COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Slovakia Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC) Third River Basin Management Plans Second Flood Risk Management Plans
Date: 2025-02-04
Institutions: Directorate-General for Environment, European Commission
Subjects: Slovakia, adaptation to climate change, application of EU law, environmental risk prevention, flood, risk management, water, water management, water pollution, watercourse

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2025  SWD(2025) 21 final  COMMISSION STAFF WORKING DOCUMENT Third River Basin Management Plans  Second Flood Hazard and Risk Maps and Second Flood Risk Management Plans Member State: Slovakia Accompanying the document REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the implementation of the Water Framework Directive (2000/60/EC) and the Floods Directive (2007/60/EC)  Third River Basin Management Plans Second Flood Risk Management Plans {COM(2025) 2 final} - {SWD(2025) 13 final} - {SWD(2025) 14 final} - {SWD(2025) 15 final} - {SWD(2025) 16 final} - {SWD(2025) 17 final} - {SWD(2025) 18 final} - {SWD(2025) 19 final} - {SWD(2025) 20 final} - {SWD(2025) 22 final} - {SWD(2025) 23 final} - {SWD(2025) 24 final} - {SWD(2025) 25 final} - {SWD(2025) 26 final} - {SWD(2025) 27 final} - {SWD(2025) 28 final} - {SWD(2025) 29 final} - {SWD(2025) 30 final} - {SWD(2025) 31 final} - {SWD(2025) 32 final} - {SWD(2025) 33 final} - {SWD(2025) 34 final} - {SWD(2025) 35 final}  
 
 
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Country specific staff working document 

Slovakia 

ENVIRONMENT 

 
 
 
 
 
 
 
 
 
Content 

Content ................................................................................................................................................................................................... 2 

SECTION A: WATER FRAMEWORK DIRECTIVE .......................................................................................................................... 3 

1. General info, member state characterisation ............................................................................................................. 4 

2. Horizontal aspects ...................................................................................................................................................................... 9 

2.1 Governance ............................................................................................................................................................................ 9 

2.2 Characterization of River Basin District ................................................................................................................. 9 

3. Policy elements contributing to biodiversity and climate change adaptation ...................................... 10 

3.1 Surface Water: what is their ecological status or potential .................................................................... 10 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) .......................................... 12 

3.3 Groundwater bodies - have they sufficient water – quantitative status ......................................... 13 

3.4 Protected Areas (identification, monitoring, objectives and measures) ........................................... 13 

3.5 What is being done to prevent/reduce hydromorphological pressures ............................................ 15 

3.6 What Slovakia is doing for abstractions and water scarcity .................................................................. 16 

3.7 Adaptation to climate change .................................................................................................................................. 17 

4. Policy elements contributing to zero pollution ........................................................................................................ 17 

4.1 Surface Water: what is their chemical status ................................................................................................. 17 

4.2 Groundwater Bodies: what is their chemical status .................................................................................... 19 

4.3 What Slovakia is doing to combat pollution from agriculture ............................................................... 21 

4.4 What Slovakia is doing to combat pollution from other sectors .......................................................... 22 

4.5  What  Slovakia  is  doing  to  combat  significant  pressures  –  overall  assessment  of  the 
Programmes of Measures .................................................................................................................................................. 22 

5. Exemptions and economics ............................................................................................................................................... 23 

5.1 To what extent are exemptions applied in Slovakia .................................................................................... 23 

5.2 Use of economic analysis and water pricing – cost recovery ................................................................ 24 

6. WFD recommendations ........................................................................................................................................................ 26 

SECTION B: FLOODS DIRECTIVE .................................................................................................................................................. 28 

7. Flood risk management under floods directive (FD) ............................................................................................ 29 

2 

 
 
 
 
SECTION A: 
WATER FRAMEWORK 
DIRECTIVE 

3 

 
 
 
1. General info, member state characterisation

Slovakia is a landlocked country (49 034 km2) located in the region of Central Europe, bordering 5 
other countries. Slovakia has a population of about 5.4 million people, with a population density just 
slightly higher than the EU average and rather concentrated in the southern plains. The Carpathian 
Mountains cover a large portion of the country with the southern part of the country consisting of 
the lowlands adjacent to the Danube River. The highest point is Gerlachovský štít at 2,655m. Many 
mighty rivers flow from these mountains, such as the longest Váh with a length of about 403 km. In 
the south of Slovakia around the Danube River are the Danubian Lowlands and hilly areas. Another 
flat area is located to the east, the East Slovak flat. 

Due to the mountainous geography, there are more than 6,000 known caves and more than 1300 
mineral  springs  and  hot  springs.  After  Austria,  Slovakia  has  the  second  largest  reserves  of  fresh 
drinking  water  in  Europe.  Slovakia  has  two  river  basin  districts,  which  are  both  international:  the 
Danube and the Vistula. 

The country features a very high share (37.4%) of land designated as nature protected areas. There 
are 9 national parks, mainly located in central Slovakia.  

Most agriculture is also produced concentration in the southern plains. Industry accounts for 30% of 
the total Slovak GDP, the largest provider being the automotive industry. 

The Danube RBD is the major RBD in Slovakia and it is shared with 18 countries. The Vistula RBD is 
shared with Poland, Czech Republic, Belarus and Ukraine. 

4 

 
 
Reporting 

The deadline for reporting the 3rd RBMPs was in March 2022. The Commission and the EEA together 
with Member States developed an electronic reporting system in WISE (Water Information System 
for  Europe).  Its  use  was  voluntary.  Some  Member  States  used  it  to  fulfil  their  obligations,  others 
reported the plans in pdf format. The cut-off date for the WISE e-reporting was September 2023 and 
the MS were assessed based on the datasets available by this date.  

By September 2023 Slovakia have not submitted full electronic reporting. Therefore, the assessment 
is based on the data mining of the pdf RBMPs. However, Slovakia reported electronically shortly after, 
and this information has been partially used in this assessment report. 

Despite the cut off dates for the production of this report, reporting continued and, for the State of 
Water  report,  the  EEA  aggregated    the  results  available  by  July    2024  in  their  products  and 
dashboards available at WISE Freshwater web portal. 

5 

 
Changes in Status, Pressures, Exemptions & Measures 

Surface 
Water 
Bodies 
(1351) 

Trend (% good 
status/potential) 

100%

Main Pressures & Changes & Exemptions 

Since 2nd RBMP, the number of SWBs in good and high ecological status have decreased significantly from 56% to 41%. By 2027, 67.7% of 
SWBs are expected to be in good ecological status, with many in high status. Although data suggests that nutrient pollution is decreasing, 
agricultural eutrophication still exerts high pressure on SWBs. Further impactful are hydromorphological alterations, such as disruption of 
longitudinal continuity (1066 impassable barriers). Emerging issues are invasive species, sediment management, and fish management. 

ECOLOGICAL 
STATUS 

50%

56%

41%

Slovakia claims that the recent deterioration is solely an apparent trend, as the number of SWBs has been reduced by merging, and 
monitoring has developed strongly since the last cycle. There are three times as many monitoring sites, hydromorphological criteria now taken 
into account, less rivers in unknown status, and more Biological Quality Elements monitored. However, 71% of classifications are under low 
confidence. 57% of SWBs have been assessed by grouping for BQEs. 

0%

2015 2021

Article 4(4) exemptions have been applied to 58 % of SWBs for ecological status, most on technical feasibility and disproportionate cost.  1 
SWB was exempted under Article 4(5) on technical feasibility and disproportionate costs. 5 SWBs were exempted under 4(7). 

