Legal Q&A · Compliance, Registers & Licences

We want to change the authorised person in the Register of Public Sector Partners. How does it work?

Law as at 5 September 2026

Short answer

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.

Your current authorised person is leaving, or you want to bring your advisory work together with one lawyer. The Register of Public Sector Partners (RPVS) provides only one route: a new authorised person can be registered only with fresh verification of the beneficial owners. If the previous person withdrew independently, a deadline is already running.

Why a change always means a replacement

Act No. 315/2016 Coll. on the Register of Public Sector Partners allows each partner only one authorised person (Section 4(8)), who alone submits all applications on the partner’s behalf (Section 5(1)). An authorised person may be a lawyer, notary, bank, auditor or tax adviser who has undertaken their duties in a written agreement (Section 2(1)(c)). Removal of one person and registration of the other therefore take place in a single filing:

The registering authority shall remove an authorised person at the public sector partner’s request only if the new authorised person submits an application to amend the registered particulars on the partner’s behalf, together with verification of the beneficial owner’s identification under Section 11(2)(b).

Section 10(3) of Act No. 315/2016 Coll. (unofficial English translation)

How replacement works

The first step is a written agreement on performing the duties of an authorised person, attached to the application (Section 5(3)). The new authorised person also declares that they have no relationship with the partner that could call their impartiality into question; personal or ownership links disqualify them (Section 19).

The second step is fresh verification: on registration, the authorised person must verify the beneficial owners’ identification (Section 11(2)(b)), impartially and with professional care (Section 11(5)). This produces a new verification document. We explain its requirements in what a verification document must contain. The inherited document is worth reviewing: the partner and authorised person are responsible for the accuracy of registered particulars (Section 11(1)), and the authorised person guarantees payment of a fine imposed on the statutory representative if registered at the time of the breach (Section 13(5)).

The third step is the application to register the change. It must be filed electronically and authorised by the authorised person, with the verification document, declaration of independence and agreement attached (Section 5(2) and (3)). The registering authority, Žilina District Court, registers the change within five working days of receipt (Section 7(1)) and notifies the former authorised person (Section 10(3)). The law requires neither the predecessor’s consent nor their cooperation.

When the former authorised person withdraws independently

If the former authorised person requested their own removal, a deadline applies:

If an authorised person is removed at their own request, the public sector partner shall secure registration of a new authorised person no later than 30 days after removal, including verification of the beneficial owner’s identification under Section 11(2)(b).

Section 10(2) of Act No. 315/2016 Coll. (unofficial English translation)

The deadline runs from removal, of which the registering authority notifies you without delay (Section 10(2)). Missing it affects payments and the contract, rather than resulting in a fine:

If the duty under Section 11(2) has not been fulfilled, or the public sector partner is late in fulfilling the duty under the third sentence of Section 10(2), a party to the contract under paragraph 1 is not in default if, for that reason, it does not perform its contractual obligations.

Section 15(2) of Act No. 315/2016 Coll. (unofficial English translation)

The other party may therefore withhold payments and, once your delay exceeds thirty days, acquires the right to withdraw from the contract (Section 15(1)). We discuss other sanctions in what happens without RPVS registration.

When to combine replacement with other steps

If a beneficial owner has also changed, notification of that change within 60 days (Section 9(1)) can be combined with the replacement in one filing. If proceedings on a substantiated complaint are underway, replacement does not stop them; they continue even after the partner’s voluntary removal (Section 12(8)). However, the new authorised person can prepare a defence based on their own verification.

How we can help

Our change of RPVS authorised person service covers taking over the matter and reviewing the inherited registration. Replacement is followed by the annual cycle of RPVS registration and authorised person services. For complex ownership structures, we support beneficial owner identification with our AML procedures for businesses.

If you have received notice that your authorised person has been removed, contact us immediately: thirty days is a short time for a foreign ownership structure.

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 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.
  2. 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.
  3. 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.
  4. 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.

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

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