The Ministry of Finance of the Slovak Republic has updated the rules for reporting transactions with related parties and issued new guidance on determining the content of transfer pricing documentation. Also, the new guidance also amends an important part of the corporate income tax return, specifically Table I (Transactions with Related Parties).

The changes focus on improving the clarity and transparency of the reported data, as well as on the preparation of simplified documentation. Detailed information is available in the Financial Bulletin (Contribution No. 23) on the Ministry’s website.

New Guidance on the Content of Transfer Pricing Documentation

The issuance of the new guidance on the content of transfer pricing documentation does not introduce significant changes. Taxpayers are still required to prepare documentation in either simplified, basic, or full form.

However, the method of preparing simplified documentation has changed. Under the new conditions, taxpayers who are required to prepare simplified transfer pricing documentation will no longer complete a separate annex to the guidance. Instead, they will only complete the updated version of Table I in the tax return.

When assessing which obligations must be fulfilled, the following comparison of the conditions under the new Guidance applies:

	Correct and Complete Reporting	Incorrect or Incomplete Reporting
Form of transfer pricing documentation	Simplified documentation (without annex)	Simplified documentation (including annex)
	including
Form of reporting transactions with related parties	Table I of the tax return	Separate annex to the Guidance

Effective Date of the New Guidance

The new guidance will first apply to transfer pricing documentation prepared for a tax period for which the deadline for filing the tax return expires after 31 December 2025.

This means that for a financial year overlapping into 2026, transfer pricing documentation must already be prepared in accordance with the new guidance.

Changes to the Tax Return Table

The revised version of Table I (Transactions with Related Parties) in the tax return focuses on reporting the following information in a structured format:

• exact type of transaction
• name of the counterparty to the controlled transaction
• registered seat of the counterparty to the controlled transaction
• value of the controlled transaction

The new version of the table has already been officially published and has the following structure:

Transaction		Impact on line 100 or line 301 of the tax return form	Name of related party	Country code
Number	Type*

*The exact type of transaction is determined by the taxpayer according to the list provided in the instructions for completing the tax return.

The purpose of this change to the special table in the tax return is to reduce the administrative burden for a selected group of taxpayers and to improve the readability of the data for the Financial Administration. The reported data will also be used for risk analysis or automated comparisons in tax audits.

For all affected companies, this means one key requirement – detailed recording of all controlled transactions with related parties.

The Ministry of Labour, Social Affairs and Family of the Slovak Republic has published Announcement No. 280/2025 Coll., which sets new meal allowance amounts for employees depending on the duration of a business trip. The new amounts will enter into force on 1 December 2025.

This change results from the fulfilment of the condition for increasing meal allowance amounts determined by the Statistical Office, as in September there was a change in the cumulative price index of meals and non-alcoholic beverages, which serves as the basis for these data.

Overview of Changes in Meal Allowances from 1 December 2025

Time Band	Previous allowance	New allowance
5 to 12 hours	EUR 8,80	EUR 9,30
12 to 18 hours	EUR 13,10	EUR 13,80
Over 18 hours	EUR 19,50	EUR 20,60

The maximum employer contribution for employee meals from 1 December 2025 will be EUR 5.12 (55% of EUR 9.30), and the minimum value of a meal voucher will be EUR 6.98 (75% of EUR 9.30). The financial contribution amount will increase from a minimum of EUR 3.63 to EUR 3.84, up to a maximum of EUR 5.12.

The increase in meal allowance amounts reflects the development of prices for meals and beverages, through which the Ministry of Labour adjusts the level of employee entitlements to meal allowances accordingly.

Parliament has approved another amendment to the Slovak Bank Transaction Tax Act. The purpose of this amendment is to incorporate several changes related to the abolition of this tax for selected groups – self-employed (entrepreneurs) – upon fulfilment of specific conditions.

We present below a summary of the key information contained in this amendment. All additional details can be found on our website Moore BDR I News.

• Addition of new definitions

Recharged expense (cost)

Following extensive public discussion and the recommendations of experts and the Slovak Chamber of Tax Advisers, a long-awaited definition of a recharged expense has been successfully incorporated into the legislation. A recharged expense represents:

• the amount of a financial transaction carried out on behalf of a taxpayer by a person other than the taxpayer; in the case of a taxpayer with limited tax liability, this financial transaction must be connected with the taxpayer’s activity in the Slovak Republic

Permanent establishment

The Slovak Bank Transaction Tax Act also adopts the definition of a permanent establishment in line with other tax laws to ensure a unified interpretation. This definition, already included in the Guidance of the Ministry of Finance on the application of the Act (available in Slovak language only), is now codified by law.

A permanent establishment shall mean:

• a fixed place or facility through which a taxpayer with limited tax liability (so-called tax non-resident) wholly or partly carries out its business activity in the Slovak Republic. This includes, in particular, a place from which the taxpayer’s activities are organised, a branch, office, workshop, workplace, sales outlet, technical installation, or a site for the exploration or extraction of natural resources. A place or facility shall be regarded as fixed if it is used on a continuous or recurring basis. In the case of a one-off activity, the place or facility in which the activity is carried out shall be considered fixed if the activity exceeds 15 days within a tax period.

