2021",
carried out in cooperation with the Ministry of Interior. For adult interested applicants for international
protection legal aid was provided in CLC’s premises.
Contacts with applications were also maintained telephone, email or applicants would come to CLC office
when needed.
The Centre for Peace Studies does not have access to Reception Centres for Applicants for International
Protection in Zagreb and Kutina from September 2018, neither access to Reception Centre for
Foreigners from the beginning of 2018, so their activities were provided out of the Centres during 2022.328
The Rehabilitation Centre for Stress and Trauma reported that their request for continuation of their work
in the Reception Centre was denied. 329
H. Differential treatment of specific nationalities in the procedure
Indicators: Treatment of Specific Nationalities

1. Are applications from specific nationalities considered manifestly well-founded? Yes No
 If yes, specify which: Syria
2. Are applications from specific nationalities considered manifestly unfounded?330 Yes No

 If yes, specify which: Algeria, Morocco, Tunisia, Albania, Bosnia and Herzegovina,
North Macedonia, Kosovo, Montenegro, Serbia
328
Information provided by the Centre for Peace Studies,18 January 2023.
329
Information provided by the Rehabilitation Centre for Stress and Trauma,18 January 2023.
330
Whether under the “safe country of origin” concept or otherwise.
80
In Croatia there are no official policies implemented with regard to nationals of particular countries, as
every application is examined individually and on a case by case basis. However, in 2021 Croatia
accepted evacuated Afghan nationals and their family members and granted them international
protection. A total of 41 Afghan citizens were admitted from August to December 2021, three of whom
left the Republic of Croatia to reunite with their families, while the rest were granted asylum.331 Out of total
number, 16 were children.332
331
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/3v5TsVi.
332
https://bit.ly/3KzksTm.
81
Reception Conditions
Short overview of the reception system
The Ministry of the Interior, or more precisely its’ Service for reception and accommodation of applicants
for international protection, is responsible for the reception of applicants of international protection and
runs two Reception Centres for applicants of International protection, which are situated in Zagreb and
Kutina. The total reception capacity of these two centres is 740 places.
In 2022, within the project “Renovation of the Reception Centre for Applicants for International Protection
in Kutina”, the Kutina Reception Centre was renovated. The aim of the project was to improve reception
and accommodation conditions, and one of the results was that accommodation capacity of Kutina center
has been increased from 100 to 140.333
The highest number of applicants for international protection than ever before has been recorded in
Croatia, which required great efforts in adapting the reception and accommodation conditions.
Applicants of international protection have the right to accommodation from the day of expressing the
intention to apply for international protection until the enforceability of the decision on the application, if
they do not have an adequate standard of living.334
A. Access and forms of reception conditions
1. Criteria and restrictions to access reception conditions
Indicators: Criteria and Restrictions to Reception Conditions

1. Does the law make material reception conditions to asylum seekers in the following stages of
the asylum procedure?
 Regular procedure Yes Reduced material conditions No
 Dublin procedure Yes Reduced material conditions No
 Admissibility procedure Yes Reduced material conditions No
 Border procedure Yes Reduced material conditions No
 Accelerated procedure Yes Reduced material conditions No
 First appeal Yes Reduced material conditions No
 Onward appeal Yes Reduced material conditions No
 Subsequent application Yes Reduced material conditions No
2. Is there a requirement in the law that only asylum seekers who lack resources are entitled to
material reception conditions? Yes No
According to the LITP, applicants do not have the same access to reception conditions, so for example
material conditions may be restricted during the subsequent application procedure.
According to the LITP, applicants are entitled to accommodation at the Reception Centres for Applicants
for International Protection, but if they want, they are allowed to stay at any address in Croatia, subject to
prior approval by the Ministry of Interior, at their own cost.335 According to the Ordinances on the
Realisation of Material Reception Conditions, they are entitled to accommodation in the Reception Centre
from the moment they express the intention to lodge an application for international protection.336
During the examination of the Dublin procedure, applicants are entitled to a place in the Reception
Centres, as well as to all other material rights as prescribed by the LITP.
333
334
Article 7(1) Ordinance on the realisation of material reception conditions
335
Article 55(4) LITP.
336
Article 7(1) Ordinance on the Realisation of Material Reception Conditions.
82
According to the Ordinance on the Realisation of Material Reception Conditions, applicants are entitled
to financial support from the day when they were accommodated in the Reception Centre (i.e. the day on
which they express the intention to apply for international protection),337 ‘either if they do not hold
possession of greater value or if they do not have secured funds for personal use on a monthly basis
amounting to more than 20% of minimum amount for social welfare support.338
Applicants are entitled to financial support if, in the month for which they have received support, they have
been accommodated in the Reception Centre for Applicants for International Protection for at least 25
consecutive days.339 The only exception from this rule in relation to continuous accommodation is the
situation when the person has been admitted in the hospital for treatment or if he or she has requested to
be absent from the Centre and that the request has been approved.340
In practice the assessment of whether or not someone possesses sufficient financial means is determined
based on the statement of the applicant about his or her financial status which should be given when
applying for international protection.341 The Reception centre where the applicant is accommodated
confirms to the applicant the right to financial assistance and issues a certificate on the right to financial
assistance.342
It is not prescribed in legislation that material reception conditions are tied to the issuance of a document
by the relevant authorities. However, according to the Ordinance on the Realisation of Material Reception
Conditions an applicant who is accommodated in the Reception Centre, will be issued an accommodation
certificate that contains information, amongst other, on the date of expression of intention to apply for
international protection as well as the date from which the person is accommodated in the Reception
Centre.343 Besides that, applicants will be given an identity card which should be issued within 3 days
from the day of lodging the application and it shall serve as a residence permit in the Republic of Croatia.344
According to the Ordinance on the Realisation of Material Reception Conditions, Reception Centre where
applicant is accommodated, confirms the right to financial support and issues certificate approving the
right to financial support.345
Applicants who are detained in the Reception Centre for Foreigners are not allowed financial support. The
Ordinance on the Realisation of Material Reception Conditions prescribes that just those applicants who
have not secured adequate standard of living have a right to material reception conditions, 346 and
accommodation in the Reception Centre for Foreigners should be considered as the adequate standard
of living is secured.347
2. Forms and levels of material reception conditions
Indicators: Forms and Levels of Material Reception Conditions

1. Amount of the monthly financial allowance/vouchers granted to asylum seekers as of 31
December 2022 (in original currency and in €): HRK 100 / €13.3
According to the LITP, material reception conditions are: accommodation in the Reception Centre, food
and clothing provided in kind, remuneration of the cost of public transport for the purpose of the procedure
for the approval international protection, and financial aid.348 The manner and conditions of providing
material reception conditions shall be established by the Ministry of Interior, while the Reception Centre
337
338
339
340
341
342
Article 25 (1) (2) Ordinance on the Realisation of Material Reception Conditions.
343
344
Article 62(1) LITP.
345
Article 25(1)-(2) Ordinance on the Realisation of Material Reception Conditions.
346
347
348
Article 55(1) LITP and Article 1(2) Ordinance on the Realisation of Material Reception Conditions.
83
shall decide on the right to financial assistance. 349 The amount of financial assistance should be
established by the decision of the Minister of Interior.350
The Decision on the Amount of Financial Assistance for Applicants for International Protection prescribes
that the amount of support is 100 HRK per month, thus approximately €13.30. Monthly financial support
to applicants is very low, although the amount varies if there are dependent family members. The amount
of 100 HRK per month is very limited and can serve only as pocket money. Since mid-2016, applicants in
Zagreb may use public transport free of charge.
The system granting material reception conditions to applicants is separate from the general welfare
system for nationals, and is less favourable for applicants as compared to nationals.
3. Reduction or withdrawal of reception conditions
Indicators: Reduction or Withdrawal of Reception Conditions

1. Does the law provide for the possibility to reduce material reception conditions?
Yes No
2. Does the legislation provide for the possibility to withdraw material reception conditions?
Yes No
Material reception conditions may be restricted or denied if the applicant:

(1) Does not reside in the Reception Centre in which accommodation has been provided for him or
her;
(2) Stays outside the Reception Centre contrary the conditions referred in the LITP i.e. stays for
longer than 24 hours without the prior consent of the Reception Centre;
(3) Possesses means which provide him or her with an appropriate standard of living; or
(4) Violates the provisions of the house rules of the Reception Centre. 351
On the basis of a case by case assessment, the Reception Centre shall render a decision to restrict or
deny some of the material reception conditions, which is proportionate to the aim pursued, taking into
account the needs of applicants who require special procedural and/or reception guarantees and
maintaining the dignity of the standard of living of the applicant. If the circumstances referred under above
mentioned points (1) and (2) cease to exist, the Reception Centre has to render a decision to revoke the
decision entirely or partially. An appeal may be brought before the Administrative Court within 8 days from
the delivery of the decision. The Ministry has the right to request repayment of the costs of
accommodation, including material damage incurred, in the cases prescribed in above mentioned points
(3) and (4).352
There is no information available whether (or how many) decisions on reduction or withdrawal of reception
conditions were taken by the Ministry of Interior from 2019 to the end of 2022.
4. Freedom of movement
Indicators: Freedom of Movement

1. Is there a mechanism for the dispersal of applicants across the territory of the country?
Yes No
2. Does the law provide for restrictions on freedom of movement? Yes No
Applicants who are not detained can freely move within the country, and generally no restrictions are
applied with regard to the area of residence. In fact, applicants are allowed to stay – at their own cost –
at any address in the Republic of Croatia, subject to prior approval by the Ministry of Interior. According
to the Ordinance on the Realisation of Material Reception Conditions, in order to stay at some other
349
Article 55(2) LITP.
350
Article 55(3) LITP.
351
Article 55(5) LITP and Article 4(1) Ordinance on the Realisation of Material Reception Conditions.
352
84
address, the applicant must provide a notarised copy of the rental agreement or a notarised statement of
the owner of the apartment stating that they accept to accommodate the applicant and would provide him
or her with the adequate standard of living, or a title deed if the applicant is the owner of the property in
which he intends to reside, or a hotel reservation if the applicant is located in a hotel.353
For those applicants who are accommodated in the Reception Centres for Applicants of International
Protection, there is an obligation to inform the Head of the centre if they want to stay out for one or more
nights, as they have to return to the centre by 23:00. According to the amendments of the Ordinance on
the Realisation of Material Reception Conditions the Applicant may stay outside the Centre for more than
24 hours with the prior approval of the Reception Centre and for a maximum of 15 days. In this case
(except in certain cases such as lack of capacity and occupancy of accommodation facilities), the
allocated room will remain reserved. For any stay longer than 15 days, the applicant must submit the
appropriate documents and register his / her residence at a new address. 354
There are only two reception centres for applicants in Croatia, so in the past relocation of applicants was
possible from one centre to the other centre due to capacity / bed management issues or where special
needs would arise. However, since the Reception Centre in Kutina was renovated and reopened in June
2014, it was decided that this centre would be primarily used for the accommodation of vulnerable groups.
The LITP foresees restrictions on freedom of movement as Alternatives to Detention. The LITP specifies
that the freedom of movement may be restricted by the following measures: 355
(1) Prohibition of movement outside the Reception Centre for applicants;
(2) Prohibition of movement outside a specific area;
(3) Appearance in person at the Reception Centre for applicants at a specific time;
(4) Handing over travel documents or tickets for deposit at the Reception Centre for applicants; or
(5) Accommodation (i.e. detention) in the Reception Centre for Foreigners.
LITP lists 4 grounds for restricting freedom of movement (which are also grounds for detention):356
1. To establish the facts and circumstances of the application which cannot be determined without
limitation on freedom of movement, in particular where there is a risk of absconding;
2. To establish or verify identity or nationality;
3. To protect national security or public order; or
4. To prevent abuse of process where, on the basis of objective criteria, which include the possibility
of access to the procedure of approval of international protection, there is a well-founded
suspicion that the intention to apply for international protection expressed during the procedure
of forced return was aimed at preventing the procedure of removal.
For detention under the same grounds, see the chapter on Detention of Asylum Seekers.
353
354
355
Article 54(5) LITP.
356
Article 54(2) LITP.
85
B. Housing
1. Types of accommodation
Indicators: Types of Accommodation

1. Number of reception centres:357 2
2. Total number of places in the reception centres: 740
3. Total number of places in private accommodation: Not applicable
4. Type of accommodation most frequently used in a regular procedure:

Reception centre Hotel or hostel Emergency shelter Private housing Other
5. Type of accommodation most frequently used in an accelerated procedure:

Reception centre Hotel or hostel Emergency shelter Private housing Other
In Croatia there are 2 Reception Centres for Applicants of International Protection:
Capacity and occupancy of Reception Centres for Asylum Seekers: 2022

Centre Location Maximum capacity Occupancy
Hotel Porin City of Zagreb 600 N/A
Kutina 80km from Zagreb 140 N/A
Total 740 N/A
In 2019 reconstruction of the Reception Centre in Zagreb was finalised. The Croatian Red Cross assessed
that living conditions greatly improved thanks to renovation.358 In 2022, the Reception Centre in Kutina
was closed due to the renovation of the facility. The renovation was realised as part of the project
"Renovation of the Reception Centre for Applicants for International Protection in Kutina” that was
implemented from January 2020 to September 2022. The implementation of the project improved the
conditions of accommodation and stay of applicants in the Reception Centre, as well as the working
conditions of officials and other personnel.359
As a result of the project, the accommodation capacity of the Reception Centre in Kutina was increased
of 40 places (from 100 to 140). Beside that project, within the framework of the AMIF fund, three more
projects were implemented in the course of 2022, with the purpose of improving the reception and
accommodation conditions for the applicants for international protection.360
As for the statistics on the occupancy in both centres, they are not available for the period from 2019 to
2022.
Both reception centres are managed directly by the Ministry of Interior. The centre in Kutina is aimed at
the accommodation of vulnerable applicants, although throughout 2019 the centre accommodated mainly
persons who came through resettlement. At the end of 2019, when all resettled persons were relocated
in other cities and provided with paid apartments, it was decided that vulnerable applicants would again
be accommodated in Kutina.
In January 2021, the Directorate for European Affairs, International Relations and European Union Funds
of the Ministry of the Interior adopted a decision on the allocation of AMIF funds for the project
“Procurement of equipment for needs of MoI's Service for reception and accommodation of applicants
for international protection and Service for international protection- NOP2”. The purpose of the project is
357
Both permanent and for first arrivals.
358
Information provided by Croatian Red Cross, 20 December 2019.
359
Ministry of Interior, Successful completion of the project "Renovation of the Reception Center for Applicants
for International Protection in Kutina", available at: https://bit.ly/3MEvOYC.
360
86
to equip reception centres in accordance with the best European practice to improve the quality of life of
applicants as well as the working conditions for state officials.361 In April 2021, the decision on the
allocation of AMIF funds for the project “Increase of accommodation capacity of the Reception Centre for
applicants for international protection in Zagreb” was adopted.362
2. Conditions in reception facilities
Indicators: Conditions in Reception Facilities

1. Are there instances of asylum seekers not having access to reception accommodation because
of a shortage of places? Yes No
2. What is the average length of stay of asylum seekers in the reception centres? Not available
3. Are unaccompanied children ever accommodated with adults in practice? Yes No
Accommodation of applicants is organised in the two reception centres for applicants of international
protection, one in Zagreb and the other in Kutina.
The renovation of Reception Centre in Kutina was finalised in 2022 and capacity of the centre increased.
The Reception Centre in Kutina is primarily aimed at the accommodation of vulnerable applicants. The
Reception Centre in Zagreb was renovated in 2019, subsequently improving the living conditions in the
centre.
In 2020, due to COVID-19, one part of the Reception Centre in Zagreb was repurposed as a self-isolation
space in order to reduce the possibility of spreading COVID-19 and protect other applicants and
employees of the Ministry of Interior as well as organisations working in the Reception Centres. The self-
isolation premises were also functioning in 2022.
In 2022, reception and accommodation of applicants for international protection was challenging due to
the number of expressed intentions to apply for international protection and to the continuation of the
COVID-19 pandemic. The practice of placing all newcomers in the Reception Centre in self-isolation, in
accordance with health recommendations, continued until May 2022. In 2022 1,403 applicants for
international protection went through self-isolation, 199 people were tested, and the total number of
COVID-19 positive people was 48. Furthermore, all interested applicants were given the opportunity to
be vaccinated, and in 2022 a total of 125 people were vaccinated.363
In early May 2022, in agreement with the epidemiologists of the Andrija Štampar Teaching Institute of
Public Health”, the mandatory preventive isolation rules for the newly arrived applicants were lifted, and
a smaller isolation area was maintained only for patients who were SARS CoV-2 positive and their
contacts. Patients with symptoms were further tested and received appropriate treatment/medical follow-
up when tested positive for SARS CoV-2.364
In March 2020, access to Reception Centres for Applicants of International Protection became subject to
visitation restrictions, i.e. only personnel of the Ministry of Interior necessary for the normal functioning of
the Centre was allowed entrance to the facilities meaning that civil society organizations had to stop with
their activities in the centres, with the exception of the Croatian Red Cross and MdM.365 The same
361
Ministry of Interior, Decision on the allocation of AMIF funds for the project “ Procurement of equipment for
needs of MoI's Service for reception and accommodation of applicants for international protection and Service
for international protection- NOP2”,available in Croatian: https://bit.ly/3hIqzIi.
362
Ministry of Interior, Decision on the allocation of AMIF funds for the project “Increase of accommodation
capacity of the Reception Centre for applicants for international protection in Zagreb”, available in Croatian:
https://bit.ly/3vL8AJm.
363
364
365
Ministry of Interior, Applicants for international protection in the Republic of Croatia are not infected with the
coronavirus, 18 March 2020 available at: https://bit.ly/3xgvIOf.
87
organisation continued in 2022 and restrictions for nonessential entries to the centres remained in place
until the end of 2022.
2.1. Overall living conditions
Applicants can go outside whenever they want, but have to be back by 11 pm. Under the House Rules
the return to Centre after 11pm is possible with the permission of the officials of the Reception Centre. If
they want to leave the centre for a few days, they also have to get permission from the Reception
Centre.366
State of facilities
People in the reception centres share rooms. In Kutina, families share a room, unaccompanied children
and single women are accommodated separately in rooms, while in Zagreb a maximum 4 persons can
share a room.367 Families are accommodated in the same room, but in Zagreb if there are more than 5
members of one family, they are given 2 rooms if possible.368 There are sufficient showers and toilets and
facilities are cleaned on a regular basis.
As reported by the Croatian Red Cross, after the renovation of Reception Centre in Zagreb in 2019, the
overall living conditions have improved greatly. Since October 2021, accommodation of applicants was
organized only in the Reception Centre in Zagreb, since the Reception Centre in Kutina was closed due
to construction work on the facility. The renovation of Reception centre in Kutina was finalised by the end
of 2022.
Food and religious practice
In both centres, residents receive three meals per day and pregnant women, recent mothers and children
up to 16 years shall be also provided with an afternoon snack.369
Kitchens, equipped by the Croatian Red Cross, where applicants can prepare meals by themselves, are
provided in the Reception Centres in Kutina,370 and in Zagreb.371 However, there is no information
available whether kitchens were in function in 2020,2021 and 2022 due to pandemic.
No problems were reported in connection to the possibility of practicing religion. In the Reception Centre
in Zagreb, there is a room for Muslim applicants to pray. In Kutina, applicants can practice their religion
in their rooms.
The Islamic Religious Community in Croatia, takes care of the spiritual and other needs of applicants for
international protection of the Muslim religion, e.g. by cooperating with officials at the Reception Centres
for Applicants for International Protection in Zagreb in order to provide psychosocial support, religious
ceremonies as well as other activities.372
2.2. Activities in the centres
The staff of the Ministry of Interior working in the reception centres was generally sufficient. However in
2022, the main challenges resulted from the COVID-19 pandemic and highest numbers of applicants than
ever recorded.
366
Article 56(6) LITP.
367
Information provided by the Croatian Red Cross, 18 March 2019.
368
369
Article 20 Ordinance on the Realisation of Material Reception Conditions.
370
371
Information provided by the Croatian Red Cross, 20 December 2019.
372
Ministry of Interior, ‘Working together to successfully integrate asylum seekers’, 3 March 2019, available in
Croatian at: https://bit.ly/34f1kWp.
88
Access to reception centres was restricted from March 2020 until the end of 2022, with the exception of
personnel of the Ministry of Interior, Croatian Red Cross and MdM who ensured the normal functioning of
the facilities.373 Apart from CRC and MdM, other civil society organisations were not present in the centres
in the course of 2022. In 2022, as in previous years, most of the applicants remained in the centre for a
very short period of time and fluctuation of applicants who were voluntarily leaving the centre was
significant. At the same time, the capacity of the centre was filling with the new persons with the same
intensity.374
In 2022, Croatian Red Cross (CRC) continued to carry out activities with applicants for international
protection in Reception Centres in Zagreb.375 Applicants were provided with psychosocial support and
social activities were organised.
CRC also provided assistance in the implementation of the medical programme in Reception Centres.
More precisely, the CRC carried out the following activities in the Reception Centres:
- reception of newly arrived applicants for international protection,
- accommodation in isolation,
- distribution of hygiene packages, baby diapers, baby hygiene, bedding, blankets, towels, clothing and
footwear, including the purchase of clothing, footwear and underwear,
- ensuring the availability of washing machines, washing powder,
- arrangement of the interior and environment of the Reception Centre,
- distribution of meals during the stay in isolation,
- providing information on hygiene in order to promote hygienic habits and healthy lifestyles and health,
- activities such as billiards, creative workshop, library, hair salon,
- providing access to health care and assistance to applicants when going for medical examinations,
- provision of medicines and other medical supplies for applicants on the recommendation of a doctor,
- provision of food and other necessities on the recommendation of a doctor, including food for babies
and young children,
- provision of orthopaedic on the recommendation of a doctor,
- procurement of medical equipment, accessories and supplies, including small furniture for outpatient
clinics in Reception Centre,
- organising care for children of single parents during their visits for medical examinations,
- activities for children, especially preschool children,
- support to parents in the care and upbringing of children,
- assistance to children in school enrolment and learning,
- Croatian language workshops,
- informatics workshops for children and adults, and
- providing psychosocial support to applicants for international protection through initial and individual
and group interviews/support.
The work of the CRC team was organised in two shifts from 8 am to 4 pm, and from 12 pm to 8 pm, and
on weekends and during holidays from 8 am to 2 pm. The focus of the CRC activity was on the reception
of new applicants, as there was a great fluctuation of applicants throughout 2022. Depending on the
epidemiological situation, the activities were adapted to the situation. However, activities that took place
in continuity were those related to the psychosocial support, the health programme, medical assistance,
procurement of aids and other medical supplies, online teaching and school-related activities (e.g.
learning and helping with homework, learning the Croatian language).
Organisations continued with providing assistance and activities also outside the Reception Centre:
373
Ministry of Interior, 'Applicants for International Protection in the Republic of Croatia are not infected with the
coronavirus', 18 March 2020, available in Croatian at: https://bit.ly/3tFPPU4.
374
375
89
AYS376 reported having sent, in the summer of 2022, a request to the Ministry of Interior to hold two-day
workshops for children in the Reception Centre. The request was rejected with the explanation that
activities for children are already carried out in the framework of projects funded through AMIF so AYS
organised workshops at the outdoor space opposite the Reception Centre.
In 2022, AYS continued to run a so-called ”free shop” where applicants for and beneficiaries of
international protection could get clothes, shoes, hygiene items, dishes and other household items free
of charge. According to AYS, applicants accommodated in the Reception Centre for Applicants of
International Protection informed them that the distribution of clothing and hygiene in the Reception Centre
was insufficient to meet needs for the whole month.
AYS also provides support in learning the Croatian language. During 2022, AYS conducted 4 informal
Croatian language courses lasting for 4 months. The course is intended for both applicants of international
protection and persons who were granted international protection and it took place in the premises of the
AYS integration centre. Each course started when it reached 10 participants. AYS conducted a literacy
course for people who are illiterate in Latin Script, so that they can start with a language course. AYS
reported that their organisation received more inquiries for the language courses compared to the capacity
of the organization. Most of the participants were applicants for international protection. During the year,
the demographics of the participants was changing. At the beginning of the war in Ukraine, a large number
of applicants from Russia joined the course, while at the end of the year, the number of people from
Burundi and Chechnya increased. In addition, AYS collaborated with Croaticum, which organizes courses
at the B1 level for people who have already know some basics of Croatian language.
In 2022, in addition to psychological support, psychotherapy and art therapy activities, the Rehabilitation
Centre for Stress and Trauma (RCT) also carried out activities focused on social mentoring, preparation
for the labor market and employment, contacts with employers, support in terms of accompaniment and
translation when exercising rights in the social welfare system, socio-cultural orientation workshops and
creative workshops, and provided support to asylum seekers at the risk of homelessness. RCT reported
that their request to continue with providing activities in the Reception Centre for Applicants of
International Protection, was rejected.377
The Centre for children, youth and family Modus provided psychosocial counselling.378
The Croatian Law Centre’s (CLC) lawyers were providing legal counseling to interested applicants in CLC
premises, but also through phone and email.
Centre for Peace Studies (CPS) did not have access to the Reception Centre, so most of their activities
targeting applicants for international protection took place in their premises or in premises of collaborating
organisations in 2022. In 2022, employees and volunteers of the CPS provided applicants for international
protection with information on the system of international protection, as well as with legal support and
counselling. CPS provided legal assistance to applicants for international protection in CPS premises but
also online, by e-mail, and by telephone. Although CPS did not implement activities in the Reception
Centre for Applicants for International Protection, the Ministry of Interior, at the CPS's request, placed
CPS' posters containing information about the possibility of free legal aid in the CPS premises, in the
Reception Centre. In addition, CPS carried out other activities such as providing support in learning the
Croatian language, providing information about life in Croatia, as well as psychosocial support.379
IOM implemented the voluntary return and reintegration programme (AVRR.hr).
Due to the COVID-19 pandemic, access to Reception Centres for applicants of international protection in
Zagreb was limited to prevent the spread of the SARS-CoV-2 virus, so IOM had to adjust its activities,
376
Information provided by Are You Syrious, 3 February 2023.
377
378
Information provided by the Centre Modus, 9 January 2023
379
90
relying on officials working in the Centre and employees of non-governmental organisations that provide
necessary services to applicants.
However, from March 2022, due to the easing of the pandemic situation, the IOM restarted carrying out
regular visits every two weeks to the Reception Center for Applicants for International Protection in Zagreb
with the aim of informing applicants about the possibility of voluntary return, and conducting consultations
with interested persons. If necessary, IOM organized voluntary return for the applicants who decided to
return.
In 2022, a sufficient number of informative multilingual posters and leaflets were provided inside the
Reception Centre, which referred applicants to IOM in case of a desire for voluntary return, In addition,
open communication channels for access to information are regularly maintained with employees of the
Ministry of Interior and non-governmental organizations working in the Reception Centre.380
2.3. Duration of stay in the centres
No information on the average length of stay in the reception centres in 2022 is available. However, in
practice, applicants do not stay for long periods in reception centres as most of them leave the country
after a few weeks or even days. Croatia is still a transit country and it is estimated that more than 70-80%
of applicants for international protection leave the country. In 2022, there was a great discrepancy
between expressed intentions and submitted applications for international protection. Namely, 12,872
persons expressed their intention to seek international protection, while only 2,727 of them submitted
application for international protection. Although there are no official statistics from which it can be
conclude that all of 10145 applicants have left Croatia, the unofficial information stipulates that the high
number of applicants after they expressed intention, did not appear at the Reception Centre for Applicants
for International Protection within the prescribed deadline, which suggests that they have continued their
journey to other EU countries.
In the regular procedure, applicants can be accommodated in the Reception Centre until the completion
of the procedure and a final decision is taken on the case (at first instance and during the administrative
dispute). When a final negative decision on the application for international protection has been taken and
the time for executing the order to leave the country has elapsed, the right to receiving reception conditions
ends.
C. Employment and education
1. Access to the labour market
Indicators: Access to the Labour Market

