Resolution CM/ResDH(2025)385
Execution of the judgments of the European Court of Human Rights
Seven cases against Croatia
(Adopted by the Committee of Ministers on 4 December 2025
at the 1545th meeting of the Ministers’ Deputies)
Application No.
Case
Judgment of
Final on
12027/10
STATILEO
10/07/2014
10/10/2014
35444/12+
BEGO AND OTHERS
15/11/2016
15/11/2016
25815/14
MIROŠEVIĆ-ANZULOVIĆ
04/10/2016
04/10/2016
37006/13
GOŠOVIĆ
04/04/2017
04/04/2017
23414/15+
SKELIN-HRVOJ AND ĐURIČIĆ
10/06/2021
10/06/2021
48981/17
ARAMBAŠIN
23/06/2022
23/06/2022
41306/18
HEGEDIŠ
23/06/2022
23/06/2022
The Committee of Ministers, under the terms of Article 46, paragraph 2, of the Convention for the Protection of Human Rights and Fundamental Freedoms, which provides that the Committee supervises the execution of final judgments of the European Court of Human Rights (hereinafter “the Convention” and “the Court”),
Having regard to the final judgments transmitted by the Court to the Committee in these cases and to the violations of the applicants’ right to the peaceful enjoyment of their property between 1997 and 2015 on account of statutory limitations on the landlords’ use of private flats, including through the rent control scheme for flats subject to protected leases (violations of Article 1 of Protocol No. 1);
Recalling the respondent State’s obligation, under Article 46, paragraph 1, of the Convention, to abide by all final judgments in cases to which it has been a party and that this obligation entails, over and above the payment of any sums awarded by the Court, the adoption by the authorities of the respondent State, where required:
- of individual measures to put an end to violations established and erase their consequences so as to achieve as far as possible restitutio in integrum; and
- of general measures preventing similar violations;
Having invited the government of the respondent State to inform the Committee of the measures taken to comply with the above-mentioned obligation;
Having examined the action report provided by the government and their further submissions indicating the measures adopted in order to give effect to the judgments including the information provided regarding the payment of the just satisfaction awarded by the Court (see documents DH-DD(2025)1137,
DH-DD(2025)1221, DH-DD(2025)1222);
Recalling that in these judgments the Court identified three main legislative shortcomings concerning the protected lease scheme, notably the inadequate level of protected rent, restrictive conditions for the termination of protected leases and the absence of any temporal limitation to the protected lease scheme;
Welcoming the adoption, in March 2024, by the Croatian Parliament of the Law on the implementation of the European Court’s judgments of the Statileo group (12027/10+) and the Constitutional Court’s decision (U-I-3242/2018) (the 2024 Law) which entered into force in April 2024 addressing the above shortcomings and striking the requisite balance between the interests of landlords and the general interest of the community; considering that the 2024 Law appears capable of securing a global solution to the issue of the protected lease scheme and thus preventing similar violations in the future;
Welcoming further the operational measures taken by the respondent State, including significant budgetary allocations secured for the full implementation of the 2024 Law which clearly demonstrate the long-term commitment to achieving a lasting global solution to the structural problem identified by the Court;
Noting further that the compensatory remedy, established by the Supreme Court in December 2018 and previously noted with satisfaction by the Committee, continues to function well and reflect the Convention standards set out in the Statileo group of cases;
Considering therefore that the respondent State has taken the appropriate legislative and other general measures, to secure the delicate balance between the interests of landlords and protected tenants;
Having thus satisfied itself that all the measures required by Article 46, paragraph 1, have been adopted,
DECLARES that it has exercised its functions under Article 46, paragraph 2, of the Convention in these cases and
DECIDES to close the examination thereof.