Under the amended Act, a permanent establishment shall also include:

• a construction site where the taxpayer’s activity exceeds 15 days during a tax period,
• the provision of services by a taxpayer exceeding 15 days during a tax period,
• a person acting on behalf of a taxpayer with limited tax liability who continuously or repeatedly negotiates, concludes, intermediates, or plays a principal role in concluding contracts,
• an insurance risk located in the Slovak Republic in connection with the activity of a taxpayer with limited tax liability,
• an organisational unit registered in the relevant Slovak register.

With regard to the time condition of exceeding 15 calendar days during a tax period, the criterion is that the taxpayer must perform the activity for at least 15 days, which need not be continuous.

Clarification of the Term “Taxpayer”

To ensure more accurate interpretation and application of the Act, the definition of taxpayer has been refined as follows:

Taxpayer	Type of taxpayer and its criteria
Taxpayer with unlimited tax liability (so-called tax resident)	A legal entity with its registered seat in Slovakia
Taxpayer with limited tax liability (so-called tax non-resident)	A legal entity without its registered seat in Slovakia
	BUT
	Maintains a payment account in Slovakia	Conducts business in Slovakia through a permanent establishment

Based on this amendment, all self-employed – entrepreneurs – are excluded from taxation under the bank transaction tax, without exception or income threshold.

his exemption will apply as of the tax period beginning January 2026.

The original threshold of revenues up to EUR 100,000 has been completely removed from the final version of the amendment. Henceforth, the Act shall apply only to legal entities meeting the above definitions.

• Allocation of a tax bank account

The amendment also clarifies the situation in which a taxpayer has not been assigned a personal taxpayer account for the payment of the financial transaction tax. In such cases, a special payment deadline applies – within 8 days of receipt of the notification from the tax authority.

• Penalties

A significant change introduced by the amendment is the linkage between breaches of obligations under the Financial Transaction Tax Act and the Tax Procedure Code. If a taxpayer executes a financial transaction on a special account that is not subject to taxation, they may be liable to a fine of:

• From EUR 30 to EUR 3 000.

The rule remains that no fine may be imposed after five years from the end of the tax period to which the fine relates. The amendment to the Financial Transaction Tax Act shall enter into force on 1 January 2026.

At the beginning of August, the OECD published a report stating that the first 15 countries had signed the Multilateral Competent Authority Agreement on the Exchange of Information (GIR MCAA). This agreement arises from an international initiative that established global tax rules and the regulatory framework known as Pillar II.

The Slovak Republic is among the first signatories of this agreement. A full list of signatory countries with their respective dates of signature is available on the following website.

What is the GIR MCAA Agreement?

The GIR MCAA (full title: Multilateral Competent Authority Agreement on the Exchange of GloBE Information) is based on Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters and the exchange of information framework.

The purpose of the GIR MCAA is to:

• Introduce additional measures to ensure transparency and prevent tax avoidance by large corporations
• Reduce the possibility of profit concealment
• Prevent tax evasion and the shifting of profits to jurisdictions with low or zero taxation

By signing the agreement, participating countries commit to automatically exchanging certain financial information regarding how large corporations operate and pay taxes within their jurisdictions. The information will be shared uniformly among all countries, ensuring that local authorities receive the necessary data.

A preliminary version of the Commentary on the GIR MCAA, published in January 2025, can be accessed at the following link (note: available in English only).

Who are the Signatories of the GIR MCAA?

The first countries to join the agreement on mutual information exchange include, among others:

• Austria
• Belgium
• France
• Ireland
• New Zealand
• Slovakia
• United Kingdom
• Japan

A complete list of signatory countries with the exact dates of signature is available on the following webpage. Regular updates on international tax developments and transnational legislation can be found in the News section of Moore BDR I News.

In September 2025, The Slovak Parliament approved the 3^rd consolidation package with the aim of further increasing state budget revenues to cover public debt. These consolidation measures underwent an accelerated approval process. The measures will take effect on January 1, 2026.

We bring you an overview of significant measures that will primarily affect employees and employers, as well as individuals – entrepreneurs.

Income Tax Act

The largest part of the consolidation measures again concerns income tax and several tax changes, which we summarize according to the individual topics that are related to:

• Income tax rate

There will be a change in the current income tax rate scheme, which will be adjusted and supplemented with new rates depending on the income (revenues) earned. These rates apply solely to individuals.

Based on this 4 income tax rates will apply from next year:

Income range	Tax rate
Up to EUR 44 000	19%
Over EUR 44 000	25%
Over EUR 60 000	30%
Over EUR 75 000	35%

Still the individual tax rates will be applied to each part of the tax base separately, depending on which exceeds the specified income threshold, rather than to the entire tax base collectively.

