Legal Q&A · IT, Software & E-commerce

What must appear on a company website even if we do not sell through it?

Law as at 5 September 2026

Short answer

Generally, these duties apply. A company website is an information society service even without sales if it promotes the business. The Electronic Commerce Act requires the business name and registered office, email and phone, register and entry number, tax identification number if VAT-registered, and the supervisory authority's name and address. The Commercial Code adds the company identification number and legal form. Details must be easily and permanently accessible, not supplied only on request. GDPR transparency and cookie rules also apply.

A brochure website with references, service descriptions and a phone number may seem legally straightforward: no sales means nothing to regulate. But the Electronic Commerce Act ties duties to whether a website is an information society service, and company websites generally are.

Sales are not a prerequisite

Act No. 22/2004 Coll. on Electronic Commerce imposes information duties on information society service providers, meaning services provided remotely “normally for remuneration” (Section 2(a)). The visitor need not make that payment. A site funded by advertising or referral commissions has an economic character, as does one promoting its operator’s business. A private blog without an economic purpose has an arguable exemption; a company website does not. General information duties under Section 4 also stand separately from electronic ordering rules under Section 5 and apply even if no contract is ever concluded through the site.

What must appear on the website

A service provider shall provide the recipient electronically with, in particular: (a) its name, business name and registered office if a legal entity, or first name, surname, place of business and residential address if an individual; (b) tax identification number if registered for value added tax; […] (c) email address and telephone number; (d) the register in which it is entered and entry number; (e) the name and address of the authority supervising its activities.

— Section 4(1) of Act No. 22/2004 Coll. (unofficial English translation)

Three details commonly go wrong. Sole traders must state their residential address alongside their place of business; a virtual office does not solve this. The supervisory authority needs its name and address, not merely “SOI”. Regulated professions also require the professional chamber, title and a reference to professional rules (Section 4(2)). Finally, details must remain available:

Information under paragraphs 1 and 2 must be easily and permanently accessible to the recipient and distinguishable from commercial communications.

— Section 4(3) of Act No. 22/2004 Coll. (unofficial English translation)

In practice, use a dedicated page linked from the footer, rather than information “on request”.

The company identification number (IČO) requirement comes from the Commercial Code (Act No. 513/1991 Coll.), not the Electronic Commerce Act. It requires business documents to state the business name, registered office or place of business, legal form, IČO and register details (Section 3a(1)), adding:

An entrepreneur must also state the particulars under paragraph 1 on its website, if it has one.

— Section 3a(3) of the Commercial Code (unofficial English translation)

If you state share capital on the website, include the amount paid up.

  • Business name, legal form and registered office; for individuals, first name, surname, place of business and residential address.
  • IČO and tax identification number if VAT-registered.
  • Email and telephone number.
  • Register and entry number, including the Commercial Register section and file number or Trade Register number.
  • Supervisory authority’s name and address, generally the Slovak Trade Inspection for an ordinary website.
  • A privacy notice under Article 13 GDPR and a cookie banner if non-essential cookies are used. We explain why this also concerns websites without forms in does a website without forms need to address the GDPR?.

What are the consequences?

The Slovak Trade Inspection supervises compliance (Section 7). A breach can attract a fine from EUR 50 to 1% of turnover for the preceding accounting period, capped at EUR 50,000. Repeating the same breach within 12 months carries EUR 100 to 2% of turnover, capped at EUR 100,000 (Section 7a(1) and (2)).

Where a website becomes an online shop

Accepting orders through the site adds electronic contracting duties, including error correction before submission and order confirmation, plus consumer information and withdrawal rights under Act No. 108/2024 Coll. We discuss these in mandatory online shop information and ordering. This article addresses only the first layer applicable to every company website.

How we can help

We review and complete your footer, About us page and website documents through our e-commerce legal services; for a site without sales, this is a one-off review. Our GDPR and personal data protection service prepares privacy notices, and our cookies and website configuration service configures banners and scripts. Simply send the website address.

This answer provides general information on the law as at 5 September 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.

More legal questions

All questions and answers
  1. We have a registered trademark but do not use it. Can we lose it? Yes. If a mark has not been genuinely used in Slovakia for an uninterrupted period of at least five years, the Office revokes it on a third party's application. The law presumes non-use, which the owner must rebut. The same rule applies to EU marks under Article 58(1)(a) of Regulation (EU) 2017/1001. An unused mark also weakens as an enforcement tool: in opposition proceedings, the other party can demand proof of genuine use.
  2. Is an accept-or-leave cookie banner lawful? No. Cookie consent must satisfy the GDPR and be freely given; accept or leave is not a real choice. The European Data Protection Board's consent guidelines expressly state that access to content must not depend on cookie consent. A banner therefore needs an equally prominent reject button on its first layer, and the website must work after rejection. The paid alternative, pay or consent, remains disputed.
  3. Nobody enters a name or email on our website. Do we need to address the GDPR at all? Generally yes, for three reasons. Under EU case law, a visitor's IP address is personal data if you can identify them with help from others, as is usually the case with ordinary server logs. The GDPR expressly treats pseudonymous identifiers, such as analytics cookies, as personal data: anonymity must be achieved rather than assumed. Embedded third-party scripts may create joint controllership where you jointly determine the purposes and means of specific operations. Depending on the setup, the third party may instead be a processor or an independent controller. The first question is therefore technical: what does your website load in the background?
  4. A client refuses to pay for standby because no intervention was needed. Are they right? Generally not. Under service contracts, standby fees pay for reserved capacity and readiness to respond within the agreed time, which has value even in a month without incidents. Entitlement depends on agreed and actually maintained availability rather than intervention numbers. In a dispute, the provider must prove availability, making duty schedules, availability records and responses to requests decisive.

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Mgr. Patrik Tulinský, LL.M. Czech and Slovak attorney · SAK 300422 · ČAK 19654

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