Legal Q&A · 09

Compliance, Registers & Licences — questions and answers.

16 answered questions on a subject we handle every day. Find related services in the catalogue: Compliance, Registers & Licences.

Answered by , Czech and Slovak attorney, admitted to the Slovak and Czech Bars (SAK 300422 · ČAK 19654).

Search questions in this area

Search covers questions, short answers and topics. To search the whole Q&A, visit the Q&A homepage.

Questions about Compliance, Registers & Licences

  1. Who is a beneficial owner, and how are they identified? A beneficial owner is always an individual, never a company. In a company, this particularly includes anyone with a direct or indirect interest of at least 25% in voting rights or registered capital, the right to appoint or remove statutory or supervisory bodies, control by other means, or entitlement to at least 25% of the economic benefit. If no such individual can be identified, senior management, meaning the statutory body, is treated as the beneficial owner.
  2. What happens if we are not registered in RPVS or miss annual verification? The consequence is more than a fine. If beneficial owner verification is missing, the public-sector counterparty is not in default when it withholds performance for that reason, so it may lawfully withhold payment of your invoice. False or incomplete data can bring a company fine equal to the economic benefit obtained, or otherwise EUR 10,000–1,000,000, and EUR 10,000–100,000 for the statutory representative. The two-year re-registration ban arises in the sanction cases governed by Section 13a, not after every voluntary deletion.
  3. What must an RPVS verification document contain, and who prepares it? Only an authorised person, a lawyer, notary, bank, auditor or tax adviser, prepares the document to evidence beneficial owner identification or verification. It must explain the information supporting the conclusion, state the partner's ownership and management structure and confirm that the facts match what was actually established. It must not contain a personal identification number or another generally applicable identifier.
  4. We are a medium-sized business. Does NIS2 apply, and must we register with NBÚ? Two things matter together: whether your activity is in Annex 1 or 2 to Act No. 69/2018 Coll. on Cybersecurity, and whether you are at least medium-sized, generally having at least 50 employees or both annual turnover and balance-sheet total above EUR 10 million. If so, you must identify this yourself and notify the National Security Authority within 60 days of starting the activity. Exceptions matter: some entities register regardless of size, and group companies count towards size.
  5. Which documents should we bring for a lawyer to authorise our agreement? Bring two valid official photo identity documents, at least one being an identity card or passport. Under professional rules, one is normally insufficient. If you have no second physical document, alternatives include eID, qualified electronic identification or two identity witnesses. A representative also needs a power of attorney bearing an officially certified signature; authorisation does not replace that certification.
  6. Why does a lawyer examine beneficial ownership when authorising an agreement? When authorising, a lawyer is an obliged entity under Act No. 297/2008 Coll. and must perform customer due diligence, including beneficial owner identification and verification, ownership structure checks, sanctions screening and politically exposed person checks. If ownership cannot be established or the client refuses cooperation, the lawyer cannot proceed. Prepare an ownership structure traced through to specific individuals.
  7. How do we give our accountant or lawyer access to the company's electronic mailbox? The statutory representative grants permission directly in the mailbox on slovensko.sk: after signing in, they add a person under Settings and Person Permissions, specify the scope (full or partial access) and its duration. The administrator processes electronic permission without delay; a paper application with a certified signature takes longer. Permission is not a power of attorney: it provides access to messages, not authority to act for the company. It can be changed or revoked at any time through the same process.
  8. What is registration in the List of Economic Operators for, and which documents do you not need to provide? The Public Procurement Office maintains the list. Registration replaces proving personal standing in each tender and is valid for all contracting authorities and entities for three years, after which a new application is needed. You do not attach documents that the Office can obtain from public administration systems: it checks Commercial Register and criminal record extracts, contributions and taxes itself. In practice, the main requirements are a correctly completed application and the fee.
  9. The contracting authority has not issued our reference. How can we obtain it? Issuing a reference is a statutory duty: ordinarily within 30 days of completion, or in specified cases within 10 days of your request. If the authority is silent, send a written request. If it still fails to issue the reference, apply to the Public Procurement Office with performance evidence. The Office issues it instead and fines the authority for non-compliance. Subcontractors do not receive Section 12 references; they prove experience through confirmation from the main contractor.
