Many clients have noticed that in their company's Commercial Register records, which are publicly available on the website www.orsr.sk, in recent weeks the following signs have been added to the names of partners, shareholders, statutory officers, proxies, etc.:  and/or

These characters indicate whether all "identification data on shareholders, statutory bodies or members of statutory bodies, heads of organisational units of enterprises, proxies, members of the supervisory body, liquidators, receivers and their representatives, heads of enterprises or organisational units of enterprises of foreign legal entities" are entered in the Commercial Register and follow the requirement to amend by 30.09.2022 certain identification data for the aforementioned persons, which have not been registered in the Commercial Register so far.

In practice, these are mainly:

a) the birth numbers of the company's partners or sole shareholder;

b) identification data of foreign natural persons - e.g. managing directors (if they do not have assigned birth numbers, these will most often be passport numbers or identification documents);  

c) identification numbers of legal persons - company's partners or sole shareholder (although foreign legislation may not know and allocate ID numbers, it is advisable to provide analogous identifiers).

In the case of Slovak legal and natural persons, the process should take place automatically by 31.05.2022, i.e. these data should be requested by the Commercial Register itself from the respective Slovak registers, the data should be amended and then the company should receive the notification on completion of the process of amending of the identification data together with the extract from the commercial register in the electronic mailbox without undue delay.

In the case of foreign natural persons or legal entities, the company itself must make the relevant filing. We are therefore currently checking the status of our clients' registrations and, where necessary, we will contact them to request that they provide us with the data that will not be automatically amended by the Commercial Register so that we can make the relevant filing on their behalf.