Despite initial success and exceptionally favorable international reviews, serious problems have accumulated over the years. Organizations that long cited the Slovak model as a benchmark are now pointing out systemic flaws. From its position as a European pioneer in 2015, Slovakia has found itself in 2024 facing serious criticism—from the very same institutions that once held it up as a model.
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European Commission (2024): Criticism of the Implementation of the AML Directive
In 2024, Slovakia faces serious criticism from the European Commission due to shortcomings in the implementation of the Anti-Money Laundering Directive. According to the assessment, the current absence of a fully functional register of beneficial owners that meets EU requirements poses a significant risk to the integrity of the Slovak financial system.
This criticism primarily concerns the second—parallel—register of beneficial owners in the Commercial Register, not the RPVS itself. However, it highlights a systemic problem: the duplication of the two registers leads to inconsistent data quality. The RPVS requires verification by an authorized person who shares responsibility for data accuracy, while the registry within the Commercial Register is based on the principle of self-declaration—and it is precisely this difference that lies at the heart of the EC’s criticism.
Open Ownership: Gradual Erosion of Mechanisms
Open Ownership highlights the gradual erosion of transparency mechanisms. From its position as a European pioneer in 2015, Slovakia has found itself facing serious criticism in 2024. Shortcomings in the quality and completeness of recorded data—especially for companies with potential ties to foreign entities—undermine the effectiveness of the entire system. This erosion is all the more paradoxical given that the RPVS itself—with its authorized person mechanism—continues to function as a rigorous verification system. The problem is not the RPVS, but its limited scope.
In its analysis *Beneficial Ownership Transparency in Slovakia — Analysis of Current Developments and Major Needs* (2024), the IDFI (Institute for Development of Freedom of Information) maps the current state of affairs and identifies the system’s key needs. The analysis confirms that despite its initially strong position, Slovakia currently faces challenges related to the quality and completeness of recorded data, identifying the existence of two registers with different verification standards as the key problem.
Open Cases: Gaps the System Cannot Close
Specific cases such as Váhostav or Pavol Gašpar—and other cases of complex cross-border structures documented by Open Ownership—illustrate that there are still ways to circumvent legal requirements—particularly through complex cross-border structures, trusts, and nominee owners. The RPVS has not eliminated them; it has merely narrowed the space in which they operate unnoticed.
These shortcomings have a historical context. In its study How to Make Beneficial Ownership Register Work (2017), Transparency International Slovakia analyzed the functioning of the first registry (at the Public Procurement Office) between 2015 and 2017. Main concerns: declarations by ultimate beneficial owners did not have to be supported by any official documentation, and the register was not linked to the commercial register. It was precisely these shortcomings that led to the creation of the RPVS with the institution of the authorized person in 2017. The current situation is paradoxical: the mechanism intended to address these issues functions well within the RPVS—yet its coverage does not extend to the entire economy, creating a systemic gap that requires a legislative solution.
