Opinion of the European Central Bank of 27 October 2017 on the role of Národná banka Slovenska in supervising the education of financial intermediaries and financial agents (CON/2017/43)
Date: 2017-10-27
Institutions: European Central Bank
Subjects: Slovakia, central bank, financial occupation, national law, professional qualifications

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 27 October 2017  

on the role of Národná banka Slovenska in supervising the education of financial intermediaries 

and financial agents  

(CON/2017/43) 

Introduction and legal basis 

On  22  September  2017  the  European  Central  Bank  (ECB)  received  a  request  from  the  Ministry  of 

Finance  of  the  Slovak  Republic  for  an  opinion  on  a  draft  Law  amending  and  supplementing  Law 

No. 186/2009  on  financial  intermediation  and  financial  consultancy  and  on  the  amendment  and 

supplementation of certain 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 1, as 

the  draft  law  relates  to  Národná  banka  Slovenska  (NBS).  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 

1.1  The primary aim of the draft law is to transpose Directive (EU) 2016/97 of the European Parliament 
and  of the Council2 and to  improve the transposition of the provisions of Directive 2014/17/EU of 
the European Parliament and of the Council3, as regards the cross-border performance of financial 

intermediation or financial consultancy in the field of real-estate credit. 

1.2 

In  addition  to  the  transposition  of  Union  directives,  the  draft  law  introduces  stricter  regulation  of 

specialised  financial  education  with  respect  to  the  requirements  for  professional  competence  of 

financial  intermediaries  and  financial  agents  as  well  as  stricter  conditions  to  be  fulfilled  by  legal 

entities providing specialised financial education.  

1.3  As  a  part  of  the  reform  of  financial  education,  the  draft  law  introduces  a  new  task  for  NBS  in 

relation to the supervision of financial education4.  

1  

2  

3  

4   

Council  Decision  98/415/EC  of  29 June  1998  on  the  consultation  of  the  European  Central  Bank  by  national 
authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 

Directive (EU) 2016/97 of the European Parliament and of the Council of 20 January 2016 on insurance distribution 
(recast) (OJ L 26, 2.2.2016, p. 19).  
Directive 2014/17/EU  of the European  Parliament  and of the Council of 4 February  2014  on credit agreements for 
consumers  relating  to  residential  immovable  property  and  amending  Directives  2008/48/EC  and  2013/36/EU  and 
Regulation (EU) No 1093/2010 (OJ L 60, 28.2.2014, p. 34). 
Point 54 of the draft law which introduces a new Article 22a on specialised financial education in Law No. 186/2009 
and  Point  90  of  the  draft  law,  which  amends  Article  38(1)  of  Law  No.  186/2009  assigning  competence  to  NBS  to 
supervise the implementation of specialised financial education. 

 
 
 
 
                                                 
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1.3.1  More  specifically,  NBS  will  be  obliged  to  maintain  a  register  of  specialised  financial  education 

providers. NBS will assess whether an applicant to be included on the list of specialised financial 

education providers has provided sufficient evidence that: (i) the applicant is authorised to perform 

educational  activity; (ii) the applicant is  of a good character (in the case  of an individual) or each 

member  of  the  statutory  body  or  management  body  of  the  applicant  responsible  for  providing 

specialised  financial  education  is  of  a  good  character  (in  the  case  of  a  legal  entity);  and  (iii)  the 

applicant  has  the  technical  and  organisational  expertise  for  providing  specialised  financial 
education 5. 

1.3.2  NBS  is  furthermore  entrusted  with  the  general  task  of  supervising  the  implementation  of financial 
education by specialised financial education providers6 as well as by financial institutions providing 

specialised  financial  education  to  employees,  financial  agents  and  financial  consultants.  This 

includes  the  power  to  impose  specific  sanctions  on  specialised  financial  education  providers  and 

on persons providing specialised financial education, which is not in line with Law No. 186/2009, as 
amended by the draft law, or who are not on NBS’s register.7 

2. 

General observations 

2.1  This  opinion  does  not  consider  whether  the  draft  law  effectively  implements  into  national  law 

Directive (EU) 2016/97 or certain provisions of Directive 2014/17/EU. The ECB only assesses the 

provisions of the draft law that impact on the tasks of NBS as a national central bank (NCB) and as 

a member of the Eurosystem and the European System of Central Banks (ESCB).  