100%

98%

71%

The strong decrease of SWBs in good chemical status is reported to be mostly due to an improved monitoring. The coverage of chemical 
monitoring has expanded from 26% of SWBs to 40% since the 2nd RBMPs. Additionally, all priority substances are included in monitoring 
now, and biota and sediment are monitored. Confidence in classification has grown, yet 56% of SWBs are still classified with low confidence 
(most of them with good status). 

CHEMICAL 
STATUS 

50%

0%

Most SWBs fail due to a small set of ubiquitous persistent toxins (uPBTs), namely mercury and PBDEs in biota, and PAHs in the water. These 
priority substances are mostly released during fossil fuel combustion and mining activities, and reach surface waters through atmospheric 
deposition. When excluding these uPBT substances only 4% of SWBs remain in poor chemical status. Besides uPBTs, PFOS and lead cause 
SWBs to fail. 

2015 2021

Pollution from industrial point sources is higlighted as a significant pressure, as well as organic pollution from municipal point sources and 
industry/agriculture. 

6 

 
 
 
Article 4(4) exemptions have been applied to all 29% of failing SWBs for chemical status, most on technical feasibility and disproportionate 
cost. 

Ground 
Water 
Bodies 
(106) 

Trend (% good 
status/potential) 

100%

Main Pressures & Changes & Exemptions 

90,6%

Since 2015, the monitoring network has been improved in extent and quality. Of the formerly 27% of GWBs in unknown status, none are 
unknown now. Thus, it is difficult to say what the actual trend in status is, although data shows an apparent strong improvement. 

70,6%

QUANTITATIVE 
STATUS 

50%

0%

2015 2021

Water abstraction is not identified as a significant pressure, yet in 8 GWBs a long-term significant drop in the water table is reported. 
Additionally, 2 GWBs fail because of diminution of groundwater-associated aquatic ecosystems, and 1 GWB because of deterioration of 
dependent terrestrial ecosystems. Major GW users are public water supply (77 %) and industry (10 %). SK reports that water scarcity can be 
considered an emerging issue for the country due to climate change. 

Article 4(4) has been applied to three GWBs in poor quantitative status on technical feasibility. Article 4(5) was applied to 7 GWBs on 
technical feasibility. 

7 

 
 
 
100%

80,2%

Like the quantitative status, the trend in chemical status of GWBs is impacted by the significant improvement of knowledge. Both GWBs in 
poor and good status have increased, since monitoring extent and resolution have grown, and fewer GWBs are in unknown status. 

62,7%

50%

CHEMICAL 
STATUS 

Although there is apparent improvement in status, a significant sustained upwards trend in concentrations of pollutants (nutrients and TOC) 
are reported, which is in contrast with reported reduction of nutrient pollution mentioned before. 

Article 4(4) has been applied to 13 GWBs on natural conditions, claiming that these would not allow for timely improvement of the status of 
the water body. Article 4(5) was applied to 3 GWBs on technical feasibility and to 1 GWB due to disproportionate costs. 

0%

2015 2021

8 

 
 
 
2. Horizontal aspects 

2.1 Governance 

Slovakia is fairly unique as it has a very centralized approach to water management, with only one 
competent  authority, the Ministry  of  Environment,  responsible  of  all  aspects of  Water  Framework 
Directive (WFD). Though in addition, the Office for Regulation of Network Industries (ÚRSO) regulates 
both drinking water and sanitation tariffs as well as water abstraction and pollution charges. 

Slovakia adopted two RBMP: one for the Danube and another for the Vistula. For both the timetable, 
the work program, the consultation plan, the overview of significant water management issues and 
the draft RBMPs were submitted for consultation for six months in accordance with the WFD.  

Since both RBDs are international, Slovakia is part of the international agreement and permanent 
cooperation body on the Danube international RBD, which has developed in addition an international 
RBMP  for  the  Danube.  For  the  Vistula,  Slovakia  rather  relies  on  bilateral  agreements  with  the 
neighbouring countries. 

Due to the delay in the elaboration of the 2nd Flood Hazard Risk Maps (FHRM) and 2nd Flood Risk 
Management Plan (FRMP), the RBMPs could not be coordinated and integrated with the FRMPs. As a 
landlocked country, Slovakia does not publish any programme of measures pursuant to the Marine 
Strategy Framework Directive is, thus there is need for coordination. 

2.2 Characterization of River Basin District 

In the 3rd RBMPs, there are 1 351 SWBs comprised of 1 328 rivers (flowing) and 23 reservoirs. Table 
1 depicts the types or water bodies. 

Table 1: Overview of Slovakia ‘s River Basin Districts (RBDs)  

RBD 

Name 

Rivers 

Lakes 

Groundwater bodies 

SK30000 

Vistula 

69 

SK40000 

Danube 

1259 

Note: * reservoirs created by damming rivers 

Source: WISE e-reporting 

0 

23* 

4 

102 

It is worth noting that there is a reduction of 11% in the number of river water bodies compared to 
the previous cycle. This is the result of changes in the boundaries of rivers or merging and grouping. 
This may cause some problems of comparability between the two cycles. On the other hand, the 
numbers of reservoirs remained stable.  

It  is  noted positively  that reference  conditions  are  established for  all  relevant  biological,  physico-
chemical  and  hydromorphological  quality  elements  for  all  river  types.  Rivers  are  the  only  natural 
surface  water  type  in  Slovakia.  Reference  conditions  for  reservoirs  were  calculated  for  selected 

9 

 
relevant biological quality elements on the basis of the results derived from long-term monitoring of 
reservoirs. 

The  3rd  RBMPs  state  that  the  reference  conditions  were  checked  and  harmonised  within  the 
intercalibration  process  at  EU  level.  It  also  indicates  that  all  biological  quality  elements  for  most 
relevant  types  were  intercalibrated,  except  for  fish  in  very  large  and  large  river  types,  where  the 
intercalibration was not completed. 

Pressures  

Surface waters 

Agricultural  areas  cover  around  47%  of  the  Slovak  territory.  Together  with  forestry,  agriculture 
represents around 2.8% of the gross value added of the country’s economy. Rural areas still comprise 
a significant share of the population. The share of organic farming (roughly 10% of the farmland) is 
slightly higher than the EU average, but the country has the ambition to cultivate 20% of its farmland 
under organic farming by 2030.  

In this context, for surface water, diffuse pollution from agriculture is described as a significant source 
of nutrient pollution. Indeed, the agricultural sector contributes 62 % of total nitrogen emissions and 
51 % of total phosphorous emissions to surface water. Diffuse pollution by atmospheric deposition 
is highlighted as a significant source of pollution by some types of substances, such as polycyclic 
aromatic hydrocarbons (PAHs) and some metals. 

For point sources of pollution, the RBMPs identify ‘municipal sources of pollution’ and in particular 
‘industrial  and  other  sources  of  pollution’  as  significant  pressures.  Such  point  sources  discharge 
priority and other relevant substances in the water causing a significant impact. Organic pollution 
from residential agglomerations, industry and agriculture is also a significant impact.  

Hydromorphological changes are also highlighted as causing a significant pressure. This is due to the 
disruption of longitudinal continuity, morphological changes and disruption of lateral continuity. The 
infrastructure projects are also identified as a significant water management problem in the context 
of hydromorphological pressures. 

