EN 
 
 
OPINION OF THE EUROPEAN CENTRAL BANK 
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 th e number of decimal places of certain types of 
securities for the purpose of rounding by redenom ination of their nominal value from the 
Slovak currency to the euro 
(CON/2008/23) 
 
Introduction and legal basis  
On 6 May 2008 the European Central Bank (ECB) received a request from Národná banka Slovenska 
(NBS) for an opinion on a draft decree laying down cer tain rules for the dual display of certain prices, 
payments and other amounts in the banking, capital ma rket, insurance industry and pension saving sectors 
(hereinafter the ‘first draft decree’) and on a draft decree laying down the number of decimal places of certain types of securities for the purpose of rounding by redenomination of their nominal value from the Slovak currency to the euro (hereinafter the ‘second 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 provisions
1, as the first and second draft decrees (hereina fter collectively the ‘draft legislative 
provisions’) relate to currency matters and means of payment. In accordance with the first sentence of 
Article 17.5 of the Rules of Procedure of the Europ ean Central Bank, the Governing Council has adopted 
this opinion. 
 1.  Purpose of the draft legislative provisions 
The first draft decree provides for dual display and ot her rules to convert certain amounts in the banking, 
capital market, insurance industry and pension savi ngs sectors and is based on Article 18(10)(a)(2) of 
Law No 659/2007 Coll. on the introduction of the euro in Slovakia and including amendments to certain 
laws (hereinafter the ‘Slovak Euro-Law’). The sec ond draft decree provides for rounding rules for certain 
types of securities and is based on Article 15(9) of the Slovak Euro-Law. The purpose of both draft 
legislative provisions is to implement the Slovak Eu ro-Law to facilitate Slova kia’s smooth changeover to 
                                                 
1  OJ L 189, 3.7.1998, p. 42.  
2 the euro. 
 
2. General observations 
The ECB welcomes the draft legislative provisions as important preparatory measures for the eventual 
introduction of the euro in Slovakia. The ECB notes that both draft legislative provisions are based on 
enabling provisions contained in the Slovak Euro -Law providing for a possibility to adopt detailed 
technical implementing measures to facilitate the smoo th changeover to the eu ro. The ECB has assessed 
this Law in Opinion CON/2007/432. 
In light of Commission Recommendation of 10 January 2008 on measures to facilitate future changeovers 
to the euro3, published after adoption of the Slovak Euro-Law, the ECB notes that mandatory dual display 
should start as soon as possible after the Council’s offi cial adoption of the irrevocably fixed conversion 
rate between the national currency and the euro. The Slovak Euro-law provides that mandatory dual 
display shall start one month after the conversion rate  is fixed, allowing also for voluntary dual display 
outside the mandatory period4. In view of the Slovak Euro-law and the Commission’s recommendation, 
the parties concerned should be encouraged to apply the draft legislative provisions in this regard from 
the day of fixing the conversion rate. 
 3. Specific observations on the first draft decree on dual display of certain amounts in financial 
markets and financial institution services in certain sectors 
Rounding rules Article 9 of the first draft decree provides: ‘Whe n converting insurance amounts from the Slovak koruna 
to the euro, the converted sum may be rounded up to the whole euro, whereby the whole euro means euro 
without cent.’  Even though the established method of rounding  is not mandatory and may be interpreted 
as being in favour of the final beneficiary in line with  Article 2(4) of the Slova k Euro-Law and its general 
principles, the ECB notes that an insurance amo unt is pursuant to Article 5 of Regulation (EC) 
No 1103/97
5 an amount to be paid or accounted for thus be ing rounded up or down to the nearest cent and 
therefore Article 9 of the first draft decree s hould be aligned with Regulation (EC) No 1103/97. 
 
                                                 
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  OJ L 23, 26.1.2008, p. 30. 
4  Article 18(1) of the Slovak Euro-Law: ‘The period of dual  display during which the 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 stipulated rules, outside the mandato ry period of dual display but from the 
conversion rate fixing date at the earliest.’ 
5  Council Regulation (EC) No 1103/97 of 17 June 1997 on certa in provisions relating to the introduction of the euro 
(OJ L 162, 19.6.1997, p. 1). Regulation as amended by Regulation (EC) No 2595/2000 (OJ L 300, 29.11.2000, p. 1). 
3 4. Specific observations on the second draft d ecree on rounding rules and redenomination of 
certain types of securities 
Rounding rules Article 1 of the second draft decree provides: ‘In respect  of redenomination of the nominal value of equity 
securities, except for fund shares, from the Slovak koruna  including the halier … to the euro including the 
cent …, the number of decimal places for the purpose of rounding the nominal value of one security shall be maximum four decimal places.’ Redenomination of the nominal value of all types of securities must comply with the principles and rules provid ed for by Article 2 of the Slovak Euro-Law
6, which is aligned 
with Regulation (EC) No 1103/97, Regulation (EC) No 974/987 and the case-law of the Court of Justice 
of the European Communities8. The Slovak Euro-Law distinguishes between (a) amounts in euro which 
are paid or accounted for (hereinafter the ‘cash final amount’) rounded to a number with two decimal 
places9; and (b) non-cash final amounts, which may be r ounded to a higher number of decimal places thus 
ensuring the appropriate level of accuracy10. 
The ECB questions the different method of rounding applying to the nominal value of equity securities 
pursuant to Article 1 of the second draft decree (four d ecimal places), on the one hand, and to the nominal 
value of mutual fund shares pursuant to Law No 594/2003 Coll.11 (six decimal places), on the other, since 
both nominal values can be considered as non-cash final amounts. In this case it appears that the principle 
of price neutrality and of the continuity of legal inst ruments is not precisely followed, thus substantially 
differing from Article 2 of the Slovak Euro-Law. The ECB therefore recommends ensuring that the same 
rounding method is used in draft legislative provisi ons for comparable non-cash amounts of all types of 
securities. 
 This opinion will be published on the ECB’s website.  Done at Frankfurt am Main, 30 May 2008. 
[signed] 
The President of the ECB 
Jean-Claude TRICHET 
                                                 
6  See e.g. the introductory sentence of Ar ticle 15(9) of the Slovak Euro-Law as an enabling provision for the adoption of 
the second draft decree. 
7  Council Regulation (EC) No 974/98 of 3 May 1998 on the introduction of the euro (OJ L 139, 11.5.1998, p. 1). 
Regulation as last amended by  Regulation (EC) No 835/2007 (OJ L 186, 18.7.2007, p. 1). 
8  Judgment in Case C-19/03 Verbraucher-Zentrale Hamburg  v O2 (Germany) GmbH & Co. OHG [2004] ECR I-8183 and 
Case C-359/05 Estager  v Receveur  principal de la recette des douanes de Brive  [2007] ECR I-00581. 
9  Article 2(3) of the Slovak Euro-Law. 
10  Article 2(4) and (5) of the Slovak Euro-Law. 
11  Article 41(8) of Law No 594/2003 Coll. on collective investme nt and including amendments to  certain laws, as amended.