Slovakia Fines You €6,000 for an Inaccessible Service — and €30,000 for Not Answering the Regulator
Czechia puts "your service isn't accessible" in its top penalty band. Slovakia puts it in the bottom one. The highest fine in the Slovak act is reserved for failing to hand over documents — and if you fix the accessibility problem, the law says the regulator must not fine you at all.
Quick answer
Slovakia's EAA law (Zákon č. 351/2022 Z. z.) caps fines twice over: every band runs "from €200 to 3% of turnover for the preceding accounting period", subject to a hard euro ceiling that depends on what you did. Failing to make the service accessible, or failing to publish the accessibility information, tops out at €6,000. Procedural failures reach €20,000. The highest ceiling, €30,000, is for failing to cooperate with the supervisory authority. Under § 10(3) the regulator must refrain from fining two of the most basic breaches if you take corrective measures. A separate, much smaller track — €100 to €3,000 — covers media access services under the Electronic Communications Act.
The inverted penalty scale
Put Slovakia and Czechia side by side and they answer the same question in opposite directions.
| Breach | Czechia | Slovakia |
|---|---|---|
| Service doesn't meet the accessibility requirements | ~€400,000 | €6,000 |
| Failure to provide information or cooperate | ~€40,000 | €30,000 |
In Czechia, inaccessibility sits in the top tier and most information and cooperation failures sit in the bottom one. In Slovakia it's the reverse: being inaccessible is the cheapest thing you can do wrong, and stonewalling the regulator is the most expensive — five times more expensive.
Read charitably, that's a coherent policy: Slovakia treats the accessibility failure as something to be fixed rather than punished, and reserves real money for the conduct that stops it being fixed. Read cynically, a Slovak business that quietly ships an inaccessible checkout faces a maximum of €6,000, and only if it also refuses to engage does the number get serious.
What the law says
§ 10(1) lists six offences a service provider can commit, lettered (a) to (f), tracking the duties in § 6(1): ensuring the service is accessible (a), publishing the accessibility information (b), having procedures in place (c), notifying the supervisory authority of non-compliance (d), taking corrective measures (e), and providing information, documentation or cooperation (f).
§ 10(2) then attaches the money — and the double cap is the distinctive part:
« od 200 eur do 3 % obratu za predchádzajúce účtovné obdobie, najviac do výšky 6 000 eur » — for offences under (a) and (b)
« od 200 eur do 3 % obratu za predchádzajúce účtovné obdobie, najviac do výšky 20 000 eur » — for offences under (c) to (e)
« od 200 eur do 3 % obratu za predchádzajúce účtovné obdobie, najviac do výšky 30 000 eur » — for offences under (f)
("from €200 to 3% of turnover for the preceding accounting period, up to a maximum of €6,000 / €20,000 / €30,000")
— Zákon č. 351/2022 Z. z., § 10(2)(a)–(c) (Slov-Lex)
| Offence (§ 10(1)) | Euro ceiling | Turnover above which the euro ceiling binds |
|---|---|---|
| (a) Service not accessible; (b) accessibility information not published | €6,000 | ~€200,000 |
| (c) No procedures; (d) no notification; (e) no corrective measures | €20,000 | ~€667,000 |
| (f) No information, documentation or cooperation | €30,000 | ~€1,000,000 |
Note how the two limbs interact. The 3%-of-turnover figure is not a route to a bigger fine — it's a second ceiling that binds first for smaller companies. A business turning over €200,000 faces a 3% cap of €6,000, so the euro cap never comes into play. Above those thresholds, the euro cap is absolute: 3% of a €50 million turnover is €1.5 million, but the fine still cannot exceed €30,000.
This is the same structural trick Poland uses, and it produces the same result — a regime that looks turnover-linked but is functionally flat for anyone of size.
The provision that switches the fine off
§ 10(3) is the reason Slovakia's low ceilings are not the whole story — in the other direction.
The supervisory authority « upustí od uloženia pokuty » — shall refrain from imposing a fine — for the offences under § 10(1)(a) and (c) where the service provider either (a) takes the corrective measures required under § 6(1)(e), or (b) demonstrates that complying with the obligation would be inconsistent with § 7(1), the fundamental-alteration and disproportionate-burden exemption.
Upustí, not môže upustiť. This is not a discretion the regulator may exercise; it is an instruction. If you fix the inaccessible service, the fine for having shipped it goes away as a matter of law.
Very few member states write that down. Belgium comes closest — Art. XV.62/7 lets officials decide a fine won't be enforced where corrective measures are applied — but that is permissive. Slovakia's is mandatory, and it covers precisely the two offences a good-faith business is most likely to commit: not being accessible, and not having procedures in place.
