You recover firmly. Will it withstand scrutiny?

Because they are assessed separately. The existence of the debt gives you a claim, but how you assert it against a consumer is assessed independently and may be considered an unfair or aggressive commercial practice even if the claim is justified. The penalty for the practice and the fate of the claim are two different matters.

Since 2024, the Consumer Protection Act has contained a separate provision on prohibited debt recovery practices. It prohibits personal visits to the debtor or persons close to them at home or work without their prior express consent, and contacting or harassing them on Saturdays, non-working days and, on other days, between six in the evening and eight the following morning. It also limits charges to reasonably incurred costs and requires their calculation and justification free of charge on request.

The prohibition on personal visits, contact time restrictions and cost rules do not apply directly to legal practice, just as they do not apply to enforcement officers and notaries. However, this is no escape route. As creditor, you remain bound by the prohibition of unfair and aggressive commercial practices and the duty to act in accordance with good morals. For supervised entities, recovery entrusted to another is treated as your own activity, for which you remain responsible. The practical implication differs from what might be expected: what matters is whether you have a defensible process, rather than who sends the demand.

It means outsourcing does not remove responsibility. According to the National Bank of Slovakia's position, representation by a lawyer or any other entity in managing and recovering claims in your name is delegated activity subject to supervision. You must ensure documents showing how it is performed are available, monitor it and remedy activity contrary to law or your instructions.

Through a system. If demands follow your own reminder system, documented in internal policies, properly applied, subject to internal controls, predictable and regularly reviewed for legality, effectiveness and lessons from complaints, the supervisory authority will not assess them as aggressive practice. That is the purpose of the internal policy: to establish a defensible standard before a complaint arrives.

That is precisely the type of conduct assessed as aggressive practice: sending a completed payment order application creates the impression that the court has already decided. The same category includes implying that separate proceedings with their own costs have started when they have not, threatening acts you are not entitled to perform, or stating a specific amount of legal representation costs before the court has ruled on them.

In interest. If the instalment agreement allows interest on unpaid ordinary interest upon default, it may be an unfair contractual term. If you add overdue principal and ordinary interest and treat the total as new principal bearing further interest, the agreement may be classified as new consumer credit, bringing an entire additional set of obligations you had not anticipated.

The prohibition of prohibited recovery practices applies to recovery of a contractual claim against a consumer, including online shops, telecoms and energy, rather than only credit. The National Bank of Slovakia's supervisory practice applies to its supervised entities, but is more broadly useful as a benchmark of acceptable conduct. These rules do not apply to business-to-business relationships.