• Minimum tax

Effective from the new year 2026, a new minimum tax bracket will be introduced for selected levels of income (revenue) achieved during the tax period.

Turnover	Minimum tax
Up to EUR 50 000	EUR 340
EUR 50 000 – 250 000	EUR 960
EUR 250 000 – 500 000	EUR 1 920
EUR 500 000 – 5 000 000	EUR 3 840
Over EUR 5 000 000	EUR 11 520

• Tax allowance (non-taxable portion of the tax base)

The amendment to the law also changes the threshold for calculating the specific amount of the non-taxable portion of the tax base per taxpayer and the non-taxable portion of the tax base per taxpayer’s spouse. The new thresholds are summarized below:

Type of tax allowance	Current limit	New limit
For taxpayer	Tax base equal to or lower than 92.8-multiple	Tax base equal to or lower than 91.8-multiple
	Tax base higher than 92.8-multiple, the portion corresponding to the difference between 44.2-multiple the minimum subsistence level and 1/4 of the tax base shall apply	Tax base higher than 91.8-multiple, the portion corresponding to the difference between 51.6-multiple the minimum subsistence level and 1/4 of the tax base shall apply
For spouse	Tax base with an assessed amount up to or above 176.8-multiple	Tax base with an assessed amount up to or above 154.8-multiple

In addition, the difference between the multiple of the minimum subsistence level and the tax base is adjusted from 63,4-multiple to 70,8-multiple when assessing the income of the taxpayer’s spouse.

• Taxation of income from players’ payment transactions

The consolidation also introduces a new special tax on income from fees charged by banks to players for payment transactions made via payment cards to player accounts.

Fees collected in this way will be part of the special tax base defined in § 17 of the Slovak Income Tax Act from January 1, 2026.

The special tax base will be taxed at an income tax rate of 54%.

Value added tax

• VAT deduction for company cars

The planned change to VAT deduction entitlement for company cars, which we informed you about in July, has ultimately been postponed to 2026 as part of the consolidation package. According to the final decision, a flat-rate deduction of 50% will apply to company car classified as fixed assets – investment property in the period from January 1, 2026 to June 30, 2028.

This deduction therefore applies to purchased, leased, or acquired motor vehicles in categories M1, L1e, and L3e.

The new rule of a flat-rate VAT deduction of 50% does not apply if the taxpayer acquires a motor vehicle as inventory (in the case of car dealers). The new wording also retains the original condition that the flat-rate deduction also applies to goods and services that the taxpayer purchases for the purposes of the motor vehicle, but also uses the vehicle for private purposes.

• VAT rate on sugar and salt

Also, the classification of containing increased amounts of sugar and salt is being adjusted from the original reduced VAT rate of 19% to the basic VAT rate of 23%. These goods include:

• salty baked goods, pretzels, salty cakes
• muffins, sweets, jam
• sweetened soft drinks
• potato chips / crisps

Goods and products that contain negligible amounts of salt and sugar remain at the original VAT rate of 19%. These include, for example:

• diet foods, whole grain baked goods
• unsalted and unflavoured products
• baby food and nutrition

It remains that the reduced rate applies only to final goods and products intended for direct human consumption, which are listed in a special annex to the VAT Act.

Social security and health insurance

A significant consolidation measure consists of the adjustment of social security and health insurance contributions starting from 2026 for all persons – sole traders, employees, and self-payers.

The most significant change is an increase in the assessment base for social security and health insurance contributions for natural persons who are entrepreneurs, which also proportionally increases the minimum contributions to social security and health insurance.

• Social security contribution (levy)

Type of social security contributor	Current levy rate in 2025	New levy rate in 2026
Self-employer	50%	60% of the average salary for the last 2 years

In addition, social and health levy holidays for sole traders are also changing, and the original one-year deferral of social security contributions is being reduced from 12 months to 6 months. This means that contributions must be paid from the first day of the sixth calendar month after obtaining a business / trade license.

• Health insurance contribution (levy)

In the case of health insurance contributions, this is a blanket increase in contributions of 1%.

Type of health contributor	Current levy rate in 2025	New levy rate in 2026
Employee	4%	5%
Employee with reduced working capacity	2%	2,5%
Self-employer	15%	16%
Self-employer´s employee with reduced working capacity	7,5%	8%

Income compensation during incapacity for work

The amendment to the law introduces the same rules for cases where an employee receives remuneration that is currently not subject to contributions during incapacity for work, maternity leave, or leave taken for nursing care.

From 2026, such remuneration will also be included in the employee’s assessment base for social and health contribution.

In addition, the employer’s obligation to pay the employee’s income during temporary incapacity for work (so-called sick leave) is extended from 10 days to up to 14 days.

Travel Allowance (Meal allowance)

Another consolidation measure allows the Ministry of Finance of the Slovak Republic to operatively change and set special (higher) meal allowance rates for specific groups of employees and selected countries. This will eliminate the difference in countries where food prices differ significantly from the meal allowance set by law.

