Slovenia Charges Big Companies Double — and Fines the Person in Charge
Austria charges SMEs less. Slovenia charges large companies more — explicitly, in the same sentence, for the same offence. It also fines the individual responsible, personally, from €50. And its service ceilings are roughly a thirteenth of Croatia's, across a shared border.
Quick answer
Slovenia's EAA law (ZDPSI, the Zakon o dostopnosti do proizvodov in storitev za invalide) sets euro bands that vary along three axes at once: what kind of operator you are, how large your company is, and whether you're the company or the named individual inside it. A legal person breaching the e-commerce accessibility rules faces €500–€5,000 — but €1,000–€10,000 if it counts as a medium or large company under the companies act. Products carry the highest band at €3,000–€40,000. The responsible individual is fined separately, from €50 to €4,000 depending on the offence. Eight authorities enforce it, and the law was amended in February 2026 to patch gaps in the original transposition.
Three variables, not one
Most member states scale the fine by what you did. Slovenia scales it by what you did, how big you are, and who you are.
By operator role. Manufacturers, importers and authorised representatives sit in the top products band, €3,000–€40,000 (Art. 34(1)). Distributors and product users sit far lower, at €1,200–€3,000. Sole traders get their own bands throughout — €2,000–€15,000 for the manufacturer tier, €800–€3,000 for the distributor tier.
By company size. This is the distinctive one, and it runs through every service category:
| Service | Legal person | Medium or large company |
|---|---|---|
| Electronic communications (Art. 35) | €500–€5,000 | €1,000–€10,000 |
| Audiovisual media access (Art. 36) | €500–€5,000 | €1,000–€10,000 |
| E-books (Art. 37) | €400–€2,000 | €800–€4,000 |
| Consumer banking (Art. 39) | €500–€5,000 | €1,000–€10,000 |
| E-commerce (Art. 40) | €500–€5,000 | €1,000–€10,000 |
By person. Alongside the company, a responsible individual is fined in their own name: €1,200–€4,000 in the manufacturer tier, €200–€400 for distributors, and €50–€250 across most service categories — including, expressly, a responsible individual within a state body or a self-governing local community.
What the law says
The products band is drafted conventionally:
« Z globo od 3.000 do 40.000 eurov se za prekršek kaznuje pravna oseba, ki v zvezi z… »
("A legal person shall be fined from €3,000 to €40,000 for an offence where, in connection with…")
— ZDPSI, Art. 34(1) (Uradni list RS)
The services bands are where the size rule appears, written into a single sentence so that the two ceilings sit side by side:
« Z globo od 500 do 5.000 eurov se kaznuje za prekršek pravna oseba, z globo od 1.000 do 10.000 eurov pa pravna oseba, ki se po zakonu, ki ureja gospodarske družbe, šteje za srednjo ali veliko gospodarsko [družbo]… »
("A legal person shall be fined from €500 to €5,000 for an offence, and a legal person which under the companies act counts as a medium or large company shall be fined from €1,000 to €10,000…")
— ZDPSI, Art. 40(1)
Compare Austria, where § 36 BaFG cuts the ceiling from €80,000 to €50,000 for micro-enterprises and SMEs. Both countries adjust for size; Slovenia frames it as an uplift for the large rather than a discount for the small. In practice the arithmetic is similar — but the drafting tells you what each legislature thought it was doing.
Art. 41 adds that fast-track misdemeanour proceedings may impose a fine above the statutory minimum — so a fast-track fine isn't automatically the lowest figure in the band.
The numbers are very small — and the border makes that visible
A large Slovenian company running a completely inaccessible online shop faces a maximum of €10,000.
Across the border in Croatia, a service provider committing the equivalent breach faces up to €132,720 — thirteen times more, under the same directive. Slovenia's top products band of €40,000 is likewise well under a third of Croatia's €132,720 manufacturer ceiling.
| Slovenia | Croatia | |
|---|---|---|
| Inaccessible e-commerce service (large company) | Up to €10,000 | Up to €132,720 |
| Non-compliant product (manufacturer) | Up to €40,000 | Up to €132,720 |
| Responsible individual (service breach) | €50–€250 | €2,650–€6,630 |
That gap is the single most useful thing to know about Slovenia. It is not that Slovenia lacks a penalty regime — it has one of the most carefully differentiated in the Union, with bands for every combination of role, size and person. It is that all of those bands are set low.
Personal liability, without the criminal law
Ireland gets attention for putting directors personally on the hook, but it does so through the criminal law — prosecution, conviction, a record. Slovenia reaches the same person administratively. The odgovorna oseba — the responsible individual — is a separate respondent in the misdemeanour proceedings, fined in their own name, with no prosecution required.
