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 detailed rules on the dual display, conversion and rounding of certain prices, payments and other amounts in the labour law and social security sectors on the euro changeover (CON/2008/27)
Date: 2008-07-01
Institutions: European Central Bank
Subjects: Slovakia, conversion rate, monetary integration, money, national law

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 detailed rules on the dual display, conversion and 

rounding of certain prices, payments and other amounts 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  prices,  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  Central  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 legislation 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  (hereinafter  the  ‘Slovak  Euro-Law’),  provides  for  technical 

instructions on the dual display, conversion and rounding 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. 

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  official  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 date 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  conversion  of  amounts  from  the  euro  to  Slovak  currency 

during  the  dual  display  period  after  the  euro  introduction  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  euro7  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  inconsistent  with  the  methodologies  and  practices  currently 

2  

3  

4  

5  
6  

7  

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. 
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 securities for the purpose of rounding by redenomination of their nominal value from 
the Slovak currency to the euro. 
ECB Opinion CON/2008/25 of 12 June 2008 at the request at the request of the Slovak Ministry of Finance on a draft 
decree laying down the scope of prices, payments and other amounts subject to dual display with regard to the field of 
gambling games and methods of their dual display. 
Recommendation 2008/78/EC (notified under document number C(2007)6912), OJ L 23, 26.1.2008, p. 30. 
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 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 date of 
fixing the conversion rate at the earliest.’ 
OJ L 162, 19.6.1997, p. 1. Regulation as last amended by Council Regulation (EC) No 2595/2000 (OJ L 300, 29.11.2000, 
p. 1). 

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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 suggest that either a consistent approach should be 

adopted to the comparable cases governed 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  citizens  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  that:  ‘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 conversion 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 remainder of the amount which is equal to or is higher than 
one half of a Slovak koruna shall be rounded up to the nearest 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 expenses, as amended, amounts are rounded up to the nearest 
whole Slovak koruna. 

3