The Cash Payment Restrictions Act is one of those laws nobody remembers until an inspection arrives. Its limits changed from 1 January 2026, returning to a dual model.
The current rules
Under § 4(1) of Act No. 394/2012 Z. z., cash payments exceeding EUR 5,000 are prohibited, unless paragraph 2 provides otherwise.
Under § 4(2), cash payments over EUR 15,000 are prohibited between individuals who are not entrepreneurs.
The higher threshold applies only when both parties are individuals who are not entrepreneurs. If either party (payer or recipient) is a legal entity or an entrepreneur, the lower threshold applies. The Act does not expressly say whether an entrepreneur paying outside their business counts as a non-entrepreneur. For such a payment, it is safer to work with the EUR 5,000 threshold.
From 1 July 2023 to 31 December 2025, a uniform EUR 15,000 limit applied to everyone; before that, the same dual regime as today applied. An older transaction must be assessed under the wording effective when payment was made, not today’s rules.
Three common pitfalls
Splitting a payment does not help. If a cash payment is split into several payments under one legal relationship, its value is their total (§ 6(2)). The prohibition therefore also covers instalments none of which exceeds the limit on its own. Only cash payments count towards the total; any part paid by bank transfer does not.
Repeated independent transactions are different. If each purchase establishes a separate legal relationship, each payment is assessed on its own, even if the monthly total exceeds the threshold. What matters is whether there is one legal relationship divided into instalments or independent transactions, not how they are invoiced. A framework agreement must be assessed by its content.
The prohibition also applies abroad. Under § 7, it extends to handing over and receiving cash abroad if this relates to a supply made in Slovakia and the payer or the recipient has its residence, registered office, establishment or place of business here (exceptions in § 8(j)).
The contract remains valid, and the problem remains too
A breach of the prohibition does not affect the validity of the legal acts on which the payment was based (§ 5). The sale agreement therefore does not become invalid.
That does not mean nothing happens. The breach is sanctioned separately, for both the payer and the recipient (§ 9 and § 10), and complicates the transaction precisely where no one needs it: proving the price was actually paid.
Implications for transactions
For property and ownership interest purchase prices, the amounts are usually far above the threshold, so the whole price cannot be paid in cash.
More interesting are advances, reservation fees and balance payments, where the temptation is to “settle it on the spot”. If the advance belongs to the same legal relationship as the purchase price, a cash advance is added to the other cash payments under that agreement.
A non-cash payment is not automatically safe, either. Money and ownership do not transfer at the same moment, so someone bears the interim risk. That is the purpose of lawyer escrow of the purchase price: money is deposited in advance and released to the seller only when the agreed condition is met.
If the customer is itself a VAT payer and pays a supplier that is a VAT payer, it also makes sense to check that the account appears in the published list of bank accounts notified to the Financial Administration. Payment to another account is one of the statutory grounds on which the customer “should and could have known” under § 69(13) of the VAT Act that the tax would not be paid. If the supplier fails to pay the tax shown on the invoice, the customer may be liable for it.
Do not confuse this with the AML threshold
Cash payment limits must be distinguished from the threshold at which someone becomes an obliged entity under anti-money laundering legislation. That is a different regime, with different figures and obligations: customer due diligence, an internal programme and reporting unusual transactions.
They are separate regimes. Compliance with one says nothing about the other, and estate agents are affected by both.
This article provides general legal information as at 26 September 2026. It does not constitute legal services or advice on your specific matter. Laws change and the details of your situation may differ. Check the appropriate course of action or contact us before making a decision.
