Running a Giveaway in Croatia: Promotional Game Rules and Deadlines

If your business plans to give away a prize in Croatia, the first question is how the winner will be chosen. A random draw is generally a promotional game (nagradna igra) and follows a formal approval process. A jury-selected contest, points-based competition, qualifying public quiz, or promotion in which everyone receives a gift of approximately equal value may fall outside that process.

The label on a social media post does not decide the classification. The mechanics do. Settle those mechanics before announcing the campaign, buying prizes, or collecting entries.

This guide covers the main business steps under Croatia's current Rulebook on the Organisation of Promotional Games, Official Gazette NN 125/2025. It is a practical overview checked on September 20, 2026, rather than advice for a specific campaign.

Is Your Giveaway a Promotional Game?

A promotional game uses chance to select winners and awards goods or services to promote an organizer's products or services. For example, a purchase-based campaign in which eligible entrants go into a random draw is the clearest case.

The Rulebook distinguishes that format from several other activities:

Do not treat every online quiz as the quiz exception. The Rulebook's definition is narrower. A judged contest, competition, promotion, or qualifying quiz is not a promotional game when its real mechanics meet the relevant definition, but consumer, advertising, privacy, and platform rules can still apply.

The process described here is for companies and other legal or natural persons registered as businesses in Croatia's court or craft register. If the format is difficult to classify, obtain Croatian legal advice before launch. A later change from judging to random selection can change the legal route.

Apply Through ePorezna Before the Campaign Starts

For a promotional game, submit the application through ePorezna at least 15 days before the planned start date. The portal lists a user guide for the application, while the current Rulebook controls the deadline and required attachments.

Prepare these attachments:

• the final proposed rules;
• proof that 5% of the prize fund's value has been paid to the Croatian Red Cross;
• a cooperation agreement if another company will run the game for the organizer; and
• any further material requested by the Ministry of Finance.

The approved rules must be published in electronic or other public media before the game begins. The publication must include the approval date, class, and registry number. Rules without approval have no legal effect. Once the game starts, they cannot be changed except for an approved force majeure change.

Set the Prize Fund Before Filing

The prize fund may contain goods and services. Winners cannot exchange them for cash, and participant payments cannot be used to fund the prizes. Value each prize at its current retail market price when applying.

The total prize fund for one promotional game cannot exceed EUR 132,722.81. The 5% Croatian Red Cross payment is calculated from the prize fund's value and must be documented for the application.

There is also a process for prizes that remain unclaimed or undistributed. If their value is more than EUR 663.61, the organizer generally must sell them publicly and pay the proceeds into the state budget within 90 days after the prize collection deadline. The Rulebook provides an exception for a prize that has expired or lost its market value.

Plan the Draw, People, and Technology

The draw must be public and open to anyone interested in attending. A committee of at least three people, called the commission in the Rulebook, supervises it. All prizes must be drawn, and reserve winners are not allowed.

A notary public must attend when any individual prize is worth more than EUR 7,000. This threshold applies per prize, not to the total fund.

If winners are selected electronically or through an application, the random-number generator needs a conformity certificate from an authorized laboratory. Certified random-number software has been mandatory since June 1, 2026. Ask the technical provider for the certificate before committing to the draw method and keep it with the campaign records. A familiar giveaway tool or a platform's built-in selector is not enough by itself unless the required certification covers the selection method being used.

The commission records the draw, signs the record, and sends it to the Ministry within eight days.

Follow the Winner, Prize, and Reporting Deadlines

The work continues after the draw. Send each winner written notice within eight days. You must also publish the winners in electronic or other public media, including each winner's name and place of residence. Set the initial prize collection deadline between 8 and 30 days after the winner receives written notice.

If a winner does not collect the prize, send another written notice and allow a further 8 to 15 days. Once the final applicable collection deadline passes, the organizer has eight days to submit the required information to the Ministry. For each individual prize worth more than EUR 1,000, include the specified winner information, prize name and value, and proof of collection. Within the same eight-day period, also submit a list of unclaimed or undistributed prizes worth more than EUR 663.61.

Build these dates into the campaign calendar before launch. The team responsible for marketing should know when the legal, operational, and technical handoffs occur, especially if an agency or software provider is involved.

Treat Entry Data and Marketing Data Separately

The rules and entry process must make information about personal-data processing available to participants. For each use of personal data, identify the purpose, the appropriate lawful basis, the data needed, who receives it, how long it will be kept, and the participant's rights.

Consent is one of six possible lawful bases under the GDPR. It is not automatically required for every piece of data used to administer a promotional game. Where consent is the appropriate basis, it must be freely given, informed, specific, and unambiguous, and participants must be able to withdraw it. The European Data Protection Board's SME guidance explains the lawful-basis test.

Adding entrants to a newsletter or using their details for separate advertising needs its own analysis. Do not hide a separate marketing purpose inside mandatory game entry. A privacy adviser can help map the purposes and lawful bases when the campaign combines entry administration, public winner announcements, profiling, or later marketing.

Check Platform Terms After the Legal Format Is Clear

Facebook, Instagram, TikTok, and other platforms can set their own promotion rules, and those terms change. Do not rely on a permanent list of allowed or prohibited actions. After settling the campaign's legal format, check the current terms for every platform used, including rules on entry actions, disclosures, releases, and administration.

Platform compliance does not replace Croatian approval, and Croatian approval does not confirm compliance with a platform's terms.

Possible Penalties

The Act on Games of Chance, with the euro conversion amendments, provides possible fines of EUR 660 to EUR 66,360 for a legal entity that organizes a promotional game in breach of the Act, without approved rules, or contrary to approved rules. The responsible person in that legal entity may face EUR 660 to EUR 6,630. A natural person covered by the penalty provision may also face EUR 660 to EUR 6,630.

These are statutory ranges, not the automatic fine in every case. They are a strong reason to classify and schedule the campaign before it goes public.

Promotional Game Action Checklist

1. Decide whether the winner is random, selected by a jury, determined by points, or whether every participant receives an approximately equal gift.
2. If selection is random, prepare the rules, retail prize values, privacy information, draw method, commission, and responsible people.
3. For electronic selection, obtain the authorized laboratory's conformity certificate from the technical provider. Arrange a notary if any prize exceeds EUR 7,000.
4. Pay 5% of the prize fund's value to the Croatian Red Cross and apply through ePorezna at least 15 days before the start, with all required attachments.
5. Publish the approved rules and approval details before accepting entries. Check the current terms of every platform used.
6. Hold the public draw, send the signed draw record within eight days, notify and publish winners, allow the required collection periods, and submit the final prize information within eight days after collection closes.

Once the legal format and approved rules are settled, Mischka Studio can help with the campaign plan and content.