If you are no longer a public sector partner and are no longer receiving performance under any contract, the correct route is removal from the register, applied for by your authorised person while they are still registered. Were the authorised person to apply for their own removal only, you would remain in the register and would have to secure a new authorised person within 30 days of that removal. Voluntary removal does not in itself trigger the two-year bar on fresh registration, but it does not end proceedings already commenced on the verification of beneficial owner data.
The contract has ended, the grant has been accounted for, and the company plans no further business with the public sector. Registration in the Register of Public Sector Partners (RPVS) does not, however, end by itself. It is made for an indefinite period (Section 7(3) of Act No. 315/2016 Coll.) and, while it lasts, so does the duty to verify beneficial owners as at 31 December each year (Section 11(2)). When a company decides to part with the register, it matters whether the company itself is removed or only its authorised person.
Two different removals
The Act distinguishes removal of the partner from removal of the authorised person. Removal of the partner is carried out by the registering authority on the application of the authorised person (Section 10(1)). It is filed exclusively electronically by the authorised person entered in the register, because all applications on the partner’s behalf are made by them alone (Section 5(1) and (2)). By this step the company leaves the register altogether.
Removal of the authorised person at their own request is something different. The company remains in the register, merely losing the person who acts for it, and the Act requires it to secure the registration of a new authorised person no later than 30 days after the removal, including fresh verification of the beneficial owners (Section 10(2)). If the company simply terminates the agreement and the lawyer has themselves removed, the company stays in the register and the period starts to run. The order of steps therefore matters: first removal of the partner, and only then termination of the agreement with the authorised person.
When removal is safe
What is decisive is whether the contract for which you registered is still running:
A public sector partner must be registered in the register at least for the duration of the contract. For the purposes of this Act, the duration of the contract under the preceding sentence means the period during which the public sector partner receives funds or acquires property, rights to property or other proprietary rights.
— Section 4(1) of Act No. 315/2016 Coll. (unofficial English translation)
While payments are still coming in under a public contract, such as final invoices or retention money, removal is premature. If removal of the partner on the application of the authorised person were to occur during the term of the contract, the other party acquires the right to withdraw from it (Section 15(1)). Before filing, therefore, go through all contracts, amendments and framework agreements, not only the one for which you once registered. An application, including an application for removal, cannot be withdrawn (Section 5(5)), so the decision must be made beforehand.
Consider the outlook as well. If you expect a new contract in the near future, fresh registration will mean identification from scratch, and verification is required in any event when a contract above the statutory threshold is concluded (Section 11(2)(d)). Finally, the Act permits registration at their own request even by a person who is not a public sector partner; such a person has the duties of a partner, but Sections 13 to 15 on sanctions and consequences for contracts do not apply to them (Section 17).
What voluntary removal will not solve
The two-year bar on fresh registration attaches to removal by a decision of the registering authority in proceedings on the verification of beneficial owner data (Section 12(7)) or for an unpaid fine (Section 13(2) and Section 13a), not to ordinary voluntary removal. If, however, proceedings on the accuracy of beneficial owner data are already under way, the registering authority completes them after a voluntary removal (Section 12(8)). Where the partner fails to defend the data credibly, proceedings on a fine and the two-year bar follow, and the statutory representative becomes a disqualified person under the Commercial Code (Section 14). Removal is therefore no escape from a problem that has already arisen. Nor does the Act attach to removal the extinction of liability for earlier breaches of duty, such as late notification of a change of beneficial owner.
How to proceed
First check that you are no longer receiving performance under any contract and that no proceedings under Section 12 are pending against the company. Then ask your authorised person to file an application for removal of the partner, and terminate the agreement with them only after the removal has been registered. If, on the contrary, you need to remain in the register and only the authorised person is changing, the procedure is described in changing an RPVS authorised person and the consequences of delay in what happens without RPVS registration.
We assess whether removal is safe in your situation and handle the removal, or the takeover of the authorised person’s role, through our change and removal of an RPVS authorised person service. If you are staying in the register, ongoing care is provided by our RPVS registration and authorised person service.
This answer provides general information on the law as at 12 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.
