Slovakia

**Report: Retail Cryptocurrency Trading Status in Slovakia**

**Date:** April 12, 2025

**Analyst:** Specialized Financial Regulatory Analyst

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**Topic: Retail_Trading_Status**

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

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**1. Current Status:** `Allowed-Regulated`

**2. Detailed Narrative Explanation:**

In Slovakia, individual citizens and residents are legally permitted to buy, sell, and hold cryptocurrencies for their own accounts. There is no specific license required for individuals engaging in personal crypto trading activities.

However, the provision of crypto-asset related *services* is a regulated activity. Historically, and until the full implementation of the EU's Markets in Crypto-Assets (MiCA) regulation, entities providing services such as virtual currency exchange or virtual currency wallet services were required to obtain a specific trade license from the Ministry of Interior's Trade Licensing Office, as mandated by amendments to the Trade Licensing Act (Act No. 455/1991) and the Act on the Protection against Money Laundering and Terrorist Financing (Act No. 297/2008, as amended, notably by Act No. 279/2020 Coll.). These service providers were, and remain, subject to stringent Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) obligations. This includes implementing Know Your Customer (KYC) procedures, customer due diligence, transaction monitoring, reporting suspicious activities to the Slovak Financial Intelligence Unit, and appointing an AML officer.

The regulatory landscape is currently undergoing a significant transition due to the implementation of the EU's MiCA regulation. Slovakia has transposed MiCA into national law via Act No. 248/2024 Coll. on Certain Obligations and Authorisations in the Field of Crypto-Assets. As of December 30, 2024, the National Bank of Slovakia (NBS) became the designated competent authority responsible for supervising the crypto-asset market and authorizing Crypto-Asset Service Providers (CASPs) under MiCA.

A grandfathering period is in effect for entities that were already authorized to provide virtual currency exchange or wallet services under the previous trade license regime before December 30, 2024. According to the National Bank of Slovakia, these entities may continue their operations under the old rules until December 30, 2025, at the latest. After this date, they must obtain a full MiCA authorization from the NBS to continue providing regulated crypto-asset services. The NBS is actively preparing for its supervisory role, planning workshops, accepting pre-licensing dialogue requests, and issuing decrees related to CASP reporting requirements (effective July 1, 2025).

While cryptocurrencies are not considered legal tender or financial instruments under specific Slovak laws (like Act No. 566/2001 on securities), they are recognized as digital assets. Income derived from cryptocurrency transactions (e.g., exchange for fiat, other crypto, goods, or services) is subject to taxation under Slovak law, with specific guidance issued by the Ministry of Finance. The NBS and other authorities have also issued warnings regarding the risks associated with investing in and trading cryptocurrencies.

In summary, while individuals can freely trade crypto, the service providers facilitating these activities operate within a regulated environment, transitioning from a trade-licensing and AML-focused regime to a comprehensive MiCA framework supervised by the National Bank of Slovakia.

**3. Supporting Excerpts/Summaries:**

*   **On Individual Trading:**
    *   "Individuals do not need any kind of licenses to trade their own funds." (Source: LegalBison, Dec 10, 2024)
    *   "Natural and legal persons buying /selling crypto-asets on their own account and who do not provide any crypto-asset services as it is defined in Art. 3 section 1 MiCA do not need any authorization from NBS." (Source: National Bank of Slovakia - Crypto-assets FAQ)

*   **On Service Provider Regulation (Pre-MiCA/Transition):**
    *   "Considered a trade, cryptocurrency activities require a registration for a Trade License in Slovakia. The Trade Licensing Act of 1991, last amended in 2020 and now in force, describes two trade activities pertaining to crypto: providing virtual currency exchange services and providing virtual currency wallet services." (Source: LegalBison, Dec 10, 2024)
    *   "...based on Act No. 279/2020 Coll., which is amending Act No. 297/2008 on the prevention of legalization of proceeds from criminal activity and terrorist financing, all businesses engaged in exchange services between virtual currencies and fiat currencies and custodian wallet providers for virtual currencies will need to be registered by Trade Licensing Office, in order to provide these services in Slovakia." (Source: National Bank of Slovakia - Crypto-Assets and ICOs FAQ)

