EN 
 
 
OPINION OF THE EUROPEAN CENTRAL BANK 
of 1 July 2008 
at the request of the Slovak Ministry of Labour, Social Affairs and Family  
on a draft decree laying down further detaile d rules on the dual display, conversion and 
rounding of certain prices, payments and other am ounts in the labour law and social security 
sectors on the euro changeover 
(CON/2008/27) 
 
Introduction and legal basis  
On 9 June 2008 the European Central Bank (ECB) received a request from the Slovak Ministry of 
Labour, Social Affairs and Family for an opinion on a draft decree laying down further detailed rules on 
the dual display, conversion and rounding of pric es, unit prices, payments and other amounts on the 
changeover from the Slovak currency to the euro in the fields of (i) wages, salaries and other 
remuneration for work; (ii) reimbursement of travel  expenses; (iii) employment services; (iv) social 
insurance and retirement pension saving, social benefits , social assistance benefits, assistance in material 
need and other social support; and (v) social  services (hereinafter the ‘draft decree’). 
The ECB’s competence to deliver an  opinion is based on Article 105(4) of the Treaty establishing the 
European Community and the first and second indents of Article 2(1) of Council Decision 98/415/EC of 
29 June 1998 on the consultation of the European Ce ntral Bank by national authorities regarding draft 
legislative provisions1, as the draft decree relates to currency matters and means of payment. In 
accordance with the first sentence of Article  17.5 of the Rules of Procedure of the 
European Central Bank, the Governing Council has adopted this opinion. 
 1.  Purpose of the draft decree 
The draft decree, which constitutes secondary legisla tion implementing primary legislation and is based 
on Article 18(10)(a)(3) of Law No 659/2007 Coll. on the introduction of the euro in Slovakia and including amendments to certain laws (hereinaft er the ‘Slovak Euro-Law’), provides for technical 
instructions on the dual display, conversion and r ounding of certain prices, payments and other amounts 
in the labour law and social security sectors. 
 
                                                 
1  OJ L 189, 3.7.1998, p. 42.  
2 2. General observations 
The ECB notes that the draft decree is based on an enabling provision contained in the Slovak Euro-Law 
pursuant to which detailed technical implementing measures may be adopted to facilitate a smooth 
changeover to the euro. The ECB has assessed the Slovak Euro-Law in Opinion CON/2007/432. 
Furthermore, ECB Opinion CON/2008/233 and CON/2008/254 assess the issue of dual display in Slovakia 
in more detail.  
In line with the Commission Recommendation of 10 January 2008 on measures to facilitate future 
changeovers to the euro5, published following adoption of the Slovak Euro-Law, mandatory dual display 
should become effective as soon as possible after offi cial adoption of the irrevocably fixed conversion 
rate between the national currency and the euro by  the Council. The Slovak  Euro-Law provides for 
mandatory dual display to start one month after the conversion rate is adopted , while also allowing for 
voluntary dual display both in advance of and following the mandatory period6. Taking into account the 
Slovak Euro-Law and the Commission Recommendation, the parties concerned should be encouraged to 
apply the draft decree in this regard from the da te of official adoption of the conversion rate. 
 3. Specific observations Article 3(2), Article 10(2), Article  14(2), Article 15(2), Article 18(2), Article 19(2), Article 29(2) and 
Article 43(2) of the draft decree provide for conve rsion of amounts from the euro to Slovak currency 
during the dual display period after the euro intr oduction date and for rounding of these amounts in 
Slovak korunas. The amounts concerned are not monetary  amounts to be paid or accounted for within the 
meaning of Article 5 of Council Regulation (EC)  No 1103/97 of 17 June 1997 on certain provisions 
relating to the introduction of the euro
7 and, they therefore fall outside the scope of application of this 
Council Regulation. Nevertheless, the ECB notes that  the draft decree applies different methodologies 
and practices of rounding which are also inconsis tent with the methodologies and practices currently 
                                                 
