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 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 (CON/2008/23)
Date: 2008-05-30
Institutions: European Central Bank
Subjects: Slovakia, conversion rate, monetary integration, money, national law

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 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 

(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 certain rules for the dual display of certain prices, 

payments and other amounts in the banking, capital market, 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  Central  Bank  by  national  authorities  regarding  draft 
legislative provisions1, as the first and second draft decrees (hereinafter 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 European 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 other rules to convert certain amounts in the banking, 

capital  market,  insurance  industry  and  pension  savings  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 second 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 Euro-Law to facilitate Slovakia’s smooth changeover to 

1  

OJ L 189, 3.7.1998, p. 42.  

 
 
 
 
                                                 
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 smooth changeover to the euro. 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 official 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: ‘When 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 Slovak Euro-Law and its general 

principles,  the  ECB  notes  that  an  insurance  amount  is  pursuant  to  Article  5  of  Regulation  (EC) 
No 1103/975 an amount to be paid or accounted for thus being rounded up or down to the nearest cent and 

therefore Article 9 of the first draft decree should be aligned with Regulation (EC) No 1103/97. 

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4  

5  

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 and on amendments to certain laws. 
OJ L 23, 26.1.2008, p. 30. 
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 basis, 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 introduction 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  mandatory  period  of  dual  display  but  from  the 
conversion rate fixing date at the earliest.’ 
Council  Regulation  (EC)  No  1103/97  of  17  June  1997  on  certain  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). 

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4. 

Specific  observations  on  the  second  draft  decree  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 provided for by Article 2 of the Slovak Euro-Law6, 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 rounded 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 decimal 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 instruments 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 provisions 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  

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8  

9  
10  
11  

See e.g. the introductory sentence of Article 15(9) of the Slovak Euro-Law as an enabling provision for the adoption of 
the second draft decree. 
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). 
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. 
Article 2(3) of the Slovak Euro-Law. 
Article 2(4) and (5) of the Slovak Euro-Law. 
Article 41(8) of Law No 594/2003 Coll. on collective investment and including amendments to certain laws, as amended. 

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