10 

 
 Figure 1: Map of the monitoring points showing eutrophication assessment in Slovakia, according to the 
reporting of the Nitrates Directive 

Source: Joint Research Center of European Commission (n.d.). JRC NITRATES DIRECTIVE - Reporting Period 7 (2016-2019) 
Trophic Status. [online] water.jrc.ec.europa.eu. Available at: 
https://water.jrc.ec.europa.eu/portal/apps/dashboards/cb6034c2a75e4df282f8a62f90c16caa. 

Note : 0% of the monitoring stations are above the threshold of 50mg/l 

Other significant pressures identified in the RBMPs are invasive alien species (In total, there are 16 
aquatic freshwater species of EU concern in Slovakia [1]), sediment management, fish management, 
the pressure on sturgeons, and pollution by microplastics. 

Groundwaters 

Diffuse pollution, from agriculture (nutrients and pesticides) as well as point pollution are highlighted 
as significant pressures. Abstraction is not identified as a significant pressure in Slovakia. 

The description and quantification of the pressures in the RBMPs is not sufficiently detailed. There are 
no significance thresholds which exist in other member States and the pressures are not linked with 
status objectives. 

11 

 
 
 
 
 
3. Policy elements contributing to biodiversity and 

climate change adaptation 

3.1 Surface Water: what is their ecological status or potential 

Monitoring 

It is welcomed that there is a very significant increase, more than a three-fold increase, in the number 
of  monitoring  sites  compared  to  the  2nd  RBMPs.  The  number  of  sampling  sites  for  surveillance 
monitoring increased from 794 to 2 682 sites, and for operational monitoring the number of sites 
increased from 1 112 to 4 165 sites1. The monitoring is covering all quality elements, including 26 
river basin specific pollutants. 

It is not clear why there is no considerable improvement on the use of monitoring data for status 
assessment,  despite  the  significant  increase  in  the  number  of  monitoring  sites.  According  to  the 
electronic reporting, the status assessment of biological and physico-chemical quality elements is 
based on almost the same number of water bodies. However, some improvements can be noted in 
the RBMPs, for example as regards the inclusion of additional quality elements. 

Status assessment 

According  to  the  available  information,  only  39,9  %  of  the  water  bodies  show  good  ecological 
status/potential  and  there  are  just  2,2%  of  water  bodies  in  high  ecological  status  or  maximum 
ecological status. None of the surface water bodies in Slovakia were reported to have unknown status 
similarly as in the 2nd RBMPs. There is a clear deterioration in the ecological status compared to the 
2nd RBMPs. The most notable deterioration is seen in the status of rivers, while the status of lakes 
has improved. Figure 3 depicts the evolution of the ecological status through the different cycles as 
well as the predictions for 2027. 

1 There are two types of monitoring: i) operational monitoring to determine the status and which covers all water bodies 
at risk and ii) surveillance monitoring aimed rather at identifying impacts and long-term changes and design monitoring 
programmes. 

12 

 
 
Figure 2 - Ecological status / potential of surface water bodies in the 1st RBMP, 2nd RBMP and 3rd RBMP 

Source: WISE e-reporting 

3.2 Hydromorphological changes and artificialization (HMWBs and AWBs) 

The level of human intervention in the water system has considerably increased compared to the 2nd 
RBMPs. Table 2 depicts the number of heavily modified and artificial water bodies. Indeed, the number 
of heavily modified water bodies (HMWBs) has increased from 258 (2nd RBMPs) to 264 (3rd RBMPs), 
or 19% and 20% of all water bodies, respectively. All lakes are heavily modified. 

The reason for designating water bodies as heavily modified is due to the presence of weirs and 
dams, channelisation and straightening of rivers, and bed stabilisation and bank reinforcement. The 
main uses which cause hydromorphological alterations are mainly flood protection and hydropower, 
but also agriculture (drainage and irrigation) and other sectors (recreation, water supply, aquaculture 
and industry).  

Table 2 Number of Heavy Modified and artificial surface water Bodies 

Modifications 

Rivers 

Lakes 

HEAVILY MODIFIED 

241 

ARTIFICIAL 

53 

23 

0 

Source: data mining and WISE e-reporting 

As  regards  artificial  water  bodies,  they  represent  a  much  smaller  share  of  water  bodies  and  the 
number of water bodies has decreased from 76 (2nd RBMPs) to 53 (3rd RBMPs) i.e., from 5.2% to 3.9 
% of all river water bodies, respectively. 

13 

 
 
No information could be found in the Plan on the reasons or uses that triggered the designation of 
artificial water bodies. Yet, some information could be found in the 2nd RBMPs demonstrating that the 
main  water  uses  behind  the  human  intervention  were  flood  protection,  followed  by  hydropower, 
irrigation, tourism/recreation, industry and drinking water supply. 

The production of hydropower is particularly important in river Hron and other small rivers its area. 
In  previous  years,  small  hydropower  plants  (SHPs)  were  placed  in  nine  potentially  affected  water 
bodies, including in river Hron, without a prior assessment as foreseen by Article 4(7) of the Water 
Framework Directive on grounds that there would not be a deterioration. The European Commission 
opened an infringement procedure which is still ongoing. Based on the latest information, Slovakia 
acknowledges that the SHPs hamper the achievement of good ecological status/potential of the river 
Hron, that mitigation measures are needed, and permit conditions need to be revised to create the 
necessary conditions for aquatic species, including restoring continuity for migratory fish, to achieve 
the environmental objectives by end of 2027.   

For each water body defined as HMWB / AWB, the ecological potential has been determined. This is 
usually based on reference conditions and classification methodology specific to the water body type. 
Where this method cannot be used, the MEP / GEP is derived from the observed status of the water 
body and the predicted response of the implementation of mitigation measures to the status of the 
water body. 

3.3 Groundwater bodies - have they sufficient water – quantitative status 

Compared to the previous cycle, the total number of delineated GWBs slightly increased from 102 
to 106, yet the area remains the same. Thus, the higher number seems the results of a change in 
methodology. It is very welcome that the number of GWBs subject to monitoring to establish the 
quantitative status has increased and it is fairly high now:  79.2 % of the total GWBs. Also, it is noted 
that thanks to these considerable efforts, the unknowns have disappeared. This implies that Slovakia 
has now a much better knowledge of the quantitative status of its GWB.   

14 

 
Figure 3 - Quantitative status of groundwater bodies in the 1st RBMP, 2nd RBMP and 3rd RBMP 

Source: WISE e-reporting 

Over abstraction does not seem to be a problem for the large majority of the GWBs since 91% are 
in  good  quantitative  status.  Yet  there  are  10 GWBs  in  poor  quantitative  status.  Unfortunately,  no 
detailed information could be found as regards the pressures significantly affecting GWBs.  

As mentioned earlier, it is worth noting that there are more than 1300 mineral springs and hot springs 
in  the  country.  The  monitoring  of  geothermal  GWBs  is  not  sufficient.  The  technical  condition  of 
monitoring devices that provide key data for the assessment of quantitative status is deteriorating. 
According to the 3rd RBMPs, there is weak legal protection for the maintenance of a long-term, stable 
and representative hydrological monitoring network of groundwater in Slovakia. 

3.4 Protected Areas (identification, monitoring, objectives and measures) 

There  are  different types and  reasons  why  certain water  bodies  are  protected  under  the  law.  For 
surface water bodies, protected areas have been designated under the Drinking Water, Bathing Water, 
Habitats  and  Birds  Directives  as  well  as  for  areas  designated  for  the  protection  of  economically 
significant aquatic species (ie. aquaculture). As mentioned earlier there is a quiet large share of the 
country designated as nature protected area. Moreover, Slovakia reported having  60,8 % of utilised 
agricultural areas in Nitrate vulnerable zone in the Nitrates report 2024.  

