Proposal 5 · detailed analysis

A Robinhood-style mobile app

In 2025 Robinhood had 27M funded customers and $4.47bn in revenue¹. Electrocoin already has a web app, so it is not starting from scratch. The proposal is to build a mobile app for crypto first, and add shares and other products later.

1. What Robinhood offers and which licence it requires

Electrocoin holds three of the ten MiCA services: (a), (c) and (d)²

Feature	What is required	Does Electrocoin have it?	Note
Buying and selling crypto	MiCA (c) and (d)	Yes²	Electrocoin sells crypto to the client itself, from its own inventory and at its own price, and buys it back from them itself. Robinhood does not sell crypto itself; it sends the client's order to other exchanges, where the purchase is executed. That requires a different type of licence³.
In-app wallet (crypto custody)	MiCA (a)	Yes²
Recurring purchases (savings plan)	MiCA (c) and (d)	Yes	The same as buying, only automatic.
Sending and receiving crypto to and from external wallets	MiCA (j) transfer	No	Robinhood has offered this in the EU since 2024⁴³
Staking (rewards for locked crypto)	No dedicated service under MiCA	Partly	Grey area: offered alongside crypto custody and with clear warnings⁵. Robinhood offers it in the EU⁶.
Shares, ETFs and fractional shares	MiFID investment firm licence, capital €150,000⁷	No	Robinhood holds a separate MiFID licence in the EU⁸. The alternative is a licensed partner.
Share derivatives (Robinhood calls them stock tokens)	MiFID, as derivatives, capital €750,000⁷	No	Robinhood classifies them as derivatives under MiFID⁹. Grey area, see below.
Options and futures (including on crypto)	MiFID, capital €750,000⁷	No	In the EU Robinhood offers crypto futures with leverage of up to 3×¹⁰.
Card, IBAN and interest on cash	E-money licence or partner bank	No	Easiest through a partner.
Copying other users	Depending on the set-up: investment advice or portfolio management¹¹	No	Robinhood offers only manual copying, and only in the US¹².
Betting on events (prediction markets)	Gambling licence	Not feasible	The Czech Republic blocked Polymarket as unlicensed gambling¹³.
Earning from routing client orders to other firms (Robinhood's US model)	–	Prohibited	Robinhood does not charge clients commission; instead it sends orders to large trading firms, which execute them and pay Robinhood a small fee for each order. In the EU this has been fully prohibited since 1 Jul 2026¹⁴

The crypto part for which Electrocoin already holds the relevant MiCA licences: buying, selling, the wallet and the savings plan².
The only extension needed for crypto: service (j), crypto transfer. With it, Electrocoin stays in the same capital class of €125,000¹⁵. HANFA decides within 40 working days of a complete application¹⁶, and Electrocoin's first application took ~5.5 months².
Shares and derivatives require a separate MiFID licence with capital of €150,000 to €750,000⁷, or a partner that already holds one. That is the second step.

Grey areas and what is not feasible

Share derivatives: Robinhood calls them stock tokens, but they are not shares; they are digital tokens on a blockchain whose price tracks the share price. The token holder is not a shareholder and has no voting rights. Robinhood classifies them as derivatives, i.e. a contract between the client and itself⁹. Robinhood handed out OpenAI and SpaceX tokens in the EU, and OpenAI said these were not its shares¹⁷. ESMA warns that tokens without shareholder rights can mislead investors¹⁸.
Staking and crypto lending: MiCA does not regulate them. They are permitted only with the client's explicit consent and risk warnings⁵.
Betting on events: treated as gambling in Europe¹³. Not feasible.
Earning from routing orders to other firms: this Robinhood revenue source in the US is prohibited in the EU¹⁴. Electrocoin earns from fees, so this is not a problem.
Gamification: ESMA considers that techniques encouraging excessive trading are never in investors' interest¹⁹. The app should not have confetti, streak rewards or leaderboards.
Copy trading: automatic copying is portfolio management, which requires a licence and a suitability assessment¹¹.

2. How much it would cost to build

All figures in this section are estimates based on the sources cited

Robinhood: development took about two years and $16M of investment before the first iPhone version²⁰, and Android followed 8 months later²¹. It was building a broker from scratch. Electrocoin already has the licence and the trading and custody systems, so it needs far less.
Labour cost: most Croatian development agencies charge $50–99 per hour²².

