Legislation and amendments · October 6, 2026 · 12 min read
goAML registration: what you must complete by 30 November 2026
If you keep accounts, advise on taxes, broker property or set up companies for clients, Slovak law treats you as an obliged entity. Since 1 June 2026 you have a new duty: to register in the goAML information system. The deadline is 30 November 2026, and it applies to a one-person trade just as much as to an office of sixty.
This is a practical guide. It covers who has to register, what to prepare, how the process runs, what the penalties are, and what else the amendment changed — including one obligation whose deadline has already passed.
What goAML is and why you cannot avoid it
goAML is the information system through which reports of unusual business transactions are submitted to the Financial Intelligence Unit of the Police Force (Finančná spravodajská jednotka). The system was developed by the United Nations Office on Drugs and Crime and is used by several countries; in Slovakia the Financial Intelligence Unit operates it.
What matters is the new wording of § 17(2) of Act No. 297/2008 Coll. A report of an unusual business transaction is submitted through this system — another form is possible only if the system is down, and even then it must be an electronic form that keeps the information confidential.
In other words: without registration you have no way to meet the reporting duty. And that duty does not announce itself in advance — it arrives with a particular client.
Who has to register
Obliged entities are listed in § 5 of Act No. 297/2008 Coll. Alongside banks and financial institutions, the list covers professions whose only connection to money laundering is that they see into their clients' money:
Who | Provision | Note |
|---|---|---|
Second-hand shops, pawnshops, auction houses and licensed auctioneers, dealers in works of art, collectors' items, antiques, cultural monuments, precious metals and precious stones | § 5(1)(m) and (b) point 13 | For art, antiques and precious metals the duty applies from a transaction value of EUR 10,000, including several linked transactions |
Operators of games of chance | § 5(1)(d) |
|
Accountants, auditors, tax advisors and others providing tax advice | § 5(1)(h) | Applies to outsourced bookkeeping and to sole traders alike |
Brokering the sale, lease and purchase of real estate | § 5(1)(i) | For leases only where the monthly rent is at least EUR 10,000 |
Attorneys and notaries | § 5(1)(j) | Only for defined acts — buying and selling real estate or a business, managing assets, opening accounts, forming and running companies |
Providers of trust or company services | § 5(1)(k) | For example providing a registered office or supplying directors |
Organisational and economic advisors, freight forwarding, public carriers and messengers | § 5(1)(l) | For defined activities |
Creditors, postal undertakings, court enforcement officers, insolvency trustees | § 5(1)(e) to (g) and (n) |
|
Anyone who carries out a cash transaction of at least EUR 10,000 | § 5(3) | Even if they are not otherwise an obliged entity. It makes no difference whether it is one transaction or several linked ones |
If you do business in any of these areas, the status of obliged entity arises by operation of law. Nobody has to notify you of it, and it does not depend on how many clients you have.
The last row is the one most people miss. Under § 5(3) an entrepreneur who is not on the list at all becomes an obliged entity simply by accepting a cash payment of at least EUR 10,000. That covers a car dealer, a construction firm or a second-hand shop that never expected to deal with AML at all.
Deadlines: who and by when
Situation | Deadline | Provision |
|---|---|---|
You were an obliged entity on 1 June 2026 | by 30 November 2026 | § 36d(1) |
You became one later | within 30 days of becoming one | § 21(2) |
Trustee of a foreign trust | by 30 November 2026 | § 36d(2) |
The 30-day deadline matters for new companies. If you set up a company today with bookkeeping as its business activity, the clock starts on its own.
What to prepare before registering
Registration is not something to squeeze in between two phone calls. Have ready:
- Identification details of the organisation — name, registered office, company number, business activity.
- Details of the person who will administer the goAML account. Usually whoever is responsible for AML matters.
- The designated responsible person under § 20(2)(h) — the person who ensures compliance, reports unusual transactions and keeps ongoing contact with the Financial Intelligence Unit. If that is not a statutory officer, it must be a senior employee.
- Attachments the system asks for to verify the organisation and its administrator.
- Your own activity programme, if you do not have one yet. It is not a condition of registration, but it is the first thing an inspection will want to see.
Registration step by step
- Open the goAML portal on the website of the Ministry of the Interior of the Slovak Republic and choose Register.
- Select the registration type obliged entity. The system distinguishes several categories; the wrong choice means submitting the application again.
- Fill in the registration form. It is split into several tabs and covers details of the organisation as well as of the account administrator.
- Attach the required documents.
- Submit the application. The system confirms receipt and notes that the application is awaiting approval by Financial Intelligence Unit staff.
- Wait for approval. Once granted, the e-mail addresses you provided receive a notice with the organisation's identification details, including the unique goAML Reporting Entity ID.
A detailed user manual with screenshots is published on the Ministry of the Interior website. Technical support is available at goaml.support@minv.sk.
Expect approval to take some time. That is exactly why it is not worth leaving registration to the last week of November — if the application is incomplete, you will be supplementing it while the deadline keeps running.
What follows registration
Registering does not end your obligations; it opens the channel through which you will meet them. Once the account is approved:
- Build goAML into your activity programme. The programme must be in writing, in the state language, adapted to your size and business activity, and approved by the statutory body (§ 20(1)). It must also set out the procedure from identifying an unusual transaction to reporting it without delay.
- Arrange training. Under § 20(3) you must arrange it at least once every calendar year and always before assigning an employee to work involving duties under the Act.
- Set up your record keeping. Data, documents and records of procedures are kept for five years from the end of the contractual relationship with the client or from carrying out the transaction (§ 19(2)).
