Proposal 4 · detailed analysis

Crypto module for banks

A bank's customer buys, sells and holds crypto directly in their bank's app, while Electrocoin provides the service in the background. Electrocoin already offers such a module to banks¹, and no Croatian bank yet offers crypto trading².

We target two banks. HPB, because Croatian Post is a co-owner and HPB sells its retail services through post offices³⁴, and Electrocoin has worked with Croatian Post since 2019.⁵ Zagrebačka banka, because it is the largest bank in Croatia⁶.

1. Does Electrocoin's MiCA licence cover this business

On 9 Apr 2026 Hanfa authorised Electrocoin for three of the ten MiCA services⁷⁸

MiCA service⁹	What it means in the module	Does Electrocoin have it?
(a) Custody of crypto-assets	The bank's customer holds crypto in the app.	Yes⁷
(c) Exchange of crypto for funds	Buying and selling crypto for euros. Electrocoin is the counterparty in each purchase and sale.	Yes⁷
(d) Exchange of crypto for other crypto	Swaps, e.g. bitcoin for ether.	Yes⁷
(j) Transfer services for crypto-assets	Sending crypto to, or receiving it from, an external wallet.	No. Needed only if the module allows sending and receiving.
(e) Execution of orders on behalf of clients	Electrocoin, as an intermediary, routes orders to other exchanges.	No. Needed only if Electrocoin were not the counterparty to the trade¹⁰.

Conclusion: the licence already covers the basic module: buying, selling, swapping and holding crypto, provided Electrocoin is the counterparty in every trade.
For the full module with sending and receiving crypto, Electrocoin needs to ask Hanfa to extend its licence to service (j), transfer of crypto-assets.
Valid outside Croatia too: the licence is passported to 30 EEA countries¹¹, and France, for example, has confirmed this¹².
The bank's role: MiCA does not allow a bank to act merely as Electrocoin's agent receiving orders¹³. So the bank either only provides access within its app (model A), or provides the service itself after notifying Hanfa (model B)¹⁴¹⁵.

Two models of partnership with a bank

Both are already in use in Europe

	A. Electrocoin provides the service, the bank provides access	B. The bank provides the service, Electrocoin is the technology partner
How it works	The customer becomes Electrocoin's client within the bank's app. Electrocoin buys, sells and holds the crypto, and pays the bank a fee for access.	The bank is the service provider to the customer. Electrocoin supplies the technology, pricing and crypto custody for the bank¹⁶.
What the bank needs	No notification to Hanfa. A contract and due diligence on Electrocoin as a partner are required¹⁷.	Notification to Hanfa at least 40 working days before launch, with policies, systems and procedures¹⁴¹⁵. Plus due diligence on the partner¹⁷.
What Electrocoin needs	The existing licence is sufficient for buying, selling and custody⁷.	The existing licence is sufficient for pricing and custody⁷. Responsibility towards the customer stays with the bank¹⁶.
Real-world example	Raiffeisen banks in Austria with Bitpanda: the bank provides access and Bitpanda pays it a fee¹⁸.	German cooperative banks (DZ Bank) and Sparkassen: the bank holds the authorisation, and the partner holds the crypto and provides pricing¹⁹²⁰.

Proposal: model A for a pilot project with HPB, as it is the quickest and the bank does not need to notify Hanfa. Banks do not want to hold crypto on their own balance sheet, as they would need far more capital against it²¹. In both models the crypto stays with Electrocoin, so the bank avoids this problem.

Real-world examples

Banks that have added crypto to their app, through a partner or on their own

Bank and country	Partner	From announcement to launch	Customer fee	Result
PostFinance, Switzerland (postal bank)	Sygnum	Launched 21 Feb 2024²²	0.95%²³	More than 36,000 crypto accounts and 565,000 transactions in two years²⁴, around 1.4% of 2.5M customers²⁵
Raiffeisen NÖ-Wien, Austria	Bitpanda	Less than 10 months, by January 2024²⁶	Not published. Bitpanda charges its own customers 1.49%²⁷	Not published. The bank receives a fee from Bitpanda¹⁸
Raiffeisen Group, 11 countries in Central and Eastern Europe, including Croatia	Bitpanda	Agreement 23 Sep 2026, first countries in the first half of 2027²⁸	Not published	Up to 18M customers within reach²⁹
Cooperative banks (meinKrypto), Germany	Boerse Stuttgart Digital	About 15 months, from September 2024 to early 2026³⁰¹⁹	According to each bank's price list	Hundreds of users per bank in the first weeks³¹
Sparkassen, Germany	DekaBank and Boerse Stuttgart Digital	About 15 months, from June 2025 to October 2026²⁰	€0.99 per order + price spread²⁰	Only just launching
KBC (Bolero), Belgium	In-house solution	About 7.5 months, from July 2025 to February 2026³²³³	Not published	Not published
BBVA, Spain	In-house solution	For all retail customers from July 2025³⁴	Not published	Not published
Openbank (Santander), Germany and Spain	Not published	Launched 16 Sep 2025³⁵	1.49%³⁵	Not published
N26, Austria and EU	Bitpanda	Launched 20 Oct 2022³⁶	1.5% bitcoin, 2.5% other³⁶	Not published

In Croatia: no bank offers crypto trading². The closest are Electrocoin and Croatian Post, with crypto in 55 post offices since 2019⁵, and Zagrebačka banka, which in 2026 offered a bitcoin-linked certificate³⁷.
Competition is coming: the Raiffeisen Group, with Bitpanda, plans crypto in 11 countries, Croatia among them²⁹. Whoever enters Croatian banks first has the advantage.
Revenue sharing between the bank and the partner is not public in any of the examples¹⁸²⁹.

