Is it legal to record a meeting in Croatia?

Kazneni zakon Art. 143, Neovlašteno zvučno snimanje i prisluškivanje. Paragraph 1: "Tko neovlašteno zvučno snimi nejavno izgovorene riječi drugoga ili tko posebnim napravama neovlašteno prisluškuje nejavno izgovorene riječi drugoga koje mu nisu namijenjene, kaznit će se kaznom zatvora do tri godine."

Read the two limbs against each other and the answer falls out. Paragraph 1 contains two offences. The qualifier "koje mu nisu namijenjene", which are not intended for him, attaches only to the eavesdropping limb. The recording limb reads simply: without authorisation sound-records the non-publicly spoken words of another. No carve-out for words addressed to the recorder. So on the text, a participant recording a meeting records the non-publicly spoken words of another, and the only question left is whether it was neovlašteno, unauthorised.

Paragraph 2 extends the same penalty to using the recorded words or making them available to a third person. Paragraph 3 raises the penalty to six months to five years for an official. Paragraph 5 makes it a complaint offence, prosecuted po prijedlogu, on proposal, so as in Portugal it is the other speaker who starts things.

Not without authorisation, which in practice means the consent of the other speakers. That is the same structure as Germany's StGB § 201, where unbefugt is the door and consent is the key.

One honest hedge. The meaning of neovlašteno as applied to a participant was not confirmed against Croatian case law or commentary. The deliberate placement of the not-intended-for-him qualifier on only one limb is a strong argument, not a conclusive one, and a flat statement of this needs a Supreme or Constitutional Court citation we do not have.

Croatia has an escape valve the other strict countries do not. Paragraph 4 is a full defence rather than a mitigation: "Nema kaznenog djela ako su radnje iz stavka 1. i 2. ovoga članka učinjene u javnom interesu ili drugom interesu koji je pretežniji od interesa zaštite privatnosti snimane ili prisluškivane osobe." No offence where the act was in the public interest or in another interest outweighing the recorded person's privacy interest. That is a proportionality test written into the criminal code, and it is why Croatia should not be described as flatly as Germany or Greece. We have no idea how courts apply it, because no decision was opened.

No authority found. The statute gives no form for authorisation, sets no express-consent standard, and there is no Croatian analogue of the French presumption of consent. Announce clearly and obtain agreement; we are not going to publish a claim that a particular form of words is sufficient.

Before we start: I record my meetings so I can write up notes afterwards. It runs on my laptop, the audio is transcribed on this machine and never uploaded, and the audio itself is not saved anywhere, only the text, in a file I keep. Is everyone alright with that? If anyone would rather I didn't, say so now and I'll turn it off.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Employee representation: consultation, not consent. Zakon o radu Art. 150(1) requires the employer, before taking a decision important for the position of workers, to consult the works council (radničko vijeće) about the intended decision and to give it the information needed to assess the effect on workers. Art. 150(3) lists what counts, and item 5 is expressly "uvođenju nove tehnologije te promjena u organizaciji i načinu rada", the introduction of new technology and changes in the organisation and manner of work. Consultation is weaker than German co-determination: the council must be heard and, on request, met with, but it cannot veto.

No provision restricting audio monitoring specifically, and this is worth saying plainly. Croatia's GDPR implementation act regulates videonadzor only. Its Art. 30 permits video surveillance of work premises where the occupational-safety conditions are met, where employees were appropriately informed in advance, and where the employer informed them before taking the decision to install it, and Art. 30(2) bans it in rest, hygiene and changing rooms. There is no audio equivalent in that act. The constraint on audio is the criminal code plus GDPR, not a bespoke surveillance regime.

AZOP, the Croatian personal data protection agency. Nothing found on meeting recording or on local transcription, and no AZOP opinion was opened in our research. That is a gap.

Start with what does not help, because it is what our own positioning tempts us into claiming. Earkeep transcribes on your own device, never writes the audio to disk and sends nothing anywhere. On the criminal layer in Croatia that changes nothing at all. A recording made without the other speakers' consent is the same act whether it was processed on your laptop or uploaded to somebody's cloud, because the provision is about making the recording rather than about where it ends up.

Where the architecture genuinely helps is data protection: no transfer, no third party in the chain, no processor agreement to sign, and nothing to reconcile if someone asks you to delete what was said. And in the conversation itself, "it stays on my laptop and the audio is never saved" is a shorter thing to explain than what a cloud notetaker requires, which makes the agreement easier to actually obtain.

Earkeep announces itself to nobody. There is no bot in the participant list and no banner on anyone else's screen, so where the announcement is what makes the recording lawful, the whole of it depends on you saying something. What the app gives you is somewhere to go when the answer is no: a pause from the live edge that releases the microphone and the system audio stream, so the operating system's own recording indicator visibly goes dark; a never-record marking for a meeting on a connected calendar; and a purge that takes the lines out of the file on your own disk with no server copy anywhere. It does not make any recording lawful, and no tool can.

• Kazneni zakon, Art. 143, zakon.hr
• Zakon o radu, Art. 150, zakon.hr
• Zakon o provedbi Opće uredbe o zaštiti podataka (video only)
• AZOP
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.