2.2  The  draft  law  confers  upon  NBS  the  new  task  of  supervising  financial  education  and  specialised 

financial education providers, as specified in paragraph 1.3. Where a new task is conferred on an 

NCB in the ESCB it must be assessed against the prohibition on monetary financing under Article 

123  of  the  Treaty.  For  the  purposes  of  that  prohibition,  Article  1(1)(b)(ii)  of  Council  Regulation 
(EC) No  3603/938  defines  ‘other  type  of  credit  facility’  as,  inter  alia,    ‘any  financing  of  the  public 

sector’s obligations vis-à-vis third parties’.  

2.3  Ensuring that Member States implement a sound budgetary policy is one of the key objectives of 
the  monetary  financing  prohibition,  which  may  not  be  circumvented9.  In  view  of  this,  the  task  of 

financing measures, which are normally the responsibility of the Member States and  funded from 

their budgetary sources rather than by the NCBs, must not be entrusted to NCBs. To decide what 

constitutes  financing  of  the  public  sector’s  obligations  vis-à-vis  third  parties,  which  can  be 

translated as the provision of central bank financing  outside the scope  of central bank tasks, it is 

necessary  to  carry  out  on  a  case-by-case  basis  an  assessment  of  whether  the  task  to  be 

undertaken  by  an  NCB  is  a  central  bank  task  or  a  government  task,  i.e.  a  task  within  the 

responsibility  of  the  Member  States.  In  other  words,  adequate  safeguards  must  be  in  place  to 

5  
6  
7  
8  

9  

Point 54 of the draft law introducing a new Article 22a in Law No. 186/2009. 
Point 90 of the draft law amending Article 38(1) of Law No. 186/2009. 
Point 94 of the draft law introducing, among others, Article 39(3) of Law No. 186/2009. 
Council  Regulation  (EC)  No  3603/93  of  13  December  1993  specifying  definitions  for  the  application  of  the 
prohibitions referred to in Articles 104 and 104b(1) of the Treaty (OJ L 332, 31.12.1993, p. 1). 
Article  123  of  the  Treaty  also  serves  the  objective  of  maintaining  price  stability  and  reinforces  central  bank 
independence. 

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ensure that circumventions of the objective of the monetary financing  prohibition  of maintaining a 

sound budgetary policy of Member States do not take place. 

2.4  As part of its discretion in the exercise of its duty, on the basis of Article 271(d) of the Treaty and 

Article 35.6 of the Statute of the European System of Central Banks and of the European Central 

Bank (hereinafter the ‘Statute of the ESCB’), to ensure that NCBs honour the obligations laid down 

by the Treaty, the Governing Council has endorsed safeguards of that kind in the form of criteria for 

determining what may be seen as falling within the scope of a public sector’s obligation within the 

meaning of Article 1(1)(b)(ii) of Regulation (EC) No 3603/93 or, in other words, what constitutes a 

government task as follows:  

First, central bank tasks are in particular those tasks that are related to  the tasks that have been 

conferred upon the ECB and the NCBs by the Treaty and the Statute of the ESCB. These tasks are 

mainly defined in Article 127(2), (5) and (6) and Article 128(1) of the Treaty, as well as Article 22 

and Article 25.1 of the Statute of the ESCB.  

Second, as Article 14.4 of the Statute of the ESCB allows NCBs to perform ‘other functions’, new 

tasks, i.e. tasks that are not related to tasks that have been conferred upon the ECB and the NCBs, 

are  not  precluded  per  se.  However,  new  tasks  that  are  undertaken  by  an  NCB  and  which  are 

atypical of NCB tasks or which are clearly dischargedon behalf of and in the exclusive interest of 

the government or of other public sector entities should be considered government tasks.  

Third, an important criterion for qualifying a new task as atypical of an NCB task or as being clearly 

on  behalf  of  and  in  the  exclusive  interest  of  the  government  or  other  public  sector  entities  is  the 

impact of the task on the institutional, financial and personal independence of that NCB.  