The practical consequence is stark. For a compliant-minded business, the Slovak exposure for those two offences isn't €6,000 or €20,000 — it's zero, provided you remediate. The €30,000 cooperation tier exists to make sure you don't ignore the letter that gives you that chance.
Two tracks, and the second one is tiny
§ 2(5) carves electronic communications, access to audiovisual media services and "112" emergency communications out of the accessibility act entirely. They're handled by amendments to the Electronic Communications Act (Zákon č. 452/2021 Z. z.), which inserted a new § 145a:
« Regulátor uloží pokutu od 100 eur do 3 000 eur poskytovateľovi služby multimodálneho prístupu »
("The Regulator shall impose a fine of between €100 and €3,000 on a provider of a multimodal access service" that fails to comply with § 60b.)
— Zákon č. 452/2021 Z. z., § 145a
€3,000. For an entire category of services, imposed by a different regulator, under a different act. It's one of the smallest EAA-related penalty ceilings in the Union, and it sits alongside a €30,000 ceiling in the same country for a documentation failure. Micro-enterprises are exempt from the multimodal-access duties altogether.
If you provide media access services in Slovakia, the number that applies to you is not the one in any published "Slovakia EAA fine" figure.
Who enforces it
| Area | Authority | Law |
|---|---|---|
| Consumer services — transport, financial services, e-books, information-society services — and designated products | SOI (Slovenská obchodná inšpekcia, the Slovak Trade Inspection) | Zákon č. 351/2022; products via Act No. 56/2018; general procedure under Act No. 128/2002 |
| Electronic communications, media access, "112" | The Regulator for electronic communications | Zákon č. 452/2021 (Electronic Communications Act) |
| Publicly procured services | Public procurement oversight | § 167 of the Public Procurement Act (§ 10a carves this out of SOI's remit) |
SOI must provide the information under § 8(2)(c) in an accessible format on request.
Has it been enforced yet?
No. SOI's annual report for 2025, published in May 2026, confirms it holds the mandate — « a nad povinnosťami ustanovenými v zákone č. 351/2022 Z. z. o prístupnosti výrobkov a služieb pre osoby so zdravotným postihnutím » — but records no accessibility inspections, findings or fines.
That's a more useful data point than mere silence: the regulator's own report, covering the law's first six months in force, had nothing to report under it.
What this means for your business
Slovakia is one of the clearest cases in the EU where engagement is worth more than perfection. The statutory logic is explicit: fix the problem and § 10(3) removes the fine; ignore the regulator and § 10(2)(c) raises the ceiling fivefold. A business that responds to the first letter, produces its documentation and remediates has an exposure close to nil. A business that doesn't has a €30,000 one — for the non-cooperation, not for the inaccessibility.
Two other things:
- If your turnover is under about €1 million, the 3% limb may be your real ceiling. At €300,000 turnover, for example, the cap in the €20,000 and €30,000 tiers is €9,000, and in the €6,000 tier it stays at €6,000.
- If you provide media access services, you're on the €100–€3,000 track under a different act and a different regulator. Check which one you're in before budgeting anything.
Frequently asked questions
What is the EAA fine in Slovakia?
From €200 up to 3% of the previous year's turnover, capped at €6,000 for failing to make the service accessible or publish the information, €20,000 for procedural failures, and €30,000 for failing to cooperate with the supervisory authority (§ 10(2)).
Why is the fine for being inaccessible lower than the fine for not cooperating?
That's the design. Slovakia treats the accessibility failure as something to be corrected — § 10(3) requires the regulator to refrain from fining it if you remediate — and reserves the largest ceiling for conduct that obstructs correction.
Can the fine really be waived?
Yes, and it isn't discretionary. § 10(3) says the authority upustí — shall refrain — from fining the § 10(1)(a) and (c) offences where you take corrective measures or show the obligation conflicts with the § 7(1) exemption.
Does the 3% of turnover mean big companies pay more?
No. It's a second ceiling, not a multiplier. Above roughly €1 million of turnover the euro caps bind absolutely, so the maximum stays €30,000 however large the company.
Who enforces it?
SOI for consumer services and designated products. Media access services go to the Regulator under the Electronic Communications Act, with a separate €100–€3,000 fine. Public procurement is carved out entirely (§ 10a).
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Official text: Zákon č. 351/2022 Z. z. (Slov-Lex)
- Czechia's EAA fine — the exact inversion, with inaccessibility in the top tier
- Poland's EAA fine — the other regime where a turnover percentage caps rather than raises