A blanket change in the meal allowance is not possible due to the need for significant consolidation. This change takes effect on 1 November 2025.

Change in public holidays

An amendment to the Labor Code effective from the new year 2026 regulates the conditions under which an employer may require an employee to work in retail establishments on public holidays, which are also days off work.

These public holidays are as follows:

• 6th January
• Easter Mondary
• 1st May
• 8th May
• 5th July
• 29th August
• 15th September
• 1st November
• 17th November

A temporary amendment to the law on public holidays stipulates that in 2026, 8th May and 15th September will not be public holidays or days off work.

The public holiday of 17 November will be permanently removed from the list of non-working days, which means that for employees, this day will be a normal working day, and employees will no longer be entitled to extra pay for working on a public holiday.

Insurance Tax Act

Another measure is an increase in the insurance tax rate from the current 8% to 10% of the premium received for non-life insurance. This does not apply to motor vehicle liability insurance.

Protection on mineral resources

An amendment to the Act on the Protection and Use of Mineral Resources (known as the Mining Act) introduces an obligation for organizations that have a permit for mining activities and the extraction of primary raw materials to pay fees for the extracted primary raw materials.

The fee applies to the following primary raw materials:

• gravel and sand
• gravel sand
• building stone

The fee is calculated as the product of the quantity of primary raw materials and a rate of EUR 1.35/t. The calculated fee is revenue for the state budget.

Every organization is required to pay the fee:

• that has a designated mining area
• that has obtained mined minerals through deposit exploration
• that has a mining permit or carries out mining activities
• a legal entity or natural person that carries out unauthorized mining of mineral resources

Special levy on collective investment

The Slovak Ministry of Finance has also focused on investment companies, management companies, and supplementary management and pension companies, increasing the special levy on profits from the original 4.36% to 15%.

General waiver of penalties

Slovakia will allow taxpayers to pay tax debts or additional tax liability by filing a tax return without incurring penalties or sanction interest.

This is a general pardon for all taxpayers from the tax office and customs office. This penalty waiver instrument is only valid for the period from January 1, 2026 to June 30, 2026.

The general pardon shall apply to	The general pardon shall not apply to
VAT Income tax Excise tax Motor vehicle tax Insurance tax	Tax prepayments Tax instalments Special levy on business activities in regulated sectors Solidary levy Local tax and municipal waste

The above list contains only a selection of consolidation measures. We would like to point out that we have focused only on measures that are relevant to our readers who are mainly entrepreneurs and companies.

In May of this year, the National Council of the Slovak Republic approved an amendment to the Income Tax Act, which modifies the current rules on the depreciation of selected assets. The purpose of this amendment is to introduce preferential treatment for certain types of assets based on their utilisation. Below, we provide detailed information on the changes that will take effect from 1 January 2026.

According to the amendment, the preferential treatment applies to technical improvements of buildings used for accommodation services or for sporting activities. These provisions are intended to support businesses operating in the tourism and sports sectors.

Technical Improvements Related to Accommodation

The amended Income Tax Act introduces a new category of asset – another depreciable asset. Such an asset is defined as:

• the total cost of technical improvements and repairs carried out on a building classified under Building Classification Code 121, used for providing accommodation services under a rental agreement and associated services, amounting to at least 10% of the building’s acquisition cost

This definition also applies to buildings leased for the same purpose under a tenancy agreement. According to the Building Act, buildings classified under Code 121 include:

• hotel buildings
• other short-term accommodation facilities
• Conditions for Applying Depreciation

The new rules clarify the conditions for entering into an accommodation agreement that allows for the depreciation of buildings and their technical improvements. Such an agreement must specify:

• The client’s right to temporary accommodation
• The agreed duration of the stay according to the purpose of the accommodation (e.g., hotel, hostel, or lodging house)

These requirements are governed by Sections 754–759 of the Slovak Civil Code.

Technical Improvements Related to Sports

Similarly, a new asset category has been introduced in the law for buildings (assets) used for sporting purposes. The definition is as follows:

• the total cost of technical improvements and repairs carried out on a building or structure classified under Building Classification Codes 1265 and 241, used for sporting activities, amounting to at least 10% of the acquisition cost of the building or structure

This definition also applies to leased buildings used for the same purpose. Buildings falling under Codes 1265 and 241 include:

• sport facilities
• Recreational and sports structures, such as sports fields and other related constructions
• Determination of Acquisition Cost

The acquisition cost for sports-related assets is the purchase price, including any costs incurred in acquiring the asset, less any reductions to this price.

For assets acquired as a gift from an individual, the acquisition cost is the value determined at the donor’s side, provided the asset was not part of the donor’s business assets and would not have qualified for tax exemption if sold on the date of donation.