1. Does the law allow for access to the labour market for asylum seekers? Yes No
 If yes, when do asylum seekers have access the labour market? 9 months
2. Does the law allow access to employment only following a labour market test? Yes No
3. Does the law only allow asylum seekers to work in specific sectors? Yes No
 If yes, specify which sectors:
4. Does the law limit asylum seekers’ employment to a maximum working time? Yes No
5. Are there restrictions to accessing employment in practice? Yes No
Applicants have the right to work after 9 months from the day of lodging the application upon which the
Ministry of Interior has not yet rendered any decision, if the procedure has not been completed due to no
380
Information provided by IOM, 18 January 2023.
91
fault of the applicant.381 To this end, they do not need a residence or work permit, or a work registration
certificate, until the decision on their application is final.382
The Ministry of Interior should issue a document at the request of an applicant to certify that the applicant
has acquired the right to work. On the other side, if the applicant does not meet the conditions, the Ministry
shall render a decision refusing to issue the certificate.383
In 2022, the Administrative Court in Zagreb received 2 lawsuits regarding certificates granting the right to
work, which were rejected.384
According to the Croatian Employment Service (CES) registration in the records of the CES is regulated
by Law on Labour Market as of 1 January 2019.385 According to the data of the CES, 2 female applicants
for international protection (one from Ukraine and 1 from Russian Federation)) were registered in their
records of unemployed persons on 31 December 2022, while 2 applicants for international protection were
receiving individual counselling at CES.386
Applicants can work on a voluntary basis in both Reception Centres.387 According to the Ordinance on
the Realisation of Material Reception Conditions, applicants accommodated in the Reception Centre for
Applicants for International Protection may, at their own request and with a signed statement, assist in
activities related to the maintenance of the centre and housing such as cleaning, landscaping, gardening,
help in storehouse, washing, ironing, painting the walls, etc., and can be voluntarily involved in work for
the benefit of local community or the work of humanitarian organisations.
Are You Syrious (AYS) reported that, in the last quarter of 2022, they provided information to applicants
of international protection on the right to work and provided support in job searching (e.g. writing CVs,
contacting employers).388 As a shortcoming to the current legislative solution, they pointed out the 9
months period for implementation of right to work, which prevents early integration into the labour market.
Centre for Peace Studies389 and Rehabilitation Centre for Stress and Trauma390 also provide support in
job searching.
2. Access to education
Indicators: Access to Education

1. Does the law provide for access to education for asylum-seeking children? Yes No
2. Are children able to access education in practice? Yes No
The right to education is a constitutional right for all children staying in Croatia. According to the LITP,
only child applicants (i.e. those under 18) are entitled to primary and secondary education.391 Applicants
who have begun to exercise the right to secondary education are allowed to continue secondary education
even after they have turned 18.
According to the LITP, the right to primary and secondary education is granted to child applicants under
the same conditions as for Croatian nationals, and children can access education within 30 days of lodging
an application.392
381
Article 61(1) LITP.
382
Article 61(5) LITP.
383
384
Information provided by Administrative Court in Zagreb, 23 January 2023.
385
Article 14 Law on Labour Market, Official Gazette 118/2018, 32/2020, 18/2022.
386
Information provided by the Croatian Employment Service, 12 January 2023.
387
Article 19 Ordinance on the Realisation of Material Reception Conditions.
388
Information provided by AYS, 3 February 2023.
389
390
Information provided by Rehabilitation Centre for Stress and Trauma, 18 January 2023.
391
Article 58(1) LITP.
392
Article 58(3) LITP.
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According to the Ministry of Interior, the procedure for enrolment of asylum-seeking children in pre-school,
elementary or high school is performed by the employees of the Reception Centre for Applicants for
International Protection, while for those children who are accommodated in social welfare institutions,
procedure is carried out by their guardians.
Child applicants are also entitled to special assistance to learn Croatian and to make up for the knowledge
they might lack in some school subjects, in the form of preparatory and supplementary classes. 393 In
November 2011, a Programme of Croatian for preparatory classes for primary and secondary school
students who do not speak or speak Croatian insufficiently was adopted. This is an intensive 70-hour
course of Croatian, spread over a maximum of one academic year.
AYS reported that the problems related to inclusion of children to preparatory classes continued in 2022.
According to them, in practice, organisation of preparatory classes is extremely lengthy and children often
wait for months before preparatory classes are approved. Also, some children have to go to another
school for preparatory classes, and as a result, they cannot attend part of classes at their own school. 394
In 2021, Centre for Peace Studies (CPS) published the thematic report” Education of Children of Asylum
Seekers and Refugees in the Republic of Croatia - (In) readiness for quality inclusion in the education
system”.395 The report analyses the response of the Republic of Croatia to the needs of children, with a
specific focus on access to education but also the identified difficulties and existing legislative framework.
In addition, the report provides some examples good practices.
According to the Ministry of Science and Education, in order to be included to the educational system,
candidates are required to have following documents: a certificate of status in the Republic of Croatia; a
certificate of residence in the Republic of Croatia; an identity document (birth certificate, identity card,
passport or corresponding document of the Ministry of the Interior of the Republic of Croatia); and a
document on previous education.396 If they do not have a document on previous education, they need to
give a statement at a public notary and then present said statement to the services of the educational
institution in order for them to organize an enrolment test and determine which class the candidate can
attend.
According to the Ministry of Labour, Pension System, Family and Social Policy unaccompanied children
faced obstacles to accessing primary and secondary education. The problems include a lack of
documentation proving these children’s previous education, acquired knowledge and skills; lengthy school
enrolment processes (especially in secondary schools); too few interpreters; issues with age assessment;
and local community resistance.397
The ombudsperson for Children reported that difficulties with inclusion in the educational system were
recorded in 2022, primarily for children enrolled in high school. The challenges relate to the
unpreparedness of educational institutions to work with children from the migrant population, insufficient
engagement of special guardians for inclusion in school, organisation and division of responsibilities of
guardians and employees of institution regarding enrolment and transportation from the institution where
the child is accommodated. On the other hand, older children are not included in educational system due
to their own lack of interest, illiteracy, lack of formal education in the country of origin or during the travel,
but also due to the fact that they often leave the country soon after arrival. Ombudsperson also reported
that although 74 procedures for enrolment were initiated, only 18 were realised.398
393
Article 58(4) LITP; Article 43 Law on Education in Primary and Secondary Schools (Official Gazette 87/08,
86/09, 92/10, 90/11, 5/12, 16/12, 86/12, 126/12, 94/13).
394
395
Information provided by Centre for Peace Studies, 10 January 2022. See also: https://bit.ly/35VYJFI.
396
Information provided by the Ministry of Science and Education during the webinar „The Protection of
Unaccompanied Children: Procedure and Exercising Rights After the Accommodation of Children” organised
by the Croatian Law Centre on 2 March 2021.
397
FRA, Migration: Key fundamental rights concerns- January- June 2121, Quarterly bulletin, available at:
https://bit.ly/3w1ydGj.
398
https://bit.ly/3NkGzQ9.
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During 2022, for 74 children (both unaccompanied, and accompanied by their families) the enrolment
process in the educational system was initiated, but only 18 of them attended school – 1 child in preschool
programme, 13 children in primary education and 4 children in secondary education. The significant
disproportion between the number of children for whom the enrolment in education system was initiated
and the number of children who attended it is the result of the dynamics of movement of applicants for
international protection and the fact that Croatia is not their destination country. In several cases, parents
resisted the enrolment of their children in the educational system, especially for girls. 399
Beyond access to schools, several organisations provide educational activities and language classes as
described in details in Conditions in Reception Facilities.
D. Health care
Indicators: Health Care
1. Is access to emergency healthcare for asylum seekers guaranteed in national legislation?
Yes No
2. Do asylum seekers have adequate access to health care in practice?
Yes Limited No
3. Is specialised treatment for victims of torture or traumatised asylum seekers available in
practice? Yes Limited No
4. If material conditions are reduced or withdrawn, are asylum seekers still given access to health
care? Yes Limited No
1. Primary health care
Applicants are entitled to health care. However, the LITP prescribes that health care includes emergency
care and necessary treatment of illnesses and serious mental disorders. 400
In 2020, an Ordinance on health care standards for applicants for international protection and foreigners
under temporary protection entered into force regulating, amongst other, initial and supplementary
medical examinations and the scope of health care for applicants of international protection. 401
Additionally, the Ordinance lists the different vulnerable groups entitled to health care as follows: persons
deprived of legal capacity, children, unaccompanied children, elderly and infirm persons, seriously ill
persons, persons with disabilities, pregnant women, single parents with a minor children, people with
mental disabilities and victims of human trafficking, victims of torture, rape or other psychological, physical
and sexual violence, such as victims of female genital mutilation. These categories of persons have a
right to psychosocial support and assistance in appropriate institutions A pregnant woman or a parturient
woman who requires monitoring of pregnancy and childbirth is entitled to health care to the same extent
as insured person from compulsory health insurance. Children up to the age of 18 are guaranteed the
entire right to health care in accordance with the legislation governing the right to health care from
compulsory health insurance.402
Medical assistance is available in the Reception Centres for Applicants for International Protection in
Zagreb and Kutina. While no information is available for the period from 2019 until the end of 2022. At
the beginning of 2019, the Ministry of Interior reported that health care is also provided by the health care
institutions in Zagreb and Kutina designated by the Ministry of Health.403 In the Health Centre, a
competent ambulance (family medicine) has been designated for the provision of health care from the
399
400
Article 57(1) LITP.
401
Official Gazette 28/2020, available in Croatia at: https://bit.ly/3asTWel.
402
Article 9 (1) (4) Ordinance on health care standards for applicants for international protection and foreigners
under temporary protection
403
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primary health care level for chronic and life-threatening illnesses. A specialist ambulance for vulnerable
groups has been appointed by the Ministry of Health and Local Health Centres. This includes: paediatric
ambulance, gynaecological ambulance, school medicine ambulance, neuropsychiatric ambulance at the
Hospital of Kutina, ambulance for addiction treatment; dental ambulances and Psychiatric Hospital in
Zagreb.
In addition, applicants are referred to local hospitals i.e. in Sisak for those accommodated in Kutina, and
the Hospital of Zagreb. The competent pharmacies, one in Zagreb and one in Kutina, have also been
determined. Vaccination is performed by doctors in health centres or by specialists of school medicine.
A medical team of MdM was present at the Reception Centre in Zagreb every working day.
Due to outbreak of COVID 19, after being accommodated in Reception Centres for Applicants of
International Protection, applicants for international protection were placed quarantine.
Until June 2021, the self-isolation period lasted 14 days for all newcomers who arrived from Bosnia and
Herzegovina, Serbia and other high-risk countries, while from June 2021 the self-isolation period was
shortened to 10 days (except for persons returned under the Dublin Regulation, whose duration of self-
isolation remained at least 14 days).404
In May 2022, the mandatory preventive isolation rules for the newly arrived applicants in the Reception
Centre for Applicants of International Protection were lifted, and a smaller isolation area was maintained
only for patients who were SARS CoV-2 positive and their contacts.405
At the beginning of the COVID-19 pandemic, the Croatian Institute for Public Health issued Protocol
related to testing for COVID-19 / SARS-CoV-2.406 The protocol states that, among others, applicants for
international protection and refugees belongs to priority groups for testing.
Information posters and/or leaflets on COVID 19 and hygiene were prepared by the Croatian Institute for
Public Health and Ministry of the Interior,407 Médecins du Monde (MdM),408 and the Croatian Red Cross. 409
Multilingual info-prevention posters and flyers for applicants were displayed in the Reception Centre for
Applicants for International Protection.
In July 2021, the government decided to provide access to COVID-19 vaccination both to Croatian citizens
and other persons who hold foreign citizenship and who do not have status of insured persons in the
Republic of Croatia.
In 2022, in cooperation with IOM Slovenia and Croatian Ministry of Interior, posters and brochures on
vaccination against COVID-19 were developed in several languages and distributed, among others, to
the Reception Centre for Applicants of International Protection. The brochures list the benefits of
vaccination against COVID-19, explain how applicants and beneficiaries of international protection can
approach vaccination, and present the currently available vaccines and their possible side effects.
Information on the validity of the vaccination certificate against COVID-19 and general protection
measures can be also found in the materials. A total of 1,300 brochures and 25 posters were distributed.
Furthermore, an awareness video for applicants and beneficiaries of international protection was
developed to raise awareness of the importance of vaccination against COVID-19 and support informed
decisions about vaccination against COVID-19. The video which is available in 5 language versions can
404
405
406
Croatian Institute for Public Health: Protocol related to testing for COVID-19 / SARS-CoV-2, 21 March 2020,
available in Croatian at: https://bit.ly/3nbDDYz.
407
Croatian Institute for Public Health and Ministry of Interior leaflets available in Croatian at:
https://bit.ly/3aotkeH; in Farsi at: https://bit.ly/2P9cf0V.
408
MdM, 'Washing hands poster', 2020, available in severl langauges at: https://bit.ly/3vfZJw1.
409
Croatian Red Cross information on available sources of information on COVID-19, available in Arabic at:
https://bit.ly/3avMuPT.
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be found on the website of IOM Croatia, as well as brochures. 410 In addition, it was distributed to key
stakeholders for their use in future prevention activities involving migrant communities.411
In 2022, as in 2021, MDM-BELGIQUE’s team also further informed applicants for international protection
about the possibility of vaccination and organised transportation with interpreters to the main public
vaccination centre in Zagreb.
In 2022, MDM-BELGIQUE’s team developed info-prevention posters/leaflets on three different topics:

"How I feel matters”, “Everyone has the right to birth control” and “There is no room for violence in the
family”; as well as a brochure on mental health.412
In 2023, MdM issued the publication “Physical and mental health of applicants for international
protection in the Republic of Croatia - new trends, observations, challenges and recommendations”.413
Complementary services by NGOs
In 2022, the MDM- BELGIQUE’s team consisted of one general practitioner, one nurse and interpreters
(4-6 interpreters throughout 2022 - for Arabic, Farsi, Russian, Spanish and French languages). 414
The MDM-BELGIQUE team provided health care for applicants for international protection in the
Reception Centre for Applicants for International Protection and facilitated their access to public health
institutions in order to gain access to the primary health care, specialist-consultative and diagnostic
examinations and treatment. This included conducting initial health examinations of newly arrived
applicants and providing continuous health consultations in the premises of the Reception Centre (work
with patients: 6 hours every working day) in order to facilitate access to a general practitioner of the
Ambulance for applicants for international protection at the local Health Centre. These activities enabled
the MDM-BELGIQUE medical team to assess the health status of applicants for international protection
and to organise appropriate treatment and additional health care following the recommendation of a
general practitioner of the Ambulance for applicants for international protection (if referral is required).
In order to provide comprehensive support and care to patients, the community worker / social worker
and interpreters/cultural mediators provided practical support to applicants for international protection in
terms of interpretation, provision of information and counselling, transport of patients to health care
facilities. MDM-Belgique arranged the dates of examinations in health care institutions, organised the
transport schedule and patient transportation (including the transport schedule for the Croatian Red
Cross) and accompanied patients to their appointments with the help of interpreters.
Regular vaccination of children and medical visits for pre-school/school enrolment were carried out
continuously in 2022 through the cooperation with the Health Centre and Andrija Štampar Teaching
Institute of Public Health. Transportation of children to relevant health institutions and hospitals and
other health centres with paediatric clinics was conducted regularly.
In 2022, the MdM’s medical team carried out 3,076 medical consultations with applicants for international
protection, out of which 2,342 were initial medical examinations of newly arrived applicants. Out of the
3,076 medical consultations: 44.7% were organized with women and 33.1% with children. The most
represented nationalities were Kurdish population from Iraq and Türkiye (25.9%), Afghans (16.7%) and
Cubans (13.6%). In addition, a total of 380 transports of 250 applicants for international protection to
health care facilities for the necessary specialist and diagnostic treatment were performed (including 27
transports for children to paediatricians/vaccinations/school medicine specialists).
Furthermore, in 2022, between 2 and 11 pregnant women were accommodated at the same time at the
Reception Centre in Zagreb (total of 101 during the entire year). MDM-BELGIQUE’s team provided them
410
See: https://croatia.iom.int/improving-access-covid-19-vaccinations
411
412
413
Available in Croatian at: https://bit.ly/3IQ6ZI7; and in English at: https://bit.ly/3C4pO6r.
414
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with comprehensive healthcare services in cooperation with the Outpatient Clinic Zagreb - Centar
(including gynaecological examinations and necessary tests) and accompanied them to the Clinical
Hospital for Women's Diseases and Obstetrics of the University Hospital Centre Zagreb, or to the „Sveti
Duh” Hospital.
In 2022, the MDM team also held info prevention workshops for women and girls. The workshops were
held on the topic of mental health and psychosocial support, and took place, on average, once a week in
the Reception Centre in Zagreb.
Given the specific conditions of the migration route, which include poor nutrition and limited possibilities
for maintaining oral hygiene, a significant number of beneficiaries needed dental services. Through
cooperation with “Health Centre Zagreb - Centar“, MDM-BELGIQUE tried to provide the necessary care
to applicants who needed dental services in order to prevent the number of emergency dental treatments
and complex interventions. For this purpose, communication was established with 12 dental medicine
specialists, and successful cooperation was established with 8 of them. Regular organisation of dental
care services presented the additional workload of organising transportation and interpretation, for MDM-
BELGIQUE’s team.
Since March 2020 and throughout 2021 and 2022, MDM-BELGIQUE’s team was also in charge of health
protection and prevention of SARS CoV-2 among the population of applicants for international protection
accommodated in the Reception Centre for Applicants in Zagreb in close cooperation with Andrija
Štampar Teaching Institute of Public Health , Ministry of Interior, Croatian Red Cross and other relevant
stakeholders.
In early May 2022 and in agreement with the epidemiologist of the Andrija Štampar Teaching Institute of
Public Health”, the mandatory preventive isolation rules for the newly arrived applicants were lifted, and
a smaller isolation area was maintained only for patients who were SARS CoV-2 positive and their
contacts. Patients with symptoms were further tested and received appropriate treatment/medical follow-
up when tested positive for SARS CoV-2.
MDM-BELGIQUE’s team further also informed applicants for international protection about the possibility
of vaccination and organised transportation with interpreters to the main public vaccination centre in
Zagreb. Lastly, multilingual info-prevention posters and flyers for applicants were displayed at the facility.
In 2022, 1403 persons went through preventive isolation area of the Reception Centre for Applicants for
International Protection (which was removed in May 2022), 199 persons were tested, 48 persons who
tested positive for SARS CoV-2 received appropriate treatment/medical follow-up and 125 persons were
supported to access vaccination against SARS CoV-2.
In total, in the period between March 2020 and December 2022, 5,569 persons went through an isolation
area in Reception Centre for Applicants for International Protection in Zagreb (removed since May 2022),
799 persons were tested; 122 persons who tested positive for SARS CoV-2 received appropriate
treatment/medical follow-up; 321 persons were supported to access vaccination against SARS CoV-2.
Two MDM-BELGIQUE’s psychologists further conducted initial psychological assessment and individual
psychological counselling (working with beneficiaries for 6 hours every working day), as well as
emergency interventions when needed in 2022. Alongside permanent team members, MDM-BELGIQUE
continued to cooperate with an external associate (psychiatrist) in 2022, who was conducting psychiatric
examinations of asylum seekers in Zagreb three times per month. Compared with previous years, in 2022,
MDM-BELGIQUE observed additional increase of sexual and gender-based violence cases (SGBV) - with
a total of 66 cases. MDM-BELGIQUE offered adequate psychological assistance and/or psychiatric
treatment to all survivors as well as assistance with other necessary referrals - in cooperation with relevant
service providers.
Main challenge encountered by MDM throughout 2022 was the large surge in the numbers of applicants
for international protection in Croatia as well as further intensification of transit migration levels (at the
beginning of 2022, applicants were staying in Croatia for, on average, 30 days, while during August and
September for an average of 3 days).
97
Besides particularly complex cases (which included post-operative care after reconstructive foot surgery,
cases of severe PTSD, suicidality, severe chronic diseases and acute conditions), increasing arrivals
resulted in a large surge in the number of first health examinations that needed to be conducted by the
team (up to 110 newcomers per day; with some weeks with around 500 arrivals), but also additional
administrative work of ordering diagnostics tests, specialist examinations and planning transport
schedules - that often needed to be cancelled because applicants left Croatia before scheduled
appointments. The increased workload resulted in high level of stress and fatigue for the origination’s
staff.
In July 2020, the Directorate for European Affairs, International Relations and European Union Funds
issued a decision on the allocation of financial resources for the implementation of the project to be
implemented by MDM.415 The aim of the project is to protect the health and prevent disease among
applicants of international protection through improved access to first examinations and medical
consultations in Reception Centres for applicants for international protection. The project lasts until 31
December 2022.
Due to lack of funding, MdM had to temporary suspend their activities inside the reception centers for
applicants for international protection from 22 May 2023.416
2. Mental health
Psychological counselling and support was provided by MdM during 2021.417
Two MdM’s psychologists conducted initial psychological assessments and individual psychological
counselling sessions every working day for 6 hours, as well as emergency interventions when needed.
Cooperation with an external associate – psychiatrist continued in 2022 who was visiting the Reception
Centre in Zagreb three times a month. An increase in the number of reported cases of sexual and gender-
based violence (SGBV) (as well as the number of applicants) compared to the previous year was noted
in 2022. A total of 66 cases were reported. MdM’s psychologists offered adequate psychological help and
support and, if necessary, included them in adequate psychological and/or psychiatric treatment. During
2022, 665 individual psychological consultations were carried out by two psychologists, and 96 specialist
psychiatric examinations were conducted by one psychiatrist.
In addition, three info-prevention posters/leaflets concerning mental health, protection of reproductive

health and violence-prevention were distributed: "How I feel matter”, “Everyone has the right to birth
control” and “There is no room for violence in the family”", as well as a brochure on mental health.
Additional info-prevention workshops for women and girls on the topics of mental health and psychosocial
support were also conducted on average once a week in the course of 2022.
Additional issues related to trauma and mental health of applicants for international protection are further
described in Screening of vulnerability.
3. Special health needs
Applicants who need special reception and/or procedural guarantees, especially victims of torture, rape
or other serious forms of psychological, physical or sexual violence, shall be provided with the appropriate
health care related to their specific condition or the consequences resulting from the mentioned acts.418
However, this type of specialised health care has been lacking for years in practice. According to the Law
on Mandatory Health Insurance and Health Care for Foreigners in the Republic of Croatia, an ordinance
which defines the scope of the right to health care for applicants who has been subject to torture, rape or
other serious forms of violence and as well as for those with special health care needs, should have been
415
Ministry of Interior: Decision on the allocation of financial resources 31 July 2020, available in Croatian at:
https://bit.ly/3eiRKat.
416
Information provided by MdM, 19 June 2023.
417
418
Article 57(2) LITP.
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adopted in previous years, however the Ordinance on health care standards for applicants for international
protection and foreigners under temporary protection was finally adopted in 2020 and entered into force
in March 2020 (see Primary health care for more information).419
According to national legislation, the procedure of recognising the personal circumstances of applicants
shall be conducted continuously by specially trained police officers, employees of the Ministry of Interior
and other competent bodies, from the moment of the expression of the intention to apply for international
protection until the delivery of the decision on the application. However, according to CLC’s knowledge
there is still no further detailed guidance available in the law, nor an early identification mechanism in the
form of internal guidance. According to the Croatian Law Centre’s insights, less evident vulnerabilities
such as those relating to victims of torture are much less likely to be identified in current practice (see
Identification).
However, in 2020, as part of the project implemented by MDM-Belgique entitled: "Empowering Women
and Children in the migrant population to take ACTion against sexual and gender-based violence (We
ACT)", Guidelines for dealing with cases of sexual violence against women and children were prepared.
The content of guidelines was incorporated in the Standard Operational Procedure in Cases of Sexual
and Gender-Based Violence in the Reception Centres for Applicants of International Protection” .420 The
Standard Operational Procedure was developed in cooperation with the Ministry of Interior, UNHCR, IOM,
MDM-BELGIQUE, the Croatian Red Cross and the Croatian Law Centre. It entered into force in April
2021.
E. Special reception needs of vulnerable groups
Indicators: Special Reception Needs

