Slovakia’s RPVS enjoys an exceptionally good reputation abroad—it is repeatedly cited as a best practice in the area of ownership transparency for companies doing business with the state. From an international perspective, Slovakia is in a strong position: the RPVS serves as a global benchmark. It receives specific positive recognition for the institution of an authorized person with joint responsibility for data accuracy, public access to data, strong sanctions, judicial review of data accuracy, and proven cross-border effect. However, the duality of the two registers—with differing levels of data verification—is at the heart of current international criticism. The solution, however, need not be complicated.
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Proposed Legislative Amendment
Given that registration in the RPVS is conducted under the supervision of an authorized person and meets all the more stringent requirements for verifying the ultimate beneficial owner than the current UBO regime in the Commercial Register, the optimal solution is a legal amendment under which entities registered in the RPVS will automatically fulfill their obligation to register beneficial ownership in the Commercial Register as well. The public sector partner would submit information once, through an authorized person, and this data would simultaneously fulfill both registration obligations.
Advantages of the Proposed Solution
The first advantage is the elimination of duplicate submissions of the same data—the partner registers them once, through an authorized person.
The second is a reduction in the administrative burden and costs for the business without compromising transparency.
The third is an improvement in the quality of data in the Commercial Register: thoroughly verified information from the RPVS is transferred to it with the authorized person bearing full joint responsibility—that is, with a higher standard of verification than that provided by the current self-declaration mechanism.
The fourth benefit is the prevention of discrepancies between registries: the data comes from a source with a higher verification standard.
The fifth advantage is directly relevant to the EC’s criticism: the commercial register receives data that meets the requirements of the new EU AML package (Directive 2024/1640) without additional regulatory burden—without the need to build a new verification system from scratch.
The sixth, systemic advantage is that it reduces the administrative burden and costs for businesses without reducing transparency—a partner registers once, through an authorized person, and the result fulfills both obligations.
Slovakia’s international standing in the area of ownership transparency for companies doing business with the state remains strong despite current challenges. Specifically, the RPVS receives positive ratings for: the institution of an authorized person with joint responsibility for the accuracy of data, which is internationally unique and the model’s strongest argument; public access to data, rare across the EU following the CJEU’s 2022 ruling; strong sanctions (fines up to €1 million, deregistration, ban on participation in public procurement); judicial review of data accuracy; and a proven cross-border effect illustrated by the Babiš/Agrofert case.
This model addresses the main international criticism—the differing quality of data across the two registers—without undermining what makes the RPVS internationally recognized: a strict verification mechanism through an authorized person.
The natural next step, therefore, is to leverage the high quality of RPVS entries for the commercial register as well—by automatically fulfilling the obligation for entities that have already been verified in the RPVS by an authorized person.