What else the amendment changed
Registration in goAML is the most visible change, but not the only one. Three others affect everyday practice:
A register extract is no longer enough to verify a beneficial owner. Under the new wording of § 10(1)(b), when verifying information about a beneficial owner you may not rely on data obtained solely from the register of legal persons. Verification must draw on reliable sources and follow a risk-based approach. If you have been filing a register extract and considering the matter closed, that is no longer sufficient.
Members of the management body are now identified too. § 7(1)(b) has been supplemented to require the names and surnames of the members of the management body of a legal person or an asset pool.
A register of foreign trusts has been created. The new § 24c establishes a register maintained by the Ministry of the Interior. Applications are filed at any district office in a regional seat; the administrative fee is EUR 100 for entry and EUR 25 for a change of data. For failing to comply, a district office may impose a fine of up to EUR 1,000.
An earlier deadline — 30 September 2026
The amendment also reached the Trade Licensing Act. Under the new wording of § 9 of Act No. 455/1991 Coll., a legal person whose beneficial owner is not of good repute may not hold a trade licence for:
- brokering the sale, lease and purchase of real estate,
- bookkeeping,
- supplying persons acting as a statutory body and similar positions for other legal persons,
- providing a registered office, an address for service and related services.
Transitional provision § 80at required a legal person whose trade licence arose before 31 May 2026 to bring its legal relationships into line by 30 September 2026.
That deadline has therefore already passed, while the registration deadline is still running. If it slipped past you, that is no reason to wait — the sooner the position is put right, the better, and in any inspection it matters that you can show when and how the shortcoming was remedied.
Penalties: what is at stake
The registration duty sits in § 21, and § 21 is among the provisions listed in § 33(1). This is not a formal slip with a formal fine.
For what | Imposed by | Amount |
|---|---|---|
Breach of duties under § 10(1) to (4) and (6), § 12, § 14 to 17, § 19(2) to (4), § 21, § 24(1) and (2) | Financial Intelligence Unit | up to twice the unlawful benefit, or up to EUR 1,000,000 — whichever is higher |
Other duties under the Act | Financial Intelligence Unit | up to EUR 200,000 |
Personal liability of a member of the statutory body, supervisory board, management body or a procurator | Financial Intelligence Unit | up to ten times the monthly average of their total income from the obliged entity over the preceding 12 months |
Breach of duties concerning the register of foreign trusts | District office in a regional seat | up to EUR 1,000 |
In setting the amount, the authority takes account of the seriousness, the duration of the unlawful conduct and its consequences, the level of cooperation during the inspection, the size and nature of the business, and whether the breach is repeated (§ 33(5)).
The upper limit is set for the full range of obliged entities, banks included, so a small accounting office will not realistically face a million euros. That does not change two things: the fine can reach a statutory officer personally, and it may be imposed within three years of the day the Financial Intelligence Unit discovered the breach, and at the latest within seven years of the day it occurred (§ 33(6)).
Five mistakes we see most often
- "This does not apply to us, we are small." Being an obliged entity depends on your business activity, not your size. A one-person trade in bookkeeping is an obliged entity just as an office of sixty is.
- Registering without an activity programme. The programme is a separate duty and tends to be the first thing an inspection asks for. Registration without it is half the job.
- A responsible person designated on paper only. If the responsible person is not a statutory officer, it must be a senior employee. A name typed into a document nobody has opened will not survive an inspection.
- Verifying a beneficial owner from a register extract. After the amendment that is not enough, and it is an easy change to miss because it has no deadline of its own.
- Training done once and for all. The Act says at least once every calendar year and always before assigning a new person to work involving duties under the Act.
Frequently asked questions
Do I have to register even if I have never filed a report?
Yes. The registration duty stands on its own and does not depend on whether you have ever come across an unusual business transaction. The point is the opposite — to have you registered before you do.
I am a sole trader and keep accounts for a few clients. Does this apply to me?
Yes. § 5(1)(h) refers to an accountant regardless of legal form or number of clients.
An external firm keeps our accounts. Do we have to register?
The status of obliged entity belongs to the firm that keeps accounts for others — your supplier, not you as its client. If you yourself provide any of the services listed in § 5, that is assessed separately.
What if I miss the 30 November 2026 deadline?
The duty does not disappear; a breach falling under § 33(1) is simply added to it. If you have missed the deadline, the best thing you can do is register as soon as possible and document when and how you remedied the shortcoming — cooperation is one of the criteria for setting the amount of a fine.
Is online training enough to meet the training requirement?
The Act does not prescribe a form. What matters is that the training addresses your own activity programme, that it takes place at least once every calendar year, and that you can show who completed it and when.
Who approves the registration and how long does it take?
Applications are approved by Financial Intelligence Unit staff. The Act sets no deadline for approval, so allow a margin and do not leave registration to the final days.
How to meet the rest of your AML obligations
Registering in goAML is one step of several. Alongside it you need an activity programme, a designated responsible person, risk assessment in place, working verification of beneficial owners, and annual training you can evidence.
Training under § 20(3) tends to be the easiest thing to forget — it has no deadline of its own in the calendar and makes itself felt only during an inspection.
That is why we have prepared an online AML course for entrepreneurs and obliged entities. It is training under § 20(3) of Act No. 297/2008 Coll., with a test, a certificate and confirmation for the company. It has 71 lessons, 480 minutes in total, you take it at your own pace, and it costs EUR 24.38 excluding VAT.
Sources: Act No. 297/2008 Coll. as in force from 1 June 2026 and Act No. 73/2026 Coll. (slov-lex.sk); the goAML information system and the user manual for obliged entities (minv.sk). Position as at 30 September 2026.
This article is for information only and does not replace legal advice. Responsibility for complying with Act No. 297/2008 Coll. rests with the obliged entity.
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