In particular, the following aspects should be taken into account:  

(a)  Whether  the  performance  of  the  new  task  creates  conflicts  of  interest  with  existing  central 

bank tasks which are not adequately addressed and does not necessarily complement those 

existing  central  bank  tasks.  If  a  conflict  of  interest  arises  between  existing  and  new  tasks, 

sufficient  safeguards  to  mitigate  that  conflict  should  be  in  place.  The  complementarity 

between a new task and the existing central bank tasks should not be interpreted broadly, so 

as  to  lead  to  the  creation  of  an  indefinite  chain  of  ancillary  tasks.  Such  complementarity 

should also be examined in relation to the financing of those tasks; 

(b)  whether without new financial resources the performance of the new task is disproportionate 

to  the  NCB’s  financial  or  organisational  capacity  and  may  have  a  negative  impact  on  the 

capacity to perform properly the existing central bank tasks; 

(c)  whether  the  performance  of  the  new  task  fits  into  the  institutional  set-up  of  the  NCB  in  the 

light of central bank independence and accountability considerations; 

(d)  whether the performance of the new task harbours substantial financial risks; 

(e)  whether the performance of the new task exposes the members of the NCB decision-making 

bodies  to  political  risks  which  are  disproportionate  and  may  also  have  an  impact  on  their 

personal  independence  and,  in  particular,  on  the  guarantee  of  term  of  office  set  out  in 

Article 14.2 of the Statute of the ESCB.  

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3. 

Specific observations 

On the basis of the criteria set out above, the following paragraphs assess whether NBS’s new task is in 

line with the monetary financing prohibition.  

3.1  New  tasks  related  to  the  tasks  conferred  upon  the  ECB  and  the  NCBs  by  the  Treaty  and  the 

Statute of the ESCB 

The supervision of financial education or specialised financial education providers is not among the 

central  banking  tasks  listed  in  Article  127(2)  or  (5)  of  the  Treaty  or  otherwise  conferred  upon  the 

NCBs by the Statute of the ESCB. Although the new task conferred on NBS relates, inter alia, to 

the provision of financial education by financial institutions, it does not form part of NBS’s prudential 

supervisory tasks. According to the explanatory report accompanying the draft law, the objective of 
the new task is rather one of financial consumer protection10. It follows that the new task conferred 

on NBS under the draft law is not directly related to the tasks conferred on the ECB and the NCBs 

by the Treaty and the Statute of the ESCB. Consequently, a careful assessment of the conferral of 

this  task  on  NBS  is  required  in  order  to  determine  whether  it  constitutes  a  government  task  and 

whether the related funding gives rise to monetary financing concerns.  

3.2  Tasks which are atypical of NCB tasks 

The  new  task  relating  to  the  supervision  of  financial  education  widens  the  scope  of  the  current 

tasks  carried  out  by  NBS  in  relation  to  the  supervision  of  financial  intermediaries  and  financial 

advisors  by  extending  NBS’s  tasks  to  include  the  supervision  of  specialised  financial  education 

providers. Currently, the tasks carried out by NBS under Law No.186/2009 include supervision of 

financial intermediation  by  an independent financial agent  and  of the provision of financial advice 

by financial advisers. In line with its current remit, NBS already possesses the powers necessary to 

ensure that the professional qualifications of financial intermediaries and financial agents meet the 

required standards. In particular, NBS, or a person appointed by it, currently ensures the conduct of 

professional examinations for specific financial sectors and the levels of professional qualifications 
of  certain  persons  active  in  the  financial  intermediation  and  financial  advisory  services 11.  NBS  is 

also  responsible  for  nominating  the  (vice-)  chairmen  and  other  members  of  the  examining  board 
and  for  approving  examination  regulations 12.  NBS  also  records  information  on  the  completion  of 

specialised financial education and professional examinations in its register of financial agents and 
financial intermediaries 13.  

