What must an RPVS verification document contain, and who prepares it?

Is there a usable verification document template?

‘Verification document template’ is a common search, but the answer is inconvenient: there is no usable template. The reason is not that nobody has published one. This is not a form with boxes; it is a reasoned professional conclusion about who actually controls the company. It must be written, rather than filled in.

Nor may the company prepare it itself. Under the Act on the Register of Public Sector Partners, it is prepared by an authorised person: a lawyer, notary, bank, auditor or tax adviser based or doing business in Slovakia who has undertaken the role in writing.

What must the document contain?

Under Section 11(6), the authorised person must:

1. Explain the information on which beneficial owner identification or verification was based.
2. State the ownership and management structure of a public sector partner that is a legal entity.
3. Provide public official information, including the office held, where known or knowable.
4. For a partner under Section 4(5), demonstrate that the conditions for the special registration of its statutory body and the members of that body instead of beneficial owners are met.
5. Declare that the stated facts correspond to the position actually established.

Point four concerns the special regime under Section 4(5): an issuer on a regulated market subject to the prescribed disclosure requirements, or a company exclusively owned and controlled by such an issuer. This must be distinguished from identifying members of senior management as substitute beneficial owners under AML law where no natural person meets the relevant criteria. These are two distinct legal grounds; difficulty uncovering the structure is not sufficient for either.

One formal limit matters: the document must not contain a generally applicable identifier (Section 11(7)), including a personal identification number. It is published, and publication does not breach commercial or bank secrecy (Section 16(3)). Anyone, including competitors, can read everything in it.

Impartiality benefits the client

The Act requires the authorised person to act impartially and with professional care, obtain all available information relevant to registration and assess it. It expressly states that the person is not bound by the public sector partner’s instructions (Section 11(5)).

This may sound restrictive, but it provides protection. A document based on independent professional assessment can withstand scrutiny. One written to reflect what the client wishes to have registered is worthless in proceedings following a qualified complaint.

When is a verification document prepared?

The performance and documentation of verification must be distinguished from what is filed with the register. A verification document accompanies the initial registration and an application concerning a beneficial owner (Section 5(3)). Verification is also performed upon the other events listed in Section 11(2). If the beneficial owner has not changed at an annual or other verification under Section 11(8), a verification notice is filed, rather than automatically filing a new verification document. Notice of annual verification must be filed by 28 February of the following year; notice of the other specified verifications must be filed without delay. An identified change is addressed by an application under Section 9 accompanied by a verification document. The Act also provides that registration of a change between 1 January and 28 February may replace the annual notice.

Why choosing the cheapest option can be costly

The authorised person guarantees the partner’s director fine, from EUR 10,000 to EUR 100,000, and escapes only by proving professional care. Document quality is therefore directly linked to the work actually invested in uncovering ownership. A lawyer treating it as a formality risks their own money.

For a simple s. r. o. with two Slovak members, the work takes a few hours. For a holding structure with foreign entities, it requires a full investigation repeated at each annual verification. That is where the difference between thorough and merely formal verification becomes most apparent. We cover both through RPVS registration and authorised-person services.