In 2025, nearly nine out of every ten public consultations run by Croatian state bodies skipped the legally required 30-day comment period. More than a third of the comments submitted by citizens were simply rejected, and another quarter were logged without any real response at all. These are not claims from a watchdog report — they are the government's own numbers, found in the Office for Legislation's newly adopted Annual Report on Public Consultation.
Public consultation constitutes the process through which a state body publishes a draft law, regulation or other act, along with an explanation of its reasons, goals and the composition of the working group that drafted it. Respectively, the public is invited to submit proposals and opinions before the act is finalized. This is done in order to enable citizens to participate in the law-making process and ensure that their voices are heard. The obligation for state administration bodies to conduct such public consultations via the central e-Consultations portal has been in force since August 2015, as according to the amendment to the Right to Access Information Act (NN 85/15).
While the numbers of the 2025 report show that participation is rising and the e-Consultations portal has gotten its necessary technical upgrades, the consultation system still faces the same structural gaps – such as limited consultation methods, rushed deadlines and thin engagement with citizens’ proposals.
Increasing civic participation
The report shows that the overwhelming majority of public consultation, namely 84%, happens through the e-Consultation portal. The headline numbers look encouraging at first glance: the number of people submitting comments rose from 4.787 in 2024 to 6.911 in 2025, and the total volume of comments nearly doubled from 13.766 to 25.657. This increase in users and comments is largely attributed by the report to users adjusting to the 2024 platform update. Before May 2024, users logged into the e-Savjetovanje portal through its own, portal-specific system. The 2024 upgrade replaced this system with secure login through the e-Građani and e-Ovlaštenja, tying every user’s account to their OIB in a single, central portal.
Gong at the time, however, warned that this change made participation in public consultations harder for civil society organizations, citing a case in which comments Gong had submitted during a public consultation were, in the final report, attributed to the personal name of its authorized representative rather than to the organization itself. Gong also described the new system as technically problematic, as exemplified by frequent unexpected log-outs of users while using the platform.
Therefore, these numbers that signify growing civic interest should not be read as plain evidence that the practice of consultation itself is becoming more participatory and inclusive, as a closer look at the report shows its structural shortcomings.
The 30-days consultation period as an exception to the rule
The report’s own findings are arguably the most jarring when it comes to the law’s default 30-day consultation period, specifically standardized in order to provide users of the portal with adequate time to read a draft, understand its implications and respond with suggestions.
While the 30-day consultation period is set as a legal rule, rather than a mere recommendation, it has been standardized with a built-in exception clause, causing compliance to be weak in practice. Croatia’s Law on Better Regulation Policy Instruments allows public consultations to run for less than 30 days, but only in exceptional circumstances, when a situation could not have been foreseen or influenced, and poses a threat to citizens' life and health, national security, property of significant value, the environment or economic activity, or causes significant economic damage. In such cases, the body responsible must provide a detailed explanation demonstrating that the conditions for shortening the consultation period have been met.
That is, in 2025, 88% of all 809 consultations ran shorter than 30 days, only 94 consultations met or exceeded the statutory standard and the average duration crept up slightly from last year’s 22 days to 24 days. This latter improvement does not, however, make up for the vast majority of consultations being shorter than the fixed 30 days. The report itself acknowledges that state bodies often invoke ‘urgency’ to justify shortened consultation periods, despite an adequate legal requirement to publish drafts and plans in advance so the 30-day window can be respected. Besides, it is worth questioning whether 88% of all consultations genuinely meet such exceptional thresholds and how rigorously these justifications are reviewed.
In this lack of time, there is a real risk that consultation functions as a mere formality applied to drafts that are already nearly finalized. It should instead be a genuine input mechanism, engaged earlier in the policy cycle and through more varied methods.
Regarding accessibility, there is genuine technical progress to note as the portal is now integrated with e-Građani and e-Ovlaštenja for secure login, as well as 2025 marking the first time a local government (Grad Šibenik) ran a consultation through the national portal. That said, other than Grad Šibenik’s uptake, local and regional use remains negligible in comparison to the national portal, with just 27 consultations, 18 participants and 61 comments across the entire local governments combined.
Comments noted, but not acted on
Of the 25.657 comments submitted in 2025, only 13% were accepted outright and further 8% were partially accepted. The largest share, namely 37%, were not accepted at all, while another 26% were merely acknowledged and noted without any substantive response. The remaining 15% (3.896 comments) received no response whatsoever, as the relevant report had not yet been published by the time this annual report was compiled, meaning citizens who commented may not yet know the outcome of their input.
These numbers would result in only about 21% of all comments producing any change. To improve this notion, the report’s own recommendations for the following year call for state administration bodies to more clearly explain why a particular proposal was accepted or rejected – a tacit admission that current justifications are often inadequate or missing.
Gong argues that turning ‘clearer explanations’ into a genuine improvement will require a careful consideration of proposed changes, backed by actively checking compliance, rather than leaving it as a soft expectation bodies can meet with generic language.
Turning intentions into concrete action
Taken together, the patterns found in the 2025 Annual Report on Public consultation point towards an increase in civic participation that is met with a system that faces genuinely unresolved gaps.The fact that only 11.6% of consultations lasted for the full 30-day period raises serious concerns, even though the law allows shorter consultation periods in exceptional circumstances.
It is essential to introduce more rigid monitoring of how proposals are accepted or rejected, to ensure that shortened consultation periods are used only where the legal conditions for doing so are met.
Along with running consultations at least according to the 30-day consultation period, the government should actively inform citizens on how to contribute to the legislative process and invite them to participate in public commenting– this should be treated as the minimum standard, rather than extra effort. For more significant legislation, this effort should extend to organizing live public consultations and in-person engagement with citizens when possible. Such structural changes could meaningfully boost both turnout and effectiveness of the consultations.
While the report does not track concrete ministry effort in implementing these steps, it does name comparable priorities for 2026. Clearer, substantive responses to comments, as well as earlier-stage engagement with drafts and proactive outreach are framed as intentions rather than binding requirements with oversight mechanisms.
Closing the gaps in the Public Consultation system, however, is a matter of enforcing, measuring and following through on the intentions stated by the Office of Legislation. Gong therefore recommends attaching concrete, measurable targets and a public reporting mechanism to each of these 2026 priorities, turning stated intentions into commitments public bodies can be held accountable for in next year's report.
