VAT registration security is being returned: who will be affected by the changes and when will they apply?
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January 26, 2026
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The Ministry of Finance of the Slovak Republic has prepared another package of measures in the area of VAT, the aim of which is to make tax collection more efficient and limit speculative or fraudulent behavior. The focus of the proposal is reintroduction of financial security for VAT registration for entities assessed as risky. In addition, the rules for deciding on registration are being tightened and the grounds for cancelling registration are being expanded.
Key change: risk subjects and 12-month collateral
The proposal targets entities with so-called. risky background. The Ministry mainly means persons who have had a history of negative tax behavior. Typically, these are situations where:
exist tax arrears,
there was serious violation of tax regulations,
the applicant has already had one in the past VAT registration cancelled ex officio,
or similar behavior occurred in persons connected by property or personnel.
From practice, it is important to understand that the criterion should not only be the "current status" of the applicant, but also his/her tax history – including links to companies he worked for in the past.
Amount of security and form of deposit
The risk entity should be obliged to submit refundable financial security for the period 12 months, within the range of:
from €5,000 to €500,000.
A deposit will be required. within 20 days from the date of delivery of the decision. The proposal envisages two ways:
wire transfer to an account maintained at the State Treasury (in favor of the Financial Directorate of the Slovak Republic),
or unconditional bank guarantee in favor of the tax office.
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What happens to the security deposit during the 12 months?
The security is intended to cover potential VAT arrears. If an arrears arise, the security can be to use for its payment. At the same time, it is true that:
if the collateral is used, it will be continuously supplement back to the amount determined by the decision,
after 12 months will return to the one who composed it, if it was not used to pay the arrears (or the procedure according to the tax code will not apply).
An important practical point is that if a compulsorily registered entity does not deposit a security in the specified amount, can be enforced.
Recording obligation: more documents, more control
In order for the tax administrator to obtain a more detailed picture of the economic activity of risky payers, the proposal introduces the possibility of imposing a so-called. recording obligation.
In practice, this means that the entrepreneur may be asked to submit not only invoices, but also accompanying documentation to the supply of goods and services, for example:
orders, contracts,
delivery notes,
transport or consignment notes,
copies of invoices,
income and expenditure documents,
payment documents and the like.
For companies, this will mainly have an impact on the setup of processes: recording, archiving, and the ability to quickly prove the reality of transactions.
The collateral has already been there once – why is it coming back?
The VAT registration guarantee is not entirely new. It was in effect in Slovakia until 2019, while it was cancelled on the grounds that, according to the analysis of the Financial Directorate of the Slovak Republic has lost its justification.
Currently, the proposal for its return is again "on the table" and is heading for an interdepartmental comment procedure. From a practical perspective, it is important that this is a measure that can significantly affect, in particular:
new companies in groups,
entrepreneurs with a "history" in closed companies,
or businesses with personnel connections to problem entities.
New registration deadlines: 21 days vs. 60 days
The proposal also brings about a change in the procedural deadlines for deciding on VAT registration. It is being introduced two-stage deadline:
within 21 days – if the request is clear and without doubt,
within 60 days – if doubts arise (e.g. whether the applicant is a taxable person or about the veracity of the data).
Within the 60-day period, the office will also be able to process the request to reject, if the applicant fails to prove his/her status.
Special regime for voluntary registration with security
If a voluntary registration requires the submission of a security deposit, the tax office will have always 60 days for a decision. And if the applicant does not deposit the security in full, the application may be rejected within this period. rejected without registration.
Deregistration: more reasons, stricter regime
The proposal tightens the conditions and expands the possibilities when the tax administrator can proceed to VAT ID withdrawal. The reason should be, for example:
repeated issuing of invoices for deliveries that did not actually take place,
or repeated application of VAT deduction from fictitious invoices.
At the same time, a legal presumption of termination of economic activity is introduced in situations where the payer:
does not declare the place of business,
or announces a place designated for delivery only,
or is repeatedly unreachable at the place of business.
In practice, this means that companies will have to more consistently monitor not only invoicing and the demonstrability of performance, but also "formal" requirements - especially communication with the office and real availability at the address.
Effectiveness of changes: two terms
The proposal divides the entry into force into two stages:
from 1. 4. 2026: most changes (verification of registration applications, expanded grounds for cancellation of registration, possibility to impose a recording obligation),
from 1. 1. 2027: key provisions on tax security and the possibility of rejecting voluntary registration due to failure to lodge a security.