CNB Confirms: Croatian Salaries Cannot be Paid into Revolut Account

Lauren Simmonds

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As Novac/Karlo Muratagic writes, here in Croatia, it is absolutely not possible to arrange to have Croatian salaries paid into a Revolut account. This is a firm conclusion that can be read from a recent statement from the Croatian National Bank, which after numerous comments came about regarding this issue.

Revolut is present for the central bank in Croatia in two instances, Revolut Payments UAB or as an electronic money institution, and Revolut Bank UAB, as a bank that has a deposit account. In both cases, this isn’t enough to be able to compete fully with existing banks in Croatia, but that doesn’t mean they won’t be able to in the future.

The story began almost a year and a half ago. Back in late December 2019, the Tax Administration issued an opinion banning the payment of Croatian salaries to Revolut Payments UAB.

“Given the fact that, according to the CNB, the legal entities that made the inquiry are considered digital electronic money institutions, ie a special type of payment service provider whose establishment and operation is regulated by the Electronic Money Act, we’re of the opinion that the payment of Croatian salaries to a kuna account of the digital institution for electronic money isn’t considered a payment made into a bank account in accordance with the provisions of the law and regulations,” stated the Tax Administration.

The stated reason, then, was precisely that it was an electronic money institution. A credit institution from another EU member state may of course establish a branch here in Croatia and through it provide mutually recognised services which it is authorised to provide in its home country. A credit institution from another EU member state may also start providing mutually recognised services in Croatia directly from the day the CNB receives the notification of it doing so.

The Revolut app had apparently ticked that box, but its statement, the CNB stated that they received a notification from Revolut, ie from Lietuvos bankas, on the provision of the carrying out of financial services in Croatia for Revolut Bank UAB. However, this only applies to the receipt of deposits and other repayable funds, while other services listed in Annex I of Directive 2013/36 / EU, which means payment services such as the payment of salaries, aren’t included and as such may not be provided in Croatia.

Payment services in this country are defined in Art. 4. of the Law on Payment Operations. The document “Revolut Bank UAB Deposit Terms” stipulates, however, that Revolut Bank UAB is not authorised to provide payment services or issue electronic money. Only the owner of both accounts, through their payment account, ie Revolut Payments UAB, can deposit money to Revolut Bank UAB or withdraw it from the deposit account.

To summarise the above, Revolut did come and is very much in operation here in Croatia, but not to its full extent. Individuals who use Revolut through this app as such have two accounts.

Initially, they are able receive an account for payment in an electronic money institution, ie Revolut Payments UAB. However, as it is an electronic money account, the Tax Administration doesn’t allow the payment of Croatian salaries to be made into it. At the moment, Croatian salaries can only be paid only to a current or giro account, and in the Croatian national currency, the kuna.

The second account, which the Revolut user opens later, is a deposit account within the credit institution. It is a new service from Revolut Bank UAB, but this account is not registered as an account for payment services. That is why the CNB stated that Croatian salaries cannot be paid into it in accordance with the law. However, the advantage of this account compared to that of the electronic money institution is that, like all other bank accounts, it is insured.

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