1. Is there an assessment of special reception needs of vulnerable persons in practice?
Yes No
The LITP enumerates as vulnerable persons: persons without legal capacity, children, unaccompanied
children, elderly and infirm persons, seriously ill persons, disabled persons, pregnant women, single
parents with minor children, persons with mental disorders and victims of trafficking, as well as victims of
torture, rape or other forms of psychological, physical and sexual violence, such as victims of female
genital mutilation.421 The LITP provides special procedural and reception guarantees (see section on
Special Procedural Guarantees).
However, up until now the Ministry of Interior does not have a special unit dealing with vulnerable groups,
but accommodates their needs in the general reception system.
When accommodating applicants in the Reception Centre, gender, age, position of vulnerable groups,
applicants with special reception needs and family unity shall be particularly taken into account.422 Those
with special reception needs may be placed in an appropriate institution or can be accredited to
accommodation in accordance with regulations on social welfare, if accommodation appropriate for their
needs cannot be provided in the Reception Centre.423
The Ordinance on the Realisation of Material Reception Conditions prescribes that reception conditions
should be adapted to the needs of applicants, psychosocial support should be provided, and special care
should be given to applicants with special reception needs. The process of identifying those with special
reception needs should be conducted by professionals who provide psychosocial support in the Reception
Centre, and if necessary, the competent Centre for Social Welfare can participate in the assessment. The
419
Official Gazette 28/2020, available in Croatia at: https://bit.ly/2QKE3ZK.
420
421
422
Article 56(4) LITP; Article 6(1) Ordinance on the Realisation of Material Reception Conditions.
423
99
Centre for Social Welfare involved in the procedure of identifying applicants with special reception needs
shall notify the Reception Centre of all measures and actions taken.424
Applicants with special health care needs shall be provided a special diet, based on the recommendations
of the physician.425
There is no monitoring mechanism in place with regards to measures for addressing special needs of
applicants accommodated in the centres. However, social workers of the Ministry of Interior and the
Croatian Red Cross are available daily in the Reception Centres and can provide support. In practice,
during their regular work and communication with applicants as well as during individual and group
support, Croatian Red Cross employees can observe the needs of vulnerable groups and, where there is
a need, can accordingly propose changes in the reception of particular applicants to the Head of
Reception Centre (for example, a person may need to be accommodated in a single room, or with other
persons, or may need to be relocated to the Reception Centre in Kutina, which is specifically designed
for vulnerable applicants).
The Ministry of Interior, depending on the needs of the applicant, cooperates with other competent bodies
in relation to reception guarantees, for example with Centres for Social Welfare which are, when
appropriate, included in the procedure for assessing special needs. In the case when adequate
accommodation cannot be provided for those persons in the Reception Centre for Applicants for
International Protection, a person would be accommodated in another appropriate institution or can be
granted accommodation according to the social welfare regulations. Also, when needed, special dietary
requirements will be provided based on the recommendation of the competent physician. Applicants
accommodated in the Reception Centre are provided with three meals a day and pregnant women, babies
and children under the age of 16 are provided with an afternoon snack. Upon recommendation of the
doctor, separate accommodation would be provided to those with special reception needs. If needed, they
would be provided with appropriate health care related to their specific health condition.426
In regard to persons with special needs who were accommodated outside Reception centres, in 2022
there were two adult applicants for international protection who were provided accommodation in special
social welfare institutions due to their health condition.427
In 2020, the NGO Rehabilitation Centre for Stress and Trauma (RCT) informed FRA that they noted
difficulties in ensuring the standards laid down in the Receptions Conditions Directive, especially for
vulnerable applicants. They reported that an applicant with amputated legs was placed in a facility for the
elderly with mental problems, which was not adapted for people in wheelchairs. They also highlighted the
lack of effective mechanisms to identify torture victims.428 Similar findings were reported by RCT in
2021.429 Centre for Peace Studies (CPS) also pointed out that there is still an inadequate system for
identifying vulnerable groups within Reception Centres for Applicants of International Protection and
Reception Centre for Foreigners. CPS also reported the questionable level of providing psychological
support to applicants in reception centres suffering from trauma, PTSD and similar conditions in which
quality, professional, individualised psychological support is needed 430
1. Reception of women and children
424
Article 12(1)-(3) Ordinance on the Realisation of Material Reception Conditions.
425
426
427
428
FRA, Migration: Key fundamental rights concerns - Quarterly bulletin 4 – 2020, available at:
https://bit.ly/3avkqMn.
429
430
Information provided by the Centre For Peace studies, 10 January 2022.
100
Separate premises are provided in the Reception Centre in Kutina for women and vulnerable groups.
Families are kept together, while single women, unaccompanied children and traumatised applicants are
accommodated in separate rooms.
2. Reception of unaccompanied children
With regard to unaccompanied children, the LITP prescribes that the guardian of an unaccompanied child
shall undertake all the necessary activities, including contact and cooperation with the competent
ministries, other state and foreign bodies, and NGOs, in order to reunite the child with his or her family if
this is in the best interests of the child.431
In practice, most unaccompanied foreign children up to now are placed in children and young people’s
homes. Children under 14 years of age are accommodated in children’s homes, while children above the
age of 14 are accommodated in Residential Child Care Institutions. Although these are open facilities,
they are not adapted to the needs of this category of children. Special concerns from various NGOs have
been raised in relation to accommodating children in Residential Child Care Institutions as their primary
function is to treat children with behavioural difficulties, so the conditions of their stay cannot be
considered suitable for this group, especially when taking into account the specific needs of these
children, as well as unavailability of interpreters in those institutions.432
The Croatian government designated two facilities for children in Zagreb and in Split for the initial
reception of UASC during which best interests’ procedures are undertaken. These procedures should be
completed within 3 months to determine appropriate solutions, including on accommodation and care.433
However, according to the Ombudsperson for Children due to the increased number, children are
accepted in other social welfare institutions.
The Ombudsperson for Children reported a lack of accommodation capacity, for example in relation to
the Centre in Zagreb where unaccompanied children are accommodated. Ombudsperson for Children
also reported about the lack of systematic support from interpreters in institutions where unaccompanied
children are accommodated.434
A Protocol on the treatment of unaccompanied children was adopted in August 2018 (see Identification)
which foresees the possibility of accommodation with foster families.
A Law on Foster Care, which entered into force on 1 January 2019 has opened the possibility for
unaccompanied children to be accommodate in the foster families.435 According to Ombudsperson for
Children, 1 unaccompanied child was placed in a foster family in 2022.436
At the end of September 2020, the Agreement for the project "New Home" was signed within the AMIF
with an estimated project duration of 24 months.437 The goal of the project is to contribute to the better
integration of unaccompanied children into community life, to ensure early integration through reception,
accommodation, care and psychosocial support and to support their inclusion in the life of the local
community.438 However in January 2022, the decision to implement the project was revoked considering
431
Article 10(3) LITP.
432
Information provided by the Centre For Peace studies, 18 January 2023; AYs, 3 February 2023, see also
433
UNHCR; UNICEF and IOM: Refugee and Migrant Children in Europe - Accompanied, Unaccompanied and
Separated, Overview of Trends January to June 2020 available in English at: https://bit.ly/32AD0OY.
434
Ombudsperson for Children: Report on the work of the Ombudsman for Children in 2022, available in Croatian
at: https://bit.ly/3NkGzQ9.
435
Official Gazette 115/2018, available in Croatian at: https://bit.ly/2xP8gh5.
436
It is not clear whether child was an applicant for international protection. Ombudsperson for Children: Report
on the work of the Ombudsman for Children in 2022, available in Croatian: https://bit.ly/3NkGzQ9.
437
EMN, Migration Bulletin, February 2021 available at: https://bit.ly/2QohgDc.
438
Ministry of Labour, Pension System, Family and Social Policy, Information on the implementation of the project
"New Home" co-financed by the Fund for Asylum, Migration and Integration, available at: https://bit.ly/3xdi7Y9.
101
that the funds of the mentioned project were intended for the reception and early integration of
unaccompanied minor girls who were supposed to be relocated from Greece through the solidarity
programme. After the girls applied for international protection at the airport in the Netherlands on their
way to Croatia in April 2021, a notification was received by Croatia in December 2021 cancelling the
transfer to Croatia as the competent Dutch court had designated the Netherlands as the state responsible
for deciding on their applications for international protection.439
The Croatian Red Cross reported having implemented two projects in 2022, aimed at supporting
unaccompanied children and experts working with unaccompanied children.440 Since unaccompanied
children are accommodated in various accommodation facilities where they often do not have services
tailored to their needs and available interpreters, CRC mobile team conducted a large number of visits to
those institutions to provide psychosocial support to children and provide material services (such as
clothing and school supplies) in 2022. An initial needs assessment was conducted with each child involved
in the projects in order to gather information about the child and determine needs and priorities. For some
children who expressed a desire for further support or needed additional information, individual support
continued. The CRC Tracing Service further assisted unaccompanied or separated children in finding
their family members and in re-establishing contact with family members, and provided support to
separated families and / or guardians in the process of reuniting with family members, in collecting
relevant documentation and provided assistance in contacting institutions in countries where family
members are located.
The shortcomings observed by CRC include inappropriate accommodation for unaccompanied children
and insufficient number of available specialised services adapted to their age and needs. Additional
challenges include difficulties in dealing with stress due to separation and / or loss of contact with family
members, language barriers and lack of interpreters for certain languages.
In 2022, 4,733 children expressed the intention to seek international protection. Among them, 436 were
unaccompanied children, of which 337 boys and 99 girls. Furthermore, in 2022, 104 unaccompanied
children submitted applications for international protection whereas 32 procedures were suspended, two
dismissed and 70 were pending.441In its Annual report on 2022, the Ombudsperson for Children states
that international protection was granted to 17 children, out of which 1 for unaccompanied child.
Regardless of the year when applications were submitted, in 2022 121 decision were issued for
unaccompanied children, 1 positive (granted international protection), 116 procedures were suspended,
three dismissed and one annulled.
In 2022, 329 children were accommodated in the Reception Centre for Applicants for International
Protection, while 107 of them were placed in social welfare institutions.442
3. Reception of victims of torture, violence and trauma
No system for early identification of victims of torture or other forms of ill-treatment by competent
authorities and professionals has yet been developed. According to the LITP, applicants who need special
reception and/or procedural guarantees, especially victims of torture, rape or other serious forms of
psychological, physical or sexual violence, shall be provided with the appropriate health care related to
their specific condition or the consequences resulting from the mentioned acts.443
439
Ministry of Interior, Decision on revocation of the decision on the allocation of funds for the implementation of
the project "New Home", available in Croatian: https://bit.ly/35UVX3E.
440
Information provided by CRC, 18 January 2023;
441
442
443
Article 57(2) LITP.
102
The system for addressing the consequences of torture among applicants was not established in practice
for years and there was a lack of clarity on who can get treatment and under which conditions, and who
should provide such treatments. However in 2020, the Ordinance on health care standards for applicants
for international protection and foreigners under temporary protection entered into force regulating,
amongst other, also the scope of health care for vulnerable groups. 444 This is discussed in detail in the
section on Health Care.
Standard Operational Procedure in Cases of Sexual and Gender-Based Violence in the Reception
Centres for Applicants of International Protection entered into force in 2021.
F. Information for asylum seekers and access to reception centres
1. Provision of information on reception
There are no specific rules for information to be provided to applicants on rights and obligations relating
to reception conditions. The provisions in the LITP on information to applicants are formulated generally.
The Ministry of Interior has to inform the applicants within 15 days of the expression of intention, about
the procedure of approval of international protection, about rights and obligations they have in that
procedure, the possibility of contact representatives of UNHCR and other organisations who work to
protect the rights of refugees, and the possibility of receiving free legal assistance. 445
In practice, according to the information available to the Croatian Law Centre, this information is given in
writing during the submission of the application for international protection.
Applicants are informed about the House Rules of the reception centres and these rules are also displayed
in a visible place in the premises of both Reception Centres for Applicants for International Protection.
According to information provided by the Croatian Red Cross in previous years, the House Rules are
available in Croatian, English, French, Arabic and Farsi. The Ministry of Interior has also specified back
in 2017, that House Rules are also available in Urdu, Pashtu, Somali and Hindi.446
Upon their arrival in the Reception Centre, applicants are also informed by social workers and
psychologists of the Croatian Red Cross about their rights and obligations, the House Rules and rules of
conduct which must be adhered to while accommodated in the Reception Centre as well as other practical
information e.g. the daily schedule of the distribution of linen, clothing and footwear, and hygiene items,
laundry services, information on daily creative workshops and other activities available in the centre.
In 2020, the Centre for cultural activities prepared 6 videos containing the necessary information for
applicants for international protection and foreigners residing in Croatia within the project „The video info
corner for asylum seekers“ which was implemented with the financial support of the Ministry of Labour,
Pension System, Family and Social Policy. The videos provide general information,447 as well as
information on legal counselling, accommodation and daily life,448 health care,449 education,450 obligation
to respect the legal framework and customs of the Republic of Croatia,451 and cultural features in the local
community.452 The videos were made with English subtitles and synchronized to Arabic.
Applicants accommodated in the reception centres also received information on COVID-19 and the
measures that need to be taken to prevent its further spread. Information posters and/or leaflets on COVID
444
Official Gazette 28/2020, 13 March 2020, available in Croatia at: https://bit.ly/2PcZGBM.
445
Article 59(2) LITP.
446
447
The video is available at: https://bit.ly/3awCMN4.
448
The video is available at: https://cutt.ly/qvKPaQo.
449
The video is available at: https://cutt.ly/6vKPjJp.
450
The video is available at: https://cutt.ly/YvKPcY4.
451
The video is available at: https://cutt.ly/YvKPQut.
452
The video is available at: https://cutt.ly/6vKPTPm.
103
19 and hygiene were prepared by the Croatian Institute for Public Health and Ministry of the Interior,453
Médecins du Monde (MdM),454 and Croatian Red Cross. 455 Leaflets with instructions from the Croatian
Institute of Public Health were translated into different languages and posted in visible places in the
facilities to raise awareness on the importance of prevention and self-isolation. IOM Croatia reported that
in 2022, materials related to COVID-19 vaccinations were developed in cooperation with IOM Slovenia
and Croatian Ministry of Interior and were distributed also to Reception centres.
The NGO Roda in cooperation with the UNICEF Office for Croatia, prepared infographics "Pregnancy and
coronavirus", "Childbirth and coronavirus" and "Breastfeeding and coronavirus" using the latest scientific
evidence available at the time (October 2020). Infographics are available in English, Romani (Chib), Baja-
Romanian, Farsi and Arabic.456
2. Access to reception centres by third parties
Indicators: Access to Reception Centres

1. Do family members, legal advisers, UNHCR and/or NGOs have access to reception centres?
Yes With limitations No
Relevant legislation does not contain any specific provisions on the access of third parties to the
Reception Centres for Applicants for International Protection, but in practice family members, legal
advisors, UNHCR and NGOs have access to these centres.
Additionally, both Reception Centres are open facilities and applicants may leave the centre according to
the house rules and are able to meet anyone outside. According to the LITP, the Croatian Red Cross,
UNHCR and other organisations involved in the protection of refugee rights or doing humanitarian work,
may conduct pedagogical, educational and similar activities and provide other types of assistance at the
reception centres, subject to prior authorisation by the Ministry of Interior.457
The employees of the Croatian Red Cross, are present in both Reception Centres for Applicants for
International Protection.
In practice, access to the centres by UNHCR and other relevant NGOs did not constitute an issue in the
past. In 2020, due to COVID-19 preventive measures, access to the reception centres was restricted for
persons who are not necessary for the normal functioning of the facilities.458
As of mid-March 2020 until the end of 2022, due to pandemic, access to Reception centres for applicants
for international protection was restricted, with the exception of persons who ensure the normal
functioning of the facilities. The civil society organisations, ,had to stop their activities in the centres. Only
employees of the Ministry of Interior, the Croatian Red Cross and Médecins du Monde (Doctors of the
World - MdM) could access the facilities on the daily bases.
G. Differential treatment of specific nationalities in reception
There is no difference in treatment with respect to reception based on nationality.
453
Croatian Institute for Public Health and Ministry of Interior leaflets available at: https://bit.ly/3tJ9d2v;
https://bit.ly/3gx4ehl.
454
MdM, Washing hands, available at: https://bit.ly/3v7lSMX; https://bit.ly/3sBfiws.
455
Croatian Red Cross information on available sources of information on COVID-19, available in Arabic at:
https://bit.ly/3n89ut5.
456
NGO Roda, Koronavirus i trudnoća, porod i dojenje na engleskom jeziku, available in Croatian and other
languages at: https://bit.ly/3v9MX1P.
457
Article 56 (2) LITP.
458
EMN, Special Annex to the 30th EMN Bulletin EU Member States & Norway: responses to COVID-19 in the
migration and asylum area, January – March 2020, available at: https://bit.ly/3sypjKV.
104
Detention of Asylum Seekers
A. General
Indicators: General Information on Detention
1. Total number of asylum seekers detained in 2022:459 Not available
2. Number of asylum seekers in detention at the end of 2022: Not available
3. Number of detention centres: 3
4. Total capacity of detention centres: N/A
During the procedure for international protection, detention is possible under all types of procedures,
where the conditions prescribed by the LITP are met. However, the majority of applicants for international
protection are not detained but are accommodated in open centres. In that sense, it is not likely that any
category of applicants would spend the whole status determination procedure in detention. The main
reasons for the detention of applicants are situations where they request international protection after
having been issued with a deportation order and situations where they left or attempted to leave Croatia
before the completion of the procedure for international protection.
At the moment, Croatia has three detention centres: the Reception Centre for Foreigners located in
Ježevo, with a total capacity of 95 places; the Transit Reception Centre in Trilj with a total capacity of 62
places; and the Transit Reception Centre in Tovarnik with a total capacity of 62 places.460 This brings the
total capacity of detention centres to 219 according to information provided by the Ministry of Interior in
2019. No information is available on whether this has changed in the period from 2020 until the end of
2022. Due to a lack of available information, it is also difficult to assess whether COVID-19 had an impact
on the number of applicants for international protection and how the health measures were implemented
in detention centres.
In 2021, the Reception Centre for Applicants for International Protection in Zagreb issued 27 decisions
on restriction of the freedom of movement, among which movement was restricted through the measure
of banning movement outside the Reception Centre for Applicants for International Protection for seven
applicants, reporting in person to the Reception Centre for Applicants for International Protection at a
certain time for six applicants and depositing travel documents and tickets for one applicant, while for 13
applicants, the freedom of movement was restricted by detention in the Reception Centre for Foreigners.
In 2021, the average duration of the restrictions on the freedom of movement at the Reception Centre for
Foreigners, based on the decision made by the Reception Centre for Applicants for International
Protection in Zagreb, was three months. Regarding the structure of applicants whose movement was
restricted by detention in the Reception Centre for Foreigners, in the above 13 cases, these were adult
male persons who were nationals of Türkiye (11), Algeria (1) and India (1). As for the legal basis for
detention in the Reception Centre for Foreigners, for 10 applicants, freedom movement was restricted on
the basis of Art. 54, para. 2, item 4 of the Law on International and Temporary Protection (LITP)
(prevention of abuse of procedure), and for three on the basis of Art. 54, para. 2, item 3 of the LITP
(protection of the national security or public order of the Republic of Croatia). Data on decisions on the
restriction of freedom issued by police administrations or stations were not provided for 2021, so it was
not possible to determine the total number of applicants for international protection whose right to freedom
of movement was restricted in 2021.461
459
Including both applicants detained in the course of the asylum procedure and persons lodging an application
from detention.
460
Information provided by the Ministry of Interior, Border Directorate, 6 February 2019.
461
building” with the financial support of UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and in English
105
505 migrants in 2021 and 905 in 2022 were detained in the Reception Centre for Foreigners in Ježevo.462
In 2022, the Service for Reception and Accommodation of Applicants for International Protection issued
85 decisions on restriction of the freedom of movement, among which movement was restricted by
detention in Reception Centre for foreigners in Ježevo (45 applicants), Transit Reception Centre for
Foreigners Trilj (32 applicants) and in Transit Reception Centre for Foreigners Tovarnik (4 applicants). In
addition, for 7 applicants for international protection, decisions on the restriction of freedom of movement
were issued by police administrations or stations after expressing intention to seek international
protection. All of them were detained in the Reception Centre for Foreigners in Ježevo. The average
duration of the detention in the Reception Centre for Foreigners Ježevo was 2 months, while in Transit
Reception Centre for Foreigners Trilj and Tovarnik 3 months.463
As for the gender composition, the Reception Centre for Foreigners Ježevo’s population was 89% male
and 11% female. In terms of age of the persons present in the centre, 75% were in the age group 18-34
and 25% in the age group 35-64. In the Transit Reception Centre for Foreigners in Trilj all applicants were
male, 66% in the age group 18-34 and 34% in the age group 35-64. In the Transit Reception Centre in
Tovarnik there were also just male applicants, 50% in the age group 18-34 and 50% in the age group 35-
64.464
Article 54 para. 11 of the Law on International and Temporary Protection (LITP) foresees that a detention
order can be issued by the Ministry of Interior, the police administration or the police station and they can
decide on a particular measure and its duration. On 24 June 2020, the Constitutional Court issued a
decision rejecting the proposal to initiate proceedings to review the constitutionality of this provision.465
The applicant considered that said provision is contrary to Article 22 para. 2 of the Constitution,466 as
Article 54 para. 11 of LITP stipulates that restrictions on the freedom of movement of third country
nationals are issued by an executive body rather than a court. Despite the fact that the Constitutional
Court did not initiate proceedings to review the constitutionality, it emphasised in its reasoning that the
provisions of the LITP must be interpreted and applied in the light of relevant EU directives and existing
case-law of the Court of Justice of the European Union (CJEU).
462
Ministry of Interior, Statistical overview of basic safety indicators and work results in 2021, available at:
https://bit.ly/3N6VXRd; Statistical overview of basic safety indicators and work results in 2022 available at:
https://bit.ly/3IRt74L.
463
464
Ibid.
465
Constitutional Court, Decision Number: U-I-503/2018, 24 June 2020, available in Croatian at:
https://bit.ly/3wY8SLs.
466
Article 22 paragraph 2 of the Croatian Constitution reads: No one shall be deprived of liberty, nor may liberty
be restricted, except when specified by law, upon which a court shall decide.
106
B. Legal framework of detention
1. Grounds for detention
Indicators: Grounds for Detention

1. In practice, are most asylum seekers detained
 on the territory: Yes No
 at the border: Yes No
2. Are asylum seekers detained in practice during the Dublin procedure?

Frequently Rarely Never
3. Are asylum seekers detained during a regular procedure in practice?