Target banks

	HPB	Zagrebačka banka
Customers	~545,000, of whom ~160,000 use mHPB⁴	~1.1M individuals and 80,000 companies³⁸
Market share (assets)	9.4%, fifth-largest bank⁴	25.8%, largest bank⁶
Profit 2025	€58.8M (Group)³⁹	€510M⁴⁰
Owner	State 53.66%, Croatian Post 11.93%³	UniCredit Group³⁸
Link to Electrocoin	HPB's services are sold in 1,016 post offices⁴, and Electrocoin already works with Croatian Post⁵.	None.
Stance on crypto	No public plans for crypto. In 2026 HPB is taking over Croatia banka⁴¹.	UniCredit does not allow direct investment in crypto⁴², but since September 2026 it has been looking for a technology partner for crypto⁴³.
Who decides	HPB's management board.	Probably the UniCredit Group in Milan, not Zagreb (estimate).

Why it makes sense: 16% of Croatians own or have owned crypto, almost three times the EU average of 6%⁴⁴. This lets banks retain customers who currently buy crypto elsewhere.

2. Timeline

4–10 months for a single bank, 15 months or more for a banking group

Phase	HPB, model A (estimate)	Basis
Agreement and due diligence on Electrocoin as a partner	~2–3 months	The bank must vet the partner before signing a contract¹⁷.
Integration with the bank's app and testing	~3–6 months	Off-the-shelf solutions for banks are rolled out in 2–6 months⁴⁵, and Bitpanda cites less than 6 months⁴⁶.
Pilot project and launch for all customers	~1–2 months	Sparkassen first tested with employees, then launched in waves²⁰.
Total	~6–10 months	RLB NÖ-Wien and Bitpanda: less than 10 months²⁶. KBC: ~7.5 months³²³³.

Model B adds a notification to Hanfa at least 40 working days, about two months, before launch¹⁴.
Zagrebačka banka: if the UniCredit Group decides, 15 months or more is realistic, as with the German banking groups³⁰¹⁹²⁰ (estimate).
Extending the licence to sending and receiving crypto can run in parallel and need not hold up the launch of the basic module.

3. Build, roll-out and maintenance costs

For Electrocoin, in two staffing variants. All figures in this section are estimates

Starting point: Electrocoin already has buying, selling and custody of crypto, so it is not building from scratch. For a bank that builds everything itself, this costs $0.5–2M and 12–24 months⁴⁵.
Variant 1, existing staff do the work: no additional staff costs.
Variant 2, 2 new hires dedicated to this project: total cost ~€75–122k gross per year⁴⁷⁴⁸.
Extending the licence to crypto transfers: the amount is not public.

Turnover and revenue estimate

All figures in this section are estimates, not data

Share of customers using the module: at PostFinance, a postal bank, ~1.4% of customers use crypto after two years²⁴²⁵. The default is 2%, because 16% of Croatians own or have owned crypto, almost three times the EU average⁴⁴.
Turnover per user: there is no public data for banks. In 2025 Bitpanda had €371M in revenue across 7.4M users⁴⁹, i.e. ~€50 per user. At a fee of ~1.5%, that is ~€3,300 in turnover per year. The default is €3,000.
Customer fee: banks charge 0.95–2.5%²³³⁵³⁶. The default is 1.5%.
Electrocoin's share of the fee: the split between bank and partner is not public¹⁸. The default is 50%.
Model A or model B: the calculation applies to both models. Turnover is the same; only the share of the fee that Electrocoin keeps differs. In model A Electrocoin charges the customer the fee and pays part of it to the bank for access, so its share would be higher, probably above 50% (estimate). In model B the bank charges the fee and pays Electrocoin for technology and custody, so its share would be lower, probably below 50% (estimate). The default of 50% is the midpoint.

Share of customers using the module2% Turnover per user per year€3,000 Customer fee1.5% Electrocoin's share of the fee50% Cost of 2 new hires per year (variant 2)€75,000

	HPB	Zagrebačka banka	Total
Module users
Turnover per month
Turnover per year
Electrocoin's revenue per month
Electrocoin's revenue per year
Variant 1: revenue with existing staff
Variant 2: revenue − cost of 2 new hires

Users = bank customers × share. Turnover = users × turnover per user. Electrocoin's revenue = turnover × fee × Electrocoin's share, i.e. net revenue after the portion that goes to the bank. Customers: HPB ~545,000⁴, Zagrebačka banka ~1.1M individuals³⁸. Comparison with Electrocoin: net revenue in 2025 was €1.18M⁵⁰, and we estimate turnover at around €59M per year⁵¹.

What to watch out for

Before signing, the bank will vet Electrocoin thoroughly as a partner: security, business continuity and exit strategy¹⁷. The documentation for this should be prepared in advance.
The line between the bank merely providing access and the bank receiving orders should be confirmed in writing with Hanfa¹³.
Zagrebačka banka offered the bitcoin certificate only in branches, with a suitability interview³⁷. This means it is cautious, but interested in crypto.