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
| 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
- 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
| 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 | |
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
- 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.
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.
Sources
- Robinhood: 2025 results (10 Feb 2026)
- HANFA: authorisation decision for Electrocoin d.o.o., MiCA (9 Apr 2026)
- AMF: Robinhood Europe UAB, MiCA services (a), (e), (g), (j) (19 Jun 2025)
- Robinhood: sending and receiving crypto in Europe (1 Oct 2024)
- ESMA Q&A 2883: MiCA regulates neither crypto lending nor staking (August 2026)
- Robinhood: stock tokens, staking and futures in the EU (30 Jun 2025)
- Directive (EU) 2019/2034, Art. 9: initial capital of investment firms €75,000 / €150,000 / €750,000
- Ecovis: Robinhood obtains MiFID brokerage and MiCA licences in Lithuania (15 Jun 2025)
- Robinhood EU: stock tokens are derivatives under MiFID II
- Crypto Briefing: Robinhood futures in Europe (1 Jul 2026)
- ESMA: supervisory briefing on copy trading (30 Mar 2023)
- Fortune: Robinhood Social, manual copying only and US only (18 Mar 2026)
- Cointelegraph: Czech Republic blocks Polymarket as unlicensed gambling (July 2026)
- PwC Legal: EU ban on payment for order flow fully in force from 1 Jul 2026
- MiCA, Annex IV: minimum capital €50,000 / €125,000 / €150,000
- MiCA Art. 63: authorisation deadlines
- Cointelegraph: OpenAI distances itself from Robinhood's tokens, Lithuania seeks clarification (7 Jul 2025)
- CryptoSlate: ESMA warns about tokenised stocks (1 Sep 2025)
- ESMA on gamification and nudging to trade (29 Apr 2022)
- TechCrunch: Robinhood after two years of development and $16M of investment (11 Dec 2014)
- TechCrunch: Robinhood on Android (13 Aug 2015)
- Clutch: rates of Croatian development agencies, mostly $50–99 per hour (October 2026)
- Topflight: cost of a crypto platform, MVP $150–200k, ready-made solution $400–600k (January 2026)
- Innowise: crypto platform costs by component (13 Jan 2026)
- Apple: rules for crypto apps (3.1.5)
- Netguru: fintech app cost, maintenance 15–20% per year (September 2026)
- Spendark: cloud costs for fintech (24 Apr 2026)
- Sumsub: user verification price $1.35–1.85
- Blaze: price of a mobile app security test $10–25k (11 May 2026)
- MojaPlaća: customer support salary
- HANFA: Ordinance on supervision fees for 2026 (0.7‰ of revenue)
- Revolut: 2024 – $591M on marketing, ~15M new users (24 Apr 2025)
- Cryptoticker: Bitpanda 2025 – ~€107M on marketing (5 Oct 2026)
- Robinhood EU: fee schedule, crypto 0.95%
- Robinhood: 2024 results (12 Feb 2025)
- eToro: 2025 results (17 Feb 2026)
- The Block: Bitpanda 2025 – €371M revenue, 7.4M users (11 Mar 2026)
- Financer: Bitpanda fee ~1.49% (10 Oct 2026)
- Revolut: 2025 – $6.0bn revenue, $876M from investing and crypto (24 Mar 2026)
- Revolut: crypto fees 0.49–1.49% + price spread
- Coinbase: shareholder letter, Q4 2024
- FINA Info.BIZ: Electrocoin d.o.o. – revenue €1.18M (2025)
- Electrocoin case study: 2025 turnover estimate (~€59M)
- DZS: 2024 population estimate, 3,211,673 adults
- Flash Eurobarometer 525: 16% of Croatians own or have owned crypto (2023)
- Dnevnik.hr: 50,000 Revolut users in Croatia (27 Sep 2019)
- Lider: Revolut has ~700,000 users in Croatia (23 Apr 2026)
- Crowdfund Insider: Bitpanda reaches 1M users (29 Jul 2019)
- Lex: eToro, 9–10% of registered users deposit money (17 Apr 2025)
- Tportal: Aircash and Bitpanda, crypto and shares in the app (28 May 2025)
- Robinhood: Q2 2026 results (29 Jul 2026)
- RaftLabs: cost of an app like Robinhood (July 2026)