2  ECB Opinion CON/2007/43 of 19 December 2007 at the request of the Slovak Ministry of Finance on a draft law on the 
introduction of the euro in Slovakia a nd on amendments to certain laws. 
3  ECB Opinion CON/2008/23 of 30 May 2008 at the request of Národná banka Slovenska on a draft decree laying down 
rules for the dual display of certain prices, payments and other amounts and on a draft decree laying down the number of 
decimal places of certain types of s ecurities for the purpose of rounding by re denomination of their nominal value from 
the Slovak currency to the euro. 
4  ECB Opinion CON/2008/25 of 12 June 2008 at the request at th e request of the Slovak Ministry of Finance on a draft 
decree laying down the scope of prices, payments and other am ounts subject to dual display with regard to the field of 
gambling games and methods of their dual display. 
5  Recommendation 2008/78/EC (notified under document  number C(2007)6912), OJ L 23, 26.1.2008, p. 30. 
6  Article 18(1) of the Slovak Euro-Law reads: ‘The period of dual display during which simultaneous dual display in the 
Slovak currency and the euro is implemented on a mandatory basi s, in the established relevant  scope of prices, payments 
and other amounts and in accordance with  other stipulated rules, shall begin one month following the date when the 
conversion rate is fixed and shall end one year following the euro introducti on date. Voluntary dual display may, under 
the stipulated rules, be implemented more broadly than in  the mandatory scope of dual display; voluntary dual display 
may also be implemented, under the sti pulated rules, outside the mandatory peri od of dual display but from the date of 
fixing the conversion rate at the earliest.’ 
7  OJ L 162, 19.6.1997, p. 1. Regulati on as last amended by Council Regulat ion (EC) No 2595/2000 (OJ L 300, 29.11.2000, 
p. 1). 
3 provided for by specific Slovak laws in the labour law and social security sectors8. As a result, under the 
draft decree different rounding rules will apply to comparable cases and comparable situations will be 
treated differently if addressed by the draft decree or by other laws currently in force in the labour law 
and social security sectors. The ECB would therefore s uggest that either a consistent approach should be 
adopted to the comparable cases govern ed by the draft decree or if different rounding rules are used in 
different but comparable sections of the draft decree,  the rationale for such different approaches should be 
explained. 
Furthermore, it should be ensured that Slovak citizen s are well informed of the change in the current 
arrangements concerning rounding in relation to the euro changeover, as stated in the Commission 
Recommendation.  
 This opinion will be published on the ECB’s website.   Done at Frankfurt am Main, 1 July 2008. 
 
[signed] 
 
The President of the ECB 
Jean-Claude TRICHET 
                                                 
8  For example, Article 19(2) of the draft decree provides th at: ‘During the dual display period after the date of the 
introduction of the euro, the amount of benefit in euro shall,  on conversion at the conversi on rate, be rounded up to whole 
Slovak korunas and shall be displayed in Slovak korunas as well.’ which is in line with the current methodology and 
practice pursuant to Article 116(7) of the Law No 461/2003 Coll. on social insurance, as amended (i.e. rounding up to the 
nearest whole koruna). Contrary to this, for example, Article 3(2) and Article 10(2) of the draft decree provide that wage, 
salary or other payments or travel expenses, respectively,  as an amount ‘[…] shall be rounded to whole Slovak korunas 
so that the total calculated remainder of  the amount which is lower than one half  of one Slovak koruna shall be rounded 
down to the nearest Slovak koruna, and the total calculated re mainder of the amount which is equal to or is higher than 
one half of a Slovak koruna shall be rounded up to the near est Slovak koruna’, while under the current methodology and 
practice pursuant to Article 130(1) of the Law No 311/2001 Coll . Labour Code, as amended, and pursuant to Article 7(7) 
and Article 8(2) of the Law No 283/2002 Coll. on travel ex penses, as amended, amounts are rounded up to the nearest 
whole Slovak koruna.