Registration in the Register of Public Sector Partners (RPVS)

No. The Register of Public Sector Partners Act requires the authorised person to identify beneficial owners upon initial registration and repeatedly verify identification thereafter, particularly as at 31 December each calendar year, when registering a beneficial owner change, upon registration as the authorised person and in connection with a contract above the statutory threshold or substantial performance under it (§ 11(2)). The result of annual verification must be notified to the registering authority by 28 February of the following year (§ 11(8)). This ongoing work is precisely what we take over.

Filing the registration application costs from €100, a reduced price instead of the usual €200. Performing the authorised person role costs €200 per year, payable only from the following calendar year, so the first year is included in the registration price. The annual amount includes everything arising during the year — verification as at 31 December, verification upon statutory events and registration of changes to information or beneficial owners. No additional payment is charged for these. More complex structures, typically involving joint-stock companies or foreign companies in the ownership chain, may cost more, which we confirm upfront.

No. We handle registration and ongoing services remotely for clients throughout Slovakia. Sign documents with a qualified electronic signature, or by hand and send them by post. This does not circumvent the rules. The Act on Prevention of Money Laundering expressly recognises verification of identification using a qualified electronic signature or an official authenticator as equivalent to verification in physical presence (§ 8(1)). If you would nevertheless like to meet, we are happy to welcome you at our Košice office.

Only an authorised person — a lawyer, notary, bank, auditor or tax adviser with a registered office or place of business in Slovakia who has undertaken in writing to fulfil the authorised person's obligations. This also includes a foreign person with the same business activity operating an enterprise or branch here (§ 2(1) of the Register of Public Sector Partners Act). A company cannot register itself. Our firm acts as an authorised person and assumes responsibility for verification.

Generally, when you receive performance funded from public resources above statutory thresholds, draw grants or EU funding, or acquire assets from the state or local authorities. There are two thresholds. A person due to receive one-off performance not exceeding €100,000, or multiple partial or recurring payments not exceeding €250,000 in total, is not a public sector partner (§ 2(2) and (3)). Value is calculated under specific rules. Recurring performance is aggregated over the entire agreed contract term, including anticipated extensions; framework agreements use the maximum framework value; values under different contracts are not added together; and calculations exclude VAT (§ 2(4)). Aggregation by calendar year applies only to healthcare providers. We assess whether the obligation applies to your case at the initial consultation.

This is not a formality without consequences. If the verification obligation is not met, the public sector contracting party is not in default if, for that reason, it does not provide the performance required by the contract (§ 15(2)). In other words, it may lawfully withhold payment of your invoices without breaching the contract. Removal of the partner from the register even gives the other party a right to withdraw from the contract (§ 15(1)). Missed verification therefore manifests as halted cash flow rather than a fine.

A fine equal to the economic benefit obtained may be imposed; if that benefit cannot be established, the fine ranges from €10,000 to €1,000,000. The registering authority imposes it on the partner if the application contains false or incomplete beneficial owner information, or the obligation to file a change application within the statutory period is not fulfilled. It imposes a fine of €10,000 to €100,000 on the statutory officer or members of the statutory body, jointly and severally (§ 13(1)). Following a qualified complaint, the court may review the information and remove the partner from the register (§ 12), after which re-registration is barred for two years (§ 13a). We therefore recommend arranging registration before signing the contract and maintaining it afterwards.

The public sector partner and authorised person are jointly responsible for the accuracy of registered information, identification and verification (§ 11(1)). In addition, the authorised person registered at the time of the breach guarantees payment of a fine imposed on the statutory officer and is released only if they prove they acted with professional care (§ 13(5)). This is why we do not treat verification as a formality — we bear our own risk.

Yes, this is common. The authorised person is changed by registering the new authorised person, who simultaneously submits verification of beneficial owner identification. If the existing authorised person leaves the register on their own initiative, a new one must be secured within 30 days (§ 10(2) and (3)). We use taking over as an opportunity to check whether the existing entry and verification document can withstand scrutiny. We do not blindly accept another person's work.

If beneficial owner information or the beneficial owner changes, you must inform the authorised person without delay. They notify the registering authority within 60 days of the change, together with a new verification document (§ 9(1)). The period is short and runs from the event, rather than its discovery. We therefore proactively ask retainer clients about changes on an ongoing basis.

No, but tracing an ownership structure with foreign entities requires more supporting documents and is repeated at every annual verification. Our firm has the advantage of understanding Czech structures as readily as domestic ones, as we are also admitted to the Czech Bar Association.