AML amendment: goAML registration by 30 November 2026 and stricter beneficial owner verification

The anti-money laundering amendment, Act No. 73/2026 Z. z., effective from 1 June 2026, introduced an obligation that is easy to miss: registration of obliged entities in the Financial Intelligence Unit’s system. It also tightened beneficial owner verification, and since 10 July 2026 the Slovak Ministry of the Interior has provided, on written request, data on beneficial owners from the register of legal entities to persons who demonstrate a legitimate interest (§ 7b of Act No. 272/2015 Z. z.). Autumn is the last opportunity to complete everything without a rush.

Who is covered?

Section 5 of Act No. 297/2008 Z. z. defines obliged entities; for several professions, what matters is not the profession itself but the type of service or the value of the transaction. Besides banks and financial institutions, these include estate agents (for lettings only where the monthly rent is at least EUR 10,000), accountants, auditors, tax advisers, asset and company service providers, insolvency administrators, enforcement officers for specified activities, and lawyers and notaries providing legal services connected with money movements, from property and business purchases to company formation and management; since 17 August 2026 expressly also when preparing a founding document in the form of a notarial deed or a document authorised by a lawyer. Any business carrying out a cash transaction worth at least EUR 10,000, even if it is split into several linked transactions, also becomes an obliged entity (§ 5(3)).

goAML registration: two deadlines

The Financial Intelligence Unit receives unusual transaction reports through goAML. Under § 21(2), an obliged entity must register within 30 days of acquiring that status. A special transitional deadline applies to entities already obliged before the amendment:

Unofficial English translation:

An obliged entity must register by 30 November 2026 in the Financial Intelligence Unit’s system under § 21(2), as effective from 1 June 2026. — § 36d(1) of Act No. 297/2008 Z. z.

Registration is more than a box to tick. Unusual transactions are reported precisely through this system; another electronic form may be used only when the system is not functioning (§ 17(2)). For breaches of the obligations under § 21, including registration, the Financial Intelligence Unit may impose a fine (§ 33(1)).

Beneficial owners: a register extract is not enough

Basic due diligence includes identifying the beneficial owner, in particular an individual holding at least 25% of the voting rights or registered capital, but also a person who otherwise controls the client (§ 6a), and verifying that identification. The law is explicit: information must come from reliable sources using a risk-based approach, and the obliged entity must not rely exclusively on data from the register of legal entities (§ 10(1)(b)). Until 31 May 2026 this prohibition applied only in higher-risk cases; the amendment extended it to all clients. Downloading and filing an extract is therefore not verification. The client’s ownership and management structure must be examined: formation documents, shareholder lists and, for more complex structures, foreign registers. See who is a beneficial owner? for how the person is identified.

The audit trail is equally important. On inspection, the obliged entity must demonstrate that the extent of due diligence matched the risk (§ 10(4)) and retain records of the client assessment, analyses and individual actions for five years after the contractual relationship with the client ends or after the occasional transaction, and longer at the Financial Intelligence Unit’s request (§ 19(2) and (3)). A general policy without client-specific records does not demonstrate adequate diligence.

What to do now

First, register in goAML before the transitional deadline. Second, audit the internal AML programme. The law requires updates, including following AML legislative amendments, and the programme is approved by the statutory body (§ 20(1)). A programme written before 2026 cannot reflect the amendment. Third, establish records for each client covering verification sources, discrepancies and decisions, and train client-facing staff.

Our guide to AML obligations for estate agencies summarises their responsibilities. Beneficial owners during lawyer authorisation explains verification when a lawyer authorises a contract.

We help establish AML arrangements, from the internal programme and registration to checking an individual client, through AML for businesses. Our external legal department can monitor ongoing obligations, while s.r.o. corporate documentation keeps structural records in order.