Depreciation Rules

The amended Annex No. 1 of the Income Tax Act adds the following items to Depreciation Group 2 without a specified KP code:

Item	KP Code	Description
2-40	–	Total cost of technical improvements and repairs carried out on a building pursuant to § 22(6)(f)
2-41	–	Total cost of technical improvements and repairs carried out on a building or structure pursuant to § 22(6)(g)

Depreciation requires the adjustment of the depreciation plan for these technical improvements carried out on buildings or structures used for accommodation or sports, over a period of six years, with depreciation calculated separately for each improvement rather than combined with the building or structure.

In addition, the depreciation period for the buildings or structures themselves may be adjusted once they meet the classification and technical improvement conditions:

• maximum depreciation period: 40 years (6th depreciation group)
• minimum period for the 6th group: 20 years

This amendment does not change the classification of the 6th depreciation group but introduces the option to shorten the depreciation period for buildings and structures designated for a specific purpose.

Non-Compliance with Depreciation Conditions

If the conditions for depreciating technical improvements are not met from 1 January 2026, taxpayers must follow the previous rules – i.e., repair costs are included in the acquisition cost of the building or structure and accounted for in its depreciation.

Technical improvements acquired and put into use in 2024 will not be reassessed under the new rules but will continue to be included in the acquisition cost as before.

Further information on tax and accounting matters or articles related to ESG can be found under the News section of Moore BDR I News.

The European Commission has set its focus on a green future and adopted the Clean Industrial Deal State Aid Framework (CISAF). This initiative, resulting in a set of new “green” rules, forms part of the European Union’s policy aimed at strengthening the resilience of the European industrial sector.

The EU prioritises a sustainable future by supporting domestic production, the development of renewable energy sources, and the decarbonisation of energy-intensive industries to ensure sufficient manufacturing capacity.

Scope of the CISAF Framework

The CISAF framework enables companies to access public funding under clear rules and simplified procedures when investing in new clean technologies. It also complements the Guidelines on State aid for climate, environmental protection and energy (CEEAG) and the Guidelines on Regional State Aid, as well as the Net Zero Industry Act.

The CISAF state aid rules focus on five key areas:

• Deployment of renewable and low-carbon fuels
• Temporary relief concerning electricity prices for energy-intensive users (EIUs), aimed at ensuring a transition towards low electricity costs
• Decarbonisation of existing production facilities
• Development of clean technology manufacturing capacity within the EU
• Reduction of investment risks in renewable energy source

Given the structure of its industrial base and renewable energy policy, Slovakia is expected to implement measures in the areas of temporary price relief, decarbonisation, and the development of clean technology manufacturing capacities.

Below we summarise the key features of selected areas likely to be most relevant for Slovak companies.

Measure	Criteria	Requirement
Temporary Price Relief (Electricity Price)	–          State aid must not exceed 50% of the average wholesale market price in the bidding zone to which the beneficiary is connected. –          The maximum limit applies to 50% of annual energy consumption. –          The reduced price must be at least EUR 50/MWh.	The beneficiary must invest at least 50% of the aid received into new or modernised assets.   The aid is limited to a three-year period (until 31 December 2030)
Industrial Decarbonisation	–          The investment payback period must not exceed five years. –          A minimum reduction of 10% in energy consumption must be achieved in decarbonised processes. –          May also apply under the safe harbour provisions.	Aid is granted at a level of 30–60% of eligible costs or according to the funding gap.   The maximum amount of aid must not exceed EUR 200 million.
Development of Clean Technology Manufacturing Capacity	–          Applies to the production of batteries, solar panels, wind turbines, heat pumps, and carbon capture, utilisation and storage (CCUS) equipment. –           Also applicable to the production of critical raw materials.	Aid may be granted either through a scheme (with transparent rules not requiring prior approval by the European Commission) or as individual aid.

Duration of State Aid

EU state aid under the CISAF framework will apply from 25 June 2025 until 31 December 2030.

Although CISAF is binding for all Member States, it allows each country to determine its own mechanisms for implementing the main areas of support. The Slovak Republic has not yet published further details; however, the support scheme for the development of clean technology manufacturing capacities is scheduled to open on 1 January 2026. It is therefore advisable for businesses to focus on the appropriate selection and preparation for the chosen application mechanisms.

Applications submitted before 1 January 2026 will remain subject to the provisions of the previous framework, TCTF (Temporary Crisis and Transition Framework).

With the adoption of the amendment to Act No. 5/2004 Coll. on Employment Services, new fundamental rules governing employers’ notification obligations in Slovakia will enter into force. This obligation applies only to the employment of specific categories of persons.

Further information on employment, including conditions for third-country nationals to obtain work permits or asylum procedures related to employment, can be found under the News section on our website Moore BDR I News.

Persons Subject to the New Notification Requirement

Under the new rules, employers will be required to electronically notify the employment of:

• citizen of a Member State of the European Union,
• family member of such a citizen,
• family member of a citizen of the Slovak Republic,
• national of a third country

Way of Notification

Notification will be possible exclusively in electronic form via the designated form:

• the form shall be prescribed by the Central Office of Labour, Social Affairs and Family,
• it must be signed using a qualified electronic signature,
• notification deadlines:
• within 7 working days from the commencement of employment
• within 7 working days from the termination of employment

All necessary information and the relevant forms are available on the website of the Office of Labour, Social Affairs and Family (Section – Employment / Tab Labour Relations) via the eSlovensko.sk portal.