	A. Basic crypto app	B. Complete crypto app	C. Full Robinhood
What it includes	iPhone and Android, buying, selling, portfolio, in-app user verification, notifications	Everything in A, plus a savings plan, price alerts, crypto sending, support tools and a security test	Everything in B, plus shares and ETFs through a partner, fractional shares and tax reports
Build cost	~€150–300k	~€350–650k	~€0.9–1.6M
Duration	~5–7 months	~8–12 months	~12–18 months
Comparison	Crypto platform, basic version: $150–200k²³	Ready-made crypto platform: $400–600k²³. Mobile app $100–250k, security $50–150k, user verification $30–100k²⁴	Crypto exchange: up to $1.24M²⁴
Licences	Existing	Existing + (j) transfer	Plus a MiFID licence or partner

Proposal: start with option A or B, crypto only. Apple also approves such an app, because Electrocoin is a licensed company²⁵. Apple and Google take no commission on crypto purchases.

3. Annual costs after the build

Excluding marketing. All figures in this section are estimates

Item	A. Basic	B. Complete	Basis
Maintenance and new features	€50–80k	€120–250k	15–20% of the build cost per year²⁶
Cloud servers	€25–40k	€45–75k	From $2,000 a month at the start to $8,000–18,000 for 10–50k users²⁷
User verification	€8–12k	€30–45k	$1.35–1.85 per verification²⁸
Security tests	€15–25k	€25–50k	Mobile app $10–25k per test²⁹
Customer support	€40–60k	€80–120k	2 to 4 people³⁰
Regulatory compliance	€0–40k	€30–90k	0 to 2 new people
HANFA supervision	0.7‰ of revenue from crypto services		³¹
Total per year	~€140–260k	~€330–630k

Marketing: the largest cost. Robinhood spent $399M on marketing in 2025¹, Revolut $591M in 2024³², and Bitpanda ~€107M in 2025³³
Existing users of Electrocoin's web app can move to the mobile app at almost no marketing cost.

4. Number of users: comparison

Company	Users	Who is counted	Crypto fee
Robinhood	27M¹	Only those who have deposited money	0.95% in the EU³⁴; in practice ~0.5% in the US³⁵
eToro	3.81M³⁶	Only those who have deposited money	–
Bitpanda	7.4M³⁷	All registered users, including those without a deposit	~1.49%³⁸
Revolut	68.3M³⁹	All customers, including those who have never invested	0.49–1.49% + price spread⁴⁰
Coinbase	–	–	~1.55% for retail customers⁴¹
Electrocoin today	Not public	–	~2% (revenue €1.18M⁴² / turnover ~€59M⁴³)

Market: Croatia has 3.21M adults⁴⁴, and 16% own or have owned crypto⁴⁵. That is ~514,000 people.
Growth rate: in Croatia, Revolut grew from 50,000 users in 2019⁴⁶ to ~700,000 in 2026.⁴⁷ Bitpanda took ~5 years to reach one million users⁴⁸.
From registration to deposit: at eToro, 9–10% of registered users deposit money⁴⁹.
Competition: Revolut is already strong in Croatia⁴⁷, and Aircash is adding crypto and shares to its app with Bitpanda⁵⁰.

Estimate: investment, revenue and payback

All figures in this section are estimates, not data. First three years, Croatia only

Registrations: the default is 3% of adults in three years. Revolut today has ~22% of adults after seven years⁴⁷⁴⁴.
Deposit: the default is 25% of registered users. At eToro it is 9–10%⁴⁹, but Electrocoin already has users and is well known in Croatia.
Turnover per user: at Robinhood ~$2,500 of crypto turnover per customer per year⁵¹. The default is €2,500.
Fee: the default is 1.5%, as at Bitpanda and Revolut³⁸⁴⁰.
Marketing cost per new user: how much marketing it takes for one user to open an account and deposit money for the first time. The default is €75, between Revolut and Robinhood³²¹.

Share of adults who register3% Share of registered users who deposit money25% Turnover per user per year€2,500 Fee1.5% App build cost€350,000 Annual costs after the build€330,000 Marketing cost for 1 user to open an account and deposit money€75

Registered users

Users with a deposit

Turnover per month / year

Revenue per month / year

Initial investment (build + marketing)

Annual costs

Revenue − costs per year

Payback period

Registered = 3.21M adults⁴⁴ × share. Users with a deposit = registered × deposit share. Turnover = users with a deposit × turnover per user. Revenue = turnover × fee; this is Electrocoin's net revenue as there is no partner. Initial investment = build + users with a deposit × marketing cost per new user. Payback = initial investment / (revenue − annual costs). Part of the turnover may come from existing web app users moving to mobile. For comparison: Electrocoin's net revenue in 2025 was €1.18M⁴², and turnover ~€59M⁴³

Points to watch

Robinhood earns most from options and interest, while crypto brings it only 7–13% of revenue⁵¹¹. A crypto app cannot replicate its revenue per user.
Competitors with large budgets are already in the market⁴⁷⁵⁰, so the app must offer something local: bill payments, payouts to an IBAN and support in Croatian.
Build cost figures come mainly from agencies and vary widely⁵²²³²⁴. Before deciding, quotes should be requested from 2–3 Croatian agencies.