An entry such as “bookkeeping” (vedenie účtovníctva) in the commercial or trade licensing register is, for many companies, a leftover from the day they were founded. Since 1 June 2026 it is no longer a mere formality. Under the AML Act it can make you an obliged person, even if you do not keep books for anyone. This also applies to Slovak subsidiaries of companies from abroad. Below you can check in a minute whether it applies to your business.
What has changed
The amendment to Act No. 297/2008 Coll. on protection against the legalisation of proceeds of crime (Act No. 73/2026 Coll.) introduced mandatory registration of all obliged persons in the goAML system from 1 June 2026. The system is operated by the Slovak Financial Intelligence Unit (Finančná spravodajská jednotka, FSJ). Under Sec. 5(1)(h) of the Act, an accountant is also an obliged person, meaning any business that has bookkeeping within its scope of business.
According to the FSJ guidance of 14 October 2026, the obligation arises as soon as the authorisation is acquired, regardless of whether you actually carry out the activity. The Act does not provide any threshold based on company size or turnover. The guidance is not legally binding, but it is the FSJ that imposes the fines, so it is worth following.
Does this apply to your business?
Tick the activities that are entered in your commercial or trade licensing register, or that you actually carry out. The result is indicative and shows what it means for you.
Obligations that arise from obliged person status
Registration in goAML
Electronic and free of charge. The obligation follows from Sec. 21(2) and the transitional provision Sec. 36d(1). The FSJ recommends not waiting until the end of the period.
Programme of own activity
A written document, including a risk assessment, approved by the statutory body and updated on an ongoing basis (Sec. 20). It includes designating a person responsible for reporting and communication with the FSJ.
Customer due diligence
Identification and verification of the client, identification of the beneficial owner and risk assessment (Sec. 10). Documentation must be retained for five years after the end of the contractual relationship (Sec. 19).
Training and reporting
Staff training at least once per calendar year (Sec. 20(3)) and electronic reporting of unusual transactions via goAML.
What is at stake if you underestimate it
A breach of the obligations is an administrative offence. For failing to register or to verify a client, the FSJ may impose a fine of up to €1,000,000 or twice the unlawful benefit, if that amount is higher (Sec. 33(1)). For a missing programme or missing training, the limit is lower, up to €200,000 (Sec. 33(3)). In addition, the managing director may be personally fined up to ten times their average monthly income from the obliged person (Sec. 33(4)).
Keep the business activity, or delete it
You carry out the activity or want to keep it
Register in goAML and prepare the programme of own activity. Start keeping client documentation so that, during an inspection, you can show that the checks are actually taking place.
You do not carry out the activity and do not plan to
We recommend applying for the deletion of the activity from the register. The change is not entered immediately, so do not delay and make sure the deletion is entered no later than 30 November 2026.
Frequently asked questions
Do I have to register if I do not actually keep books?
Yes, if it is entered in your scope of business. According to the FSJ guidance, the obligation arises as soon as the authorisation is acquired. The alternative is to delete this activity from the register.
Does this also apply to small companies or companies with no turnover?
Yes. For accountants the Act sets no threshold based on company size or turnover.
Am I an obliged person if I have an in-house accountant?
No, provided you do not have bookkeeping entered in your scope of business. An employee who does the accounting for their employer is not an obliged person. What matters is the registered scope of business, not who in the company does the accounting.
How much does registration in goAML cost?
Registration itself is free of charge. The programme of own activity and client documentation are what require time and preparation.
What if I miss the deadline of 30 November 2026?
Failing to register is an administrative offence for which the FSJ may impose a fine of up to €1,000,000. We therefore recommend preparing the registration well in advance.
The deadline is approaching. Get in touch with us in time.
We will help you assess your business activities, prepare the documents for deletion from the register, register in goAML and draw up the programme of own activity.
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This information is of a general nature and does not constitute legal advice. The interactive tool is indicative and does not replace an assessment of your specific situation. It reflects the legislation and the FSJ interpretation as at 10 November 2026. The Slovak wording of the Act is authoritative.
Sources
Act No. 297/2008 Coll., as amended by Act No. 73/2026 Coll. (in Slovak): https://static.slov-lex.sk/static/SK/ZZ/2008/297/20260601.html
FSJ guidance No. PPZ-FSJ2-2026/074347-014 of 14 October 2026 (in Slovak): https://www.minv.sk/swift_data/source/policia/fsj/kpo/UgoAML.pdf