In  contrast  with  the  tasks  currently  performed  by  NBS  under  Law  No.186/2009,  the  content  and 

scope  of  specialised  financial  education,  the  manner  in  which  it  is  provided  and  other  relevant 

details  are  only  determined  by  the  Decree  of  the  Ministry  of  Finance  of  the  Slovak  Republic  No. 
600/200914  (hereinafter  the  ‘decree’).  According  to  the  decree,  specialised  financial  education  is 

provided  by  financial  institutions  or  educational  facilities.  In  defining  an  educational  facility,  the 

decree refers to Law No. 131/2002 on universities and Law No. 245/2008 on training and education 

10  
11  
12  
13  
14  

See Explanatory Report to the draft law. 

Article 22(3) of Law No. 186/2009. 
Article 22(2) of Law No. 186/2009. 
Article 17(1)(n) and (o) and 17(7)(l) and (m) of Law No. 186/2009.  

The legal basis for the decree is Article 22(9) of Law No. 186/2009. 

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(school  law).  Therefore,  the  adequate  provision  of  specialised  financial  education  falls  within  the 

scope of government policies on education. It follows  that even  where the new task conferred on 

NBS  might  be  regarded  as  being  complementary  to  a  certain  extent  to  the  supervision  currently 

exercised by the NBS over entities providing financial services to consumers due to the fact that it 

contributes  to  ensuring  appropriate  professional  qualifications  of  financial  intermediaries  and 

financial agents, this task would nonetheless be at least partially discharged on behalf of and in the 

interest of the government. 

It is, consequently, necessary to analyse whether the new task to be conferred on NBS relating to 

the supervision of specialised financial education is a typical task that is also undertaken by other 

NCBs of the European System of Central Banks (ESCB). While the majority of NCBs of the ESCB 

do not appear to have been assigned specific tasks of this nature, the ECB has identified a number 
of Member States, including Croatia 15, the Czech Republic 16, Greece17, Hungary18, Portugal19 and 

15  

16  

17  

18  

In Croatia, where there is insufficient evidence to support claims of the required level of knowledge and competency 
Hrvatska  narodna  banka  (HNB)  may  reject  an  application  for,  or  terminate,  a  licence  as  a  credit  intermediary.  In 
accordance with the requirements laid down by Directive 2014/17/EU and transposed into Croatian law, HNB issues 
a by-law outlining the process for training sales staff and a certificate of adequate knowledge and expertise. A credit 
institution  is  also  obliged  to  prepare  a  training  programme  and  submit  it  to  HNB  no  later  than  31  January  of  each 
calendar year.  

In the Czech Republic, persons who are required to sit professional exams as a precondition for providing particular 
services in the financial market (e.g. consumer credit, capital markets, pensions, handling banknotes and coins) may 
be examined only by providers of financial education holding accreditation from Česká národní banka (ČNB). ČNB 
may  issue  Decrees  regulating  the  precise  operation  of  providers  of  financial  education.  ČNB  may  also  impose 
administrative  penalties  and  sanctions  in  connection  with  the  supervision  of  accredited  providers  of  financial 
education.  

In Greece, pursuant to Article 14 of Law 3606/2007, implementing Directive 2004/39/EC of the European Parliament 
and of the Council of 21 April 2004 on markets in financial instruments amending Council Directive 85/611/EEC and 
93/6/EEC and Directive 2000/12/EC of the European Parliament and of the Council and repealing Council Directive 
93/22/EEC (OJ L 145, 30.402004, p. 1), the Bank of Greece (BoG) was assigned the task of ensuring that persons 
providing investment services or performing investment activities on behalf of credit institutions possess the required 
knowledge  and  competence.  This  task  is  exercised  through  Joint  Decisions  of  the  BoG  and  the  Hellenic  Capital 
Market Commission (HCMC). Candidates are required to pass certification examinations on a specified syllabus or 
to successfully complete the relevant certification training course. In both cases, they obtain a certificate confirming 
their knowledge and competence to provide investment services or engage in investment activities. For renewal of 
the  certificate,  candidates  are  required  to  pass  the  certification  examination  or  successfully  complete  a  refresher 
course.  The  BoG  is  assigned  a  number  of  tasks  in  relation  to  the  certification  process,  including  the  eligibility 
assessment  procedure  and  handling  of  the  relevant  documentation.  The  conditions  for  participating  in  the 
certification examinations, the examination syllabus, issues relating to the organisation of the refresher courses, the 
examinations procedure, the conditions and  procedure for the renewal and withdrawal of the certificate, as well as 
the fees to be paid by the candidates are all outlined in a Joint BoG/HCMC Decision. The examinations and relevant 
courses  may  be  carried  out  by  various  entities,  following  an  assessment  of  their  capability  by  the  BoG  and  the 
HCMC.  The  supervision  of  the  examinations  is  assigned  to  a  three-member  Board  of  Examiners,  of  which  one 
member  is  recommended  by  the  BoG.  Remuneration  of  the  members  of  the  Board  of  Examiners  is  specified  in  a 
Joint Decision of the HCMC and the BoG and the relevant cost falls on the HCMC and the BoG, which in turn charge 
examination fees to the candidates. 
In Hungary, under the 40/2015. (XII.30.) Decree of the Ministry of National economy related to financial, insurance 
and capital markets service providers’ agents, the Magyar Nemzeti Bank (MNB) is responsible for ensuring that the 
requirements for official examinations and examiners’ activity are complied with. The financial education of financial, 
insurance and capital markets service providers’ agents may be carried out by a trainer firm registered with the MNB, 
and by an announced trainer, based on the requirements defined by the law. The MNB organises the official exams 
of financial, insurance and capital markets service providers’ agents, and ensures the examiners. 