  10. We drive a van with a trailer abroad. Do we need a tachograph from 1 July 2026? Very probably yes. If the vehicle's maximum permissible mass, including any trailer, exceeds 2.5 tonnes and you carry goods across borders, it must have a second-generation smart tachograph from 1 July 2026. The driver must observe driving times, breaks and rest periods as truck drivers do. The new extension for combinations over 2.5 and up to 3.5 tonnes applies to international transport and cabotage. Above 3.5 tonnes, domestic journeys may also be covered; statutory exemptions must always be assessed. At an inspection, the relevant records for the inspection day and the preceding 56 days must be produced.
  11. How does the authority calculate a fine for a GDPR breach? The EDPB methodology in Guidelines 04/2022 uses five steps: identify the processing operations, set a starting amount based on the infringement category, severity and the undertaking's turnover, adjust for aggravating and mitigating factors, check the statutory ceiling, and assess effectiveness and proportionality. Ceilings are EUR 10 or 20 million, or 2% or 4% of worldwide turnover for undertakings. Turnover means the whole group, rather than only the company at fault. Arguments can address severity, remediation and enhanced cooperation; mandatory notification itself is neutral. Inability to pay is considered only exceptionally.
  12. Do we need an internal whistleblowing system? Yes, if you employ at least 50 people; public authorities are covered from five employees, and employers in financial services, transport safety or environmental services regardless of size. The system requires a designated responsible person, published reporting channels, an internal policy and a register of reports. Receipt must be acknowledged within seven days and investigation results communicated within 90 days. The Whistleblower Protection Office may impose a fine of up to EUR 50,000, or EUR 100,000 for employers with at least 250 employees.
  13. We want to change the authorised person in the Register of Public Sector Partners. How does it work? The change is always a replacement, because the register allows only one authorised person. You sign a written agreement with the new person, who verifies the beneficial owners afresh, prepares a verification document and electronically applies to register the change; the law does not require cooperation from the former person. However, if the former person requested their own removal, you must secure a replacement within 30 days of removal. After that period the other contracting party may withhold payments and, if the delay exceeds 30 days, withdraw from the contract.
  14. When is a certified signature enough, and when do we need lawyer authorisation? These are different legal procedures. Official signature certification by a notary, municipality or district office confirms only that a particular person signed the document; its content is not reviewed. In authorisation, a lawyer drafts the contract, establishes the parties' identities, checks legality and bears liability for damage. The cadastre does not require certified signatures on such contracts. Since 17 August 2026, incorporation documents and business interest transfers require lawyer authorisation or a notarial deed. A qualified electronic signature with a timestamp replaces a handwritten signature and its certification, but not authorisation or a notarial deed.
  15. We want to operate a guarding service. What do we need for a private security licence? The regional Police Force directorate grants a guarding licence for ten years. For a company, it checks reliability and especially the people involved. Every statutory body member must be at least 21, of good character, reliable, medically fit and professionally qualified, with the required education and experience and a type P competence card after an Interior Ministry examination. Members with interests of 15% or more must be of good character and reliable. Attach personal documents, the founding deed and the fee. Unlicensed operation risks a fine and activity ban.
  16. What do we need for a road haulage operator authorisation for vehicles over 3.5 tonnes? The district office in the regional capital grants road transport operator authorisation for ten years if the undertaking proves four requirements under Regulation (EC) No. 1071/2009: an effective and stable establishment in Slovakia, good repute of statutory representatives and the transport manager, financial standing comprising equity of at least EUR 9,000 for the first vehicle and EUR 5,000 for each additional vehicle over 3.5 tonnes, and the appointed transport manager's professional competence verified by examination. Transport to other EU countries additionally requires a Community licence and evidence of it in every vehicle.

Cannot find your question? Ask us — we will reply by email. Answers in this Q&A are general information and do not constitute legal services.

Other Q&A topics

Need help in this area?

Tell us about your situation. We will reply within 24 hours.

A Q&A answer explains the rule; a consultation addresses your situation. For each topic, we can explain what needs to be done and by when.

Book an initial consultation Ask your own question
Contact a lawyer