EN ECB-PUBLIC  
 
 
OPINION OF THE EUROPEAN CENTRAL BANK 
of 14 October 2011 
on the financial statements register  
(CON/2011/80) 
 
Introduction and legal basis  
On 14 September 2011 the European Central Bank (ECB) received a request from the Slovak Ministry of 
Finance for an opinion on the draft law ame nding Law No 431/2002 Coll. on accounting, and on 
amendments to some laws (hereinafter the ‘draft law’). 
The ECB’s competence to deliver an  opinion is based on Articles 127(4) and 282(5) of the Treaty on the 
Functioning of the European Union and the third indent  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 law relates to Národná banka  Slovenska. 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 law 
The draft law establishes a register for financial stat ements managed by the Ministry of Finance. In 
substance, the centralised registration of financia l statements will free entities from the obligation to 
submit such statements to various other authorities.  Some of these entities supervised by Národná banka 
Slovenska (NBS) are currently obliged to submit their financial statements to NBS. As a consequence of 
the proposed amendments
2, they will register their financial statements centrally, instead of submitting 
them to NBS. The register will be divided into  public and non-public secti ons. The public section will 
include financial statements of banks, branches of foreign banks, management companies, branches of 
management companies, insurance companies, bran ches of foreign insurance companies, reinsurance 
companies, branches of foreign reinsurance comp anies, retirement pension savings management 
companies, supplementary pension asset mana gement companies and the stock exchange3 (hereinafter 
‘financial institutions’). The documents in the public section of the register will be available to the public 
through the website free of charge4. 
                                                 
1  OJ L 189, 3.7.1998, p. 42.  
2  Articles XII, XVII, XXVIII, XXXI V and XL of the draft law. 
3  Article I, points 22 and 10 of the draft law. 
4  Article I, point 22 of the draft law - proposed Article 23c(1). 
ECB-PUBLIC 
2 At present, financial institutions are obliged to publis h their financial statements on their websites. Under 
the draft law, financial institutions may opt to anno unce on their websites only that such statements have 
been registered5. 
The draft law provides that financial institutions will also prepare and register reports on selected data 
from financial statements6 and amends the rules on valuation methods7 and the sanctions regime8. 
 2. General observations  The ECB understands that although NBS will no longe r receive financial statements from the entities 
directly, the financial statements will be registered  within unchanged deadlines and accessible to NBS. 
Provided that the draft laws triggers only this pr ocedural change and the re quired information remains 
available to NBS as a financial market supervisor, the ECB has no observations.  
 This opinion will be published on the ECB’s website.    Done at Frankfurt am Main, 14 October 2011. 
 
[signed] 
 
The Vice-President of the ECB 
Vítor CONSTÂNCIO 
                                                 
5  Article I, point 14 of the draft la w - proposed amendment to Article 21(5). 
6  Article I, points 13, 19 and point 22 of the draft law - proposed Article 23(2)(h). 
7  Article I, points 23 to 30 of the draft law. 
8  Article I, point 34 of the draft law.