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Slovenia20, where NCBs appear to perform tasks similar to that conferred on NBS by the draft law. 

The new task conferred on NBS regarding the supervision of specialised financial education does 

not, therefore, appear to be atypical for a national central bank of the ESCB. 

3.3 

Impact of the tasks on the independence of NBS 

The impact of the new task on the institutional, financial and personal independence of NBS must 

also be taken into consideration. 

3.3.1  Extent to  which the performance  of the  new task creates conflicts  of  interest with existing central 

bank tasks 

No  apparent  conflicts  of  interest  with  other  existing  central  bank  tasks  arise  from  the  NBS’s  new 

task of supervising specialised financial education providers.  

3.3.2  Extent  to  which  the  performance  of  the  new  task  places  a  disproportionate  burden  on  NBS’s 

financial or organisational capacity 

The principle of financial independence requires that Member States may not put their NCBs in a 

position where they have insufficient financial resources to carry out both their ESCB-related tasks 

and  their  national  tasks,  from  an  operational  and  financial  perspective.  Furthermore,  when 

allocating specific new tasks to NCBs, each NCB concerned should  have additional financial and 

human resources at its disposal to ensure that the tasks can be carried  out  without  impacting on 

the  NCB’s  operational  or  financial  capacity  (including  sufficient  human  resources)  to  perform  its 

ESCB  tasks.  In  order  to  ensure  that  NBS’s  capacity  to  perform  its  ESCB-related  tasks  is  not 

impacted, NBS must, therefore, be in a position to avail itself of the necessary resources, including 

personnel, for performing assessments and registrations and issuing directions under the draft law.  

In this regard, it is noted that the draft law requires applicants to pay a fee for entry in the register of 
specialised financial education providers. The application fee represents income for NBS21.  

However,  given  that  NBS’s  new  task  would  extend  beyond  the  maintenance  of  the  register  of 

specialised  financial  education  providers,  to  also  include  assessing  whether  the  conditions  of  the 

draft law are met, it is difficult at this stage to predict the resources that would be required to ensure 

the  sound  supervision  of  specialised  financial  education.  Therefore,  it  is  not  clear  whether  the 

