Do you run an accounting firm or keep books as a sole trader? Then you are an obliged entity under the AML Act, and you must register in the goAML system even if you have never reported anything. Let us look at who has to register, which deadline to watch and how to fill in the application.
An accountant is among the obliged entities under the AML Act. According to the Financial Intelligence Unit (FIU), this means anyone who keeps books as the subject of their business, that is, a sole-trader accountant as well as an accounting s. r. o.
In the reasoning of its opinion, the FIU adds that bookkeeping should be the main subject of the business. In its conclusion, however, it speaks only of performing the activity of an accountant as a business activity. If you keep accounts for other companies only alongside a different main business, your status may not be clear-cut. It is safer to assume that you are an obliged entity, or to check directly with the FIU.
An in-house accountant who keeps a company’s books as its employee is not an obliged entity. An FIU opinion is not law, but in an inspection the FIU treats following it as acting in accordance with the Act.
For accountants the Act sets no threshold on the number of clients or turnover. It has such a threshold only for some other obliged entities, for example dealers in art or precious metals. An accountant with a single client is therefore an obliged entity as well.
The obligation to register was introduced by amendment No. 73/2026 Coll. with effect from 1 June 2026. The deadline depends on since when you have been an obliged entity:
If you started doing business between 1 June and 30 November 2026, the Act does not expressly say which of the two deadlines applies. The safe approach is to register within 30 days of starting business, and in any case by 30 November 2026. The FIU also has to approve the registration, so do not leave it to the last day.
goAML is a system of the Financial Intelligence Unit of the Presidium of the Police Force, through which reports of unusual business transactions are submitted.
From 1 June 2026 the report is submitted through this system. By other electronic means only when the system is not working. Previously the Act also allowed reporting in person, in writing or by telephone.
An unusual business transaction, even a mere attempt at one, must be reported without undue delay. Anyone who is not registered at that moment has no way to file the report and must still wait for the registration to be approved. That is why it pays to have access arranged before you need it.
The FIU may also write to you via goAML. Messages arrive in the “Správy” (Messages) tab, and for each new one the system sends a notification to your registered e-mail.
A PDF or an image of the document is enough.
Register on the production goAML portal. The Ministry of the Interior also publishes a training environment, but it serves only for training and testing.
At the bottom of the main page, click “Zaregistrovať sa” (Register) and choose “Povinná osoba” (Obliged entity). User registration is intended only for further people from an already registered firm.
Mandatory fields are marked with an asterisk and highlighted in red. In the “Typ” (Type) field, choose the item that corresponds to the accountant’s activity. You add the address and telephone via the expandable sections “Adresy” (Addresses) and “Telefóny” (Telephones).
The administrator is the person who will be in charge of the firm’s access and will be the first contact for the FIU. The username must have at least four letters or digits and must not contain spaces. The FIU recommends starting it with an abbreviation of the firm.
In the “Prílohy” (Attachments) tab, upload a document prepared according to your legal form, either by dragging it with the mouse or via “Vybrať súbory” (Select files).
The tab “Náhľad a registrácia” (Preview and registration) opens only after all mandatory fields are filled in. Check the details, copy the code from the image and click “Registrovať” (Register).
First you receive an e-mail saying that the application has been submitted. The FIU then approves the registration, and once it is approved the administrator receives an e-mail with the firm’s details, including the goAML Reporting Entity ID. Keep this e-mail, as you will need the identifier when adding colleagues.
You log in with the username and password from your registration. If two-factor authentication is on, you also add a code from the Google Authenticator app or a code sent to you by e-mail.
Another person registers via user registration and first enters your firm’s goAML Reporting Entity ID. Their application is approved by the FIU or by your firm’s administrator.
Every obliged entity must have a written own-activity programme in Slovak, adapted to the size and activity of the firm and approved by its statutory representative. The programme describes how the firm vets clients, assesses risks and retains data.
The programme must also designate a specific person in charge of reports and contact with the FIU. If this is not the statutory representative, it must be a managerial employee. The administrator in goAML and this person do not automatically have to be the same individual.
Employees who perform tasks under the AML Act must be familiarised with the programme at least once per calendar year and always before they start such work.
An accountant who works only for another accounting firm, has no clients of their own and follows that firm’s programme does not need an own programme. This exception, however, concerns only the programme. Registration in goAML remains mandatory.
When goAML is not working, the report is submitted by other electronic means that guarantee the information does not reach an unauthorised person. Send questions about the system to goaml.support@minv.sk.
The FIU may impose a fine for failing to meet the registration obligation. For a breach of § 21 it is up to €1,000,000, and for a breach of obligations that the Act does not list separately, up to €200,000. Missing the transitional deadline of 30 November 2026 is a breach of § 36d, which is not among the separately listed obligations. The Act does not say expressly which limit applies to it.
When setting the amount of a fine, the FIU takes into account the seriousness and duration of the breach, its consequences, cooperation during the inspection, the size of the firm and whether the breach is repeated.
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