For surface water bodies, protected areas have been identified for bathing waters, Birds and Habitats 
Directive  (Natura  2000)  sites,  vulnerable  zones  under  the  Nitrates  Directive  and  areas  for  the 
protection of freshwater fish. For groundwaters, nutrient sensitive protected areas and drinking water 
protected areas have been designated. 

15 

 
 
 
Table  3  -  Number  of  protected  areas  in  Slovakia  by  2021,  per  type  of  protected  area  and  type  of 
associated water body  

Protected area type 

Number of water bodies associated with protected areas  

Bathing waters  

32 

Areas designated under Birds Directive: total 44 of which 24 are dependent on water 

Natura 2000 

Areas of European importance: total 642 of which 492 are dependent on water 

Nitrate vulnerable zones 

 1,223 municipalities representing 65.8% of the total used agricultural land in the 
Slovakia  

Freshwater Fish protected 
areas 

Source: Data mining 

58 water bodies associated with freshwater fish protected areas 

Slovakia applies the ‘whole country’ approach to the designation of sensitive areas under the Urban 
Wastewater Treatment Directive. As a landlocked country, it has not designated shellfish protected 
areas. No information could be found on whether there were changes introduced compared to the 
previous cycle.  

In terms of reinforced measures, additional objectives have been set in all RBMPs for groundwater 
drinking water protected areas. Additional objectives are also described in the 3rd RBMPs for Natura 
2000  areas,  where  the  overall  goal  is  to  ensure  a  favourable  state  of  protection  of  habitats  of 
European importance and a favourable state of protection of species of European importance in their 
natural range. Slovakia indicated that work has begun to establish more stringent objectives for Birds 
and Habitats protected areas associated with GWBs – in relation to their chemical status and to meet 
the  ambition  of  the  2030  Biodiversity  strategy.    The  RBMPs  describe  also  further  objectives  for 
wetlands. Additional objectives are defined for sensitive areas where a removal of 75% of phosphorus 
and nitrogen must be achieved by wastewater treatment plants. In addition, in Nitrate Vulnerable 
Zones,  specific  farming  practices  must  be  respected  and  specific  concentration  of  nitrates  in 
groundwater  must  be  met.  For  other  protected  areas  than  those  described  above  no  additional 
objectives were deemed necessary as reaching good ecological  status is considered sufficient.  No 
information was found on additional measures related to specific types of protected areas. However, 
the 3rd RBMPs indicates that, if necessary, additional measures can be taken in protected areas. 

It is worth noting that while information is provided on the overall ecological status for surface and 
groundwater, no information could be found on status linked to the protected areas. Thus, it cannot 
be  concluded  whether  their  designation  as  protected  as  well  as  the  reinforced  measures  applied 
therein have led to an enhanced state. Yet, it is positively noted that no exemptions have been applied 
to protected areas. 

16 

 
3.5 What is being done to prevent/reduce hydromorphological pressures 

Significant hydromorphological pressures on rivers are reported for both RBDs in the 3rd RBMPs.  

Although prioritisation of measures related to restoration of river continuity was carried out in the 
1st and 2nd RBMPs, overall management objectives in terms of restoring river continuity have not 
been set in the 3rd RBMPs. 

The types of specific mitigation measures described in the 3rd RBMPs include fish ladders, bypass 
channels,  habitat  restoration,  removal  of  structures,  reconnection  of  meander  bends,  setting  of 
ecological flows, measures to address hydropeaking (which correspond to KTM5, KTM6 and KTM7), 
as well as research activities (KTM14).  

In terms of basic measures planned to tackle hydromorphological pressures, there is an authorisation 
and  /  or  permitting  regime  in  place  to  control  physical  modifications  in  both  RBDs.  There  is  an 
indication in both RBMPs that a systematic revision of permits will be undertaken once the definition 
of e-flows is complete. This is described in the RBMPs as a planned measure, but no further details 
on the frequency of the review is included. This review is planned because ecological flows have not 
yet been introduced and the current permits are based on a different concept (i.e. minimum flows).  

There is also a register of physical modifications of water bodies described in the 3rd RBMPs. 

The design of new and existing structural measures, such as flood defences, storage dams and tidal 
barriers, was reported to have been adapted to take into account WFD objectives in both RBDs. 

The  3rd  RBMPs  indicate  that  given  the  many  barriers  and  limited  financial  resources  for 
implementation,  a  comprehensive  ecological  prioritisation  of  rivers  will be  undertaken  in  the  next 
period to select the water bodies where efforts should be focused to restore longitudinal continuity. 
Actions that are ecologically effective and will have the greatest impact will be prioritised (KTM14). 
This will take into account fish migration passage and requirements, as well as sediment continuity, 
number of barriers above and below the reach, distance from the confluence, length of the restored 
reach, ecological status of water bodies, habitat connectivity and protected areas. 

Slovakia  published  a  list  of  national  measure  types  for  river  revitalisation  to  tackle  various 
hydromorphological pressures and assessed their efficiency on a low, medium, high scale. Out of 46 
measures, 2 were rated as low efficiency, 24 as medium and 20 as high efficiency. 

With  respect  to  the  ambition  of  hydromorphological  measures  in  closing  the  gap  to  good 
status/potential for hydromorphological pressures, no clear information was found in the RBMPs. 

3.6 What Slovakia is doing for abstractions and water scarcity 

As it was already the case in the previous cycle, water abstraction is not identified as a significant 
pressure  at  the  RBD  level  or  in  significant  portions  of  any  RBD  and  Slovakia  addresses  water 
abstraction/scarcity  issues  only  relevant  for  specific  regions  across  the  country.  No  significant 
changes have been introduced since the last cycle.  

The major users of surface water are industry (54 %) and public water supply (34 %). The major 
users of groundwater are public water supply (77 %) and industry (10 %). The RBMPs do not data on 
trends on water consumption. The current estimation of the annual Water Exploitation Index+ for the 

17 

 
country is 0.2-1.4 % for the period (2016-2019) which is very low. However, in the 3rd RBMPs, 10 
GWBs (i.e., 9.4 % of total GWBs) are assessed in poor quantitative status. The reason for invoked is 
the deterioration of the water balance or the long-term significant downward trends of groundwater 
tables in 8 GWBs. Due to climate change, water scarcity is a topic that can become an emerging issue 
in Slovakia although it has not been so far.  

As a reaction Slovakia is implementing some measures grouped in key type of measures (KTM).  

KTM7 – Improvements in flow regime and / or establishment of ecological flows” are not planned for 
the 2021-2027 period in all RBDs. However, measures with the same focus are reported under WISE 
e-reporting category "Other KTMs" in the Danube RBD (e.g. setting up an effective control mechanism 
and strengthening control activities; improvement of quantitative status of GWBs). 

Other related supplementary measures planned for the 2021-2027 period in all RBDs are “KTM14 - 
Research,  improvement  of  knowledge  base  reducing  uncertainty”  (e.g.  improving  knowledge  on 
hydrological  conditions;  verification  and  refinement  of  usable  amounts  of  groundwater; 
hydrogeothermal evaluation of GWBs) 

 As  regards  permits,  conditions  to  grant  or  refuse  permits  for  abstraction  of  ground  water  are 
stipulated in the national  legislation so not a lot  of information is included in the 3rd RBMPs. The 
specific conditions are set up to maintain good quantitative status of groundwater (art. 21(7) Act 
364/2004 (Water Act). Thus, there is a concession, authorisation, and / or permitting regime to control 
surface and groundwater abstractions and impoundments. Furthermore, there is an updated register 
of  abstractions  from  surface  water  and  groundwater  and  impoundments.  Small  abstractions  are 
exempted from permitting and controls. Abstraction permits may be issued for a period of ten years, 
after which they expire. The validity of the permit may be extended by the state water authority. 