Other Ways of Notification

As of 1 September 2025, it will no longer be possible to deliver the information card by post or in person. Documents submitted in this manner will not be considered as fulfilling the employer’s obligation. We therefore recommend ensuring that all required online access credentials to the relevant official portals are obtained in advance.

Other Key Changes in Notification Obligations

Temporary Incapacity for Work – Shortened Reporting Period

Effective from 1 September 2025, a shorter period will be introduced for reporting the commencement and termination of temporary incapacity for work (so-called sick leave) for natural persons — within 3 working days from the start or end of incapacity, confirmed by a medical certificate.

This obligation shall apply only until the end of 2025.

Employment Agencies – Digitalisation and Specific Obligations

Employment agencies engaged in temporary work assignments will be required to notify the authorities of the commencement and termination of a temporary assignment within 7 working days. The notification must be submitted electronically and signed with a qualified electronic signature.

These obligations shall take effect on 1 September 2025.

Transitional Provisions for Existing Employment Agencies

Employment agencies that hold valid licences issued before 1 September 2025 must comply with the obligation to report changes in relevant circumstances no later than 30 November 2025.

With respect to the requirement concerning equity of at least EUR 30,000, this condition must be fulfilled by 31 December 2026 (otherwise, the agency risks having its licence revoked).

Under the new rules, it is expressly stipulated that the value of the registered capital is not included in this amount. In practice, this means that agencies must, in addition to their registered capital, possess further resources (for example, retained earnings or other capital funds) amounting to at least EUR 30,000.

While this may represent an increased financial burden for newly established agencies, the measure is intended to prevent the granting of licences to entities lacking sufficient capital backing.

The Slovak Republic has adopted an amendment to the Securities and Investment Services Act in connection with the establishment of a European Single Access Point (ESAP), which provides centralized access to publicly available information on financial services, capital markets and sustainability. The mandatory disclosure of crypto-assets for payment and investment purposes is related to the amendment to the DAC8 Directive.

ESAP is operated by the European Securities and Markets Authority (ESAP), and the transposition will increase administrative requirements for entrepreneurs and public administrations with the aim of better information on products and markets.

• Disclosure of information

The following persons carrying out activities related to securities trading or capital market activities shall submit information to the new European single access point:

Entity	Kind of information
Securities dealer that is part of a financial conglomerate	Description of the legal form, management and organizational structure
Target company whose shares are the subject of a takeover bid	Information on the selection of the competent authority authorized to supervise the takeover bid
Offeror – legal entity or natural person that has taken the decision to make a takeover bid	Notice submitted to the board of directors of the target company and the NBS that it will make a takeover bid Draft takeover bid
Board of directors of the target company	Opinion on the takeover bid, including the opinion of the target company’s employee representatives
Asset manager	Principles of involving asset managers in the exercise of shareholder rights
Voting advisor	Information on the code of conduct and reports on its application and information on the preparation of analyses and advice on models and methodologies (which it applies, what resources it uses, procedures for ensuring risk quality, etc.)
Member of a subgroup	Information on the conclusion of a group support agreement and a description of the general terms and conditions of this agreement
Securities dealer that is not a small and unrelated dealer	Publication of documents other than financial statements through designated media, in particular on the website of the securities dealer
Parent securities dealer	Articles of association and list of shareholders with qualifying holdings in full or in the form of links to equivalent information for a group of securities dealers
Bank (Issuer) of Covered Bonds	The value of the cover pool, the maturity ratio and structure, market risk and other
Bank as Part of a Financial Conglomerate	A description of its legal form, management and organizational structure
Stock Exchange	A current list of its shareholders and members of the stock exchange and any change in its registered capital that results in an increase or decrease in shares

The amendment extends the scope of application to electronic money and digital currencies of central banks. Therefore, the National Bank of Slovakia will also be obliged to make information available:

• information on remedial measures and fines
• information on the type of remedial measure and fine imposed, the nature of the violation, the name and surname, permanent address or business name, registered office and identification number of the person on whom the remedial measure or fine was imposed
• information on appeals filed against the decision to impose a fine
• information on the introduction of compulsory administration over a securities dealer, data on the compulsory administrator and his representative, the termination of compulsory administration over a securities dealer and the related changes are entered in the commercial register

This information will be made available for the first time after January 9, 2030.