19  

20  

21   

In Portugal, following the transposition of Directive 2014/17/EU, credit institutions will be required to ensure that their 
staff have an appropriate level of knowledge and competence. Under Decree-Law 74-A/2017 of 23 June 2017, (entry 
into force on 1 January 2018) credit institutions will have complied with regulatory requirements where, for instance, 
their  employees  hold  a  certificate  of  professional  competence.  Credit  intermediaries  must  also  conform  to  specific 
requirements of knowledge and competence and, for those providing services on mortgage credit agreements, the 
knowledge and competences of their staff. Under the Credit Intermediaries Law (recently approved by Decree-Law 
81-C/2017,  of  7  July  2017),  the  Banco  de  Portugal  must  assess  compliance  with  the  relevant  requirements 
throughout the authorisation procedure. Compliance with the relevant requirements can, again, only be ascertained 
by a certificate of professional competence. According to Decree-Law 74-A/2017 and the Credit Intermediaries Law, 
certificates of professional competence may only be issued by entities certified by the Banco de Portugal. Under the 
relevant  provisions,  the  Banco  de  Portugal  is  also  responsible  for  monitoring  those  entities  and  may  revoke  its 
certification if it concludes that the conditions required have ceased to exist. However, the Banco de Portugal has not 
been empowered to impose administrative penalties or sanctions on those entities. The fulfilment of these tasks is 
financed by the Banco de Portugal. 
In Slovenia, under the Consumer Credit Act credit providers and credit intermediaries must have properly qualified 
staff.  Banka  Slovenije  is  responsible  for  the  supervising  compliance  with  the  Consumer  Credit  Act  of  credit 
institutions,  leasing  companies  and  certain  credit  intermediaries.  Banka  Slovenije’s  supervision  extends  to 
compliance with the provisions of Consumer Credit Act that regulates education. These tasks of Banka Slovenije are 
financed by the subjects of its supervision. 
Point 54 of the draft law which introduces a new Article 22a(8) in Law No. 186/2009. 

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application fees would cover all the costs related to performing the new task, or whether additional 

resources would be required, which could impact NBS’s regular budget.  

3.3.3  Extent to which performance of the new task fits into  NBS’s institutional set-up, in the light of the 

principles of central bank independence and accountability  

Given that the objective underpinning the new task conferred on NBS by the draft law is similar to 

the  objective  of  ensuring  adequate  professional  qualifications  of  financial  intermediaries  and 

financial agents, which underlies NBS’s existing supervisory tasks as mentioned in paragraph 3.2, 

the performance of the new task does not appear to conflict with NBS’s institutional set-up.  

3.3.4  Extent to which the performance of tasks harbours substantial financial risks 

The  draft  law  does  not  directly  address  NBS’s  potential  liability  in  the  event  of  any  legal  action, 

application or other legal proceeding for damages in relation to the exercise (or failure to exercise) 

of its powers under the draft law. In the absence of any provision in the draft law excluding NBS’s 

liability in performing the tasks under the draft law, NBS would ultimately be liable for damages in 

accordance  with  Slovak  state  liability  rules.  Therefore,  the  new  task  conferred  on  NBS  under  the 

draft law would entail additional financial risks. 

3.3.5  Extent  to  which  the  performance  of  the  new  task  exposes  members  of  NBS’s  decision-making 

bodies to disproportionate political risks and has an impact on their personal independence 

The performance of the new task does not appear to expose NBS’s decision-making bodies to any 

disproportionate political risk or to have an impact on their personal independence. As mentioned 

in paragraph 3.3.3, the new task shares a common objective with existing supervisory tasks of NBS 

to ensure appropriate professional qualifications of financial intermediaries and financial agents. 

3.4  Conclusion regarding the compatibility of the draft law with the prohibition on monetary financing 

The supervision of financial education or specialised financial education providers is not among the 

central  banking  tasks  listed  in  the  Treaty.  The  new  task conferred  on  NBS  could  be  regarded  as 

complementing the supervisory tasks currently performed by NBS, in the light of its contribution to 

the  objective  of  ensuring  adequate  professional  qualifications  of  financial  intermediaries  and 

financial agents. Furthermore, this task might be seen as a legitimate task to be conferred on the 

NBS given that this task does not appear to be atypical for NCBs in the ESCB. However, ensuring 

the sound provision of specialised financial education forms part of the educational policies of the 

State. In this respect, the new task would be administered at least in part on behalf of and in the 

interest  of  the  government.  Additionally,  there  is  uncertainty  as  regards  the  additional  financial 

burden  imposed  on  NBS  in  undertaking  this  task.  The  ECB  therefore  recommends  that  the 

consulting authority take these concerns into account in its decision on whether to confer the new  

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task of supervising specialised financial education on NBS. 

This opinion will be published on the ECB’s website. 

Done at Frankfurt am Main, 27 October 2017. 

[signed] 

The President of the ECB 

Mario DRAGHI 

ECB-PUBLIC 

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