However, it must be noted with concern that ecological flows were not defined and implemented in 
the  country  during  the  period  2015-2021.  Therefore,  there  is  not  an  explicit  link  between  the 
implementation of e-flows and the authorisation process and / or review of permits to control water 
abstractions  and  impoundments.  As  a  result,  permits  do  not  consider  the  need  to  maintain  good 
ecological status of surface water bodies.  

The national RBMPs and the international RBMPs of the Danube and the Vistula, where Slovakia is 
located,  do  not  report  any  coordination  specifically  on  water  abstraction  /  scarcity  issues  at  the 
international level. The 3rd RBMPs included measures to address water abstraction. These measures 
focus  on  e-flows  definition  and  enforcement,  control  of  abstraction,  water  efficiency  through 
awareness  raising, protection  of  drinking  water protected  areas  from  abstraction,  climate  change 
adaptation, research and knowledge building. 

3.7 Adaptation to climate change 

Both  the  Danube  RBMP  and  the  Vistula  RBMP  contain  a  chapter  dedicated  to  the  assessment  of 
climate change impacts on water management. These include the impacts of droughts, with historical 
assessments  of  the  hydrological  regime.  The  RBMPs  note  that  extensive  modelling  is  underway 
coupled with the establishment of drought operational monitoring and early warning systems.  The 
Slovakian RBMPs include cross-reference to measures from the Slovakian Climate Change Adaptation 
Strategy (2018) and Action Plan (2021). In addition to the above, the 2018 Action Plan "H2Odnota je 
voda" for dealing with the consequences of drought and water shortage, contains preventive and 

18 

 
operational measures on how to fight the consequences of drought in Slovakia.2 No explicit mention 
could be found to the existence of dedicated drought management plans, yet the aforementioned 
Action Plan could perhaps be considered an equivalent instrument since it focuses on drought and 
water scarcity issues. 

Yet the measures referred to remain generic, are largely small-scale in nature- with the view to pilot 
measures to combat  drought  and analyse their effectiveness to inform longer-term management 
decisions.  These measures are not explicitly referred to in the RBMPs. However, in the RBMPs there 
is a generic Key Type of Measure 24 - "Adaptation to climate change" has been made operational 
with a measure ‘verify the water potential and groundwater available sources in relation to changing 
climatic  conditions  in  order  to  prevent  further  lowering  of  groundwater  levels  and  to  avoid  the 
negative impacts of climate change’. 

4. Policy elements contributing to zero pollution 

4.1 Surface Water: what is their chemical status 

Monitoring  

There are two types of monitoring: i) operational monitoring to determine the status and which covers 
all water bodies at risk and ii) surveillance monitoring aimed rather at identifying impacts and long-
term changes. 

It  is  very  welcome  that,  compared  to  the  previous  cycle,  the  share  water  bodies  that  have  been 
monitored  for  chemical  status  has  increased  from  26%  (390  water  bodies)  to  40%  (541  water 
bodies). This is due to two reasons: increased efforts made by the authorities but also to the fact that 
a change in classification has reduced the number of water bodies in the country from 1510 to 1351. 

Member States are required to undertake monitoring for all priority substances which are discharged 
into the river basin or sub-basin. The details on monitoring and frequency are described in the Annual 
monitoring programmes for water of Slovakia. The 3rd RBMPs for both the Danube and Vistula RBDs 
mention that both operational and surveillance monitoring are undertaken. It is noted positively that, 
for the first time, this includes biota and sediment monitoring. It is also stated that all 45 priority 
substances, those that substances that are of EU concern, are included in the monitoring campaign 
but with some caveats. It is noted that the monitoring period used for the chemical status assessment 
is  2013  to  2018. Grouping  approaches  have  been used,  that means  that  results  from monitored 
SWBs  have been  combined  with  extrapolations  for adjacent  water bodies.  The  RBMPs  report  that 
inventories of emissions have been developed based on a combination of the pollutant release and 
transfer register and monitoring to help identify discharges and potential pressures. The RBMPs state 
that for surveillance monitoring (covering water, biota, and sediment), 10 sites across Slovakia were 
selected and monitoring was carried out for all relevant priority substances (12  substances in the 
Vistula, and 34 substances in the Danube RBD). No further details on this issue are provided. 

2 Schmidt et al., (2023) Stock-taking analysis and outlook of drought policies, planning and management in EU Member 
States.  Final  report  under  contract  “Technical  and  scientific  support  to  the  European  Drought  Observatory  (EDO)  for 
Resilience and Adaptation - Lot 2: In-depth assessment of drought management plans and a report on climate adaptation 
actions against drought in different sectors” 

19 

 
 
Status assessment 

Figure 3 is based on the e-reporting to WISE and reflects the chemical status of SWBs in Slovakia 
reported in the 1st, 2nd and 3rd RBMPs[1]. At the time of the 2nd RBMPs it was assessed that 98 % 
of water bodies (1,473 water bodies) were in good chemical status and 2% (37 water bodies) had 
failed to achieve good chemical status. Note that no water bodies were in unknown status in the 1st, 
2nd or 3rd RBMPs. The 3rd RBMPs (including uPBTs) shows a decline in this situation with 72 % now 
achieving good chemical status, and 29 % failing to achieve good chemical status. When excluding 
uPBTs, 96% of surface water bodies in Slovakia are in good status. 

Figure 4 Chemical status of SWBs in the 1st RBMP, 2nd RBMP and 3rd RBMP 

Source: WISE e-reporting 

According to the EQS Directive3, eight priority substances and groups of priority substances behave 
like  ubiquitous,  persistent,  bioaccumulable  and  toxic  substances  (uPBT)4.  These  substances  are 
generally  expected  to  cause  widespread  exceedances,  and  their  emissions  can  be  challenging  to 
tackle  (e.g.,  due  to  long-range  atmospheric  transport  and  deposition).  The  main  EQS  failures  in 
Slovakia  occur due to  uPBT  substances,  namely,  mercury,  PBDEs,  PAHs,  PFOS, dioxins  and  furans, 
tributyltin,  and  heptachlor  and  heptachlor  epoxide.  As  in  many  other  Member  States,  the  three 
substances that primarily cause issues are Mercury and polybrominated diphenyl ethers (PBDEs) (in 
biota), and PAHs in surface water. Since the WFD operates a ‘one out, all out’ approach a water body 
can fail in relation to one or more than one substance (e.g. due to Mercury and PBDEs).  

[1] Note that the data presented within the electronic reporting to WISE covers the status excluding uPBT substances. The 
Danube RBMP in particular reflects that the overall status has 71% of WBs are in good status and 29% are in poor status. 
The electronic reporting (excluding uPBTs) has 94% good chemical status and 6% poor chemical status across Slovakia. 
3 Amended by Directive 2013/39/EU 
4  Brominated  diphenylether,  Mercury  and  its  compounds,  Polyaromatic  hydrocarbons  (PAH),  Tributyltin,  PFOS,  dioxins, 
hexabromocyclodecane and heptachlor 

20 

 
 
 
However, based on the 389 water bodies that fail to achieve good chemical status, the 241 water 
bodies fail due to exceedances of Mercury. Whereas PBDEs cause failures in 217 water bodies and 
benzo(a)pyrene in 153 water bodies. If PAHs and fluoranthene are counted together they are a cause 
of failure in 182 water bodies. 

