Any company or sole trader that wants to receive public funds above the statutory threshold — a one-off payment exceeding EUR 100,000, or recurring payments totalling more than EUR 250,000 in a calendar year — or that signs a contract with the Slovak state or a municipality, must be entered in the Register of Public Sector Partners (RPVS). Without a valid entry the public-sector counterparty may not pay, and the company faces a fine of up to the benefit it received. You never file the entry yourself; it is always done through an authorised person.
What is the Register of Public Sector Partners?
The Register of Public Sector Partners was introduced by Act No. 315/2016 Coll., in force since 1 February 2017 and often called the anti-shell-company act. It is a publicly accessible list of individuals and legal entities that do business with the state or otherwise draw on public money, together with details of who really stands behind them. The aim is transparency: for every entity receiving public funds there must be an identifiable person — the beneficial owner.
The register is administered by the Ministry of Justice of the Slovak Republic and entries are made by the registering authority, the District Court in Žilina. Anyone can inspect it free of charge via the justice.gov.sk portal. This obligation is distinct from recording the beneficial owner directly in the Commercial Register — two separate records with different scope and purpose, distinct again from routine corporate steps such as changing the registered seat of a Slovak s.r.o.
When must a company register?
The decisive factor is the amount of public funding. You must register if a single contract brings you a one-off payment above EUR 100,000, or if recurring payments total more than EUR 250,000 in a calendar year. This applies above all to public procurement, subsidies, EU funds, acquisition of state or municipal property, and to reimbursements from public health insurance above these limits.
The entry must be effective before the contract is signed or the payment is made — a public buyer may not pay an entity that does not appear in the register. The obligation may also fall on a subcontractor whose share of the contract exceeds the same limits. Example: a construction firm that wins a municipal tender worth EUR 180,000 must be registered before the contract is signed; otherwise the municipality cannot pay even the first invoice.
Who is the authorised person and why can’t you register yourself?
You cannot file the entry directly. The law entrusts it to an authorised person: an attorney, notary, bank, auditor or tax advisor with a seat or place of business in Slovakia. You conclude an agreement with the authorised person, who then prepares and files the registration proposal, identifies the beneficial owner and draws up a so-called verification document.
The authorised person is not a mere administrative intermediary — they are liable for the accuracy of the beneficial owner’s identification and face the same fine as the partner in the event of a false entry. That is precisely why they scrutinise the ownership structure — much like the review a buyer runs during due diligence before buying a company — along with the articles of association and statutory representatives’ declarations.
Who is the beneficial owner?
The beneficial owner is always a specific individual who actually owns or controls the company. Typically it is a person with a direct or indirect share of at least 25% of the registered capital or voting rights, or with a right to at least 25% of the economic benefit from the business. If no such person can be determined, the members of senior management are treated as the beneficial owners.
The identification is always verified by the authorised person, who must be able to defend it with documents rather than a mere declaration. Responsibility for the accuracy of the data is a key issue for statutory bodies and overlaps with the wider question of directors’ liability when keeping company records.
What penalties apply for non-compliance?
The sanctions for breaching the RPVS rules are among the strictest in Slovak commercial law. If a partner states false data about the beneficial owner or fails to register, it faces a fine equal to the economic benefit obtained from public funds. If that benefit cannot be quantified, the fine ranges from EUR 10,000 to EUR 1,000,000. A separate fine of EUR 10,000 to EUR 100,000 may be imposed on members of the statutory body, who are personally liable for it.
On top of the monetary penalty comes deletion from the register and a ban on re-registration for up to two years, which effectively bars the firm from public contracts. The counterparty may also withdraw from the contract or suspend performance. The combined effect of these consequences usually far exceeds the cost of a proper and timely entry.
How does registration work and what must be monitored?
Registration is electronic and the authorised person files it with the registering court together with the verification document. Good news for the budget: the registration proposal is exempt from court fees, so you pay only the fee agreed with the authorised person. Registration should not be treated as a one-off event — ongoing maintenance follows.
The authorised person must re-verify the beneficial owner later too: on every change in the ownership structure, as at 31 December each calendar year, and before performance under more significant contracts. Any change must be reflected in the register in good time, otherwise the partner risks the same sanctions as for the initial failure. Businesses that deal with the public sector regularly are best served by a long-term relationship with an authorised person.
STEINIGER | law firm — before signing a contract with the public sector it pays to have the ownership structure and the identification of the beneficial owner reviewed in advance, so that the entry in the register holds up and the company does not lose the contract over a formal defect.
Are you preparing to bid for a public contract or a subsidy and need your entry in the Register of Public Sector Partners done correctly and on time?
FAQ
Who must register in the Register of Public Sector Partners?
Any individual or legal entity that receives public funds above the limit or signs a contract with the state or a municipality must register. The limit is a one-off payment above EUR 100,000 or recurring payments totalling more than EUR 250,000 in a calendar year. The obligation may also fall on a subcontractor whose share of the contract exceeds these amounts. The entry must be effective before the contract is signed.
How much does RPVS registration cost?
The registration proposal itself is exempt from court fees. You therefore pay only the fee to the authorised person — an attorney, notary, auditor, bank or tax advisor — who prepares the entry and identifies the beneficial owner. The amount depends on the complexity of the ownership structure and is a matter of agreement. You should also budget for ongoing maintenance and the annual re-verification of the entry.
What happens to a company that fails to register or files false data?
The partner faces a fine equal to the economic benefit obtained, and if that cannot be quantified, from EUR 10,000 to EUR 1,000,000. Members of the statutory body may be personally fined between EUR 10,000 and EUR 100,000, for which they are liable. Deletion from the register and a ban on re-registration for up to two years follow, cutting the firm off from public contracts. The counterparty may withdraw from the contract.