The LITP lays down the grounds for restricting the freedom of movement of applicants and foreigners
under transfer, including through detention in a Reception Centre for Foreigners.467 Detention may be
ordered for 4 reasons, 468 if it is established by individual assessment that other measures (see section on
Alternatives to Detention) would not achieve the purpose of restriction of freedom of movement:
1. To establish the facts and circumstances of the application which cannot be determined without
limitation on freedom of movement, in particular where there is a risk of absconding;
2. To establish and verify identity or nationality;
3. To protect national security or public order; or
4. To prevent abuse of procedure where, on the basis of objective criteria, which include the possibility
of access to the procedure of approval of international protection, there is a well-founded suspicion
that the intention to apply for international protection expressed during the procedure of forced return
was aimed at preventing the procedure of removal.
In practice, however, detention is not used systematically.
Moreover, Article 54(3) explicitly provides for the possibility to restrict freedom of movement or detain a
foreigner for the purposes of transfer to another Member State under the Dublin Regulation only in cases
where there is a “risk of absconding”. It should be noted that the LITP does not refer to a “significant risk
of absconding” in accordance with Article 28(2) of the Dublin III Regulation, however.
The existence of a “risk of absconding” is determined on the basis of all the facts and circumstances of
the concrete case, especially with regard to:469
- Previous attempts to abscond;
- Refusal to submit to verification and establishment of identity;
- Concealing or providing false information on the identity and/or nationality;
- Violation of the reception centre’s house rules;
- A Eurodac ‘hit; and
- Opposition to a Dublin transfer.
In 2022, in the Reception Centre for Foreigners Ježevo, the freedom of movement was restricted for 32
applicants on the basis of Art. 54, para. 2, item 4 of LITP (prevention of abuse of procedure), and for 13
on the basis of Art. 54, para. 2, item 3 of the LITP (protection of the national security or public order of the
Republic of Croatia). For all applicants in Transit Reception Centre Trilj and Transit Reception Centre
Tovarnik the freedom of movement was restricted on the basis of Art. 54, para. 2, item 4. During 2022,
in 4 cases freedom of movement was restricted by applying alternatives to detention on the basis of Art.
467
Article 54(5) LITP.
468
Article 54(2) LITP.
469
Article 54(4) LITP.
107
54, para. 5, item 1 (measure of banning movement outside the Reception Centre for Applicants for
International Protection).470
In practice, however, detention is rarely used during the Dublin procedure. According to the Ministry of
Interior, detention was used in 2 cases during the Dublin procedure in the course of 2018.471 In 2021, this
option was used in only one case, and the person was detained in the Reception Centre for Foreigners. 472
No public information on detention during the Dublin procedure is available for 2022.
The LITP specifies that detention in Reception Centre for Foreigners may be imposed if, by individual
assessment, it is established that other measures would not achieve the purpose of restriction of freedom
of movement.473 Prior to the LITP, the majority of detention decisions were uniform and based on the
same grounds (therefore no individual assessment had been done), while under the LITP individual
assessment should be done when ordering detention. However, in 2019 a few attorneys at law and one
legal representative from an NGO have reported that decisions on the restriction of freedom of movement
do not contain any reasoning behind the individual assessment. They simply state that the individual
assessment has determined that detention is necessary because other measures cannot achieve the
purpose of restricting freedom of movement.474 Similar reports were made by two attorneys at law in
2021.475
According to the Ministry of Interior, the individual assessment requested for the purpose of the restriction
of freedom of movement is done based on personal circumstances such as belonging to vulnerable group
(unaccompanied child, person with disability, health problems, family relations) as well as based on
behaviour of the applicant for international protection and his or her attitude towards the House Rules of
the Reception Centre for Applicants for International Protection.476
In practice applicants are usually detained where they request international protection after having been
issued with a deportation order and situations where they have left or attempted to leave Croatia before
the completion of the procedure for international protection.
Where a person expresses the intention to apply for international protection from the detention centre,
after having been detained on the basis of one of the immigration detention grounds as specified by the
Law on foreigners in the Reception Centre for Foreigners, he or she must either be released and
transferred to an open centre (Zagreb or Kutina) or must be served with a new restriction of freedom of
movement decision on one of the grounds for detention as specified by LITP. According to information
from the Border Police Directorate in 2018, if the intention is expressed in the Reception Centre for
Foreigners in Ježevo, the intention is then received by the centre, which then informs by email the service
dealing with applicants for international protection about the intention to seek international protection. The
Service for Reception and accommodation of applicants for international protection organises the lodging
of the application for international protection on the first following working day and, depending on the
assessment, issues the decision on the restriction of freedom of movement, i.e. a detention order. If the
decision on the restriction of freedom of movement is not issued, the applicant would be moved to the
Reception Centre for Applicants for International Protection. Intentions to apply for international protection
470
471
Information provided by the Ministry of Interior, 28 January 2019.472 Croatian Law Centre: The
Croatian Asylum System In 2021 - National Report, The report was prepared as part of the project “Access to
the territory and the asylum system in Croatia - legal support and capacity building” with the financial support
of UNHCR; available in Croatian at: https://bit.ly/3NgBDfc and in English at: https://bit.ly/3NBvVpC.
472
473
Article 54(6) LITP.
474
Information provided by attorneys at law on 3 December 2019, 6 December 2019, 16 December 2019 and 21
January 2020.
475
Information provided by attorneys at law on 27 December 2021 and 29 December 2021.
476
108
that are expressed in the Transit Reception Centres in Trilj and Tovarnik are received by local police
stations based on their territorial jurisdiction.477
In 2021, the Ombudsperson conducted an investigative proceeding in regard to preventing access to

international protection in the reception centre for foreigners. 478
In 2022, persons detained in the Reception Centre for Foreigners contacted directly by phone the
Center for Peace Studies on several occasions, and declared not being able access to the asylum
system.479
2. Alternatives to detention
Indicators: Alternatives to Detention

1. Which alternatives to detention have been laid down in the law? Reporting duties
Surrendering documents
Financial guarantee
Residence restrictions
Other
2. Are alternatives to detention used in practice? Yes No
The same authority i.e. the Ministry of Interior, the police administration or the police station can decide
and render decision on a particular alternative measure and its duration.480
Article 54(6) LITP explicitly states that detention is only permissible where less coercive alternatives
cannot be applied.
The alternatives to detention are the other measures listed in Article 54(5) LITP for the restriction of
applicants’ freedom of movement:
(1) Prohibition of movement outside the Reception Centre for applicants;
(2) Prohibition of movement outside a specific area;
(3) Appearance in person at the Reception Centre for applicants at a specific time;
(4) Handing over travel documents or tickets for deposit at the Reception Centre for applicants;
In 2018, 6 alternatives to detention were applied based on decisions taken by the Reception Centre for
Asylum Seekers or the Asylum Department, all of which ordered reporting obligations and were based on
public order grounds.481 No information is available for 2019, 2020, 2021 and 2022.
During 2022, in 4 cases freedom of movement was restricted by applying alternatives to detention on
the basis of Art. 54, para. 5, item 1 (measure of banning movement outside the Reception Centre for
Applicants for International Protection).482
477
Information provided by the Ministry of Interior, Border Directorate, 17 August 2018.
478
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/37ypocG. 479 Information
provided by Centre for Peace Studies, 18 January 2023.
479
480
481
482
109
3. Detention of vulnerable applicants
Indicators: Detention of Vulnerable Applicants

1. Are unaccompanied asylum-seeking children detained in practice?
 If frequently or rarely, are they only detained in border/transit zones? Yes No
2. Are asylum seeking children in families detained in practice?

The LITP allows for the detention of vulnerable applicants, if detention is suited to their special needs. 483
Moreover, it provides for detention of unaccompanied children, although for as short a period as
possible.484 No information is available on the number of vulnerable applicants who were detained in the
detention centres in the course of 2019 and 2020.
While there is no public data on the use of detention for vulnerable applicants for international protection
in 2022, the Ombudsperson for Children reported that the freedom of movement of 7 accompanied
children of irregular migrants was restricted during the year. They were held in the Reception Centre for
Foreigners Ježevo (5) and in the Transit Reception centres for foreigners Trilj and Tovarnik (2).485
In 2022, according to the Ministry of Interior’s Border Directorate, in the Reception Centre for Foreigners
in Zagreb 5 separated children were accommodated – nationals of Türkiye, China and Iraq. In the Transit
Reception Centre for Foreigners in Tovarnik there were 2 unaccompanied children from Türkiye detained,
while there were no unaccompanied children detained in Transit Reception Centre for Foreigners Trilj in
the course of 2022.486
In 2021,487 there were no were child applicants for international protection (accompanied or
unaccompanied) and applicants with special reception needs detained in the Reception Centre for
Foreigners (or in the Transit Reception Centres).
In 2022,488 there were no child applicants for international protection (accompanied or unaccompanied)
in detention.
4. Duration of detention
Indicators: Duration of Detention

1. What is the maximum detention period set in the law (incl. extensions): 6 months
2. In practice, how long in average are asylum seekers detained? Not available
Article 54(9) LITP provides a maximum detention time limit of 3 months, which may be extended by
another 3 months. Where detention is applied in a Dublin procedure, however, it cannot exceed 6 weeks
from the establishment of the responsibility of another Member State of the European Economic Area. If
an administrative dispute has been initiated, the time limit of 6 weeks shall be counted from the time the
decision on dismissal becomes final.489
483
Article 54(7) LITP.
484
Article 54(8) LITP.
485
https://bit.ly/43C5ZPL.
486
487
488
489
110
According to the Ministry of Interior the average duration of detention of applicants in 2018 was 3
months.490 In 2022, the average duration of the detention in the Reception Centre for Foreigners Ježevo
was of 2 months, while in the Transit Reception Centre for Foreigners in Trilj and Tovarnik it was 3
months.491
C. Detention conditions
1. Place of detention
Indicators: Place of Detention

1. Does the law allow for asylum seekers to be detained in prisons for the purpose of the asylum
procedure (i.e. not as a result of criminal charges)? Yes No
2. If so, are asylum seekers ever detained in practice in prisons for the purpose of the asylum
procedure? Yes No
1.1. Pre-removal and transit detention centres (“Reception Centres for

Foreigners”)
Applicants for international protection are detained in the same premises as irregular migrants.492
There is a pre-removal detention centre (“Reception Centre for Foreigners”) in Ježevo, 30km from
Zagreb, which has a total capacity of 95 places.493 The centre has capacity to accommodate 68 men, 12
women and 15 vulnerable persons. The special wing for vulnerable groups in Ježevo was finalised at the
end of 2015 in order to detain women, families and unaccompanied children.
According to the CPT report, the separate two-storey residential unit for vulnerable groups in the
Reception centre for Foreigners in Ježevo consisted of five three-bedded rooms (each measuring 10 m2)
and four four-bedded family rooms (each measuring approximately 16 m2 ) all of which have an adjoining
sanitary annex equipped with a toilet, washbasin, and shower. The unit also possessed a spacious
communal room, a kitchen for the preparation of food for children and a playground. The premises were
in an adequate state of repair and hygiene and provided ample space and equipment.494
There are also two Transit Reception Centres for Foreigners in Trilj and Tovarnik, close to the Bosnian
and Serbian borders respectively. Both centres are considered as Reception Centres for Foreigners.495
Each centre can accommodate 62 migrants, and include a separate wing for vulnerable groups with 12
places.496
The activities performed by these centres are defined by the Decree on Internal Organisation of the
Ministry of Interior,497 and it is envisaged that the Transit Reception Centres will serve for the detention of
foreigners apprehended for irregular crossing of the EU’s external border until their transfer to Ježevo or
until removal under a readmission agreement. This would mean that they are primarily intended for shorter
accommodation of foreigners.
490
491
492
493
Information provided by the Border Directorate, 30 January 2018.
494
to 14 August 2020, available at: https://rm.coe.int/1680a4c199
495
496
Information provided by the Border Directorate, 6 February 2019.
497
Official Gazette 97/2020, 7/2022 Article 100f, Article 409 and Article 674.
111
1.2. Airport transit zones and police stations
According to the information for 2018 provided by the Border Directorate of the Ministry of Interior,498
places of deprivation of liberty for the accommodation of irregular migrants also include airport transit
zones and premises in police stations. Special premises exist at Zagreb Airport (14 places) and at
Dubrovnik Airport (6 places), while at other airports, space for international departure is in use for these
purposes.
The total number of persons whose entry was refused at the airports in 2022 was 1,035. The total number
of refusal of entry in 2022 was 11,521, which also includes land (10,434), sea (51) and rivers (1).499
The total number of police stations at the end of 2018 was 184, while the total number of places where
migrants can be detained in police stations is 162. In 2018, 1,243 migrants were deprived of liberty in
police stations. However, no information was made available since 2019.
In August 2020, the Council of Europe Committee for the Prevention of Torture (CPT) completed a five-
day rapid reaction visit to Croatia to examine the treatment of persons attempting to enter the country and
apprehended by the police.500 Beside the Reception Centre for Foreigners in Ježevo, the delegation
visited the Cetingrad Border Police Station, the Donji Lapac Border Police Station, the Korenica Border
Police Station, and the Intervention Police Unit of the Karlovac Police Administration (Mali Erjavec). The
preliminary observations of the delegation were presented to the Croatian authorities at the end of the
visit. According to the Croatian Ombudsperson, the report on the CPT visit was adopted in November and
the CoE Commissioner for Human Rights urged to Croatia to publish it, as it is common practice for CPT
reports to be made public, with exceptions being very rare.501 The CPT report on the visit to Croatia was
finally published in December 2021.502
2. Conditions in detention facilities
Indicators: Conditions in Detention Facilities

1. Do detainees have access to health care in practice? Yes No
 If yes, is it limited to emergency health care? Yes No
The Border Police Directorate of the Ministry of Interior is in charge of the management of the detention
centre and the staff working within the centre are mainly police officers. In 2019, the Ministry of Interior
reported that a total 75 employees work in the Reception Centre for Foreigners in Ježevo, 33 in the
Transit Reception Centre in Tovarnik and 42 in the Transit Reception Centre in Trilj.503 No new data is
available for 2020,2021 and 2022.
The new Ordinance on accommodation in the Reception Centre for Foreigners and the method of
calculating the costs of forced removal entered into force at the beginning of January 2022.504
In 2020, the Ombudswoman initiated an investigation proceeding related to access to free legal aid for
irregular migrants detained in the Reception Centre for foreigners in Ježevo. It was determined that they
were not adequately informed that they are entitle to free legal aid. They were also not made aware of
498
Information provided by the Border Directorate, 6 February 2019.
499
Ministry of Interior, Statistical overview of basic safety indicators and work results in 2022, available at:
https://bit.ly/3IRt74L.
500
Council of Europe, ‘Council of Europe anti-torture Committee carries out rapid reaction visit to Croatia to
examine treatment of migrants’, 18 August 2020, available at: https://bit.ly/3dIr9ok.
501
502
503
Information provided by the Ministry of Interior, Border Directorate, 6 February 2019.
504
Official Gazette 145/2021, 155/2022
112
contact persons they may turn to for legal advice and / or legal representation. The Ombudswoman
recommended that information on free legal aid is printed in languages usually spoken by foreigners in
return procedures, posted on the notice boards of the Centre and provided to each migrant when issuing
a return decision.505 In 2021, the Ombudsperson conducted one investigative proceedings regarding the
inability to access the international protection procedure in the reception centre for foreigners.506
According to the Ombudsman's report for 2022,507 difficulties were reported in realization of rights of
detained persons, especially due to the insufficient and inadequate information provided. In addition, in
2022, the Ombudswoman conducted investigations based on complaints from applicants for international
protection, their family members, as well as on information provided by civil society organizations and
determined that, at border police stations, interpretation was not provided when processing cases and
issuing decisions on restriction on freedom of movement. Detained persons also complained that they
were not aware of the reasons for the restriction of movement imposed on them, and that they were not
informed about the status of their cases.
The CPT report on its visit to Croatia in 2020 was published in December 2021.508 The CPT delegation
visited inter alia the Reception Centre for Foreigners in Ježevo. Almost all the persons who met with
CPT’s delegation at Reception Centre for Foreigners in Ježevo stated that they were treated correctly and
respectfully by the staff in Ježevo. However, the CPT recommended that staff working in the Centre no
longer carry baton s in detention areas and that staff should be provided with regular training on cultural
mediation and on techniques to de-escalate tense situations. The CPT also provided a set of other
recommendations regarding the conditions in the Centre, the importance to schedule outdoor activities
and the access healthcare. It also recommended that more formal and reliable systems should be put in
place to ensure that all detained persons fully understand the grounds for their detention and the
possibilities to challenge such a decision as well as any decisions on extending the period of detention,
but also that all persons held under aliens’ legislation (i.e. under the Law on Foreigners and the LITP)
have an effective right of access to a lawyer. In addition, even if the right of detainees to lodge complaints
to the Director of the Reception Centre is already regulated, the CPT recommended that an effective
complaint system should be introduced at the Reception Centre in Ježevo. This should include the
installation of dedicated complaints boxes as well as a central register of complaints where the date,
subject matter, processing, and response should be recorded. Further, in order to strengthen the
effectiveness of the system, detained persons who are dissatisfied with the response to their complaints
should be able to appeal to a second instance body within the Ministry of the Interior.
2.1. Overall conditions
Conditions in the detention centre are satisfactory. According to the Ombudsman's report for 2022,509 all
three reception centres for foreigners (transit-reception centres in Tovarnik and Trilj and Ježevo Reception
Centre) are working on further improvement of accommodation conditions by investing in construction or
improvement of existing accommodation capacities.
In May 2022, a Decision was made on the allocation of financial resources for the implementation of the
project "Improvement of accommodation and working conditions in the Transit Reception Centre for
foreigners Trilj" within the framework of the Fund for Asylum, Migration and Integration.510
The purpose of this project is to improve the accommodation and working conditions in the Transit
Reception Centre for foreigners in Trilj through the construction of sanitary facilities, the separation of the
505
506
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/3OdvWOS.
507
Report of the Ombudswoman for 2022, available in Croatian at: https://bit.ly/3MNkaLf.
508
509
510
Ministry of Interior: Project "Improvement of accommodation and working conditions in the Transit Reception
Centre for foreigners Trilj"; available at: https://bit.ly/46cW8SH.
113
living area from the reception area for foreigners, the installation of a video surveillance system and an
alarm bell, and the procurement of additional necessary equipment and furniture.
The new Ordinance on accommodation in the Reception Centre for Foreigners and the method of
calculating the costs of forced removal entered into force at the beginning of January 2022.511 The
Ordinance was amended at the end of December 2022, due to the entry of the Republic of Croatia into
the Eurozone.
According to the Ordinance, each room must guarantee 4m 2 per person and have access to daylight.512
Every person has their own bed and there is sufficient space and separation between beds, as well as
sufficient space to store personal possessions. Men and women are separated.513 Detainees are
provided with clothes,514 although they are all dressed in identical tracksuits and cannot, in usual
circumstances, use their clothes. Upon arrival in the Centre and during their stay, persons use the clothes,
bed linen and hygiene supplies they are assigned. If necessary, their clothes are being washed and put
away packed in a storage room, and only exceptionally foreigners may be allowed to use their own
clothes, if the clothes are suitable for staying in the centre.515
According to the CPT report on its visit to Croatia in 2020, upon admission, detained persons had their
personal clothes washed, disinfected, and stored for the entire period of detention and were provided
with two sets of standard clothes and shoes from the centre. However, several detained persons
complained that they could only change their clothes once a week, which was insufficient to maintain
basic hygiene, especially during summer. Furthermore, personal hygiene kits were provided to all
detainees on a weekly basis. In terms of food, several foreign nationals complained about the
monotonous food provide for dinner which always consisted of canned meat paste, which is confirmed
by the weekly menus.516
There used to be a so-called library within the centre so detainees had access to books in a few
languages. Yet, according to the CPT report, the Centre had no library. However, in response to the
report, the Croatian Government reported that bookcases have been set up in the living area. The books
are available in English, German, Italian, Spanish, Russian, Turkish, Arabic, Urdu, Pashto and Farsi and
the list is continuously updated.
However, no internet access is available. The centre is cleaned on a regular basis and there are sufficient
showers and toilets. There is a common room with a TV available and migrants can spend most of the
day there, watching TV or playing cards. There is also a facility for buying cigarettes and drinks. There
are two public phones available to migrants at the Centre that can be used at their own cost. However,
detained migrants are not allowed to use their mobile phones, which are seized upon admission to the
Centre.517
If a person is in possession of any cash, it will be temporarily seized.518

While staying in the Centre, people may however use the seized cash for the necessary payment; the
exchange of foreign currencies is done once a week. Any detainee cannot be in possession of an amount
of money superior to EUR 53.09.519
The costs of accommodation of foreigners in the centre are charged as a flat rate at the amount of 33.18
euros and are calculated from the day accommodation until the day of discharge from the centre.520
511
Official Gazette 145/2021, 155/2022
512
Article 9 Detention Centre Ordinance.
513
Ibid.
514
515
516
517
Article 8 paragraph 3 Detention Centre Ordinance.
518
Article 21 paragraph1 Detention Centre Ordinance
519
520
Article 27 paragraphs 5 -6 Detention Centre Ordinance.
114
These costs are borne by the foreigners themselves and in the case of families, the costs are borne by
the person who holds the funds.521
According to the Ordinance, persons are provided with three meals a day, of which at least one must be
a warm meal. Children are provided with four meals a day. Specific diets can be prepared upon request
for religious reasons, or when ordered by a doctor (e.g. for pregnant women).522 In practice, quality of
food is generally reported to be of a satisfactory level.
People are entitled to stay outdoors for at least two hours a day in a specially designated area within the
Centre (there is a football playground serving as an outdoor exercise area).523 This does not always
happen for example during bad weather conditions
Migrants, have the right to practice their religion, but they must respect the religious and cultural
worldviews of other people in the centre. In addition, upon their requests, foreigners will be allowed be in
contact with religious communities.524
However in 2022, detained persons reported to Ombudswoman problems related to nutrition, the inability
to make phone calls, inadequate health care, the behaviour of police officers and similar.525
With the support of the EU financial instrument “Asylum, Migration and Integration Fund” (AMIF) a new
kitchen, laundry and heating system were installed in the course of 2019 as well as a football field.526 At
the end of 2020, the decision was brought on the allocation of additional financial resources for the
implementation of the project "Assistance in maintaining an adequate level of accommodation in the
Reception Centre for Foreigners" within the Asylum, Migration and Integration Fund.527
In October 2020, information was published according to which the Reception centre for Foreigners in
Ježevo implements the project: "Improvement of accommodation conditions and working conditions in
the Reception Center for Foreigners in Ježevo“. The aim of the project is to ensure adequate
accommodation conditions for third-country nationals in accordance with EU standards, improve the
infrastructure and to raise the level of quality of services as well as working conditions for employees in
the Centre.528 In June 2021, the Decision on the allocation of financial resources for the implementation
of the project "Improvement of accommodation and working conditions in the Reception Centre for
Foreigners in Ježevo - II. phase" was adopted.529 In May 2021, the Decision on the allocation of financial
resources for the implementation of the project "Improvement of accommodation and working conditions
in the Transit Reception Centre Trilj” was adopted. 530
As regards police stations, a case concerning conditions in detention i.e. premises in the Border Police
station of Bajakovo, Daraibou v. Croatia, was lodged on 19 December 2017 and was communicated by
521
522
Article 16 paragraphs 2-5 Detention Centre Ordinance.
523
524
525
526
527
Decision on the allocation of additional financial resources for the implementation of the project "Assistance
in maintaining an adequate level of accommodation in the Reception Centre for Foreigners", available at:
https://bit.ly/3KAeu4W.
528
Ministry of Interior: Project "Improvement of accommodation conditions and working conditions in the
Reception Center for Foreigners in Ježevo“, 23 October 2020, available at: https://bit.ly/3emgiiW.529
Decision on the allocation of financial resources for the implementation of the project "Improvement of living
and working conditions in the Reception Centre for Foreigners in Ježevo - II. phase", available at:
https://bit.ly/3KzJKRi.
529
Decision on the allocation of financial resources for the implementation of the project "Improvement of living
and working conditions in the Reception Centre for Foreigners in Ježevo - II. phase", available at:
https://bit.ly/3KzJKRi.
530
Decision on the allocation of financial resources for the implementation of the project "Improvement of
accommodation and working conditions in the Transit Reception Centre Trilj”, available at:
https://bit.ly/3MI0197; Decision on allocation of additional financial resources , available at:
https://bit.ly/43i8eI7.
115
the ECtHR on 23 October 2018.531 The applicant complained under the substantive and procedural
aspects of Articles 2 and 3 ECHR that Croatia is responsible for not preventing a life-threatening situation,
a fire in the police station, owing to which he suffered grave bodily injuries and that no effective
investigation has been carried out in that respect. In January 2023, the ECtHR delivered its ruling in
Daraibou v. Croatia.532 The ECtHR established, unanimously, that two violations of Article 2 (right to
life/investigation) of the European Convention on Human Rights occurred. The ECtHR concluded that the
authorities had failed to provide the applicant with sufficient and reasonable protection of his life and limb,
in violation of Article 2. It also held that there had been a further violation of Article 2 as concerned the
investigation into the tragic fire. Although the authorities’ initial reaction had been prompt, certain
questions – concerning searches and monitoring of detainees, as well as the adequacy of the premises
– had been left unanswered and no attempt had been made to establish whether there had been broader
institutional shortcomings which could have prevented similar errors in the future.533
2.2. Health care and special needs in detention
During the stay in the centre, access to health care services is provided to third country nationals. In case
individual medical condition worsens outside of the working hours of the centre’s doctor's office, officials
will take measures to provide assistance and all measures to eliminate the danger to foreigner’s life or
health. Special medical care is provided to pregnant women and women giving birth.534
During admission to the centre, the foreigner is obliged to undergo a general medical examination.535
Immediately upon placement in the centre, the person is obliged to inform the officials about any existing
health and mental condition. In case of infection or suspicion of the existence of an infectious disease,
the foreigner is placed in a special room and provided with medical care.536
According to Ministry of Interior, health and medical care of persons who are accommodated at the
Reception Centre in Ježevo is conducted by a general practitioner in the branch office of the Medical
Centre Dugo Selo.537 As of 1 January 2021, a full-time nurse has been employed in the office who
conducts a basic medical examination and screening immediately after a foreign national is
accommodated in the Centre. A doctor comes to the office on Tuesdays and Thursdays and when called
by the nurse. An emergency medical service also comes to the Centre when called. If a person does not
speak English, the telephone interpretation is conducted by interpreters with whom the Ministry of the
Interior has concluded an agreement either during a basic medical examination, a screening, or during
health checks but also when transporting persons to specialist examinations and during treatments in
hospitals and specialised institutions. Psychosocial assistance and protection is conducted in cooperation
with the Croatian Red Cross whose psychologists and psychiatrists come to the Centre accompanied by
interpreters twice a week and when called. They transfer foreign nationals to specialised institutions if
specialist examinations are needed and with the authorisation of a doctor. Due to the COVID-19
pandemic, persons undergo a PCR test before accommodation at the Centre and by a rapid antigen tests
during their stay at the Centre. In addition, all persons located at the Centre have the option to be
vaccinated against COVID-19.
There is no special mechanism in the detention centre to identify persons with special reception needs.
Although vulnerable applicants were rarely detained in the past few years, when that happened,
vulnerable persons were usually transferred to open centres upon request from lawyers working in NGOs.
However, within the Centre a special facility exists for vulnerable groups. This facility is an integral part
531
ECtHR, Daraibou v. Croatia, Application No 84523/17, available at: https://bit.ly/2RZ2uCI.
532
ECtHR, Daraibou v. Croatia, Judgment, available at: http://bit.ly/3THBvbb.
533
ECtHR, Press Releases: Judgment Daraibou v. Croatia - fatal fire in police-station basement room used to
detain illegal migrants; available at: https://bit.ly/3lFUYfS.
534
535
Article 12 paragraph 2 Detention Centre Ordinance
536
537
2020, available in English: https://rm.coe.int/1680a5acfc and Croatian: https://rm.coe.int/1680a5acfd.
116
of the Reception Centre for Foreigners, which is an organisational unit of the Border Police Directorate.
The facility has a capacity of 27 places. Beside rooms for accommodation, the facility has a living room
and a playroom for children, and facilities for education, health care, isolation, psychologists and
educators. 538
In 2022, Croatian Red Cross continued to provide psychosocial support and made a leaflet on the topic
of mental health and psychosocial support for detained persons. The leaflet states what reactions people
in detention can have and what they can do to make it easier for themselves.539
3. Access to detention facilities
Indicators: Access to Detention Facilities