The other important substances which cause failure to achieve good chemical status relate to PFOS 
(22 water bodies), Lead (16 water bodies), Octylphenol (6 water bodies), dioxins and furans (4 water 
bodies), Cadmium (7 water bodies), Heptachlor and Heptachlor epoxide (3 water bodies based on 
biota and 2 water bodies based on surface water), Nickel (2 water bodies), and Tributyltin (2 water 
bodies). 

For some of these substances the exceedances are localised (e.g., contaminated sites), for example 
“heptachlor and heptachlor epoxide” is a pesticide that has been banned in the European Union since 
1984. 

In order to show the progress made in tackling other priority substances, Member States have the 
possibility  to  present  the information  related  to  chemical  status  separately  for  these  substances. 
Both RBMPs make use of the clause to present the data including all substances and also excluding 
uPBTs. For the Danube if the uPBT substances are excluded, the number of water bodies in good 
chemical status is 94 %. For the Vistula RBD if uPBT substances are excluded 100% water bodies 
(that is all 69) achieve good chemical status. 

Regrettably, Slovakia does not provide any estimation of the share of water bodies achieving good 
chemical status by 2027. 

4.2 Groundwater Bodies: what is their chemical status 

Monitoring 

The total number of GWBs in Slovakia is 106, increasing from 102 in the 2nd RBMPs (4 % increase), 
but the total GWB area remained almost the same. The change in the number of GWBs is due to the 
new  knowledge  acquired  about  geothermal  sources.  As  a  result,  4  new  geothermal  GWBs  are 
delineated. Slovakia performs a sound monitoring of groundwaters. It is worth noting that in the 3rd 
RBMPs, 79% of GWBs (84) are monitored to ascertain their chemical status.  

All substances causing risk of deterioration in chemical status, i.e. GWD Annex I and Annex II (Part B) 
substances and WFD Annex V (Point 2.4.2) core parameters are subject to monitoring.  

Status assessment 

A gap analysis could not be identified for the pressures significantly affecting GWBs. It is noted with 
concern that the assessment of impacts on groundwater dependent ecosystems and saline or other 
intrusions  are  not  considered  in  the  assessment  of  chemical  status  of  GWBs,  although  the  issue 
existed already in the 2nd RBMPs. 

There  is  no  indication  in  the  3rd  RBMPs  that  threshold  values  have  been  coordinated  with 
neighbouring countries. The time series being used for the trends and trend reversal assessments 
extend only up to 2017 and the applied methodology is not elaborated (e.g., selection of monitoring 
frequencies  and  locations,  baseline  levels  for  substances  that  occur  both  naturally  and  from 

21 

 
anthropogenic  sources,  distinction  between  upward  trends  and  variation  of  natural  background 
levels).  

Figure 5 Chemical status of GWBs 1st RBMP, 2nd RBMP and 3rd RBMP 

Source: WISE e-reporting 

In Slovakia, 80 out of 106 GWBs are assessed in good chemical status (i.e., 80.2 % of total GWBs 
and 68,8 % of total area) and 13 GWBs (i.e., 12.3 % of total GWBs and 23,0 % of total area) are 
assessed in poor chemical status in the 3rd RBMPs (Figure 5).  

A  clear  improvement  can  be  seen  compared  to  the  previous  cycle,  when  64  GWBs  were  in  good 
chemical status and 11 GWBs were in poor chemical status (i.e., 62.7 % and 10.8 % of total GWBs, 
or 60.6 % and 17.2 % of total area respectively). This is largely due to the significant improvement 
in knowledge between the cycles, since unknowns have gone from 27 to 8 GWBs. 

However,  there  are  15  GWBs  at  risk  of  failing  to  achieve  good  chemical  status  by  2027  due  to 
nitrates, ammonium, phosphates, sulphates, arsenic, total organic carbon and pesticides. 

The top five pollutants causing failure to achieve good chemical status of GWBs are phosphates (5.7 
% of total GWBs), nitrates (5.7 %), ammonium (5.7 %), sulphate (5.7 %) and total organic carbon 
(TOC) (3.8 %). 

In addition to the ground water pollution, it is important to mention the old waste dump sites, which 
remain untreated, like in Bratislava’s Vrakuňa chemical dump (in close vicinity of the drinking water 
reservoir  Žitný  Ostrov).  Slovakia  should  speed  up  addressing  these  problems  and  explore  the 
possibilities of a better use of EU funds.  

22 

 
 
4.3 What Slovakia is doing to combat pollution from agriculture 

Agricultural pressures have been identified as significant in the 3rd RBMP. Yet the intensity of these 
and the measures taken remain the same as in the previous cycle. Some data suggests that the 
nitrogen and phosphorus pollution is decreasing. Regrettably, the RBMPs include limited information 
on the applied measures and the expected effects. Moreover, it is noted with concerns that despite 
some mentions to modelling, there are no data quantifying the agricultural nutrient load reduction 
needed  to  achieve  the  environmental  objectives.  This  would  be  very  much  needed  to  tailor  the 
measures that must be applied. For pesticide pollution, there is no gap assessment either. the RBMPs 
mention  that  there  is  one  GWB  at  risk  of  failing  good  status  by  2027  due  to  pesticide  pollution. 
However, there is no further information about the specific measures planned to reduce the risk.  

The international RBMP for Danube includes assessments of nutrient loads including considerations 
of the agriculture shares as can be seen in the figure below. 

Figure 6  Share of sources in the overall Total Nitrogen emissions in the Danube countries for the reference 
period (2015-2018)  

Source: Danube River Basin Management Plan Update 2021 

The  PoM  provides  information  on  measures  addressing  nutrients  and  pesticide  pollution  from 
agriculture and sorts them according to basic and supplementary measures and whether they are 
mandatory or voluntary. For nutrients from agriculture, only Key Type Measure 2 – Reduce nutrient 
pollution from agriculture- has been reported as a basic measure. Under KTM2, there is reference to 
basic  measures  such  as  those  included  under  the  Nitrates  Directive  and  cross-compliance 
requirements under the Common Agricultural Policy (CAP)5. For basic measures, the farmers cover 
the costs of the measures. Examples of such measures include the changes to nutrient application 
standards and the adjustment of environmental nutrient loading limits through the adaptation of 
national legislation with appropriate penalties, which fall under the category of basic measures under 
the WFD.  There is limited information on whether these measures will continue to be implemented 
and the extent to which they can deliver significant improvements.  

5There is also information about relevant measures in “Mapping and analysis of CAP strategic plans” (2023-
2027)  the link Mapping and Analysis of CAP Strategic Plans - European Commission (europa.eu) 

23 

 
 
 
 
Pollution from pesticides is addressed the same way as nutrients and the RBMPs include only general 
references to the basic measures under cross-compliance requirements. As supplementary measures, 
the  RBMPs  make  reference  to  the  Rural  Development  Programme.  Here  again,  the  group  of  the 
measures for pesticides seem to be voluntary. 

In relation to the application of the polluter’s pay principle, this is partly applied for agriculture. In 
Slovakia, these basic measures are implemented by the Fertiliser Act, which also includes measures 
for nitrate vulnerable zones as defined under the EU Nitrates Directive. So beyond the Nitrates Action 
Plan, there seems to be very few mandatory measures for farmers. The supplementary measures 
are funded by the CAP6 or by national support. Under the CAP for 2023-2027, Slovakia aims for an 
increase from 13.7% in 2022 to 20% coverage of the agricultural lands by organic farming in 20307.  