The amounts are small (€50–€250 in most service categories). The principle is not: in Slovenia, an accessibility misdemeanour produces a named individual with a personal fine, and it does so through an ordinary inspection process rather than a courtroom.
Eight authorities, with banking split four ways
| Authority | Covers |
|---|---|
| TIRS (Market Inspectorate) | Products, e-commerce, and the general default |
| AKOS | Electronic communications, and now e-books and telecoms compliance under the 2026 amendment |
| Maritime Administration, Civil Aviation Agency, Infrastructure Inspectorate | Transport modes |
| Banka Slovenije, TIRS and the Information Commissioner — jointly | Consumer credit-related banking services |
| Securities Market Agency | Financial-instruments services |
| Banka Slovenije alone | Payment services and e-money |
Consumer banking alone is split four ways, with three authorities acting jointly on one sub-category. For comparison, Croatia manages the same category with two and Italy with one.
Two procedural details worth carrying: under Art. 33 the operator bears the costs of the surveillance procedure where non-compliance is found (sampling itself is free), and under Art. 29 there is a streamlined route for purely formal non-conformities — CE marking, declaration, documentation, identification — that skips the full Art. 27 procedure unless you fail to correct.
The law was patched in February 2026
Slovenia amended ZDPSI eight months after it started applying. ZDPSI-A (Uradni list RS no. 14/2026, 24 February 2026, in force the following day) did not touch the penalties — Arts. 34–41 are unchanged — but it did:
- extend or clarify the scope for self-service terminals, e-commerce services and rail passenger transport, and add definitions for emergency communications and urban/intercity transport;
- add functional performance criteria as an alternative to technical specifications, and require providers to document compliance in their general terms and conditions;
- strengthen real-time text for emergency calls to 112, 113 and 116 000;
- add specific e-commerce requirements covering identification, security and payment functionality;
- give consumer organisations legal standing — a private-enforcement route that did not previously exist;
- designate AKOS for e-books and telecoms compliance (new Art. 32.a) and clarify the rail inspection authority.
The amendment is worth flagging for two reasons. Anyone who assessed Slovenian scope against the 2023 text may have read e-commerce or self-service terminals more narrowly than the law now does — that is no longer safe. And the new consumer-organisation standing is a route that doesn't depend on any of the eight regulators acting.
Has it been enforced yet?
No fines or proceedings have surfaced. With eight authorities running separate misdemeanour processes and no central publication requirement, Slovenia is another market where the absence of reported cases is weak evidence — there is no single place a case would appear.
What this means for your business
- If you're a medium or large company, assume the upper band applies from the outset. The test is the companies act classification, not anything accessibility-specific, so you already know which side of it you're on.
- If you sell products into Slovenia, that's where the real money is: €3,000–€40,000 for manufacturers and importers, four times the service ceiling, plus €1,200–€4,000 for the responsible individual and the cost of the surveillance procedure under Art. 33.
- Re-check your scope against ZDPSI-A, not the 2023 original. If your Slovenian analysis predates February 2026, it was done against an older version of the law.
Frequently asked questions
What is the EAA fine in Slovenia?
It depends on three things. Products: €3,000–€40,000 for manufacturers, importers and authorised representatives; €1,200–€3,000 for distributors. Services: €500–€5,000 for a legal person, doubling to €1,000–€10,000 for a medium or large company. Responsible individuals are fined separately, from €50 to €4,000.
Do large companies really pay more?
Yes, expressly. Art. 40(1) and its equivalents set one band for a legal person and a higher band for a legal person that counts as a medium or large company under the companies act.
Can I be fined personally?
Yes. The odgovorna oseba is a separate respondent, fined in their own name — administratively, with no prosecution required.
Who enforces it?
Eight authorities, led by TIRS. Consumer banking alone is divided between Banka Slovenije, TIRS, the Information Commissioner and the Securities Market Agency.
Has the law changed since 2025?
Yes. ZDPSI-A (24 February 2026) extended or clarified the scope for self-service terminals, e-commerce and rail transport and gave consumer organisations legal standing. The penalties were not changed.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Official text: ZDPSI, Uradni list RS 14/2023 (Uradni list RS)
- Croatia's EAA fine — the same border, thirteen times the ceiling
- Austria's EAA fines — the other size-tiered regime, drafted as a discount rather than an uplift
- Ireland's EAA fines — personal liability, reached through the criminal law instead