1. Is access to detention centres allowed to
 Lawyers: Yes Limited No
 NGOs: Yes Limited No
 UNHCR: Yes Limited No
 Family members: Yes Limited No
According to the Detention Centre Ordinance, after being placed in the centre, individuals are entitled to
one free phone call with their country's diplomatic mission or consular office, and to another private phone
call lasting up to 5 minutes. An exception is provided for minors who have the right to talk to their
guardians by phone without cost and limitation. Foreigners can make other calls through the public phone
in the centre at their own expense.540
Persons are allowed to receive visits at least twice a week.541 The centre must be notified about the visit
in writing at least two days earlier. A visit may be prohibited if it is established that the visitor is not
announced or if he or she poses a threat to public order, public security and health or that he or she is
prone to improper behaviour and violation of regulations. Visits to third-country nationals shall take place
in a special room for visits. The visit may last for up to an hour, regardless of the number of visitors. On
an exceptional basis, a visit may last longer if approved by the head of the centre or the person
designated by the head of the centre. A police officer can terminate a visit, if during the visit security,
order and peace in the centre are disturbed or if it is determined that the visitor has arrived in a different
capacity than announced.
Persons shall be provided with an opportunity to communicate with their attorney and the competent
national or international institutions or organisations in the field of protection of human rights and
fundamental freedoms, with which the Ministry of Interior has concluded a cooperation agreement. In
order to effectively realise such communication, the attorney and representatives of humanitarian and
other organisations for the protection of human rights shall be provided with access to the centre in
accordance with the rules on visits,542 meaning that visits must be announced two day in advance and
may last up to maximum one hour.
3.1. Access of lawyers to detention facilities
In 2019, attorneys at law reported problems in accessing the Reception Centre Ježevo as well as
problems in relation to privacy with their client.543 No such information was received in relation to 2020. In
2021, one lawyer reported that problems persisted in that regard.544
According to the Ombudsman's report for 2022545, difficulties in accessing legal aid providers were
observed in all three centres, as also reported to the Ombudsman by the Croatian Bar Association.
538
Information provided by the Border Police Directorate, 14 October 2015.
539
Information provided by the, 18 January 2023.
540
541
542
Article 25(5-6) Detention Centre Ordinance, citing Article 19.
543
Information provided by attorneys at law, 3 December 2019.
544
Information provided by attorneys at law, 29 December 2021.
545
117
The Civil Rights Project (CRP) Sisak, an NGO that provides free legal aid to applicants for international
protection in the procedure before Administrative Court reported the problems experienced in accessing
the Reception Centre for Foreigners in Ježevo in 2022.546
3.2. Access of NGOs and UNHCR to detention facilities
During 2022, the Croatian Red Cross did not face issues in accessing transit reception centres and
reception centres for foreigners. During 2022, CRC visited the Transit Centre in Trilj 4 times, the Transit
Centre in Tovarnik 3 times and the Reception Centre for Foreigners in Ježevo was visited by CRC on a
weekly basis. In the Centres, the Croatian Red Cross provided individual and group psychosocial support,
social activities, and detained persons were also provided with humanitarian aid, phone cards and other
necessities according to their needs. A leaflet on the topic of mental health and psychosocial support was
prepared by CRC in the course of 2022.547
During 2021, the Croatian Red Cross held trainings for employees in the Reception centres in Ježevo,
Trilj and Tovarnik. CRC in cooperation with the ICRC, held a workshop "Capacity Building, Review of
Cooperation and Exchange of Best Practices" for the heads of all centres and 2 employees of each centre.
Educational workshops on identifying vulnerable groups of migrants were also held in Trilj and Tovarnik
in cooperation with UNHCR. In addition to police officers working in the Centres, police officers from
border police stations Trilj and Tovarnik also participated.
In 2022, the Croatian Red Cross held training for employees of the three Centres, on the following topics:
the entry of the Republic of Croatia into the Schengen Area and the changes that come with that; the
transition from International Humanitarian Law to International Law on Human Rights; Immigration
detention - communication with the migrant population; health epidemiological difficulties in the migrant
population and urgent first aid procedures with an emphasis on potential situations in detention.
IOM reported that they did not encounter any problem with accessing reception centre in 2022.548 IOM
maintained open communication channels with staff working in the Reception Centres to allow migrants
staying there to return voluntarily to their country of origin.
In 2021, IOM held two trainings for border police officers as part of the project “Improving Access to
COVID-19 Vaccinations for Vulnerable Migrants” funded by the Swiss Agency for Development and
Cooperation. The training was held in the premises of the Transit Reception Center for Foreigners in
Tovarnik and in the premises of the Police Academy for employees of the Reception Center for
Foreigners Ježevo. The topic of the training was: health care at the workplace - prevention of COVID-19
diseases and other infectious diseases, vaccination and health needs, challenges among migrants and
refugees from the perspective of border police officers (how to identify a potentially ill migrant person,
further treatment), and maintaining mental health. 27 border police officers participated to the training.
In 2022, IOM held the third training for border police officers as part of the project “Improving Access to
COVID-19 Vaccinations for Vulnerable Migrants”. The training took place in the premises of the Transit
Reception Centre for foreigners in Trilj. The topics covered by the training were the same as in 2021.
In practice, NGOs are facing obstacles to accessing detention centres for the past several years. The
Centre for Peace Studies does not have access to the Reception Centre for Foreigners in Ježevo and
the Transit Reception Centre for Foreigners in Tovarnik and Trilj since the beginning of 2018.549 CRP
Sisak, reported the problems with the access to Reception Centre for Foreigners in Ježevo in 2022. 550
UNHCR has also access to the Centres. However, every visit should be announced in advance.
546
Information provided by Civil Rights Project Sisak, 9 January 2022.
547
Information provided by Croatian Red Cross, 18 January 2022
548
549
Information provided by the Centre for Peace Studies, 22 January 2021, also confirmed on 18 January 2023.
550
118
D. Procedural safeguards
1. Judicial review of the detention order
Indicators: Judicial Review of Detention

1. Is there an automatic review of the lawfulness of detention? Yes No
2. If yes, at what interval is the detention order reviewed?
Applicants for international protection are informed orally by the staff of the Ministry of Interior about the
reasons of their detention during the delivery of the decision.
In practice, the interpreter is present at the delivery of the decision reads decision to them, although an
attorney reported in 2019 that clients were not informed about the reasons of detention.551 However in
2022, the national Ombudswoman conducted investigations based on the complaints of applicants for
international protection, their family members, as well as on information provided by civil society
organizations and determined that, at border police stations, in the procedure of passing a decision on
restriction of freedom of movement, interpretation was not provided.552
The LITP does not provide for automatic review of the lawfulness of detention.
Applicants may lodge a law suit to the Administrative Court against a detention decision within 8 days
after its delivery. The authority that has issued the decision i.e. Ministry of Interior, the police
administration or the police station, shall submit the case file to the Administrative Court no later than
within 8 days of the day of receipt of the decision by which the Administrative Court requests the case file.
The Administrative Court shall render a decision after a personal interview within 15 days from the day of
receipt of the case file.
However, there are no legal consequences for not respecting the 15-day time limit prescribed by the
relevant legislation. The complaint does not suspend the decision.
According to the Administrative Court in Zagreb, the court registry application does not recognise the
difference between cases in which freedom of movement was restricted by other alternative measures
than detention in the Reception Centre for Foreigners.553 Thus it is not possible to report in how many
cases the court had to decide on detention in the Reception Centre for Foreigners.
In 2022, Administrative Court of Zagreb decided in 40 cases regarding the procedure apply to restrict
asylum seekers’ freedom of movement. Most law suits against restriction of the freedom of movement
presented before the Administrative Court of Zagreb were rejected in 2022. Out of the 40 law suits, more
than half (27) were rejected, 10 were accepted, 1 was accepted and referred back and 2 were referred.
Other Administrative Courts did not deal with lawsuits against restrictions to the freedom of movement in
the course of 2022.
The average duration of the judicial review of procedure of restriction of the freedom of movement in 2021
was 43 days554 and 38 days in 2022before the Administrative Court of Zagreb.555
In 2022, the High Administrative Court received 4 onward appeals in cases of detention in the Reception
Centre for Foreigners and they were rejected.556
551
Information provided by attorneys-at-law, 3 December 2019.
552
Report of the Ombudsman for 2022, available in Croatian at: https://bit.ly/3MNkaLf.
553
Information provided by the Administrative Court in Zagreb, 18 February 2021.
554
Information provided by the Administrative Court in Zagreb, 31 January 2022.
555
Information provided by the Administrative Court in Zagreb, 23 January 2023.
556
Information provided by the High Administrative Court, 13 January 2023.
119
2. Legal assistance for review of detention
Indicators: Legal Assistance for Review of Detention

1. Does the law provide for access to free legal assistance for the review of detention?
Yes No
2. Do asylum seekers have effective access to free legal assistance in practice?
Yes No
In detention cases, applicants are entitled to free legal aid similarly to their right to legal aid in the
international protection procedure (see Legal assistance). In practice when a decision is delivered to
detained applicants they are also given the list of providers of free legal aid from which they can choose
an attorney or lawyer from NGO, who are then notified by the Ministry of Interior. Attorneys and lawyers
from NGO organise the interpreter for the appointment and then inform the Ministry of Interior. According
to national legislation the measure of accommodation at the reception centre for foreigners (i.e. detention)
may be imposed if, following an individual assessment, it is established that other alternative measures
would not achieve the purpose of restriction of freedom of movement. However, in previous years legal
representatives reported that decisions on the restriction of freedom of movement do not always contain
a reasoning behind the individual assessment. They simply state that the individual assessment has
determined that detention is necessary because other measures cannot achieve the purpose of restricting
freedom of movement.557 One attorney reported that detention decisions are often brought in standard
form that all look alike, and that the Administrative Court usually confirms them.558
In the past lawyers and legal representatives could easily contact and meet with their clients. However in
2018 and 2019, they faced difficulties in accessing the Reception Centre for Foreigners in Ježevo as well
as the Transit Reception Centres. The Centre for Peace Studies in Croatia reported that lawyers providing
support to applicants for international protection in the Ježevo Reception Centre for Foreigners could not
hold confidential conversations with their clients, as a police officer is always in the room.559 No such
difficulties were reported in 2020 and 2021. However, according to the Ombudswoman, in 2022 difficult
access of legal aid providers was observed in all three centres.560
E. Differential treatment of specific nationalities in detention
There is no information suggesting that specific nationalities are being more susceptible to detention or
systematically detained or that specific nationalities stay longer in detention in practice.
However, AYS reported that applicants for international protection who visited their Integration Centre,
reported to them in October 2022, that approximately ten person who were previously accommodated in
the Reception Centre for Applicants of International protection were detained. Allegedly, according to
applicants who approached AYS, detention decisions were preceded by numerous discriminatory actions
of the staff of the Reception Centre for Applicants of International Protection.561
557
Information provided by attorneys at law, 3 December 2019, 6 December 2019.16 December 2019, 21 January
2020.
558
Information provided by attorney at law, 27 December 2021.
559
FRA, Migration flows: Key fundamental rights concerns – Q2, 2019, available at: https://bit.ly/3dXREnQ.
560
561
Information provided by AYS, 3 February 2023.
120
Content of International Protection
The previous Action plan for the integration of beneficiaries of international protection, which covered the
period from 2017-2019, foresaw the adoption of a relocation plan once a year to monitor the integration
of persons granted international protection based on their needs.562 However, this was never applied in
practice. As the Integration Action Plan expired at the end of 2019, a new one was still under development
in 2022, although it was planned that it would cover the period from 2020 to 2022.563 By the end of 2022,
the new Action Plan was still not adopted.
In October 2020, the Office for Human Rights and the Rights of National Minorities of the Government of
the Republic of Croatia held its first meeting of integration coordinators at the local level (within the project
‘‘INCLuDE’’) where the draft Action Plan for the integration of persons granted international protection for
year 2021-2023 was presented, emphasising the importance of including as many local and regional self-
government units as possible.564
On 14 November 2019, the Government issued a decision on the composition of the new Permanent
Commission for the Implementation of Integration of Foreigners in Croatian Society.565 The latter is
composed of representatives of: state administration’s bodies, Governmental Offices, local and regional
self-government units, public institutions as well as of a representative of a non-governmental
organisation. The composition of this new commission has been modified insofar as it provides for the
appointment of a representative of local and regional unit and a representative of non-governmental
organisation, which were not part of the previous commission.566
The aforementioned Decision further foresees the establishment of a Working Group of the Permanent
Commission for the Implementation of Integration of Foreigners in Croatian Society. The Working Group
prepares, for the Government of the Republic of Croatia, proposals of national strategies and plans in the
field of integration of refugees or foreigners under subsidiary protection, ensures operational
implementation of planned tasks, reports to the Permanent Commission on implementation and progress
or possible difficulties related to planned activities and performs other tasks entrusted to them by the
Permanent Commission. In January 2020, the Governmental Office for cooperation with NGOs published
a public call for proposal of representatives of civil society organizations for membership in the Working
Group.567 In May 2020, beside representatives of various institutions and competent ministries,
representative of UNHCR, the Croatian Red Cross, the Centre for Peace Studies and the Croatian Law
Centre were appointed as members of working group.
In June 2022, a session of the Permanent Commission for the Implementation of the Integration of
Foreigners into Croatian Society was held. In the session, a Decision was adopted for the establishment
and appointment of members of the Working Group for the preparation of the Protocol of Procedures for
the Integration of Persons Granted International Protection.568 The meeting was also convened with the
aim of exchanging information on normative changes and improved practices in providing guaranteed
services to persons under international and temporary protection.569 At the session held on 19 December
2022, the Permanent Commission unanimously adopted the Protocol on Procedures for the Integration
562
The Government of the Republic of Croatia – Office for Human Rights and the Rights of National Minorities,
Action plan for integration of persons who have been granted international protection for the period from 2017
to 2019, available at: https://bit.ly/34i1Eng and in Croatian at: https://bit.ly/2Xi0bfd.
563
EMN, Migration bulletin, November 2020, available at: https://bit.ly/3vjA5Xf.
564
EMN Migration bulletin, February 2021 available at: https://bit.ly/2QMD8YW.
565
Croatian Government, 'Decision on Establishment of the Permanent Commission for Implementation of
Integration of Aliens into Croatian Society', 15 November 2019, available in Croatian at: https://bit.ly/2z5RSJC.
amended on 30 October 2020, available at: https://bit.ly/3tR67cQ.
566
Croatian Government, ‘Information meeting of the Permanent Commission for Implementation of Integration
of Aliens into Croatian Society Held’, 23 December 2019, available in Croatian at: https://bit.ly/2UPn6Nu.
567
Governmental Office for cooperation with NGOs: public call, 15 January 2020, available in Croatian at:
https://bit.ly/3dMGpAF.
568
EMN, Bulletin n. 39, April - June 2022, available at: https://bit.ly/4047pBf.
569
The Government of the Republic of Croatia – Office for Human Rights and the Rights of National Minorities,
The 3rd session of the Permanent Commission for the Integration of Foreigners into Croatian Society was
held; available at: https://bit.ly/3OPIkqV.
121
of Persons Granted International Protection. The Protocol570 was prepared in a participatory process and
through cooperation with representatives of the academia, local self-government units and competent
departmental bodies. The Working Group for the preparation of the Protocol on Procedures for the
Integration of Persons Granted International Protection, consisted of representatives of the Ministry of
Interior, the Ministry of Labour, the Pension System, Family and Social Policy, the Ministry of Science and
Education, the Ministry of Health, the Central State Office for reconstruction and housing, the Croatian
Employment Service, the City of Zagreb, City of Karlovac and City of Varaždin.571
In 2022, the new Law on Recognition and Evaluation of Foreign Educational Qualifications572 entered into
force. The Law prescribes the possibility of evaluating foreign educational qualifications for the purpose
of continuing education at the same or higher level of education and for the purpose of accessing the
labour market for beneficiaries of international and temporary protection and their family members.
In 2021, the City of Zagreb prepared the draft of the ‘Action plan of the City of Zagreb for integration of
beneficiaries of international protection for the period from 2021 to 2022’.573 The draft was under public
consultation until 15 July 2021.574
The Action Plan of the City of Zagreb for the Integration of Applicants for and Beneficiaries of International
Protection for 2022575 was adopted in January 2022, making the City of Zagreb the first unit of local and
regional self-government in Croatia to adopt such strategic document.576 Measures and activities include
social protection, health care, language learning and education, work and employment, strengthening
local capacities and intercity and international cooperation. The action plan of the City of Zagreb was
adopted for 2022 because it was one of the activity within CONNECTION project - CONNEcting Cities
Towards Integration action, which ended in 2022. As part of the new project UNITES - Urban InTEgration
Strategies through co-design, the development of a new action plan is envisaged.577
In May 2022, eight civil society organisations signed a cooperation agreement with the City of Zagreb to
carry out activities from the Action Plan of the City of Zagreb for the integration of applicants for
international protection and persons granted international protection for the year 2022. These activities
are part of the project Connection - CONNEcting Cities Towards Integration actiON project.578
In 2022, the integration.zagreb.hr website, funded by the Connection project, was created. The website
contains information on the rights and services provided by the City of Zagreb for applicants of
international protection, persons granted international protection and persons under temporary protection,
i.e. displaced persons from Ukraine. The information is published in Croatian, English, Arabic, Farsi and
Ukrainian and refers to services in the fields of social protection, health care, education, employment, free
legal aid and cultural activities organised by the cultural centres of the City of Zagreb.579
In 2021, the Ministry of Interior published frequently asked questions and answers in regard to status of
international protection in several language.580
Basic information for the Integration of Foreigners can be found in an amended guide for integration which
was prepared by the Croatian Governmental Office for Human Rights and the Rights of National Minorities
in 2019. The guide is available in 7 languages (Croatian, English, French, Ukrainian, Arabic, Urdu and
570
Text of the Protocol on Procedures for the Integration of Persons Granted International Protection is available
in Croatian at: https://bit.ly/3K49FD3. and in English: https://bit.ly/3N6l4Uj.
571
Office for Human Rights and the Rights of National Minorities: The Protocol on Procedures for the Integration
of Persons Granted International Protection has been published, available at: http://bit.ly/3z1cWww.
572
Law on Recognition and Evaluation of Foreign Educational Qualifications, Official Gazette 69/2022, available
in Croatian at: https://bit.ly/3OPwI79.
573
The draft of the Action plan is available at: https://bit.ly/3hHLvzj.
574
City of Zagreb: Report on the conducted public consultation available at: https://bit.ly/3HPcgwh.
575
Text of the Action Plan in Croatian is available at: https://bit.ly/3Zbg9o0.
576
See more at: http://bit.ly/40cXQjw.
577
Office for Human Rights and the Rights of National Minorities: The Protocol on Procedures for the Integration
of Persons Granted International Protection, available at: https://bit.ly/3Zhngeq.
578
EMN, Bulletin n. 39, April - June 2022, available at: https://bit.ly/3K49FD3.
579
Ibid.
580
Ministry of Interior: Frequently asked questions, available at: https://bit.ly/3jrnayt.
122
Farsi).581 In 2022, the Office for Human Rights and the Rights of National Minorities published an updated
edition of the Guide for Integration in Croatian and Ukrainian.582
In May 2022, the Office for Human Rights and the Rights of National Minorities issued the publication
Social Inclusion of Persons Granted International Protection in the Republic of Croatia – data collection
system development and recommendations, which is available in Croatian and English. The purpose of
the research was the creation of a database on the social inclusion of persons granted international
protection and the establishment of a data collection system that will serve for the systematic monitoring
of the successful inclusion in society of persons granted international protection. The main goal is to
monitor and evaluate the effects of integration policies in individual areas using a series of indicators.583
In April 2022, the first meeting of the coordinators (representatives of competent bodies and public
institutions in key areas of integration) for the collection of data on the social inclusion of persons granted
international protection was held. During May and June 2022, several schools in Zagreb, Osijek and Sisak
organised social actions in the community. The aim was to empower local communities to accept citizens
of third countries. The actions were organised as part of the project "INCLuDE of the Office for Human
Rights and the Rights of National Minorities, together with students, school employees, and residents of
local communities. 584
In 2021, the Office for Human Rights and Rights of National Minorities produced an informative video to
raise awareness of the importance of the successful integration of persons granted international
protection.585 The objective of the video is to promote the acceptance and inclusion in society of third-
country nationals seeking international protection and those granted it through a clear and concise
overview of their rights and obligations and the challenges they face along the way.
In 2022, the video was translated in seven languages (Arabic, English, Farsi, French, Kurdish, Pashto
and Turkish).586
In February 2023, the Office for Human Rights and the Rights of National Minorities issued a brochure
"The Rights of Persons Granted International and Temporary Protection". The brochure contains
information on the available mechanisms for the protection and promotion of human rights and the
suppression of discrimination in Croatia, especially in the context of international and temporary
protection. The brochure is available in twelve languages: Arabic, English, Farsi, Filipino, French, Hindi,
Croatian, Nepali, Pashto, Spanish, Turkish and Ukrainian.587
In 2022, the Governmental Office for Gender Equality, in cooperation with the Ministry of Interior and
UNHCR, published a leaflet intended to inform victims of gender-based violence about available
protection options and services. The leaflet is intended primarily for female migrants, refugees and
581
Croatian Government, ‘An updated edition of the Integration Guide has been published’, 21 January 2019,
available in Croatian at: https://bit.ly/2Xi52wX.
582
Office for Human Rights and the Rights of National Minorities: An updated edition of the publication Guide
for Integration published, available at: http://bit.ly/3K46LxT.
583
Office for Human Rights and the Rights of National Minorities: Publication Social Inclusion of Persons Granted
International Protection in the Republic of Croatia – data collection system development and
recommendations, issued, available at: http://bit.ly/3lx3o9D.
584
EMN, Bulletin n. 39, April - June 2022, available at: https://bit.ly/3K49FD3.
585
EMN HR, Video: Inclusion of a person under international protection into Croatian society, 16 September
2021, https://bit.ly/3Ms4kof. The video is a part of the INCLuDE project - Interdepartmental Cooperation in
Empowering Third-Country Nationals co-financed by the Asylum, Migration and Integration Fund (AMIF),
which aims to strengthen the preconditions for social inclusion of third-country nationals with emphasis on
persons granted international protection in the Republic of Croatia.
586
Office for Human Rights and Rights of National Minorities: Video "Inclusion of persons under international
protection in Croatian society" translated into 7 languages: Arabic, English, Farsi, French, Kurdish, Pashto
and Turkish, available at: http://bit.ly/3lx4rq5. The videos are available at the following links:
https://www.youtube.com/watch?v=buppk_IR7MI; https://youtu.be/TshH_VF6TtY;
https://youtu.be/1h12SRmaYQw; https://youtu.be/hGI15wrq8ZA;
https://www.youtube.com/watch?v=2dJ6x8_5VxI; https://youtu.be/mNvzuhIMFHY;
https://youtu.be/WUrLp6kvJMc.
587
Office for Human Rights and the Rights of National Minorities: Brochure Rights of the persons granted
international and temporary protection issued, available at: http://bit.ly/3lGIJQn.
123
applicants for international protection, although it acknowledges that gender-based violence can be
committed against men. It is available in 8 languages (Arabic, Croatian, English, Farsi, French, Kurdish,
Turkish and Urdu).588
In 2021, the Ministry of Interior created the application “Resettle in Croatia”.589 The application was created
with the aim of providing faster and easier access to information and guidelines for persons who arrive in
Croatia under a resettlement programme, and who are granted international protection upon arrival. The
application was developed as part of the project "Establishment of a resettlement mechanism" co-financed
by the European Union from the Asylum, Migration and Integration Fund. In addition to information on the
different steps, i.e. the procedure in the Republic of Türkiye and after the arrival in the Republic of Croatia
for persons from the resettlement programme, the application offers information on the rights that persons
acquire after obtaining international protection and how to exercise these rights and obligations in the
Republic of Croatia. The application further offers all persons who have been granted asylum or subsidiary
protection in the Republic of Croatia useful information on all important aspects of life in the Republic of
Croatia from health care, education, work, housing to easier access to activities necessary for daily
functioning. The application is available in Croatian, English, Arabic and Kurdish.590
In 2022, IOM Croatia, in cooperation with IOM Slovenia and Croatian Ministry of Interior, prepared
brochures and posters as well as video clips for applicants for and beneficiaries of international protection
on vaccination against COVID-19 in 5 different languages. 591 In July 2022, the IOM, in cooperation with
the Ministry of the Interior, has started the implementation of the project "Technical assistance in the
integration of third-country nationals into the Republic of Croatia". The project is broadly directed at
migrants, including, applicants for and beneficiaries of international protection. During 2022, an analysis
of the legislative framework in the field of integration for third-country nationals was carried out, as well
as an analysis of stakeholders in the field of integration at the national, regional and local levels.
On the ‘Help’ website run by UNHCR, persons granted international protection can also find information
about their rights, obligations and the services available to them in Croatia.592 In 2022, UNHCR Croatia
presented the Toolkit for Effective Inclusion of Refugees, developed by UNHCR and the Migration Policy
Group, to local and regional authorities, local NGOs, representatives of public services and other key
stakeholders. In addition, in 2022 UNHCR launched an awareness-raising campaign in the ten largest
Croatian cities on the World Refugee Day, which included the creation of visual works in key urban
locations by renowned Croatian artists. In addition, UNHCR organized a conference for Croatian
journalists on the topic of reporting on refugee inclusion (increasing visibility in the media, ethical
dilemmas and professional standards when reporting on refugees). Second year of partnership with IKEA
Croatia, which provided three-month fully paid internship opportunities for 11 refugees in IKEA Zagreb,
has successfully continued.593
In 2022, the association RODA (Parents in Action), with the support of UNICEF, created a website
(https://www.parentingincroatia.eu/) where basic information is provided to families on the move and
families with children staying in Croatia. For now, the texts are available in Croatian and Ukrainian, and
the plan is to adapt and translate the texts into English, Arabic, Farsi and French.594
In January 2022, Croatian Law Centre started the implementation of the project "Complementary
pathways for Southeast Europe - COMP4SEE". The project aims to contribute to the development of
588
Office for Gender Equality, The Office for Gender Equality published a leaflet for female migrants, refugees
and asylum seekers, available at: https://bit.ly/3FNHzte.
589
EMN HR. Resettle in Croatia, available at: https://bit.ly/3hRLEQt.
590
Application (Re)Settle in Croatia is available via Google Play: https://bit.ly/3hHzBp4; and Apple App Store:
https://apple.co/3Mvkihh.
591
Information provided by IOM Croatia, 18 January 2023., materials available at: https://bit.ly/3MNl1LX.
592
UNHCR, Help, Website available at: https://bit.ly/3sPxNNF; see also videos available at: https://bit.ly/3nki3RI.
593
594
Information provided by RODA, 6 December 2022.
124
complementary pathways by creating new models of private sponsorship and by making and advocating
recommendations for improving national systems in the area of family reunification.
As reported in previous years, beneficiaries of international protection still face challenges in exercising
their rights, as detailed in this Chapter. The MIPEX 2020 ranking listed Croatia among the countries
categorised as Equality on paper - Slightly unfavourable.595
In the summer 2020, UNHCR conducted a so-called participatory assessment, a process through which
consultations with refugees are carried out. The participatory assessment confirmed that COVID-19 had
an impact on all areas of refugee lives, from language learning, access to gainful employment to social
integration into local communities.596 The lack of language skills and the need to have additional Croatian
language classes were repeatedly mentioned throughout the assessment, covering employability
(especially for women), additional training, communication with neighbours, doing errands and generally
through their perception of being accepted and integrated into society.
Lack of Croatian language courses was reported in 2022 as well.597 The Ministry of Interior terminated its
cooperation with the Ministry of Science and Education, among other things, due to its failure to hold
language courses. Since language courses financed from the state budget are not available, this
constitutes a problem for persons under international protection who are located outside the capital city
of Zagreb and do not have access to organizations that hold informal courses.598
The Ombudsman's report for 2022 states that according to the Ministry of Interior, the above mentioned
contract was terminated because the Ministry of Science and Education applied it in a way that contrary
to the principles of good financial management and the rules of the profession. In addition, the report
states that Croatian language courses, when conducted, are organized only at A1 and A2 levels, while
B2 level is required for performing jobs and obtaining citizenship. Therefore, the Ombudswoman
recommended to the Ministry of Interior and the Ministry of Science and Education to find a way to finance
and implement customized B-level Croatian language courses for persons granted international protection
as soon as possible.599
Refugees often face multiple challenges while attempting to successfully integrate into local labour
markets, such as language barriers, difficulties in recognition of previously acquired skills, and limited
social and professional networks in the area where they are looking for jobs.
In 2021, Centre for Peace Studies (CPS) published a short thematic manual on how to facilitate integration
into the Croatian labour market.600 The manual is divided in three parts, one part aimed for third-country
nationals and the other two for NGOs and employers on how to help third - country nationals with
integration into the labour market in Croatia.
According to Ombudsperson’s report for 2022, civil society organizations stressed that there are
differences in access to rights for persons displaced from Ukraine and for beneficiaries under international
protection.
The main problems in integration identified by the Ombudsperson are: non-implementation of Croatian
language courses, delays in preparatory classes for children, and difficulties in accessing high
education.601
595
Equality on paper means that immigrants do not enjoy equal opportunities. This group of countries goes only
halfway towards providing immigrants with basic rights and a secure future. Policies may encourage the public
to see immigrants as subordinates, not equal and not potential citizens. See the Mipex key findings here:
https://www.mipex.eu/key-findings.
596
UNHCR, 2020 Participatory Assessment Croatia, Impact of COVID-19 pandemic on refugee integration in
Croatia, March 2021, available at: https://bit.ly/35WojdK.
597
Information provided by Rehabilitation Centre for Stress and Trauma, 18 January 2023; AYS. 3 February
2023.
598
Information provided by AYS. 3 February 2023.
599
Ombudsperson, Annual report 2022, available in Croatian at: https://bit.ly/3OKwMVW.
600
Available at: https://bit.ly/3sOwwcZ.
601
125
The Croatian Red Cross reported that beneficiaries of international protection continued to face
challenges in exercising their rights in the health care system and accessing housing after two years of
subsidized housing. Croatian language courses are still problematic as reported by CRC.602
The Centre for Peace studies (CPS) reported that in 2022, beneficiaries of international protection
encountered a number of institutional barriers as well as discrimination practices in exercising their rights.
CPS reported problems relating to Croatian language courses, the access to the healthcare system,
delays in preparatory classes for children, challenges in accessing high education and exercising rights
of the students, and the access to the housing system. CPS also reported problems in the recognition of
qualifications and notification of diplomas when persons have documents proving their education, as well
as a lack of customised procedures for recognition of qualifications when they do not have documents.603
Civil Rights Project Sisak reported problems with the access to housing after expiration of two years of
subsidised housing.604
Are You Syrious? (AYS) reported problems within the system of subsidised housing as in practice,
accommodation is waived for several months. AYS reported problems with accessing preparatory classes
for children and higher education, as well as challenges within the health system.605
Civis Mundi, which carries out activities in the area of the cities of Rijeka and Sisak and the municipality
of Viškovo, reported problems with the Croatian language courses, small and inadequate accommodation
facilities, challenges in accessing the higher education and employment.606
In overcoming those challenges, beneficiaries are assisted by various NGOs:
 At the end of November 2018, the Platform “Danube Compass” was introduced to help with
migrants' economic and social integration into society.607 The Danube Compass covers living,
working, language learning, education, daily life and health and offers an overview of main rights. The
Croatian version brings content available in Croatian and English but also in Arabic, Farsi and Urdu.608
“Danube Compass“ is thus a central place for all integration services that migrants can use, as well
as the institutions and organisations that work with migrants.609 In 2021, Danube Compass, has been
updated and translated into Arabic, English, Farsi and Urdu.610
 A Web platform for integration is provided by the NGO Mi.611
 In the course of 2022, Rehabilitation Centre for Stress and Trauma (RCT), carried out activities
with beneficiaries of international protection related to the access to the labour market, assistance in
family reunification procedure and activities with unaccompanied children.612
 Centre for children, youth and family –Modus provided psychosocial counselling. In addition, they
provided assistance with learning for children under international protection.613
602
Information provided by CRC, 18 January 2023.
603
604
605
606
Information provided by Civis Mundi, 14 February 2023
607
The Danube Compass was created under the project “Danube Region Information Platform for Economic
Integration of Migrants (DRIM)”, funded by the European Union’s INTER-REGs programme.
608
Information provided by Centre for Peace Studies, 27 December 2018. See also:
http://hr.danubecompass.org/.
609
EMN, Bulletin, July 2019, available at: https://bit.ly/34GhR5V.
610
EMN Bulletin Number 35, April – June 2021, available at: . https://bit.ly/34sYBxm.
611
The website is available at: https://www.irh.hr/.
612
613
Information provided by the Centre Modus, 9 January 2023
126
 In 2022, the Civil Rights Project Sisak provided psychosocial assistance and free legal aid, including
assistance in finding adequate housing. They issued a manual that, among other categories, targets
beneficiaries granted international protection.614
 In March 2020, the Ministry of Interior and the NGO “Centre for Cultural Dialogue” (CCD) concluded
an agreement on the allocation of financial resources for the implementation of the project "New
Neighbours - inclusion of persons who have been granted international protection in Croatian society”,
aiming at improving their living conditions (through AMIF). The implementation of the project began
in April 2020.615 The project is implemented in partnership with the Islamic Community in Croatia and
with the support of the Ministry of Interior. The aim of the project is to increase the success of
integration in the three years for 200 people in Croatia who have been granted international
protection.616 CCD assists beneficiaries of international protection through seven mobile teams
composed of a caseworker and cultural mediator in Zagreb, Osijek, Slavonski Brod, Sisak, Karlovac,
Rijeka, Pula and Zadar. An integral part of their assistance consists in preparing individual integration
plans and assistance with access to services. If beneficiaries of international protection accept their
services, they will receive an information package from the Ministry of Interior and the CCD will be
notified.617 The project ended in March 2023.
 The Croatian Red Cross (CRC) in 2022 provided support to beneficiaries of international protection
under their integration programme in the field of health care, employment and family reunification.
CRC also provided group activities such as going to museums, Science Park, sports, educational
activities for beneficiaries in Zagreb, Karlovac and Sisak. A leaflet on the first steps in integration of
refugees is available at CRC’s website.618
 In 2022, AYS assisted beneficiaries of international protection with activities on access to the labour
market, which in practice meant assisting them in drafting resumes, finding suitable jobs in rapport to
beneficiaries’ education, work experience and contacting potential employers. AYS also provided
individual consultations by phone and in person on the rights of persons under international protection
particularly regarding rights from the social welfare system, pension insurance, health care.
Beneficiaries were also assisted in several health care institutions (health centres, hospitals, dental
practice, etc.) Support to school-aged children was also provided in learning the language, mastering
school materials, cooperating with schools and mediating in the communication of parents with the
school. Assistance was also provided in enrolling in primary and secondary school, as well as in
higher education and adult education. AYS continued to run a so-called FREE SHOP - a place where
applicants for and beneficiaries of international protection can get clothes, shoes, hygiene items,
dishes and other household items free of charge. AYS also provided 4 informal initial Croatian
language courses for applicants for international protection and beneficiaries with granted
international protection. Due to increase in unemployment among persons under international
protection, in cooperation with the Solidarna foundation and the association Wir Packen’s An, AYS
continued with the support program in the form of covering one rent or offering one-time aid to cover
the cost of food for people in unfavourable socio-economic conditions. Throughout 2022, they helped
29 households. Throughout 2022, AYS prepared leaflets on the rights of beneficiaries of international
protection. Leaflets are available in Arabic, Persian, Kurdish and Spanish.619
 In 2022, lawyers of the Croatian Law Centre, as UNHCR’s implementing partner, provided legal
information to beneficiaries of international protection in person, over the phone, WhatsApp and e-
mail. In 2022, CLC updated Croatian version of the handbook “Integration of refugees into Croatian
Society- legislation and realization in practice” ” with the financial support of UNHCR. The booklet is
intended to all those actors who provide direct assistance and support to persons who were granted
614
Civil Rights Project Sisak: Manual, available in Croatian at: https://bit.ly/42qdOas.
615
EMN, Migration Bulletin number 31, August 2020, available at: https://bit.ly/2QRsD6C.
616
Center for Culture of Dialogue: The Project of the Center for Culture of Dialogue "New Neighbours" presented
to the public, available at: https://bit.ly/3aCWE0U.
617
UNHCR: Living in Croatia, available at: https://bit.ly/3vldp92.
618
Leaflet available at: https://bit.ly/32RH656.
619
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international protection in Croatia, but also to all other actors in the field of integration assisting such
persons. The booklet is available in Croatian and English and contains six chapters: Framework for
the Integration of Refugees into Croatian Society; The Provision of Social Services to Persons
Granted International Protection at the Local Level in Croatia; An Overview of the Standards
Regarding the Right to work and Access to the Labour Market of Persons Granted International
Protection; An Overview of International, European and National Standards of the Recognition of
Qualifications of Refugees; The Concept of Family Reunification in the Republic of Croatia, Access
to Free Legal Aid for Persons Granted International Protection. 620 In 2022, CLC held a second module
of trainings on the topic Development and strengthening of inter-sector cooperation in local self-
government units. Education was a part of the Government’s Office for Human Rights and Rights of
National Minorities' project “Include – Interdepartmental Cooperation on Strengthening of the Third-
country Nationals". Three two-day educations were held in Zagreb, Rijeka and Osijek.
 The Center for Peace Studies (CPS) provided different types of support to persons granted
international protection such as individual informal courses on the Croatian language, support in
accessing the labour market, information on life in Croatia and general psychosocial support.
Furthermore, their lawyer and the volunteer lawyers provided legal information and advice on various
status issues.621
 In the cities of Rijeka and Sisak and the municipality of Viškovo, the CIVIS MUNDI association
assisted beneficiaries of international protection in 2022. Their activities included the following:
donations of hygiene items, clothes and shoes, appliances; organisation of city tours and its
surroundings in order for beneficiaries to familiarize themselves with the place of residence; helping
with the enrolment of persons granted international protection in an intensive Croatian language
course; creative workshops, assisting in employment; helping in everyday life (enrolling in sports
activities); organisation of psychosocial support groups etc.622 From May 2020 to December 2022,
Civis Mundi implemented the Project: "Improvements of the Integration Procedure"623
A. Status and residence
1. Residence permit
Indicators: Residence Permit