4.4 What Slovakia is doing to combat pollution from other sectors 

Slovakia’s RBMPs report that there are measures to eliminate pollution of surface waters by priority 
substances and to progressively reduce pollution by other substances, which would otherwise prevent 
achievement of the objectives set out in WFD. The basic measures include compliance with the Urban 
Waste Water Treatment Directive and the Industrial Emissions Directive as the main instruments to 
address chemical pollution. 

Overall, 93% of the urban waste water in Slovakia is treated according to the requirements of the 
UWWTD. This is above the EU average of 76%. According to the 2nd RBMPs discharges of urban waste 
water  contributed  significantly to  less  than good  water  quality in  8.7%  of  river  water bodies  and 
13.7%  of  groundwater  bodies  area.  Discharges  of  waste  water  from  unconnected  dwellings 
contributed  significantly  to  less  than  good  water  quality  in  14.4%  of  groundwater  bodies  area. 
Discharges from storm water overflows were not reported as significant pressures.  

Supplementary measures include for example KTM14 on further knowledge gathering on measures 
to address chemical pollution. It also includes KTM10, where it is mentioned that the environmental 
tax on wastewater discharges should consider the emissions of hazardous substances.  

There is no information in the RBMPs that allows to determine whether measures planned to address 
all drivers causing chemical pollution. Even though RBMPs list the KTM that are to be applied, they 
do not provide sufficient details of their actual implementation or how they are expected to address 
specific drivers causing chemical pollution. Worth noting is the key measures pertaining to revision 
of permits / authorisations and construction of wastewater treatment plants which were already in 
the 1st and 2nd cycles.  In the 3rd RBMPs, the same measures are listed but no further details are 
provided. 

4.5 What Slovakia is doing to combat significant pressures – overall 

assessment of the Programmes of Measures 

The Key Types of Measures (KTM) are groups of measures identified by Member States in the PoM, 
which  target  the  same  pressure  or  purpose.  The  RBMPs  do  distinguish  between  basic  and 
supplementary measures. The prioritisation of measures is mentioned for the purpose of removing 

6 Mapping and analysis of CAP strategic Plans (2023 – 2027)  Mapping and Analysis of CAP Strategic Plans - European 
Commission (europa.eu) 
7 At a glance: Slovakia’s CAP Strategic Plan (europa.eu) 

24 

 
 
hydromorphological pressures. The prioritisation includes synergistic effects of different measures on 
the  water  bodies  affected  by  hydromorphological  pressures,  these  pressures  are  usually  the 
clearance of barriers for fish. Also, all other types of measures to improve the hydromorphological 
quality of SWBs were considered, including the protection of Natura 2000 sites. 

Other  significant  water  management  issues  mentioned  in  the  RBMPs  are  Sediment  quality 
management  and  Revitalisation  of  regulated  rivers,  with the  aim  of  supporting  natural  processes 
that lead to the restoration and preservation of the biodiversity of the river ecosystem. 

For  Slovakia  no  information  has  been  found  on  a  full  gap  analysis  for  all pressures  in  the  RBMP 
documents. Progress has been made in the delineation of water bodies and in identifying pressures. 
There  are  a  wide  variety  of  measures  presented,  but  it  is  not  possible  to  ascertain  with  100  % 
certainty if these cover all pressures, without analysis of the electronic reporting8. 

5. Exemptions and economics 

5.1 To what extent are exemptions applied in Slovakia 

Article 4(4) 

Article 4(4) exemptions have been applied to 787 SWBs (58 % of SWBs) for ecological status and to 
389 SWBs (29 % of SWBs) for chemical status. This represents a considerable increase compared to 
the  previous  cycle  even  if  it  is  not  possible  to  make  a  direct  comparison  of  the  application  of 
exemptions with the 2nd RBMPs. Indeed, this is due to the reduction in the number of surface water 
bodies (decreasing from 1510 to 1351 SWBs). All Article 4(4) exemptions have been justified based 
on technical feasibility, disproportionate costs and natural conditions. The application of Article 4(4) 
to  GWBs  remained  the  same  for  quantitative  status  (3  GWBs)  and  increased  for  chemical  status 
(from 11 to 13).  

It  is  worth  noting  that  Slovakia  has  developed  a  ”Methodology  for  Economic  Explanation  of 
Exemptions“  under  Article  4(4)  and  4(5)  of  the  WFD  to  establish  whether  a  water  body  may  be 
exempted from achieving the environmental objectives. The methodology contains essential criteria 
and further guidance on the logic to be applied when applying one of the two provisions.   

Article 4(5) 

Equally, it is noted with concern the considerable increase in the use of Article 4(5) derogations for 
groundwaters. In the 2nd RBMPs, Article 4(5) was applied in one surface water body of the Danube 
RBD due to technical feasibility and disproportionate costs. In the 3rd RBMPs, one SWB was exempted 
based on grounds of technical feasibility and disproportionate costs (ecological status), seven GWBs 
based on grounds of technical feasibility (for quantitative status), five GWBs due to disproportionate 
costs (for quantitative status) and three GWBs based on grounds of technical feasibility (for chemical 
status) and one GWB due to disproportionate costs (for chemical status).  

For  surface  water  body  SKH0023,  a  justification  for  applying  Article  4(5)  exemption  is  provided, 
including details on the source of pollution, measures applied, technological and economic impact of 

8 The partial electronic reporting (which was only available for the Vistula RBD at the time of writing) has reported “all 
measures completed”. Delays, lack of finance and extreme events were reported as the only obstacles. 

25 

 
 
ensuring compliance at the manufacturing plant level. For groundwater bodies, the RBMPs contain 
water body specific descriptions and detailed justifications for applying Article 4(5) exemptions on 
the grounds of technical feasibility including details on the status, sources of pressures, measures 
planned and implemented, climatic and hydrogeological conditions etc. The application of Article 4(5) 
to GWBs was made on the grounds of technical feasibility and affected seven GWBs (quantitative 
status) and three GWBs (chemical status). 

It is noted positively that exemptions pursuant to Article 4(6) (temporary deterioration for reason of 
‘force majeure’) have not been applied. 

It is noted that Article 4(7) (deterioration or prevention of achievement of good status or potential 
as a result of new modifications or new sustainable human development activities) has been applied 
to 5 surface water bodies of the Danube and Vistula RBD, whereas it was not invoked in any case for 
the previous cycle. 

Figure 7 Type of exemptions reported to be applied to SWBs and GWBs for the 3rd RBMPs in Slovakia 

Note: updated numbers available at WISE e-reporting 

Source: Data mining  

There  has  been  a  steady  progress  on  transparent  application  of  Article  4  exemptions.  While  the 
overall  number  of  exemptions  remains  considerable  and,  in  some  cases,  increasing,  progress has 
been  made  in  relation  to  providing  clear  and  transparent  justifications,  albeit  not  in  all  cases  as 
required by the law. In particular, significant progress has been achieved in relation to justifying Article 
4(7) exemptions: the assessment of each exemption is very detailed; however, it is not entirely clear 
whether cumulative effects have been explicitly considered. 

5.2 Use of economic analysis and water pricing – cost recovery 

in  response  to  the  Commission’s 
The  RBMPs  present  an  enhanced  economic  analysis 
recommendations on the 2nd RBMPs. The table below reports on the presence in the RBMPs of the 
various assessment elements as listed in WFD Annex III.  

