Yes. The Slovak Commercial Code recognises a joint-stock company with variable share capital, which the Collective Investment Act calls an investment fund with variable share capital. It may be established only for collective investment, not as an ordinary commercial company. It is managed by a management company authorised by Národná banka Slovenska or manages itself under an authorisation. For smaller funds for professional investors, NBS also allows establishment without authorisation, subject to entry in its register of managers. Compared with a Czech SICAV, it has a higher minimum share capital and does not divide shares into founder shares and investment shares.
Slovakia also has an equivalent of the Czech SICAV, which may be considered for an investment club, family wealth management or a real estate project involving several investors. The Commercial Code regulates it as a joint-stock company with variable share capital (Sections 220b to 220e), and Act No. 203/2011 Z. z. on Collective Investment as an investment fund with variable share capital (Section 26d(1)). It is not, however, a form that anyone may use for any purpose.
For collective investment only
The following quotation is reproduced in its original language:
Akciovú spoločnosť s premenlivým základným imaním možno založiť len na účely vykonávania kolektívneho investovania podľa osobitného predpisu.
The share capital equals the net assets and is divided into shares without a nominal value. The minimum is EUR 125 000 unless specific legislation provides otherwise, and the minimum amount specified in the articles of association is entered in the Commercial Register (Section 220b, paragraphs 1 and 2). The business name must include the designation “investment fund with variable share capital”, and the company cannot be established through an invitation to subscribe for shares (Section 220b, paragraphs 4 and 6). Within the range between the registered and maximum share capital, an investor joins by applying for a share to be issued, and the capital increases upon payment of its price. Within that range, an investor exits by applying for redemption of the share, and the capital decreases upon payment of the redemption proceeds (Section 220d(3) and Section 220e(2)). The company may not issue securities other than shares (Section 220c(4)).
Two routes under the Collective Investment Act
An investment fund with variable share capital is a domestic collective investment undertaking (Section 4(2), letter a)) and is established as a standard or special fund (Section 4(3)). It is managed by an authorised management company under a management agreement or manages itself as a self-managed fund under an authorisation pursuant to Section 28 or Section 28a (Section 26a(1) and Section 26b(1)). A self-managed fund must have initial capital of at least EUR 300 000 (Section 26c(5)). Its articles of association must also contain the particulars required for fund rules, and the provisions governing approval of a mutual fund’s rules apply, with the necessary adaptations, to their approval (Section 26d, paragraphs 2 and 4). The fund may establish sub-funds with segregated assets (Section 26e).
The Act also provides for a variable-capital fund that is an undertaking under Section 4(2), letter b), and only such a fund may issue shares in exchange for a non-cash contribution (Section 15a(2) of Act No. 203/2011 Z. z.). In its December 2024 questions and answers on registered managers, Národná banka Slovenska states that a self-managed company of this type may be established without authorisation if it meets the thresholds applicable to a registered manager, is entered in the register of managers maintained by NBS and is neither a public special fund nor a special fund for qualified investors. Shares in such a fund may be distributed only to professional investors, and to qualified investors only within the limits of Section 31d (Section 4(4)). The conditions for this route are explained in the question on the Slovak equivalent of Section 15 ZISIF (in Slovak).
How it differs from a Czech SICAV
The Czech SICAV is explained in detail in the question what is a SICAV (in Slovak). It differs from the Slovak framework in two main respects:
- The registered share capital of a Czech SICAV must be at least CZK 1 or EUR 1 (Section 155(2) of Act No. 240/2013 Sb.). The Slovak minimum share capital is EUR 125 000.
- Czech law divides SICAV shares into founder shares and investment shares (Section 158). Neither the Slovak Commercial Code nor the Collective Investment Act provides for this division. The founder of an investment fund with variable share capital may request redemption of a share only after 6 months from the start of issuing shares to investors, unless the articles of association specify a longer period (Section 15a(4) of Act No. 203/2011 Z. z.).
Both frameworks provide for a public invitation to subscribe for shares. In Czechia, investment shares are subscribed for on that basis (Section 163(1) of Act No. 240/2013 Sb.). In Slovakia, shares beyond the registered share capital may be issued only on the basis of a public invitation to subscribe for them, unless specific legislation provides otherwise (Section 220c(2) of the Commercial Code). According to NBS, this also applies to special funds for qualified investors and funds of registered managers. The invitation should, however, be a brief notice of the opportunity to subscribe for shares, rather than a recommendation or a targeted offer.
We will assess whether your plans are suited to a Slovak investment fund with variable share capital, another structure or a Czech SICAV through our investment structure review. We will handle the formation of a Czech SICAV through our Czech FKI or SICAV formation (in Slovak) service.
This answer provides general information on the law as at 3 October 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.