1. What is the duration of residence permits granted to beneficiaries of protection?
 Refugee status 5 years
 Subsidiary protection 3 years
There is a difference in duration of residence permit issued to recognised refugees (“asylees”) and
beneficiaries of subsidiary protection. A residence permit shall be issued to an asylee for a period of
five years,624 and to foreigner under subsidiary protection for a period of 3 years.625
Both categories have the right to residence in the Republic of Croatia from the day of the delivery of the
decision approving international protection, which is demonstrated by their residence permit. The right to
residence in the Republic of Croatia shall be established by the decision approving international
620
Croatian Law Centre, The integration of refugees into Croatian society: Legislation and realisation in practice,
available in Croatian at: https://bit.ly/3tCsO5u; and in English at: https://bit.ly/3MxIqjf.
621
Information provided by the Centre for Peace Studies, 18 January 2023.
622
Information provided by Civis Mundi, 14 February 2023.
623
See: https://civis-mundi.hr/projekti/.
624
Article 75(2) LITP.
625
Article 75(3) LITP.
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protection.626 The request for issuing residence permit should be submitted to the competent police
administration,627 and the residence permit should be issued within 30 days from submitting the request. 628
According to the Ministry of Interior 411 residence permits were issued to asylees and 79 to foreigners
under subsidiary protection in 2018.629 No information is available for 2019 and 2020.
In 2021, 257 residence permits were issued to asylees and 24 residence permits to foreigners under
subsidiary protection,630 while in 2022, residence permits were issued to a total of 211 persons who has
been granted with international protection status (183 asylees and 28 persons under subsidiary
protection).631
However, the decision approving international protection shall be revoked in the part relating to approval
of the right of residence in the Republic of Croatia if the asylee or foreigner under subsidiary protection
moves out of the Republic of Croatia or resides continually abroad for longer than 6 months without
previously informing the Ministry of Interior of this fact.632
2. Civil registration
According to the Law on State Register, in the Republic of Croatia, the personal status of citizens (birth,
marriage and death) and other information related to those facts are recorded in the State Register. 633
The registration of a birth of child into the Birth Register is made on the basis of the oral registration or
written applications to the registrar in a place where the child was born. If a child is born in a health
institution, it is required that a health institution reports a birth. If a child is born outside a health institution,
the father of the child is required to report the child’s birth, or the person in whose place of residence the
child was born or a mother when she is capable of it, or a midwife, or a doctor who participated in the
childbirth.
When these persons are not present, or when they cannot report the birth, the person who finds out about
the birth is obliged to report it. The birth of a child must be reported within 15 days of the birth. Marriage
is regulated by the Family Law. 634 Preconditions for marriage are divided into those needed for the
existence of marriage and preconditions for the validity of marriage. For the existence of marriage, it is
necessary for the spouses to be opposite sexes, to have given their consent to enter into marriage and
for a civil marriage to be contracted before a registrar or a religious marriage to be contracted in
accordance with the relevant provision of Family Law. If at the time of entering into marriage any of the
preconditions referred to above has not been fulfilled, no legal effects of marriage shall ensue.
For the validity of marriage, a marriage may not be entered into by a person under the age of eighteen.
As an exception, the court may allow a sixteen-year-old person to enter into marriage, provided that the
court finds the person mentally and physically mature enough to marry, and that there is a justifiable
reason for marriage. In addition, a person incapable of discernment may not enter into marriage. Marriage
may not be contracted between persons of lineal consanguinity or collateral consanguinity between a
sister and a brother, a stepsister and a stepbrother, the child and its sister or stepsister or brother or
626
627
Article 75(1) LITP; Article 10(1) Ordinance on the Forms and Data Collections in the Procedure for International
and Temporary Protection.
628
Article 12(1) Ordinance on the Forms and Data Collections in the Procedure for International and Temporary
Protection.
629
630
631
632
Article 65(3) LITP.
633
Official Gazette 96/1993, 76/2013,98/2019, 133/2022.
634
Official Gazette 103/15, 98/2019, 47/2020.
129
stepbrother, or between the children of sisters and brothers or stepsisters and stepbrothers. This shall
also apply to relationships established by adoption. A marriage may not be entered into by a person who
is already married or is in a same-sex life partnership registered under the relevant legislation. A marriage
that is contracted contrary to the provisions above is not valid and the provisions for annulment shall
apply.
Family Law regulates civil marriage and religious marriage with the effects of a civil marriage. Civil
marriage is contracted before a registrar, while religious marriage is contracted before an official of a
religious community that has a regulated legal relationship thereof with the Republic of Croatia. The
spouses must give notice of their intention to enter into a civil marriage in person to the registrar competent
for the place where they wish to enter into marriage. They must enclose relevant documents at the
registrar’s request. Asylees and foreigners under subsidiary protection, when reporting their intention,
have to provide the certificate that they have been granted asylum or subsidiary protection and adequate
proof of non-existence of another marriage. Adequate proof is considered to be a statement made before
a public notary or before a registrar where they announce their intention to marry.
The registrar shall verify, on the basis of the spouses’ consent and by using other means, whether the
preconditions for entering into marriage have been met. If a court decision is needed for entering into
marriage to take place, the registrar shall ask the spouses to obtain one. After having verified that the
preconditions for entering into marriage have been met, the registrar shall take a statement from the
spouses on the choice of the surname.
The spouses shall confirm by their signatures that they understand their personal rights and
responsibilities in marriage, as well as the possibility of determining property relations.
The registrar shall determine the date of marriage upon the agreement with the spouses who want to
enter into a civil marriage usually in the period between the thirtieth and forty-fifth day since the day of
giving the notice of the intention to enter into marriage.
A marriage is contracted in the presence of the spouses, the registrar and two witnesses who have to be
of full age and have legal capacity. The spouses who want to enter into a religious marriage shall obtain
from the registrar competent for the place where they wish to enter into marriage a certificate of having
fulfilled all marriage preconditions.
The official of the religious community before whom the religious marriage has been contracted shall
submit the registrar the document signed by the spouses, the witnesses and the religious community
official which confirms that the marriage has been contracted. This document must be submitted to the
registrar within five days of the date of the contraction of marriage. The registrar is obliged to record the
religious marriage into a marriage register within three days of the day of receipt of the document.
Immediately upon entering the records on the contracted marriage into a marriage register, the registrar
shall submit the marriage certificate to the spouses. The registrar shall inform the spouses that the
marriage certificate from a national marriage register is a proof that the religious marriage they entered
into is equal in effect to a civil marriage.
3. Long-term residence
Indicators: Long-Term Residence

1. Number of long-term residence permits issued to beneficiaries in 2022: Not available
A new Law on Foreigners entered into force on 1 January 2021 and was amended in the course of 2022.
One of the novelties introduced in 2021 was the distinction between long-term residence and permanent
residence. Long-term residence may be granted to a third-country national who, prior to the day of
submission of application for long term residence, has been granted temporary stay, asylum or subsidiary
protection in the Republic of Croatia for an uninterrupted period of five years. A third-country national shall
be deemed as having continuously resided in the Republic of Croatia even if he or she was absent from
the Republic of Croatia within the five-year period for up to ten months in total for multiple absences, or
130
up to six months for a single absence. At the time of deciding on the application for a long-term residence,
the third-country national must have a granted temporary residence, asylum or subsidiary protection in
the Republic of Croatia. The third-country national shall not be granted long-term residence if his or her
asylum or subsidiary protection has been annulled.635
The 5 years’ residence period required for the approval of long-term residence for refugees or
beneficiaries of subsidiary protection, shall be calculated also to include the time before international
protection was granted i.e. to include a half of the time from the day when the application for international
protection was lodged until the day when international protection was granted, or the entire period of time
if it exceeds 18 months.636
A beneficiary shall submit an application for a long-term residence to the Police Administration or Police
Station based on the place of his/her temporary residence. The Ministry of Interior must approve the
granting of long-term residence and an administrative dispute may be initiated against the Ministry’s
decision in case it has been rejected.637
Long term residence shall be granted to a third-country national who, along with the above conditions:638
1. Has a valid foreign travel document;
2. Has means of subsistence;
3. Has health insurance;
4. Knows the Croatian language and the Latin script; and
5. Is not considered to be a threat to public policy or national security.
Asylees and foreigners under subsidiary protection are not obliged to meet the condition of having a valid
foreign travel document.639
An application for the issuance of a residence permit shall be submitted by a third-country national on
long-term residence within eight days from the day s/he was granted long-term residence in the Republic
of Croatia.640
In 2018, 8 long term residence statuses were granted to asylees and 7 to foreigners under subsidiary
protection. A total of 15 long-term residence permits for asylees and 13 for subsidiary protection
beneficiaries were valid at the end of 2018.641 However, no information is available for 2019 and 2020.
In 2021, 4 long-term residence permits were approved (3 to asylees, 1 to a beneficiary of subsidiary

protection),642
4. Naturalisation
Indicators: Naturalisation
1. What is the waiting period for obtaining citizenship? 8 years
2. Number of citizenship grants to beneficiaries in 2022: Not available
Requirements for the acquisition and termination of Croatian citizenship are regulated by the Law on
Croatian Citizenship.643
635
Article 150 (1) (4) Law on Foreigners
636
Article 151(3) Law on Foreigners.
637
Article 152(1)(3) Law on Foreigners.
638
Article 153 (1) Law on Foreigners.
639
640
641
642
643
Official Gazette 53/1991, 70/1991, 28/1992, 113/1993, 4/1994, 130/2011, 110/2015, 102/2019, 138/2021.
131
An application for Croatian citizenship on grounds of naturalisation should be submitted at the competent
police administration or police station, where the place of temporary or permanent residence is located.
Physically handicapped persons can submit the application via their legal representative or attorney. An
application can also be submitted at diplomatic missions or consular offices of the Republic of Croatia
abroad.644
A foreign citizen who submit application for acquiring Croatian citizenship shall acquire Croatian
citizenship by naturalisation if he or she:645
1. Has reached the age of eighteen years;
2. Has had his or her foreign citizenship revoked or he or she submits proof that he or she will get a
revocation if admitted to Croatian citizenship;646
3. Before submitting application, he or she has lived at registered place of residence for a period of
8 years constantly on the territory of the Republic of Croatia and has been granted permanent
residence permit;
4. Is proficient in the Croatian language and Latin script and is familiar with the Croatian culture and
social system;
5. Respects the legal order of the Republic of Croatia, has covered all due taxes and other financial
obligations towards public bodies and there are no security related restrictions to accessing
Croatian citizenship.
According to the LITP, if refugees or beneficiaries under subsidiary protection are not able for objective
reasons to obtain official documents from their country of origin necessary to acquire Croatian citizenship,
official documents of the Republic of Croatia shall be taken into account in the procedure to acquire
Croatian citizenship, along with other documents they possess, on the basis of which it may be assessed
whether they meet the conditions for the acquisition of Croatian citizenship. 647 A decision to refuse an
application for Croatian citizenship may not be based exclusively on the fact that the necessary official
documents of the country of origin have not been submitted.
In 2018 and 2019, no person granted international protection acquired Croatian citizenship. In 2020,
nine persons were granted Croatian citizenship.648
In 2021, two persons who were granted subsidiary protection got Croatian citizenship.649 The similar
was reported for 2022 i.e. two persons with subsidiary protection were granted Croatian citizenship.650
644
Article 24 (3)(4) Law on Croatian Citizenship.
645
Article 8(1)(5) Law on Croatian Citizenship.
646
This condition is deemed met if the application was submitted by a stateless person or person would lose his
or her existing nationality by naturalisation in Croatia. If a foreign country does not permit dismissal from its
citizenship or it places requirements or dismissal which cannot be fulfilled, a statement of the applicant who
has submitted a request will be sufficient to renounce his foreign citizenship under the conditions of acquisition
of Croatian citizenship.
647
648
Office for Human Rights and Rights of National Minorities of the Government of the Republic of Croatia:
INCLuDE Social Inclusion of Persons Granted International Protection in the Republic of Croatia,year of
publication: 2022, available in English at: https://bit.ly/3E23GKi; and in Croatian at: https://bit.ly/3O3c4xz.
649
650
132
5. Cessation and review of protection status
Indicators: Cessation
1. Is a personal interview of the beneficiary in most cases conducted in practice in the cessation
procedure? Yes No
2. Does the law provide for an appeal against the first instance decision in the cessation
procedure? Yes No
3. Do beneficiaries have access to free legal assistance at first instance in practice?