26 

 
 
The economic analysis takes into account long-term forecasts of water supply, but the corresponding 
water demand forecasts only run until 2027, i.e. the end of the programming period. While of course 
the Programme of Measures contains the investments until 2027, the strategic orientation of the 
investment efforts thus appears underdeveloped, i.e. whether the built-up capacity will be sufficient 
for the medium and long term, and how to combine investments with demand management, i.e. the 
extent  of  investments  in  water  use  efficiency.  While  the  economic  analysis  also  includes  volume 
estimates  associated  with  the  different  water  services,  differentiated  overuse  types /  sectors,  the 
presence and use of cost and price estimates for the water services could not be verified. 

Figure 8 Requirements under Annex III of the Water Framework Directive 

1 

2 

3 

4 

5 

6 

7 

long term forecasts of water supply  

differentiated over type of supply source 

long term forecasts of water demand 

differentiated over user type/sectors 

volume estimates for the distinct water services 

differentiated over user type/sectors 

cost and price estimates for the distinct water services 

differentiated over user type/sectors 

investment forecasts - total 

differentiated over type of supply source 

costing of measures 

judgements about the most cost-effective combination of measures 

The RBMPs provide the estimates of the potential costs of measures and the extent this is meant to 
be  financed  by  national,  private  or  EU  funding,  but  they  do  not  say much  about  the  use  of  cost-
effectiveness analysis (CEA) and more generally the criteria for prioritising measures.  For instance, 
while CEA is mentioned in the context of addressing hydromorphological pressures, river restoration 
measures  appear  to  have been  selected  at  the  hand  of  a  set  of “revitalisation  priorities”  with  an 
unclear role of the cost factor.  

The RBMPs do not provide a clear overall conclusion as to whether pricing policy provides adequate 
incentives  to  use  water  efficiently,  although  the  provided  information  seems  to  suggest  that  on 
balance limited to modest incentives have been put in place. The regulatory authority (the Office for 
Regulation  of  Network  Industries)  sets  a  single  combined  tariff  for  the  two  broad  water  services 
'drinking water provision' and 'sanitary services', based on “economically justified costs” and this cost-
based price setting is reportedly applied uniformly across Slovakia and over the household, industrial 
and agricultural sectors. This tariff is based on a unit rate applied on consumption volumes, with a 
threshold below which no price is charged (a variant of a social tariff). Moreover, there is a fee applied 
to water used for hydropower generation, while the unit rate of water abstraction is the same for 
public water supply systems and for industry.  

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
However, the RBMP offers evidence that groundwater abstraction charges should be higher for all 
sectors,  with  the  exception  of  drinking  water,  and  that  from  an  efficiency  perspective,  prices  for 
irrigation  water  abstraction  should  gradually  increase  up  to  the  level  of  drinking  water  prices. 
Nevertheless, it appears that the RBMPs have not opted for this course of action as this would bring 
undesirable social and economic impacts on the agriculture sector. Similar to the pricing threshold 
applied  to  drinking  water  consumption,  this  appears  to  concern  an  implicit  call  on  the  mitigation 
factors on water services’ cost recovery as foreseen in article 9 of the WFD.  

The RBMP reports for the period 2016-2018, (nearly) full cost recovery rates for the collective water 
supply and sanitation services and high recovery rates for the other us water services (with only a 
few incidental exceptions). Because a lack of a sectorial breakdown, there does not seem too much 
specific and quantitative corroboration of the RBMPs’ general assurance that the three broad water 
user sectors (agriculture, industry and households) provide an adequate contribution to cost recovery.  

There does not appear to be a comprehensive appraisal of the environmental and resource costs, as 
the national methodology is reported to be still under development. For now, these costs are assumed 
to be largely captured by the revenues of water abstraction and pollution fees in place. However, as 
regards the former, it is unclear whether abstraction fees can vary with scarcity conditions; and as 
regards the latter, there is no account that the fee rates reflect the actual environmental damage 
costs and that the fee captures all pollution. This qualifies the RBMPs’ statement that the polluter 
pays principle has been applied in the cost recovery efforts. 

6. WFD recommendations 

Recommendations - Slovakia should: 

1. 

Increase the level of ambition and accelerate action to reduce the compliance gap as much as possible by 
2027. This implies: 

a) 

the development of more robust Programmes of Measures based on a clearer assessment of the gap 
to be bridged to reach good status and a clearer prioritization of measures. 

2. 

Identify and put in place, as appropriate, additional measures to reduce existing persistent environmental 
challenges  (pressures)  preventing  the  achievement  of good status based  on  robust  gap  analyses.  This 
implies for example: 

a)  Slovakia should develop more robust Programmes of Measures based on a clearer assessment of the 
gap to be bridged to reach good status and a clearer prioritization of measures. Also, the programme 
of measures should identify for each measure how success (or failure) of a measure will eventually be 
measured, allowing for feedback loops and improvements; 

b)  Slovakia should enhance measures to reduce pressures from agriculture by adopting measures also 
beyond voluntary measures subsidies under the CAP Strategic Plan and reduce impacts on surface 
water bodies; 

c)  Slovakia should provide information on how mitigation measures improve the status of various BQEs. 

d)  Slovakia  should  take  all  necessary  mitigation  measures  to  reduce  the  harmful  impacts  of  (small) 
hydropower plants installed along river Hron and other rivers. These measures are necessary to allow 

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these water bodies to make progress towards reaching good status by end of 2027 as foreseen by the 
Water Framework Directive. 

3.  Slovakia should increase investments and ensure adequate financing including implementation of cohesion 
funding to effectively implement the Programme of Measures to reach the objectives of the WFD. This 
involves in particular: 

a)  Slovakia  should  more  explore  possibilities  of  make  polluters  pay  (Article  9  WFD),  to  clean  up 
contaminated  industrial  sites  (especially  for  pollution  from  agriculture  brown  fields)  and  reducing 
nutrient and pesticide pollution; 

b)  Slovakia should do a proper assessment on funding needs and reflect them in the RBMPs. 

4.  As regards monitoring, assessment, data management and reporting, Slovakia should: 

a)  define a methodology for ecological flows based on CIS Guidance No. 31 and apply it in practice when 

granting water permits; 

b)  establish the nutrient and pesticide load reduction needed to achieve the environmental objectives; 

c) 

In cooperation with the Commission and the EEA, ensure timely reporting in line with WFD requirements 
and more complete electronic reporting for future cycles, and make better use of the opportunities 
from digitalisation and earth observation to enable a better assessment of the state of implementation 
of the WFD and reduce reporting burden; 

d)  Further  improve  data  quality  and  data  comparability  by  harmonising  methods  and  electronically 
collected data across RBDs, on monitoring, assessments, projections, economic assessment, etc. and 
make all data openly available through timely publication in line with the requirements of the INSPIRE, 
Open Data and Public Sector Information Directive (PSI) Directives and the public sector High Value 
Datasets  (Commission  Implementing  Regulation  (EU)  2023/138)  to  help  eliminate  the  need  for 
reporting. 

5.  On the use of economic tools, Slovakia should: 

a) 

b) 

improve price incentives and application of the polluter-pays principle (PPP); 

transparently and more clearly report on the economic analysis. 

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SECTION B: 
FLOODS DIRECTIVE 

30 

 
 
 
7. Flood risk management under floods directive (FD) 

Slovakia has failed to comply with its legal obligation and has not reported the 2nd FHRMs and the 
2nd FRMPs in time. The Commission has thus been bound to launch legal proceedings.  

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