The following documents will be made available on ESAP (a “specialized portal operated by the Finance Directorate”):

• ordinary individual financial statements
• extraordinary individual financial statements
• ordinary consolidated financial statements
• extraordinary consolidated financial statements
• auditors’ reports
• individual annual reports
• consolidated annual reports
• annual financial reports pursuant to a special regulation
• sustainability reports and assurance opinion documents
• assurance reports on sustainability reporting

These documents will only be required to be submitted by selected companies (unlike the register of financial statements where all accounting entities submit documents). These are the following companies:

Company	Conditions for submitting reports to ESAP*
Bank (except NBS), reinsurance company and insurance company (except health insurance company)	in each of the two immediately preceding accounting periods it meets at least two of the following conditions: 1.       the total amount of assets exceeded EUR 25,000,000 2.       the net turnover exceeded EUR 50,000,000 3.       the average number of employees during the accounting period exceeded 250	issued securities which are admitted to trading on a regulated market of a Member State and in each of the two immediately preceding accounting periods fulfils at least two conditions: 1.       the total amount of assets exceeded EUR 5,000,000 but did not exceed EUR 25,000,000 2.       the net turnover exceeded EUR 10,000,000 but did not exceed EUR 50,000,000 3.       the average number of employees during the accounting period exceeded 50 and did not exceed 250
Trading company
Subsidiary with a foreign ultimate parent entity	the net turnover based on its consolidated financial statements achieved in the territory of the Slovak Republic and the territories of other Member States exceeded EUR 150,000,000 in each of the two immediately preceding accounting periods
Organizational unit of a foreign entity	in the immediately preceding accounting period, its net turnover exceeded EUR 50,000,000 and the criteria of Condition 2 are also met	a foreign entity is: 1.       a related foreign entity, where the net turnover of its foreign ultimate parent entity in the territory of the European Union exceeded EUR 150,000,000, based on its consolidated financial statements in each of the two immediately preceding accounting periods, or 2.       a foreign independent entity, whose net turnover in the territory of the European Union exceeded EUR 150,000,000, based on its financial statements, in each of the two immediately preceding accounting periods
Parent entity that is a bank (excluding NBS), reinsurance company and insurance company (excluding health insurance company)	in each of the two immediately preceding accounting periods it meets at least two conditions: 1.       the total amount of assets of the parent accounting entity and all its subsidiaries is greater than EUR 30,000,000 2.       the net turnover of the parent accounting entity and all its subsidiaries is greater than EUR 60,000,000 3.       the average calculated number of employees of the parent accounting entity and all its subsidiaries for the accounting period exceeded 250	in each of the two immediately preceding accounting periods it meets at least two conditions: 1.       the total amount of assets of the parent accounting entity and all its subsidiaries is greater than EUR 25,000,000 2.       the net turnover of the parent accounting entity and all its subsidiaries is greater than EUR 50,000,000 3.       the average calculated number of employees of the parent accounting entity and all its subsidiaries for the accounting period exceeded 250
Parent entity that is a trading company

* In selected cases, only one of the two conditions listed above is considered. The detailed examination is based on the interpretation of the Accounting Act.

The ESAP obligations have had the effect of incorporating the filing obligation for public joint-stock companies, banks, and stock exchanges into the Commercial Code, the Banking Act, and the Accounting Act. Detailed information about the ESAP procedure can be found on the European ESAP portal.

The summer months were a time of several brief legal changes that have an impact on employment and income taxation as well as contributions to the state budget. Below we summarise for you a current overview of the brief changes.

You can find out more about other amendments to the tax and business environment on our website – Moore BDR I News.

• Improving the employment of third-country nationals

The government approved the conditions of residence of foreigners intending to improve the possibilities of state authorities and address the current problems and challenges of employers when expire their permits to work in Slovakia.

The most important changes for foreigners concern the following areas:

Area	Change
Validity of national visas	The validity of visas issued to third-country nationals is extended from 90 days to 120 days
Limits for temporary residence applications	Quotas for applications for temporary residence for business purposes are being introduced from 2 years to 4 years (Applicants will have to submit their applications to Slovak embassies abroad, along with a business plan and all documents translated into Slovak by a certified translator)
Change of residence purpose	When changing the purpose of residence to business, a period of 2 years is set for requesting a change due to business activity
Reduction of administration	The obligation to prove the financial security of applicants will be eliminated (only a 3-month bank statement will be sufficient)

Currently employers submit notifications about their employees via post. From September 1, 2025, the obligation to submit notifications via the electronic platform slovensko.sk will be introduced.

• Changes in benefits from guarantee insurance

From July 1, 2025 the maximum benefit of guarantee insurance that the Social Insurance Agency pays to employees in the event of the employer’s insolvency will increase.

The new maximum amount will amount to EUR 4,572, which is higher by EUR 282 than in the previous period (from July 1, 2024 to June 30, 2025 its maximum amount was EUR 4,290).

For insured persons who are already receiving the benefit, the amount of the benefit will not change from July.

• Short-time work and short-time work allowances (so-called Kurz Arbeit)

The parliament finally approved the amendment to the law on support during short-time work in connection with the effects of the introduced American tariffs. The reason for this assistance is unpredictable transnational economic circumstances.

Employers are obliged therefore prove in their application:

• the existence of unforeseen transnational economic circumstances
• reasons for the limitation of activity

The provision and assessment of entitlement is the responsibility of the Central Office of Labor, Social Affairs and Family.