*   **On AML/KYC Requirements:**
    *   "Slovakia's domestic AML law, “Act on protection against money laundering and terrorist financing” issued in 2008 and amended lastly in 2020, compiles the rules and requirements that apply to crypto businesses in Slovakia: KYC and client due diligence, transaction monitoring and reporting, etc." (Source: LegalBison, Dec 10, 2024)
    *   "All crypto asset related service providers need to follow the rules on identification and due diligence of their clients, establish internal policies, report suspicious activities and other AML/CTF requirements." (Source: CMS Law, Sep 6, 2023)

*   **On MiCA Implementation and NBS Role:**
    *   "Market with crypto-assets will soon make part of the regulated financial market. For the provision of activities concerning crypto-assets, it will be necessary to obtain authorization from the national competent authority in charge of supervision, which is, in the Slovak Republic, National Bank of Slovakia." (Source: National Bank of Slovakia - Crypto-assets)
    *   "The provisions of the MiCA Regulation relating to the provision of crypto-asset services began to apply on 30 December 2024." (Source: National Bank of Slovakia - Crypto-assets)
    *   "Slovakia has transposed MiCA into Act No. 248/2024 Coll. on Certain Obligations and Authorisations in the Field of Crypto-Assets." (Source: Kinstellar, Undated, accessed Apr 2025)
    *   "The Bank Board discussed and approved an NBS Decree on reporting by crypto-asset service providers (CASPs). [...] The Decree takes effect on 1 July 2025." (Source: National Bank of Slovakia - Press Release, Mar 25, 2025)

*   **On the Grandfathering/Transition Period:**
    *   "Persons who were authorized in the Slovak Republic to provide virtual currency exchange services or virtual currency wallet services before 30 December 2024 may continue to perform crypto-asset related services until 30 December 2025 at the latest. After this date, only entities that hold an authorization to provide crypto-asset services issued by the National Bank of Slovakia or the competent foreign supervisory authority will be allowed to carry out such activities." (Source: National Bank of Slovakia - Crypto-assets)
    *   "...Slovakia's transition period will end on 30 December [2025]..." (Source: KassaiLaw, Nov 20, 2024)

*   **On Taxation:**
    *   "On March 23, 2018, the Ministry of Finance published guidance explaining that revenues stemming from cryptocurrencies must be taxed and that any type of exchange... must be considered to be a taxable transfer." (Source: Freeman Law, citing Ministry of Finance 2018 guidance)

**4. Source URLs:**

*   **National Bank of Slovakia (NBS) - Crypto-assets Page:** https://nbs.sk/en/financial-market-supervision/subjects-of-the-financial-market/crypto-assets/ (Primary Source)
*   **National Bank of Slovakia (NBS) - Crypto-Assets and ICOs FAQ:** https://nbs.sk/en/financial-market-supervision/nbs-position-statements/crypto-assets-and-initial-coin-offerings-icos/ (Primary Source)
*   **National Bank of Slovakia (NBS) - Press Release March 25, 2025:** https://nbs.sk/en/press/press-releases-nbs/statement-from-the-nbs-bank-boards-5th-meeting-of-2025/ (Primary Source)
*   **LegalBison - Slovakia Crypto License:** https://legalbison.com/crypto-license/slovakia/ (Secondary Source - Legal/Consulting Firm)
*   **CMS Law - Expert Guide to Crypto Regulation in Slovakia:** https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-regulation/slovakia (Secondary Source - Law Firm)
*   **Kinstellar - MiCA Implementation Status:** https://www.kinstellar.com/insights/detail/1835/navigating-the-legal-landscape-the-implementation-status-of-mica (Secondary Source - Law Firm)
*   **KassaiLaw - MiCA Grandfathering Period:** https://kassailaw.com/are-you-ready-for-mica-grandfathering-period-explained/ (Secondary Source - Law Firm)
*   **Freeman Law - Slovakia and Cryptocurrency:** https://freemanlaw.com/slovakia/ (Secondary Source - Law Firm)