Slovakia UBO Register: What AMLD6 Changes by 2027

The UBO register in Slovakia is about to get a serious rewrite, and if you manage entities there, now is the time to look. Slovakia has spent years running beneficial ownership data through a handful of registers, each built for a slightly different purpose. Then along came AMLD6, the EU’s Sixth Anti-Money Laundering Directive, with a firm deadline and firmer expectations. What does that mean for your Slovak companies? Less guesswork, more scrutiny, and a register that finally has to answer to one European standard. Let me walk you through it.

How did Slovakia handle beneficial ownership before?

Slovakia’s rules sit mainly in Act No. 297/2008 Coll. (the AML Act), with the beneficial owner definition tucked into Section 6a. Since 1 November 2018, under Act No. 52/2018 Coll., most companies in the Commercial Register (Obchodný register) have had to record their beneficial owners.

Here’s the catch: that data isn’t public. Only authorities and certain obliged entities can see it. Beneficial ownership has effectively been spread across three registers, each with its own logic:

• the Commercial Register (Obchodný register), where most companies record their owners, but which stays closed to the public;
• the Register of Public Sector Partners (Act No. 315/2016 Coll.), the one genuinely public tool, though it only covers companies doing business with the state;
• the Register of Legal Entities (Act No. 272/2015 Coll.), which carries its own beneficial ownership section.

Three registers, three logics. You can see where the friction comes from.

What is AMLD6?

When people say AMLD6, they usually mean the whole 2024 package, not one text:

• the directive itself, Directive (EU) 2024/1640;
• the AML Regulation, Regulation (EU) 2024/1624;
• the regulation that set up AMLA, the EU’s new Anti-Money Laundering Authority in Frankfurt, running since 1 July 2025.

The split matters. The Regulation applies directly across the EU. The directive has to be written into Slovak law first. That deadline is 10 July 2027. Mark it.

The 2027 timeline

Worth being concrete here, because “the deadline” is easy to nod at and hard to picture. And 10 July 2027 isn’t even a single event: AMLD6’s deadlines are staggered, so some of the work is already behind you and some is still to come.

On 10 July 2027, three things land at once:

• The old rulebook switches off. The 2015 directive (AMLD4, as amended by AMLD5) is repealed, so it stops being the reference point.
• The AML Regulation switches on, directly. From that day, obliged entities across the EU apply the same due diligence, the same beneficial-ownership checks and the same reporting rules, including the 25% test below. Slovakia doesn’t get to interpret them; they apply as written.
• Slovakia’s own law has to be ready. The parts left to national law, the register’s structure, supervisory powers, penalties and FIU cooperation, have to be in force in Slovak law by then.

Put simply, 2027 is the year your Slovak entity data has to be right and current against one European standard, with a regulator that can check it. That’s what you’re actually preparing for.

But the clock started earlier, and two milestones are already behind us. Here is how the dates fall:

• 10 July 2025, already passed. Member States had to guarantee comprehensive access to beneficial-ownership data, including for people with a legitimate interest. The Commission has named Slovakia among the member states that hadn’t fully notified the measures for this, so it’s a live gap, not a hypothetical one.
• 10 July 2026, just passed. The provisions on register access and its exceptions (Articles 11, 12, 13 and 15) fell due.
• 10 July 2027. Main transposition, the Regulation applies, the old directive is repealed. Everything above takes full effect.
• 10 July 2029. The single access point to real estate information (Article 18) follows later.

So 2026 was the year to prepare, 2027 is the year to be compliant, and part of the reform is already overdue in Slovakia. The runway is shorter than the 2027 headline suggests.

Who counts as a beneficial owner?

The definition is being reshaped by two forces: one already in force, one arriving in 2027.

• Slovakia has already widened its own rule. With effect from 15 January 2025, an amendment to the AML Act broadened who counts as a beneficial owner. For a general partnership (verejná obchodná spoločnosť) and a limited partnership (komanditná spoločnosť), every partner now qualifies, whatever the size of their stake. If you manage partnerships there, your existing records may already be out of date. Worth a look before anyone asks.
• From 10 July 2027, a single EU test takes over. Regulation (EU) 2024/1624 sets one definition that applies directly, without waiting for Slovak law. Under Article 52(1), a beneficial owner is anyone holding 25% or more of shares, voting rights or other ownership interest, directly or indirectly. Indirect holdings get multiplied along each chain and added across chains, so split stakes no longer slip through. And under Article 52(2), the Commission can lower the threshold to no less than 15% for higher-risk sectors. One standard, applied the same way from Bratislava to the rest of the Union.

So the test you measure against is shifting: today the Slovak definition governs (including that 2025 widening for partnerships); from 2027 the EU-wide test applies directly across the Union. Re-checking who your beneficial owners actually are is worth doing before the EU test takes over.

What changes for the register itself?

The register has already changed hands, and it is about to change in substance.

• The change of hands has happened. From 1 June 2026, the Register of Legal Entities, and the beneficial ownership data inside it, moved from the Statistical Office to the Ministry of the Interior, following an amendment to Act No. 272/2015 Coll. Administrative plumbing, yes, but the sort of change that quietly alters where you file and who you deal with. File it under “small things that trip people up.”
• The change of substance is coming. Under Article 10 of Directive (EU) 2024/1640, national beneficial ownership registers have to hold richer, better-quality data and connect to the rest of Europe through a central platform. The people running the register also get real teeth: they can verify information, request documents, and carry out on-site checks where needed.

Who gets to look? The legitimate interest question

This is where it gets interesting. Back in November 2022, the Court of Justice struck down blanket public access to beneficial ownership registers in its judgment in Joined Cases C-37/20 and C-601/20, ruling it went too far on privacy.

AMLD6 threads the needle:

• Authorities and obliged entities keep broad access under Article 11.
• Everyone else (think journalists and civil society groups) can apply on the basis of legitimate interest under Article 12, with a verification and mutual-recognition procedure set out in Article 13 and narrow exceptions under Article 15.

For Slovakia, whose commercial-register UBO data has been closed to the public, that’s a real shift in posture.

What should entity managers check now?

No need to panic, but a bit of housekeeping goes a long way. A few sensible moves:

• Confirm your Slovak UBO records still match reality, especially after the 15 January 2025 definition change.
• Re-run the ownership maths for layered structures against the 25% test in Article 52(1), adding split stakes across chains.
• Note the 10 July 2027 transposition deadline and watch for the Slovak implementing law.
• Check where your filings now land after the 1 June 2026 move to the Ministry of the Interior.

None of this is urgent today. All of it is easier done calmly now than in a rush later.

What’s next?

Managing a UBO register update requires detailed planning and full legal awareness. For more insights into processes in other jurisdictions, explore our article, Italy’s UBO Register: New Access Rules and a Path to Reopening.

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