Cessation of international protection is regulated by LITP. Asylum shall be ceased if:651

1. The refugee (“asylee”) voluntarily accepts the protection of the country of which he/she is a
national;
2. The asylee acquires the citizenship of the country whose protection he or she may enjoy;
3. The asylee voluntarily returns and resides in the country he or she left or outside of which he or
she has resided due to fear of persecution;
4. The circumstances in the asylee's country of origin, on the basis of which international protection
was approved, cease to exist;
5. The refugee voluntarily re-acquires the nationality of his or her country of origin, which he or she
had previously lost.
Subsidiary protection shall be ceased if the circumstances on the basis of which it was granted cease
to exist or are altered to such an extent that further protection is no longer necessary.652 After establishing
that the circumstances related to the cessation of international protection referred have ceased to exist in
a significant and permanent manner, the Ministry of Interior shall inform the refugee or beneficiary of
subsidiary protection accordingly and shall allow him or her to make an oral statement for the record.653
The Ministry of Interior shall render a decision to revoke the decision approving international protection
and a claim may be brought before the Administrative Court within 8 days of the day of delivery of the
decision.
However only asylees in whose case the circumstances in the country of origin, on the basis of which
international protection was approved, cease to exist have the right to free legal assistance, meaning that
a legal representative can be paid from the state budget to submit a law suit and represent the beneficiary
before the Administrative Court.654
According to the Ministry of Interior, there were no cases of cessation of international protection in 2015,
2016, 2017 or 2018.655 However, the Ministry continuously examines whether the legal requirements for
cessation are fulfilled. This provision applies without exception to all categories of foreigners who have
previously been granted international protection. No information on cases of cessation of international
protection is available for 2019 and 2020.
In 2021, subsidiary protection was ceased for one Georgian national pursuant to Art. 49, para. 2 of the
LITP.656
651
Article 49(1) LITP.
652
Article 49(2) LITP.
653
Article 49(3) LITP.
654
Article 72 LITP.
655
Information provided by the Ministry of Interior, 2 March 2017; 13 February 2018, 28 January 2019.
656
133
6. Withdrawal of protection status
Indicators: Withdrawal
1. Is a personal interview of the beneficiary in most cases conducted in practice in the withdrawal
procedure? Yes No
2. Does the law provide for an appeal against the withdrawal decision? Yes No
3. Do beneficiaries have access to free legal assistance at first instance in practice?

According to the LITP, international protection shall be revoked if:657

1. Reasons for exclusion are subsequently established;
2. It is established that status was recognised on the basis of incorrectly presented or omitted facts,
false presentation of important facts and circumstances, or the use of unreliable documents or
other documents which were decisive for the approval of international protection; or
3. The person to whom international protection was granted represents a risk to the national security
or public order of the Republic of Croatia.
After establishing that circumstances have arisen relating to the revocation of international protection, the
Ministry of Interior shall inform the refugee or beneficiary of subsidiary protection of the reasons for
revocation and shall allow him or her to make an oral statement about those circumstances for the record.
The Ministry of Interior renders a decision to revoke the decision approving international protection. A law
suit may be brought before the Administrative Court against that decision within 8 days from the day the
decision is delivered.
A third-country national or stateless person who represents a risk to the national security or public order
of the Republic of Croatia as provided above, whilst in the Republic of Croatia, shall enjoy rights pursuant
to the 1951 Convention, especially in relation to the prohibition of discrimination, freedom of religion,
access to courts, education, non-punishment of irregular entry or stay, expulsion and respect of the non-
refoulement principle.
In 2018, the Ministry of Interior revoked international protection for 3 persons (2 refugees and 1 holder of
subsidiary protection). Out of those, one asylum status of an Afghan national and one subsidiary
protection status of unknown citizenship were revoked on the basis that person to whom international
protection was granted represented a risk to the national security or public order of the Republic of Croatia,
while one asylum status of an Iraqi national was revoked on the basis that reasons for exclusion were
subsequently established.658
According to the Ministry of Interior, 2 asylum statuses (applications from 2016 and 2017) and 3 subsidiary
protection (applications from 2009) were annulled in 2020.659
In 2021, international protection was annulled for four persons. 660
657
Article 50 LITP.
658
659
Source: Ministry of Interior, Statistical overview of basic safety indicators and work results in 2020, available
at: https://bit.ly/2QsZP4H, 163.
660
at: https://bit.ly/3NBv.
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B. Family reunification
1. Criteria and conditions
Indicators: Family Reunification

1. Is there a waiting period before a beneficiary can apply for family reunification?
Yes No
 If yes, what is the waiting period?
2. Does the law set a maximum time limit for submitting a family reunification application?
Yes No
 If yes, what is the time limit?
3. Does the law set a minimum income requirement? Yes No
In Croatia, family reunification is regulated primarily by the LITP,661 as well as by the Law on Foreigners.
At the moment, no requirements in relation to waiting periods before a beneficiary can apply for family
reunification or a maximum time limit for applying for family reunification are prescribed by the legislation,
nor is there a minimum income requirement.
A family member for whom reasons exist for exclusion and for reasons of protection of the national security
or public order of the Republic of Croatia shall not have the right of family reunification.662
The Croatian Law Centre, in cooperation with UNHCR Croatia, the Ministry of the Interior and the Ministry
of Foreign and European Affairs, created leaflets with information on the procedure for family reunification.
The leaflet was published in Croatian, and translated into Arabic, Farsi and English. 663
In practice, family reunification procedures remain lengthy and highly bureaucratized that beneficiaries of
protection alone, without additional support, can hardly manage.
In 2020, the Croatian Law Centre prepared the updated analyses of the institute of family reunification in
Croatia.664 The paper explains the conditions for family reunification, stages in the family reunification
process, but also the reasons when exclusion from the right to family reunification may occur. The paper
also lists the most common problems that arise in these procedures:
- non-receipt of applications for family reunification by embassies and / or consular missions of the
Republic of Croatia due to incomplete documentation;
- distance of embassies and / or consular offices of the Republic of Croatia from the countries of origin
where persons who want to apply for family reunification are situated:
- uneven practice of some honorary consuls located in countries where there are no diplomatic
missions and / or consular missions of the Republic of Croatia, as some are reluctant to participate in
connecting persons in need and embassies and / or consular missions:
- family members who want to reunite with a beneficiary of international protection and who are in war-
torn countries are often unable to obtain travel documents, which makes it impossible to initiate the
procedure itself;
- obtaining documents proving kinship with a beneficiary of international protection is also a problematic
for persons who want to reunite;
- the problem of financing travel expenses which include airplane tickets, fees, travel health insurance,
travel expenses to the country where the diplomatic mission and / or consular post of the Republic of
Croatia is located, and financing accommodation / staying costs in that country pending a decision.
661
Article 66 LITP.
662
Article 66(5) LITP.
663
CLC, UNHCR, Ministry of Interior and Ministry of Foreign and European affairs, Family reunification in Croatia
- Information for persons granted international protection, available in Croatian at: https://bit.ly/2RfNCgY; in
Arabic at: https://bit.ly/2V7Prh5; in Farsi at: https://bit.ly/2whB6Ge; and in English at: https://bit.ly/2Xi6lwe.
664
Croatian Law Centre: Analyses of the institute of family reunification, September 2019, available in Croatian
at: https://bit.ly/3elXNLn.
135
1.1. Eligible family members
Both refugees (“asylees”) and beneficiaries of subsidiary protection have the right to family reunification
with following family members:
- the spouse or unmarried partner under the regulations of the Republic of Croatia, and persons
who are in a union, which under the regulations of the Republic of Croatia may be deemed to be
a life partnership or informal life partnership;
- the minor child of the marital or unmarried partners; their minor adopted child; the minor child and
minor adopted child of a married, unmarried or life partner who exercises parental care of the
child;
- the adult unmarried child of a refugee or beneficiary of subsidiary protection who, due to his or
her state of health is not able to take care of his or her own needs;
- the parent or other legal representative of a minor;
- a relative of the first degree in a direct ascending blood line, with whom he or she lived in a shared
household, if it is established that he or she is dependent on the care of a refugee or beneficiary
of subsidiary protection.
A minor child of a refugee or beneficiary of subsidiary protection who has not formed their own family shall
follow the legal status of their legal representative to whom international protection has been granted, on
which the Ministry of Interior shall render a decision.
In the case of family reunification of refugees or beneficiaries of subsidiary protection, for a person who
is unable to obtain official documents to prove a specific family relationship, circumstances shall be taken
into consideration on the basis of which it may be assessed whether or not such a relationship exists. A
decision to refuse an application for family reunification cannot be based exclusively on the fact that no
official document exists to prove a specific family relationship. 665
1.2. Family reunification procedure
The family reunification procedure consists of two stages. First, an application for the temporary stay is
submitted; once temporary stay is granted, an application for the issuance of a long-term visa has to be
submitted.
National legislation stipulates that in the case of reunification with an asylee or a foreigner under
subsidiary protection, the procedure is initiated by a family member of the person who has been granted
international protection in Croatia, by submitting an application to the competent Croatian
diplomatic/consular representation. In practice, if some problems exist and family members cannot reach
the competent Diplomatic Mission, some Diplomatic Missions or Consular Offices of the Republic of
Croatia allow applications to be submitted at some other Croatian mission. The application for temporary
stay based on family reunification may be submitted regular mail. Once temporary stay for the purpose of
family reunification is granted, the person has to apply for visa to enter Croatia. Family member has to
appear in person at the embassy or external service provider to make an application for a visa to enter
Croatia and provide biometric data. The legal time limit for issuing the visa is 15 days from the date of
submission of the application for a long-term visa. However, this period can be extended up to a maximum
of 45 days, if there are justified reasons to do so. 666
In practice, the whole procedure lasts approximately six to nine months, and in some cases even the
whole year from the date of submission of application for temporary stay until family member come to
Croatia.
All family members of asylees and foreigners under subsidiary protection shall regulate their residence
pursuant to the provisions of the Law on Foreigners in order to be able to enter Croatia, which means that
they should submit applications for temporary stay.
Family members of asylees and foreigners under subsidiary protection who regulate their stay pursuant
665
Article 66(6) LITP.
666
Article 37(6) Law on Foreigner
136
to the provisions of the Law on Foreigners have to fulfil the following requirements:
- justify the purpose of temporary stay,
- hold a valid foreign travel document,
- when applying for temporary stay for the first time, provide a document proving that s/he has not
been convicted of criminal offences by a final ruling, which has been issued by home country or
a country in which s/he has resided for more than a year immediately prior to arriving in the
Republic of Croatia,
- has not been forbidden to enter into the Republic of Croatia and stay in the Republic of Croatia,
or if no alert has been issued in SIS for the purpose of forbidding his entry
- does not pose threat to public policy, national security or public health.667
However, they do not to provide proof of health insurance and proof of means of subsistence in order to
be granted temporary stay for the purpose of family reunification.668 If, during the procedure for granting
temporary stay, the close family member cannot provide proof of the existence of a certain familial
relationship with a third-country national who has been granted international protection, other proof of the
existence of such relationship can also be taken into account, which is assessed in line with the legislation
governing the general administrative procedure.669
A temporary stay permit shall be issued with the period of validity of up to one year and the validity of the
foreign travel document should be for three months beyond the period of validity of the temporary stay
permit.670
According to the Ministry of Interior, there were 39 applications for family reunification in 2018. 29
applications were approved and 10 were still pending at the end of 2018.
In 2021. total of 60 applications for temporary stay were submitted for the purpose of family reunification
with persons granted international protection. Out of these, 47 were granted (Bangladesh 1, DR Congo
7, Egypt 1, Eritrea 4, Iraq 2, Iran 1, Yemen 1, Jordan 1, Pakistan 3, Sierra Leone 2, Syria 20, Northern
Macedonia 1, Sudan 1, Türkiye 1, Ukraine 1) while 13 (Afghanistan 1, Eritrea 4, Russia 1, Syria 7) were
pending.671
In 2022, a total of 64 requests for family reunification with beneficiaries of international protection were
submitted, and by the end of 2022, 21 requests were in the process, while 43 requests were approved.
The largest number of requests were submitted by nationals of Syria, Iraq and Iran.672
2. Status and rights of family members
A minor child who has not started his/her own family and who has joined a person who has been granted
international protection in Croatia follows the legal status of a representative who has been granted
international protection,673 which means that child will be granted asylum or subsidiary protection
depending on the status of the family member the child is joining. As previously stated, in order to enter
Croatia, a child must have been granted temporary stay, and when a minor child of a person who has
667
Article 59(1) Law on Foreigner.
668
669
670
Article 61 (1),(2), (5) Law on Foreigners.
671
672
673
Article 66, paragraph 2 of the AITP: A minor child of an asylee and a foreigner under subsidiary protection
who has not started his/her own family follows the legal position of a legal representative who has been granted
international protection, which shall be decided upon by the Ministry.
137
been granted international protection comes to Croatia, the parent who has been granted protection
submits an application for international protection for the child.674
Other family members are granted temporary stay in accordance with Law on Foreigners.
A family member of an asylee or beneficiary of subsidiary protection who is legally resident in the Republic
of Croatia shall exercise the same rights as the beneficiary of international protection.675
C. Movement and mobility
1. Freedom of movement
Beneficiaries of international protection have freedom of movement within the State and are not allocated
to specific geographic regions within the country.
According to the LITP, asylees and beneficiaries of subsidiary protection have the right to social welfare
pursuant to the regulations governing the domain of social welfare of Croatian citizens.676 However some
rights from the social welfare system can vary depending on local self-administration and regional self-
administration.
2. Travel documents
There is a difference in the type and duration of travel documents issued to refugees and beneficiaries
of subsidiary protection. Asylees are issued a passport for refuges valid for 5 years,677 while foreigners
under subsidiary protection are issued special passport for foreigners, valid for 2 years. 678
Recognised refugees can travel within the EU without a visa, while foreigners under subsidiary
protection may be required to apply for a visa in order to travel to other EU countries.
A special travel document for foreigners may be issued to a foreigner who has been granted subsidiary
protection and is unable to obtain a national travel document due to no fault of his or her own.679 Such a
special travel document for foreigners is valid for a 2-year period.680
The request for both passport for refugees and special passport for foreigners should be submitted to the
competent police administration or police station.
Beneficiaries are requested to notify authorities of their intention to travel or stay abroad, irrespective of
the destination as they do not have to mention their destination. If a person stayed abroad longer than the
allowed duration, for example 6 months, she or he might lose his or her right to stay in Croatia and would
thus have to regulate his or her stay again upon return.681
In 2021, a total of 77 travel documents were issued in accordance with Convention relating to the Status
of Refugees, and 5 special travel documents for persons granted subsidiary protection.682
674
Ministry of Interior, Most frequently asked questions - international protection, available at:
https://bit.ly/3N9uhvi.
675
Article 66(4) LITP.
676
Article 73 LITP.
677
Article 75(6) LITP.
678
Article 75(8) LITP; Article 6(3) Law on Foreigners.
679
Article 8(1) Law on Foreigners
680
Article 65(8) Ordinance on stay of third country nationals in the Republic of Croatia.
681
EMN study, Beneficiaries of international protection travelling to their country of origin, November 2019,
available at: https://bit.ly/2Rfrtz1.
682
138
D. Housing
Indicators: Housing
1. For how long are beneficiaries entitled to stay in reception centres? Two years 683
2. Number of beneficiaries staying in reception centres as of 31 December 2022: Not available
According to the amendments of the LITP adopted in December 2017, entered into force on 1 January
2018, asylees and foreigners under subsidiary protection have the right to accommodation if they do not
possess the financial means or property to support themselves.684
The procedure for recognising the right to accommodation is initiated by the submission of a request to
the competent social welfare centre. The competent Centre is the centre in the place of domicile of the
asylee and foreigner under subsidiary protection. The Centre renders a decision. An appeal may be
lodged against the decision within 15 days of the date of delivery of the decision, but appeal does not
delay enforcement of decision. The ministry responsible for social welfare renders a decision on the
appeal, against which a lawsuit may be filed with the competent administrative court within eight days of
the date of service of the decision. Asylees and foreigners under subsidiary protection have the right to
accommodation for a maximum period of two years from the date on which the decision approving
international protection is served.685 With the expiry of 2 years’ time limit they have the right to
accommodation pursuant to the legislation regulating the field of social welfare.686 In practice however,
beneficiaries of international protection are allowed to stay in the Reception Centre for Applicants for
International Protection until appropriate accommodation (a flat) is found for them.
If the Centre establishes that the asylee or foreigner under subsidiary protection generates the financial
means or owns property that could be used to generate funds to participate in the payment of
accommodation costs, the decision recognising the right to accommodation shall state that the asylee or
foreigner under subsidiary protection is to participate in the payment of accommodation costs by making
a payment into the account of the Central State Office for Reconstruction and Housing.
If the Centre, in procedures within its remit, establishes, after the decision recognising the right to
accommodation becomes enforceable, that the asylee or foreigner under subsidiary protection has the
financial means or property to generate funds to participate in the payment of accommodation costs, it
shall quash the decision and issue a new decision, recognising the right to accommodation of the asylee
or foreigner under subsidiary protection and establishing the obligation to participate in the payment of
accommodation costs. An appeal against the decision may be lodged within 15 days of the delivery of the
decision but it does not delay its enforcement.687 The ministry responsible for social welfare renders a
decision on the appeal, against which a lawsuit may be filed with the competent administrative court within
eight days of the date of delivery of the decision.
The right to accommodation of an asylee and foreigner under subsidiary protection shall cease in the
following cases:688
- upon the expiry of 2 years’ time limit;
- upon personal request;
- if he or she refuses the accommodation provided without justified reason;
- if he or she fails without justified reason to reside at the registered address for a period longer
than 30 days;
- if he or she does not meet the conditions for recognition of the right to accommodation;
- if it is established that he or she fails to take due and responsible care of the accommodation
provided;
683
This time limit is foreseen by law but does not reflect the reality in practice, as explained further below.
684
Articles 67 and 67a LITP.
685
Article 67(4) LITP.
686
Article 67(5) LITP.
687
Article 67 (7) LITP.
688
Article 67(8) LITP.
139
- if it is established that he or she uses the accommodation provided contrary to its purpose.
Save in the case referred to in item 1 above, the Centre, after establishing in the prescribed procedure
the conditions referred to in items 2 to 7 above, shall quash the decision and shall adopt a new decision
establishing the termination of the right to accommodation, against which an appeal may be lodged within
15 days from the date on which the decision is delivered. The appeal does not delay the enforcement of
the decision. The ministry responsible for social welfare shall render a decision on the appeal, against
which a lawsuit may be filed with the competent administrative court within eight days of the date of service
of the decision.
Enforceable decisions shall be delivered to the Central State Office for Reconstruction and Housing Care.
Pursuant to the decision recognising the right to accommodation, the Central State Office for
Reconstruction and Housing shall secure to asylees and foreigners under subsidiary protection housing
units that are the property of the Republic of Croatia or are at the disposal of the Central State Office as
per lease agreements concluded with other natural persons.
The Central State Office for Reconstruction and Housing shall sign a contract on lease or sublease of the
housing unit with the asylee and foreigner under subsidiary protection whose right to accommodation is
recognised, for a maximum period of two years from the date on which the decision approving
international protection becomes enforceable. The contract on the lease or sublease shall define mutual
rights and obligations.
Funds for the costs of accommodation shall be earmarked in the State Budget of the Republic of Croatia
under the item for the Central State Office for Reconstruction and Housing Care.
The provision of accommodation also includes the process of finding, adapting, furnishing, maintaining,
and the settlement of utility costs and leasing costs for the housing unit provided. The Ordinance on
participation of asylees, foreigners under subsidiary protection and foreigners under temporary protection
in the payment of accommodation costs entered into force in July 2018. 689 The ordinance prescribes
when the beneficiary under international protection, for whom the Centre for social welfare determined
that possess property, in the period while he / she is provided with subsidised accommodation, should
participate in the payment of accommodation costs.
In practice, despite the low number of beneficiaries of international protection, persons wait for state
subsidised accommodation for several months according to AYS.690 This is problematic as this time is
also calculated under 2 years of state subsidised accommodation.
According to the Central State Office for Reconstruction and Housing one important element taken into
account for the purpose of housing of beneficiaries of international protection is to avoid any form of
isolation or “ghettoization”. Beneficiaries of international protection are therefore accommodated across
the Republic of Croatia, rather than in one town or in housing units at a same address. In addition,
although there were no official reports, the Central State Office for Reconstruction and Housing noticed
problems with finding landlords willing to rent a property to refugees after their legal right to free
accommodation has expired.691
Centre for Peace Studies (CPS) reported that persons under international protection, were exposed to
discrimination and are faced with prejudice when trying to rent an apartment after two years of subsidized
housing. CPS also underlined that the general rise in housing prices was observed.692 Data provided by
Central State Office for Reconstruction and Housing Care show that in 2021, the right to accommodation
689
690
Information provided by Are you Syrious, 3 February 2023.
691
692
Information provided by the Centre for Peace Studies, 18 January 2022.
140
was used by 64 beneficiaries, while 105 lease agreements were terminated due to the expiration of the
two-year period. Further data by Central State Office for Reconstruction and Housing Care show that the
capacities for accommodation are sufficient.693
Similarly, the Croatian Red Cross (CRC) reported that challenges were observed in securing
accommodation for beneficiaries whose right to paid housing has expired.694 This is mainly due to high
rents, discrimination and the reluctance of landlords to rent their apartments to beneficiaries of
international protection. It is especially difficult to find an apartment for large families both due to the need
to find a bigger apartment and the overhead costs which are much higher. In bigger families, it is also
frequent that it is only the husband/father who works and there is thus only one salary that needs to bear
the costs of housing, utilities and other living expenses, which is why many of them find themselves at
risk of poverty. CRC often refer families who contact them due to difficult financial situations to the
competent social welfare centre to exercise the right to one-time assistance.
Difficulties in housing after expiration of 2-years period in the situation of pandemic was also addressed
by other NGOs. In 2022 AYS, assisted in finding accommodation after the expiration of two years of state-
funded accommodation.695 Due to the increase in unemployment among beneficiaries of international
protection caused by the COVID-19 pandemic, in cooperation with the Solidarna Foundation and Wir
Packens, AYS continued with the programme of covering one rent for people who are unable to cover
housing costs and one-time aid to cover the cost of food for people who find themselves in unfavourable
socio-economic conditions. During 2022, AYS provided assistance to 29 households.
In 2022, Civil Rights Project (CRP) Sisak provided free legal aid to beneficiaries of international protection
in finding suitable accommodation after the expiration of the secured state funded two-year
accommodation.696
E. Employment and education
1. Access to the labour market
Beneficiaries of international protection have the right to work in the Republic of Croatia, without a
residence and work permit or certificate of registration of work.697 Both asylees and foreigners under
subsidiary protection have access to the labour market, without distinction.
However, access to rights and their exercise in the practical life of each beneficiary is challenging. The
main obstacle is still the language barrier and the language courses, which is a precondition for successful
integration and accessing the labour market.
In order to carry out the quality integration of asylees and foreigners under subsidiary protection in
Croatian society, the Ministry of Science and Education, in cooperation with the Sector for Schengen
Coordination and European Union funds of the Ministry of Interior, prepared the project "Integration of
refugees and foreigners under subsidiary protection in Croatian society, education and preparation for
inclusion in the labour market ".
The project was targeting persons who were granted asylum and subsidiary protection who wish to
engage in a course of learning the Croatian language, history and culture, or who require the translation
of diplomas or certificates for continuation of education or inclusion into the labour market, or who wish to
continue primary or secondary education. The project activities were free of charge for beneficiaries and
693
Ombudsperson, Annual report 2021, available in Croatian at: https://bit.ly/3MdomlB.
694
Information provided by CRC, 18 January 2023.
695
696
Information provided by the Civil Rights Project (CRP) Sisak, 9 January 2023.
697
Article 68(1) LITP.
141
funded by the AMIF – the EU Asylum, Migration and Integration Fund. 698 However, in September 2022,
the Ministry of Interior took the decision to terminate the agreement with the Ministry of Science and
Education related to the implementation of the mentioned project, among other things, since Croatian
language courses were not held.699
According to Croatian Red Cross (CRC) 700, in 2022, the Croatian language course were still not
conducted continuously and when carried out, were not adapted to all participants who are not on the
same level of previous knowledge of the Croatian language, nor are equally capable of mastering the
material.
Centre for Peace Studies (CPS) also reported persisting problems with Croatian language courses as
they are not implemented continuously nor tailored to the specific group for which they are intended to. In
addition, courses last only limited number of hours which is not enough for beneficiaries to properly learn
the language and be able to use it in their everyday life.701
Similar problems with Croatian language courses were also reported by the Rehabilitation Centre for
Stress and Trauma (RCT)702 and Are You Syrious.703
CPS704 pointed out at the problems in the recognition of qualifications and validation of diplomas. For
those beneficiaries who do not poses documents, according to CPS there are no adapted procedures for
recognizing qualifications which take into account the specific circumstances in which refugees often find
themselves. In addition, CPS reported insufficiently available requalification programs that are closely
related to (lack of) knowledge of the Croatian language and consequently to (lack of) possibility of
participation.
As mentioned in Housing, asylees and foreigners under subsidiary protection have the right to
accommodation if they do not hold financial resources or possessions of significant value, for no longer
than 2 years from the day of the delivery of the decision approving international protection.705 It is expected
that within this period, they would learn the language and find a job to support themselves. However in
practice, many of them after 2 years still do not know the Croatian language and accordingly have
problems finding appropriate employment.
UNHCR’s Participatory Assessment conducted in summer 2020 showed that beneficiaries of international
protection often face multiple challenges while attempting to successfully integrate into local labour
markets, such as language barriers, difficulties in recognition of previously acquired skills, and limited
social and professional networks in the area in which they are looking for jobs 706
Many other NGOs such as Centre for Cultural Dialogue,707 Jesuit Refugee Service (JRS), the Centre for
Peace Studies, the Rehabilitation Centre for Stress and Trauma, Are you Syrious (AYS), CRP Sisak also
provide assistance during integration. The Integration Centre “SOL”, which is run by JRS and was opened
698
Ministry of Science and Education: Information on Croatian language courses and translation of diplomas and
certificates for persons with asylum status or persons under subsidiary protection, available at:
https://bit.ly/3jrADX3.
699
Ministry of Interior: Decision on the cancellation of the Decision on the allocation of financial resources for the
implementation of the project "Integration of asylees and foreigners under subsidiary protection into Croatian
society, education and preparation for inclusion in the labor market"; available in Croatian at:
https://bit.ly/3lzxqtk.
700
Information provided by Croatian Red Cross, 18 January 2023.
701
702
703
Information provided by Are you Syrious, 3 February 2023,
704
705
Article 67(4) LITP.
706
UNHCR, 2020 Participatory Assessment Croatia, Impact of COVID-19 pandemic on refugee integration in
Croatia, March 2021, available at: https://bit.ly/3ISKbFv.
707
See: https://ccd.hr/.
142
in 2018, provides support and guidance to individuals and families in the Republic of Croatia, who have
been granted international protection, in their integration process.708
In 2022, Croatian Red Cross (CRC) provided support regarding employment by phone. CRC maintained
cooperation with employers, and one meeting was held with the aim of exchanging experiences and
determining the future needs of employers and users. 709
Civis mundi provided mediation services in finding employment for persons granted international
protection.710
With the support of JRS, in 2022, 9 persons completed the A1 level of the Croatian language and 17
persons were trained as confectioners, waiters and pizza makers.711
In the course of 2022, AYS provided information to persons under international protection on their right to
work as well as assistance in job searching.
In 2022, the Rehabilitation Centre for Stress and Trauma (RCT) made contacts with 11 employers, and
18 beneficiaries of international protection concluded fixed-term contracts.712
The Croatian Employment Service (CES) is responsible for the implementation of measures in the field
of employment of foreigners, with particular emphasis on asylees and foreigners under subsidiary
protection. According to the Law on the Labour Market asylee, foreigner under subsidiary protection and
foreigner under temporary protection, as well as their family members may apply to the CES. According
to this Law, they are equal with Croatian citizens in terms of rights and obligations.
When applying for inclusion in the register of unemployed persons, CES assigns employment counsellors
to beneficiaries of international protection. They provide assistance and information about available jobs,
how to compile resumes and applications to employers, and gives them the opportunity to use measures
an active policy of employment and the exercise of other rights. They also inform them about their
obligations as unemployed persons. 713
According to CES, 55 asylees (of which 31 women), 5 foreigners under subsidiary protection (of which 3
women), 5 members of families of persons that were granted international protection (of which 4women),
633 persons under temporary protection (of which 515 women) and 2 female applicants for international
protection were inscribed in their registry as unemployed on 31 December 2022.714 According to the data
of the CES from January 1 until December 2022, 84 asylees, 8 persons under subsidiary protection, 8
member of families of persons under international protection, 2 applicants for international protection and
1604 persons under temporary protection were provided individual counselling at CES and a total of 2318
individual counselling for these users were conducted, while 2 asylees, 1 person under subsidiary
protection and 171 foreigners under temporary protection were included in active employment policy
measures. Most of the persons registered were from Ukraine (633), Syria (25), Afghanistan (15), Iraq
(8) and Türkiye (5).
Similarly to previous years, CES highlighted the lack of knowledge of Croatian and/or English as well as
a low motivation to learn the language and to be engaged in other programmes that can raise the chances
of gaining employment, as a major obstacles to the integration of beneficiaries of protection. Despite that
CES recorded the successful employment of persons under international and temporary protection.
2. Access to education
708
JRS, 'Refuge Integration Centre „SOL“ opened' , 2018, available at: https://bit.ly/3chtSBs.
709
Information provided by Croatian Red Cross, 18 January 2023.
710
711
JRS, Annual report 2022, available at: https://bit.ly/3C7rigq.
712
713
Croatian Association of Social Workers: Handbook- The role of social welfare in the process of integration of
persons with international protection, available at: https://bit.ly/3xhMv64.
714
Information provided by the Croatian Employment Service, 12 January 2023.
143
According to the LITP, beneficiaries of international protection have the right to elementary, secondary
and higher education under the same conditions as Croatian citizens, pursuant to separate regulations. 715
Asylees and foreigners under subsidiary protection shall exercise the right to adult education as well as
the right to recognition of foreign qualifications pursuant to the regulations on adult education under the
same conditions as Croatian citizens.
For asylees and foreigners under subsidiary protection, who for justified reasons are not able to provide
the necessary documentation to prove their foreign qualifications, an assessment shall be conducted of
their prior learning. The assessment of the prior learning of beneficiaries of international protection shall
be conducted by a competent body, pursuant to the regulations governing regulated professions and
recognition of foreign vocational qualifications.
A decision to refuse an application for recognition of foreign vocational qualifications cannot be based
exclusively on the fact that no official documents exist to prove a specific foreign vocational qualification.
If an asylee or foreigner under subsidiary protection does not have sufficient financial resources available,
the translation of foreign documents for the purpose of recognition of foreign qualifications shall be
provided from the State Budget of the Republic of Croatia, under the item of the Ministry competent for
education.
During 2022 the Ministry of Science and Education organized 23 courses of Croatian language, history
and culture for asylees and foreigners under subsidiary protection with the aim of their inclusion in
Croatian society. Furthermore, in the same period documentation (diplomas and certificates) were
translated for 15 asylees and foreigners under subsidiary protection. In 2022, 5 persons under
international protection were enrolled at the following universities: Faculty of Law, Faculty of Political
Sciences, Faculty of Mining and Geology, Faculty of Architecture and Faculty of Civil Engineering, while
only one refugee student is the beneficiary of a stipend.716
However, in September 2022, the Ministry of Interior took the decision to terminate the agreement with
the Ministry of Science and Education, among other things, due to the fact that Croatian language courses
were not held.717
According to the Ombudsman's report for 2022, civil society organizations stressed that there are
differences in the implementation of preparatory classes in the Croatian language for children under
international protection, for which the approval of the Ministry of Science and Education must first be
obtained, which sometimes takes months, compared to the preparatory classes that are organized for
children displaced from Ukraine, which is organized within couple of days. The Ombudsman's report
further emphasized that, although students under international protection are guaranteed the right to
higher education under the same conditions as Croatian citizens, the ordinance from 2013, which
regulates the exercise of the right to cover part of students' food costs, does not mention them.
Recognizing said shortcoming, the Ministry of Science and Education regulated the issue of their nutrition
with a special decision, and a new ordinance is being drafted that will systematically regulate the issue of
nutrition for the aforementioned category of students.718
In 2022, the new Law on Recognition and Evaluation of Foreign Educational Qualifications719 entered into
force. The Law prescribes the possibility of evaluating foreign educational qualifications for the purpose
715
Article 70 LITP.
716
717
Ministry of Interior: Decision on the cancellation of the Decision on the allocation of financial resources for the
implementation of the project "Integration of asylees and foreigners under subsidiary protection into Croatian
society, education and preparation for inclusion in the labor market"; available in Croatian at:
https://bit.ly/3lzxqtk.
718
719
Law on Recognition and Evaluation of Foreign Educational Qualifications, Official Gazette 69/2022, available
in Croatian at: https://bit.ly/3OPwI79.
144
of continuing education at the same or higher level of education and for the purpose of accessing the
labour market for beneficiaries of international and temporary protection and their family members.
To be included into the education system, beneficiaries must have a certificate of their status in Croatia,
a certificate of residence, an identity document (e.g. birth certificate, identity card, passport or relevant
document of the Ministry of Interior) and a document of previous education. If it is not possible to enclose
a document on previous education, it is necessary to give a statement to the notary public, which is then
presented to the school’s professional service to organise an enrolment test in order to determine the
class that the candidate can attend.
Centre for Peace Studies reported several problems in the educational system: problems with preparatory
classes for children; lack of preparedness of schools; insufficient number of teaching assistants; problems
in realizing the right to higher education; problems in exercising majority of rights enjoyed by regular
students, such as the right to subsidized accommodation and food and the possibility of receiving a
scholarship; difficulties with the recognition of qualifications and nostrification of diplomas when persons
have documents proving their education, as well as a lack of customised procedures for recognition of
qualifications when they do not have documents.720
According to Civis Mundi, higher education is hard-to-reach for persons granted international protection.
According to them this is due to few reasons: the slowness of the competent Ministry of Science and
Education in translation and nostrification of documentation but also due to the high costs for continuation
or enrolment in the higher education.721
AYS reported that in the course of 2022, they continued to provide educational support to children granted
international protection i.e. 77 volunteers provided 2,407 hours of educational support to 48 school aged
children from 21 families.722 The support programme included support in language learning, mastering
school materials, cooperation with schools and mediation in communication between parents and the
school. The similar support in 2022 was provided by the Centre for children, youth and family – Modus. 723
In 2022, Modus provided learning assistance to children under the international protection. The activity
was carried out by volunteers in the premises of the school attended by children. As a rule, volunteers
and children met once a week for 60 minutes or once every two weeks for 90 minutes. In addition to
support in writing homeworks and preparing for tests, the engagement of volunteers was designed to act
as friends-mentors for children and at the same time provide additional social support in the integration
of children. In addition, joint gatherings of children, parents and volunteers involved in the project were
organized in 2022.
In 2021, Centre for Peace Studies (CPS) published the thematic report” Education of Children of Asylum
Seekers and Refugees in the Republic of Croatia - (In) readiness for quality inclusion in the education
system”.724 The report analyses the response of the Republic of Croatia to the needs of children, with a
specific focus on access to education but also the identified difficulties and existing legislative framework.
In addition, the report provides examples of good practices.
Centre for Peace Studies (CPS) also reported obstacles in the access of beneficiaries granted
international protection to higher education in practice in 2022.725 Although, they have the right to higher
education similarly to Croatian citizens, there is no specific category for enrolling persons granted
international protection to faculties, so they are enrolled either as other foreigners, which means they have
to pay high tuition fees, or as Croatian citizens - which means that they have to take state graduation
exam. There is also the problem of non-recognition of foreign educational qualifications in cases where
beneficiaries have documents to prove their previous education. In addition, problems arise in the exercise
of most of the rights enjoyed by full-time students, such as the right to subsidized accommodation and
meals or the possibility of obtaining a scholarship.
720
721
722
723
Information provided by the Centre for children, youth and family –Modus, 9 January 2022.
724
Information provided by Centre for Peace Studies, 10 January 2022. See: https://bit.ly/3MuI8Kb.
725
Information provided by Centre for Peace Studies, 18January 2023.
145
For students who have insufficient knowledge of the Croatian language, the school is obliged to organise
preparatory classes, but according to Centre for Peace Studies (CPS) and AYS, practice has shown that
the process of organising preparatory classes is extremely long and children often wait several months
before such classes are approved. Also, some children have to go to another school for preparatory
classes, and as a result, they are not attending part of their classes at their own school. 726 However in
2022, AYS reported that this process was simplified by only in regard to children from Ukraine.
AYS also reported that children are, due to non-standardized tests, often enrolled in lower classes than
their peers. For this reason, most of the children are in the class with others
which are not at their developmental level and are often victims of violence and social isolation. In addition,
AYS reported that, although higher education should be available for persons granted international
protection under the same conditions as Croatian citizens, for those who have not yet received Croatian
citizenship, the only option is enrolment according to the quota for foreigners. Furthermore, not all faculties
apply this quota.
Between 2018 and 2020, the number of students under international protection included in primary
education (101) for whom preparatory classes have been approved was at its highest in 2019. That year,
the total number of approved classes for learners of Croatian (7,070) and the total number of approved
Croatian classes including methodical preparation for teachers (10,605) were at their highest as well. In
2020 and 2021, the number of students belonging to this category decreased significantly, especially in
2021, when only 29 students granted international protection attended primary school.727
In May and June 2022, several schools in Zagreb, Osijek and Sisak organized social actions in the
community. The aim was to empower local communities to accept citizens of third countries. The actions
were organized as part of the project "INCLuDE of the Office for Human Rights and the Rights of National
Minorities, together with students, school employees, and residents of local communities. 728
F. Social welfare
Asylees and foreigners under subsidiary protection have the right to social welfare pursuant to the
regulations governing the domain of social welfare of Croatian citizens. 729 In February 2022, a new Law
on Social Welfare entered into force.730
The Law on Social Welfare regulates that asylees, foreigners under subsidiary protection, and foreigners
under temporary protection as well as members of their family who legally reside in Republic of Croatia,
can receive benefits and services in the social welfare system under the conditions prescribed by this
Law, and the Law on international and temporary protection.731
Social welfare activities are performed by social welfare institutions, local and regional self-government
units, associations, religious communities, other legal persons, craftsmen and other physical persons
performing social welfare activities.
Some basic information are also provided in materials (i.e. videos and a brochure) prepared by the
Croatian Law Centre.732
726
Information provided by Centre for Peace Studies, 10 January 2022 and Are You Syrious, 7 February 2022
and 3 February 2023.
727
728
EMN, Quarterly Bulletin (April - June 2022), available at: https://bit.ly/43hrsOg.
729
Article 73 LITP.
730
Official Gazette 18/2022 , available at: https://bit.ly/3uxR6PN, amendments: Official Gazette 46/2022 available
at: http://bit.ly/3TIJc1a, and Official Gazette 119 /2022 available at: http://bit.ly/3z5vnjQ.
731
Official Gazette 18/2022, 46/2022, 119 /2022.
732
Croatian law Centre, video „You have a right to social welfare rights: https://bit.ly/3dPKWCc;
https://bit.ly/3aCwtaY; https://bit.ly/32OY9VG; and brochure available at: https://bit.ly/2RZdkJz.
146
The realisation of social rights in Croatia also depends on the place of residence.
The social rights to which beneficiaries of international protection are entitled in the welfare system include
care and assistance allowance; one-time allowances; up-to-employment allowance, education-related
allowances; allowance for vulnerable energy buyers; housing allowance – right granted at the level of
local self-government units; fuel allowance – right granted at the level of regional self-government units;
personal needs allowance for a residential care beneficiary; personal disability allowance; status of a
parent caretaker or status of a caretaker; guaranteed minimum benefit. It also includes social welfare
services (initial social welfare service; counselling and assistance; attendance; psychosocial support;
early intervention; assistance with inclusion into programmes of upbringing and regular education –
integration; day care; accommodation and organised housing). In 2018, persons under international
protection exercised mostly the right to one-time allowance (226) and the right to a guaranteed minimum
benefit (389). Regarding social welfare services, the majority of beneficiaries used the initial social welfare
service (63) (provision of information, recognition and initial assessment of needs). In 2019, the number
of persons (asylees and household members) under international protection exercising the right to a
guaranteed minimum benefit (225) and initial social welfare service (137 asylees) decreased. In 2020, the
right to a guaranteed minimum benefit was exercised by 213 asylees with household members, while 107
of them exercised the right to the initial social welfare service.733
In 2022, according to the Ministry of Labour, Pension System, Family and Social Policy, a total of 18
persons under international protection has been granted with a minimum guaranteed allowance, one
person has been granted with disability allowance and one person was granted a allowance for assistance
and care. One person has been granted with status of a parent-caregiver and in the reporting period there
were 85 proceedings in which the right to a one-time financial compensation was approved.734
Following the Amendments to the Decision of Social Welfare in 2019,735 the social rights provided by the
City of Zagreb were extend to families of asylees and foreigners under subsidiary protection.736
In 2021, a manual entitled "The role of social welfare in the integration of persons with international
protection" was prepared within a project implemented by the Croatian Association of Social Workers in
partnership with the Centre for Social Welfare Split and with the support of the Ministry of Labour,
Pensions, Family and Social Policy, as well as the Ministry of Interior.737 The manual is intended for social
workers and other experts and associates of social welfare centres across the Centres for Social Welfare
and their branches in Croatia.738
G. Health care
According to the LITP, asylees and foreigners under subsidiary protection shall exercise the right to health
care pursuant to the regulations governing health insurance and health care of foreigners in the Republic
of Croatia.739 The costs of health care shall be paid from the State Budget under the item of the Ministry
competent for health care.
The Law on Mandatory Health Insurance and Health Care for Foreigners in the Republic of Croatia
prescribes that asylees, foreigners under subsidiary protection, foreigners under temporary protection and
733
734
735
Amendments available in Croatian at: https://bit.ly/2UQoMXa.
736
City of Zagreb, Social welfare decision, 4 April 2019, available at: https://bit.ly/2URy7hj.
737
The manual is available at: https://bit.ly/3pNh13c.
738
Croatian Association of Social Workers, Manual "The role of social welfare in the integration of persons with
international protection, 2021, available at: http://husr.hr/web/?p=4983.
739
147
their family members they have a right to health care,740 in the same scope as health insured persons
under mandatory health insurance.741
Amendments to the Law on Mandatory Health Insurance and Health Care for Foreigners in the Republic
of Croatia, which entered into force in February 2018, provide that the right to health care is provided on
the basis of a valid document issued by the Ministry of Interior.742 The competent police administration or
police station is obliged to notify the ministry competent for health that the asylum, subsidiary protection
or temporary protection was granted to foreigner, at the latest within 8 days from the date when the
decision on granted asylum, subsidiary protection or temporary protection became final.743
This means that there is a difference between the unemployed and employed beneficiaries of international
protection. Unemployed beneficiaries of international protection are not insured within the Croatian Health
Insurance Fund, but the costs of their health care are covered from the state budget from the position of
the ministry responsible for health. In the case of unemployed beneficiary, health care providers should
send invoices, a copy of the residence permit and accompanying medical documentation directly to the
Ministry of Health. This category of beneficiaries does not have a health insurance card, but prove their
status with a residence permit card. Also, they do not have a personal identification number nor are they
in the Central Health Information System of the Republic of Croatia. When a beneficiary of international
protection gets a job and starts paying health insurance contributions, s/he becomes an insured person.
However, unlike Croatian citizens, their family members cannot acquire the right to compulsory health
insurance through the insured beneficiary, but costs continue to be covered by the state budget through
the Ministry of Health. If a beneficiary of international protection losses employment, he/she ceases to be
insured by Croatian Health Insurance Fund.744 However in practice, healthcare professionals are not
sufficiently familiar with the rights of beneficiaries international protection and the way in which they can
exercise their right to health care.
In 2020, the Ministry of Health provided instructions to relevant health care institutions and pharmacies
on the way that medicines should be provided to asylees and persons under subsidiary protection.745
According to these instructions, the pharmacy delivers an invoice addressed to the Ministry of Health to
the Croatian Health Insurance Fund. A prescription form and a copy of a document issued by the Ministry
of the Interior which shows the status of the foreigner to whom the invoice was issued, should be attached
to the invoice. The Croatian Health Insurance Fund subsequently submits an invoice for payment to the
Ministry of Health after having reviewed the conformity of the medicines prescribed. If it is a medicine
that is on the basic list of medicines of the Croatian Health Insurance Fund, the price of the medicine is
borne entirely by the Ministry of Health, while in the case of a medicine from the supplementary list, the
price is partly borne by the person and partly by the Ministry of Health. If a person is issued a private
prescription, the person bears the full cost of the medicine.
Since July 2021, following the decision of the Government of the Republic of Croatia on ensuring
vaccination against COVID-19, vaccination against COVID-19 is also available to persons who are not
insured.746
Problems in the health system were reported by Are You Syrious, the Croatian Red Cross, the Centre for
Peace Studies, the Rehabilitation Centre for Stress and Trauma, and other actors.
740
Article 17 Law on Mandatory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
741
Article 21(1) Law on Mandatory Health Insurance and Health Care for Foreigners in the Republic of Croatia.
742
743
744
Croatian Association of Social Workers: Handbook- The role of social welfare in the process of integration of
persons with international protection, available at: https://bit.ly/3uti9M5.
745
Letter from the Ministry of Health to Croatian Health Insurance Fund, available at: https://bit.ly/3tD9kh1.
746
Government of the Republic of Croatia, Decision on ensuring vaccination against COVID-19 disease of
citizens to the Republic of Croatia and other persons who do not have the status of insured person in the
Republic of Croatia https://bit.ly/370qZrl.
148
In course of 2022, AYS747 provided information on the scope of right to health care protection to
beneficiaries of international protection, but also assisted them with enrolment procedures or when
persons undertook medical examinations. AYS highlighted that shortcomings continue to be the non-
recognition of the right to health care for beneficiaries of international protection. AYS also reported that
the lack of translation during health checks remains unsolved.
The same challenges were reported by the Centre for Peace Studies (CPS). In addition, according to
CPS; pharmacies are also not informed about the procedure for dispensing medicines to persons under
international protection. Therefore, beneficiaries of international protection’s requests are often rejected.
CPS also reported that some beneficiaries were treated discriminatorily by doctors and health workers
who did not want to examine and provide treatment to some refugees due to unfounded fear that they
would spread Covid-19 or other diseases 748
The Croatian Red Cross (CRC) also reported problems related to health care and provision of services in
healthcare facilities as healthcare professionals are not sufficiently familiar with the rights of persons under
international protection and the way in which they can exercise their right to health care. According to
CRC, doctors are rejecting beneficiaries arguing that they reached their maximum quota of patients or
because they do not have a health card so they referred them to the Croatian Health Insurance Fund.
Health professionals are often not sufficiently educated on how to enter their data into the Central Health
Information System of the Republic of Croatia (CEZIH). 749
In 2022, the Rehabilitation Centre for Stress and Trauma reported that there is no system for the
prevention of mental health issues in place, nor available psychiatric institutions with interpreters. They
also pointed out that a small part of the beneficiaries have serious mental health problems and need
psychiatric treatment, which they cannot get within the system due to the language barrier. 750
Centre for children, youth and family –Modus in the course of 2022 provided psychosocial counselling for
beneficiaries of international protection with the assistance of the interpreters.751
In 2021, the JRS prepared a report on the mental health of refugees in local communities affected by
earthquakes and the pandemic. The aim of the report is to advocate for the improvement of mental health
services for refugees going through the integration in Croatia and for provision of adequate professional
assistance with the help of interpreters in health facilities in earthquake-affected areas.752
747
748
749
Information provided by CRC, 18 January 2023
750
751
Information provided by the Centre for children, youth and family –Modus, 9 January 2022.
752
JRS, Overview of the results of the research "Mental health of refugees in local communities affected by
earthquakes and pandemic", available in Croatian at: https://bit.ly/3O4tme0.
149
ANNEX I – Transposition of the CEAS in national legislation
All legal standards of the CEAS have been transposed in Croatian legislation.
Directives and other measures transposed into national legislation
Directive Deadline for Date of Official title of corresponding act Web Link
transposition transposition
Directive 2011/95/EU 21 December 2013 22 November 2013 Amendment to the Law on Asylum http://bit.ly/1MRraQ5 (HR)
Recast Qualification Official Gazette 79/07, 88/10, 143/13 http://bit.ly/1J7yrxu (HR)