• Exemption of income of a professional surrogate parent

The income of natural persons exempt from tax also includes a financial contribution provided to a professional surrogate parent for the renovation of an apartment or family house in accordance with a special regulation (the Act on Social and Legal Protection of Children and on Social Guardianship).

Simultaneously, this income of a professional parent will not be considered income for the purposes of the assessment basis for the entitlement to sickness benefit pursuant to Section 30 b of Act No. 461/2003 Coll. on Social Insurance.

This change is related to the amendment of the status of a professional surrogate parent who is also in an employment relationship.

The exemption will only apply to income in the following year from 1 January 2026.

• Improving the conditions for filling unattractive positions

The Slovak government has adopted an amendment to the Employment Services Act, the purpose of which is to encourage the permanently unemployed to accept job offers. This intention is related to the tightening of the collection of benefits in material need (which are demotivating for the work environment).

According to the new rules, individuals registered with the labour office who are permanently looking for work or persons who receive material need are obliged to decide to accept the provided job opportunity if:

• according to medical examinations, they are fit to perform work
• they are provided with an adequate job opportunity without the need for significant technical or professional knowledge
• their entitlement to various social benefits is reassessed
• they have been excluded from the register of persons in material need

The advantage for these potential applicants is the entitlement to a commuting allowance (state incentives for commuting to work).

Employers will thus have the opportunity to approach suitable candidates directly through the Employment Service and offer them permanently unattractive positions or permanently vacant positions.

• Indirect introduction of a financial contribution exempts from taxation

With the adoption of the government’s draft law on certain measures to increase the resilience of the Slovak Republic in the field of defence and security, new benefits were incorporated into the Income Tax Act in the form of an incentive contribution and a financial contribution that will be exempt from income for individuals.

This financial and motivational assessment is intended to increase the interest of individuals as well as ordinary employees in participating in reserves that will provide assistance in emergency situations and at the same time will not be able to perform their normal profession.

The incentive contribution will be provided in connection with the inclusion of a citizen or employee in:

• operational
• emergency
• military reserves

The tax-exempt financial contribution under the government bill concerns exclusively:

• fulfilling the tasks of the newly established gendarmerie corps

The amendment to the law will enter into force on July 1, 2025.

At the same time, there have been recent changes related to the following laws

• Amendment to the local development fee

An upper limit for the development fee rate has been set at EUR 5 – EUR 50 for each m2 of floor area of ​​the above-ground part of the building, including any commenced m2.

The above fee change takes into account the increase in prices – since 2016 no inflationary effects have been taken into account in the calculation of the established fee. Therefore, the introduced inflation coefficient will also take into account future fee calculations.

The inflation coefficient will be regularly published by the Ministry of Finance in the financial bulletin for each period according to data from the Statistical Office. The transitional provision establishes the inflation coefficient for 2026 based on the consumer price index for July 2025 compared to July 2024.

The inflation coefficient is calculated as the proportion of:

• the consumer price index for July of the calendar year preceding the calendar year in which this inflation coefficient is to be used, and
• the consumer price index for July 2024, if the generally binding regulation in which at least one rate of the development fee has been adjusted is effective no later than 1 January 2026, or
• the consumer price index for July of the calendar year preceding the calendar year in which at least one rate of the development fee has been adjusted in a generally binding regulation effective after 1 January 2026.

If the inflation coefficient reaches a value lower than 1 – 1 is stated in calculation.

Guidance on the validity of legislation during the transitional period:

The obligation to pay the fee arises by 31 December 2025	Legislation valid until 31 October 2025
Income received until 31 December 2025	Applies as amended from 1 November 2025-1 January 2026
Publication of the inflation coefficient of the Ministry of Finance of the Slovak Republic	After 31 October 20125

The amendment enters into force on November 1, 2025.

• Industrial property regulation

The aim of amending the laws under the jurisdiction of the Industrial Property Office of the Slovak Republic regulating individual subjects of industrial property protection is to introduce legal regulation of the reimbursement of procedural costs incurred by participants in litigation proceedings before this office.

The amendment will proceed to the revision of the rates of maintenance fees and the revision of the rates of administrative fees included in the Tariff of Administrative Fees in Part XVI. Industrial Rights. This change is related to:

• long-term unchanged fees and price increases
• frequent use of certain services by selected groups
• low contribution to the state budget

The amendment to fees was directly reflected in the amendment of several laws, whose provisions on fees and costs of proceedings were amended. These laws are:

• patents and supplementary protection certificates act
• design act
• utility models act
• act on the fee for maintaining the validity of a patent, on the fee for maintaining the validity of a European patent with effects for the Slovak Republic and on the fee for maintaining the validity of a supplementary protection certificate for medicinal products and plant protection products
• trademarks act
• administrative fees act

The above changes in fees and costs will enter into force on 1 July 2025. For older proceedings, the legislation in force at the time of the proceedings shall apply.