Is “accounting services” listed in your Commercial Register, even though you actually provide IT services, construction work, or other activities? If so, you are an obligated entity under the AML Act and must register in the goAML system by November 30, 2026 —or have this business activity removed from your records. As many as 80% of active limited liability companies (s.r.o.) list “accounting services” as their business activity in the Commercial Register. We recommend that most of them have this entry removed. Here’s how to decide.

What has changed, and since when?

The amendment to the AML Act (Act No. 73/2026 Z. z.) took effect on June 1, 2026. It introduced mandatory registration of all “reporting entities” in the goAML system, which is operated by the Financial Intelligence Unit (FSJ) under the Police Force Presidium. Unusual business transactions have been reported via goAML since January 1, 2025—the FSJ does not accept reports via email or letter.

Two deadlines you need to know:

• Were you already a required entity as of June 1, 2026? You must register by November 30, 2026 (Section 36d(1)).
• Will you become one later (for example, by registering a new business)? You have 30 days (§ 21(2)).

Registration is free of charge. But that doesn't mean it's free—we'll get to that.

Why does this also apply to companies that don't keep accounting records?

This is the point where most business owners get stuck: “I do have it on record, but I’ve never provided this service. So I’m not a taxable person after all.”

In its guidance dated October 14, 2026 (No. PPZ-FSJ2-2026/074347-014), the FSJ explicitly identified this as an incorrect interpretation. In the case of bookkeeping and other “high-risk” trades, the status of a liable person arises solely from the authorization itself —that is, from the entry in the trade or commercial register. Whether you actually carry out the activity is irrelevant.

The guideline is not legally binding, but the FSJ states that it will consider compliance with the law if a business follows the procedure outlined in it during an audit. You would have to defend any contrary interpretation—before the FSJ or in court. For a small business owner, this is an unnecessary risk. Law firms and industry portals also confirm this conclusion; no relevant source claims otherwise.

The FSJ also recommends the following: if you are not currently engaged in a particular business activity and do not plan to do so, bring your registered business activities in line with your actual operations. In other words, delete them.

Quick Check: Does This Apply to My Business?

Don't base your decision on what you actually do. Get a copy of your entry in the Commercial Register or Trade License Register and see what's listed there.

Group 1 – Registration is sufficient; you are automatically required to: maintain accounting records · provide tax consulting · conduct audits · engage in real estate activities (purchase and sale) · currency exchange · factoring and forfaiting · financial leasing · granting of credits and loans · organizing voluntary auctions · freight forwarding, courier, and postal services · financial intermediation · gambling.

Group 2 – the obligation arises only upon the actual performance of specific activities: attorneys, notaries, bailiffs, and—note— the activities of business, organizational, and economic consultants. This activity in and of itself does not give rise to an obligation. What matters is whether, for example, you incorporate companies or conduct real estate transactions for clients. General consulting (business plans, cost analyses) does not require registration with goAML. If you have only “economic consulting” listed, do not delete it unnecessarily.

Group 3 – for transactions of €10,000 or more: real estate brokerage (monthly rent of €10,000 or more), trade in art, antiques, and precious metals.

Group 4 – any business owner conducting a cash transaction of €10,000 or more. In practice, this is rare, since as of January 1, 2026, cash payments exceeding €5,000 between businesses are prohibited.

Who is not affected by this

• An in-house accountant, as an employee of the company, is not a required party. If the company only keeps its own books and does not have a registered business activity for “bookkeeping,” it is not subject to this obligation.
• A limited liability company (S.r.o.) registered solely for “economic consulting,” which neither incorporates companies for clients nor engages in real estate transactions.
• If you are enrolled in multiple high-risk courses, one registration is sufficient—list your primary activity and note the others in the comments section.

Option A: Delete what you don't use (recommended for most companies)

If you do not provide accounting services to clients and do not plan to do so in the next 12 months, there is no point in registering with the FSJ and maintaining AML documentation for an activity you do not perform. Narrowing the scope of your business is a one-time step, and once it is completed, AML obligations related to this line of business no longer apply to you.

A Three-Step Process for Forming a Limited Liability Company (s.r.o.):

1. Resolution of the general meeting (or sole shareholder) to narrow the scope of business.
2. Notification of the termination of business operations in the relevant trade to the Trade Licensing Office. The trade ceases to exist on the date specified in the notification; otherwise, on the day following delivery (Section 57 of the Trade Licensing Act). This is the decisive step: the termination takes effect upon removal from the Trade Register. From that date forward, you are no longer a registered business operator with respect to that trade.
3. Updating the Commercial Register. After deletion from the Trade License Register, the change must also be recorded in the Commercial Register so that the Commercial Register extract reflects the actual situation. Effective August 17, 2026, a new Commercial Register Act (No. 29/2026 Coll.) will take effect; the entry will be made within 2 business days of submission of a complete application—an incomplete application will be rejected outright under the new regulations.

How much does it cost with us: We’ll handle the narrowing of the scope of business for €129 + VAT. The price includes the court fee and the attorney’s fee. We file the petition through the court; the processing time is 6 business days.