Directive http://bit.ly/1IogkxD (HR)
Law on International and Temporary Protection http://bit.ly/1hIaq3Q (HR)

Official Gazette 70/15, 127/2017 https://bit.ly/2pPntru (HR)
Directive 2013/32/EU 20 July 2015 2 July 2015 Law on International and Temporary Protection http://bit.ly/1hIaq3Q (HR)
Recast Asylum Article 31(3)-(5) to be Official Gazette 70/15, 127/2017 https://bit.ly/2pPntru (HR)
transposed by 20 July
Procedures Directive 2018
Directive 2013/33/EU 20 July 2015 2 July 2015 Law on International and Temporary Protection http://bit.ly/1hIaq3Q (HR)
Recast Reception Official Gazette 70/15, 127/2017 https://bit.ly/2pPntru (HR)

Conditions Directive
Regulation (EU) No Directly applicable 2 July 2015 Law on International and Temporary Protection http://bit.ly/1hIaq3Q (HR)
604/2013 20 July 2013 Official Gazette 70/15, 127/2017 https://bit.ly/2pPntru (HR)
Dublin III Regulation
150

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Country Report: Croatia

The Asylum Information Database (AIDA)

Glossary & List of Abbreviations ..........................................................................................6

Overview of the legal framework ...........................................................................................9

Overview of the main changes since the previous update ................................................16

Asylum Procedure ................................................................................................................20

1. Flow chart ............................................................................................................................ 20

2. Types of procedures ............................................................................................................ 21

4. Determining authority ........................................................................................................... 22

5. Short overview of the asylum procedure ............................................................................... 23

B. Access to the procedure and registration ............................................................................ 25

1. Access to the territory and pushbacks .................................................................................. 25

2. Registration of the asylum application .................................................................................. 37

1. Regular procedure ............................................................................................................... 40

3. Admissibility procedure ........................................................................................................ 53

4. Border procedure (border and transit zones) ........................................................................ 56

5. Accelerated procedure ......................................................................................................... 57

D. Guarantees for vulnerable groups of asylum seekers ......................................................... 60

2. Special procedural guarantees ............................................................................................. 66

3. Use of medical reports ......................................................................................................... 68

4. Legal representation of unaccompanied children .................................................................. 68

E. Subsequent applications ....................................................................................................... 72

F. The safe country concepts .................................................................................................... 74

1. Safe country of origin ........................................................................................................... 74

3. First country of asylum ......................................................................................................... 77

1. Provision of information on the procedure............................................................................. 77

2. Access to NGOs and UNHCR .............................................................................................. 80

H. Differential treatment of specific nationalities in the procedure ......................................... 80

Reception Conditions ...........................................................................................................82

A. Access and forms of reception conditions........................................................................... 82

1. Criteria and restrictions to access reception conditions ......................................................... 82

2. Forms and levels of material reception conditions ................................................................. 83

3. Reduction or withdrawal of reception conditions ................................................................... 84

4. Freedom of movement ......................................................................................................... 84

1. Types of accommodation ..................................................................................................... 86

2. Conditions in reception facilities ........................................................................................... 87

C. Employment and education................................................................................................... 91

1. Access to the labour market ................................................................................................. 91

2. Access to education ............................................................................................................. 92

D. Health care ............................................................................................................................. 94

E. Special reception needs of vulnerable groups ..................................................................... 99

1. Provision of information on reception .................................................................................. 103

2. Access to reception centres by third parties ........................................................................ 104

G. Differential treatment of specific nationalities in reception ............................................... 104

Detention of Asylum Seekers ............................................................................................105

A. General ................................................................................................................................. 105

B. Legal framework of detention ............................................................................................. 107

1. Grounds for detention......................................................................................................... 107

2. Alternatives to detention ..................................................................................................... 109

3. Detention of vulnerable applicants ...................................................................................... 110

4. Duration of detention .......................................................................................................... 110

C. Detention conditions ........................................................................................................... 111

2. Conditions in detention facilities ......................................................................................... 112

3. Access to detention facilities............................................................................................... 117

D. Procedural safeguards ........................................................................................................ 119

1. Judicial review of the detention order.................................................................................. 119

2. Legal assistance for review of detention ............................................................................. 120

E. Differential treatment of specific nationalities in detention ............................................... 120