Things to watch out for:

• The removal from the Trade Register must take effect before November 30, 2026. The six-day deadline applies to the court. There is no statutory deadline for canceling a business license at the Trade Licensing Office—and the offices will be overwhelmed in November. If you want to be sure, submit your application by mid-November. Preferably today.
• The cancellation has no retroactive effect. If you were a liable party, your liability ceases as of the date of cancellation, not retroactively.
• Review the entire statement, not just the accounting entries. An obligation may also arise from other sources (real estate activities, freight forwarding, loans).
• Real estate services and freight forwarding will be regulated trades as of January 1, 2025. After deregistration, you can only re-register for these trades by demonstrating professional competence. Unregulated trades (such as bookkeeping) can be registered later without any issues.

Option B: Sign up (if you do accounting for clients)

If you are currently providing accounting, tax consulting, or other high-risk services to clients—or plan to do so within the next year—you cannot avoid registration. Here is the six-step process:

1. Where: Ministry of the Interior of the Slovak Republic portal (minv.sk/?IS_goAML) → goAML Web production environment. Select the “Organization” form and the “Obligated Entity” type. The form has 4 tabs: Obligated Entity, Administrator, Attachments, Preview, and Registration.
2. Prepare the required documents in advance: a legal entity must submit a current extract from the Commercial Register in PDF format that is valid for legal purposes (a link to the register or a screenshot is not sufficient); a sole proprietor must submit an extract from the Trade Register or a certificate of business authorization.
3. Fill in the information as shown on the statement: address type “residential,” contact “business,” phone “mobile.” If you do not have a SWIFT/BIC, enter a dash “-.” Do not fill in optional personal information (social security number, ID number).
4. Tips: Turn off your browser’s autofill feature; FSJ Support recommends Microsoft Edge. Select your language before you begin—switching languages will clear the entire form. The form has other issues as well; we’ve reviewed it on behalf of our clients and documented them— you can find instructions and a list of the form’s errors in a separate article.
5. Administrator: Ideally, this should be the person designated within the organization to liaise with the FSJ. Someone must monitor their email—if the FSJ requests additional information and no one responds, the request will remain pending.
6. After submitting the application, you must wait for approval from the FSJ. There is no statutory deadline. You will receive your goAML Reporting Entity ID only after approval. Do not create a second organization.

Is the deadline met upon submission, or only upon approval? Interpretations vary. Submitting a complete application should be sufficient, but the FSJ may deem the initial submission incomplete—and in that case, the November 30 deadline may not be met. The safest approach: have your registration approved before the deadline. Don’t wait until the last week.

What Happens After Registration

Registration is just the first step. A regulated entity—even without a single client—must have:

• a program of its own activities in Slovak, approved by the statutory representative, with a designated contact person for the FSJ (Section 20),
• risk assessment (Section 20a),
• training for employees prior to their start date and at least once a year (Section 20(3)),
• Readiness for the FSJ inspection – by registering, you are voluntarily placing yourselves under supervision,
• If the firm has clients: identification and verification of the client and the beneficial owner; assessment and reporting of unusual transactions; retention of records for 5 years.

That's exactly why "I'll just sign up so I can have some peace" isn't a free option. It's the first step into a process that will cost you time every year.

Decision at a Glance

	Deletion of the Scope of Business	Registration for goAML
Cargo	One-time fee: 129 € + VAT (including court fees and attorney's fees)	0 € for registration
What's Next	Nothing—the AML obligations associated with this business activity end	internal operations program, risk assessment, annual training, FSJ oversight
Time required	Sign the decision; we'll take care of the rest	Filling out the form, preparing documentation, ongoing implementation
Risk Associated with the Due Date	Trade Licensing Office: no statutory deadline—submit as soon as possible	Approval of the FSJ without a statutory deadline – submit as soon as possible
Who is it for?	You do not provide accounting services for clients, and you do not plan to do so within the next 12 months	Do you provide accounting services to clients, or will you be doing so soon?

Our position: If you don't issue invoices for your bookkeeping, delete it. If you ever want it again, you can register it again as a general trade.

What Could Happen If You Do Nothing

Failure to comply with the registration requirement constitutes an administrative offense. The law (Section 33 of the AML Act) provides for a fine of up to €1,000,000 or twice the amount of the unauthorized gain. Failure to have a program of internal controls or a risk assessment may result in a fine of up to €200,000. A managing director may be personally fined up to 10 times their average monthly income from the company. The FSJ will publish its decision on the fine on its website for 5 years, and if noncompliance persists for more than 12 months, it may initiate proceedings to revoke the business license.

The reality is more lenient than the statutory maximums: according to case law , fines in the range of €3,000–15,000 are common for small businesses . Even that, however, is more than it costs to have the business registration canceled—and it’s a fine for a business license you don’t even use.

What to Do Today

Get a copy of your business registry extract. If you see “bookkeeping” or another business activity from Group 1 listed there that you don’t actually perform, have it removed—and don’t wait until the last week of November to do so.

Don't want to deal with this? We'll handle the narrowing of your company's scope of business for €129 + VAT—including court fees and attorney's fees—through the court within 6 business days. Order a change for your s.r.o.

This article does not constitute binding legal advice. If you are unsure whether this requirement applies to your company, please contact us and we will review your statement together. As of November 7, 2026.