Financial Administration steps up tax arrears recovery: what to do before tax enforcement begins

In 2026, the Slovak Financial Administration is recovering tax arrears faster and with greater success, shortening the time between the tax due date and the first actual intervention. Over the first four months of the year, tax enforcement officers collected more than 107 million euros for the state budget, approximately 7.8 million euros more than a year earlier. The recovery success rate exceeded 45%, representing a year-on-year increase of 8 percentage points, and 13 797 tax enforcement proceedings were initiated by 30 April 2026. Companies and sole traders should therefore verify even seemingly minor or administratively generated arrears and address them without undue delay.

Tax arrears do not originate only upon the commencement of enforcement. They arise as soon as the due tax amount is not paid properly and on time.

When tax arrears arise

The Slovak Tax Code defines tax arrears as an outstanding tax amount past its due date. A lack of financial liquidity is not the only cause. Arrears can also occur due to payment to an incorrect bank account, using an erroneous variable symbol, remitting an incorrect sum, or when funds are debited from the bank account after the due date.

Confirming that the company sent the payment is therefore insufficient. It is equally important that the Financial Administration correctly identified and allocated the payment to the specific tax liability. Proper payment recording can be verified online.

Verifying tax arrears in the Saldokonto

You can review the status of your personal tax account in the Personal Internet Zone of the Financial Administration under the Saldokonto section. Unpaid assessments, unallocated payments, and payments made after the due date are displayed there. All data reflects the status as of the previous day.

If the figures do not correspond with your accounting records or bank statements, contact the tax administrator and prepare proof of payment with the date, amount, variable symbol, and bank account number. Such discrepancies can often be clarified or eliminated before enforcement begins.

Significance of the 170-euro threshold

The 170-euro threshold is applied in the Tax Code in two specific situations, but it does not represent a general threshold for initiating tax enforcement:

• The Financial Directorate publishes a list of tax debtors containing entities with aggregate tax arrears exceeding 170 euros. The list is updated monthly, is publicly accessible, and specifies the business name, registered seat, and arrear amount.
• An arrear whose aggregate amount across all taxes does not exceed 170 euros is classified by law as a temporarily unenforceable arrear. This does not represent forgiveness or cancellation of the debt. If the debt increases or additional obligations arise, the situation changes.

Neither of these two situations determines when the tax administrator proceeds with recovery.

Risk of tax enforcement

The law does not establish a minimum amount for initiating tax enforcement. Practical experience shows that tax offices follow a graduated approach. For arrears roughly between 170 and 1 000 euros, a reminder or demand for payment is generally issued first. For amounts exceeding 1 000 euros, the risk increases that the file will be transferred directly to the enforcement department without further delay.

This is not a statutory threshold or an official rule of the Financial Administration, but an observation from practice.

Addressing such arrears should therefore not be postponed in the expectation that the tax administrator will always issue a reminder first.

Changes in tax enforcement from 1 September 2026

Technical enforcement capabilities are also changing. Act No. 131/2026 Coll., amending the Tax Code, allows the creation of a lien and the commencement of tax enforcement proceedings on a motor vehicle to be recorded directly in the vehicle register electronically. The tax administrator may also arrange the location, towing, impoundment, and appraisal of the vehicle. A new coercive measure is the electronic retention of the vehicle registration certificate.

For companies operating a vehicle fleet, this means measures against a vehicle can occur rapidly without prior physical contact with a tax enforcement officer.

Tax enforcement procedure

1. Demand for payment of arrears. The tax administrator sets an additional period of at least 15 days. An objection may be filed within 15 days and has suspensive effect. However, the law does not impose the demand as a mandatory requirement.
2. Commencement of tax enforcement proceedings. The decision takes legal effect on the day of issuance, no appeal is admissible, and it is not served on the debtor. It is served on entities subject to the asset disposal prohibition, such as the bank.
3. Tax enforcement notice. Specifies a deadline of up to eight days to pay and designates the assets subject to enforcement. An appeal may be filed within 15 days, strictly on statutory grounds.
4. Tax enforcement order. Issued after the deadline expires without payment. It takes legal effect on the date of issuance, and no legal remedies against it are admissible.

Impact of tax enforcement on a company

The method of enforcement is chosen by the tax administrator, who may apply multiple methods simultaneously against a single debtor. The Tax Code permits in particular:

• garnishing receivables, including funds held in bank accounts,
• executing deductions from wages or other income,
• seizing cash or selling movable property, securities, or real estate,
• seizing property rights in a commercial company or selling the enterprise or part thereof,
• suspending a driving licence when statutory conditions are met.

Tax enforcement therefore does not merely entail additional financial costs. Freezing funds, restricting the disposal of assets, or disrupting operations can affect payroll, supplier payments, and the company's day-to-day operations.

Default interest

Default interest is added to the debt amount. Its annual rate is four times the basic rate of the European Central Bank, but at least 15%. It is calculated for each day of delay, for a maximum of four years. At a 15% rate, delay on arrears of 10 000 euros over one year would result in interest of approximately 1 500 euros. Interest is not assessed if it does not exceed 5 euros at a tax or customs office.

Limitation period and expiry of the right to enforce arrears

The right to enforce tax arrears is subject to a limitation period of six years following the end of the calendar year in which the arrears arose. Limitation is not applied automatically; the debtor must raise an objection. Serving a demand for payment starts a new six-year period, and the right to enforce arrears expires definitively after 20 years. One cannot rely merely on the lapse of time when dealing with tax arrears.

Steps to take after discovering tax arrears

Identified arrears must be reviewed without undue delay. We recommend contacting your accountant or tax advisor, who can verify whether the recorded arrears correspond to submitted tax returns, decisions, and completed payments, helping to identify any discrepancy. We subsequently recommend proceeding as follows:

1. Compare the Saldokonto with tax returns, decisions, bank statements, and internal records.
2. Verify the bank account number, variable symbol, amount, and debit date of each disputed payment.
3. If arrears are recorded correctly and liquidity permits, settle them as soon as possible and check the accounting entry.
4. If you disagree with the records, contact the tax administrator and submit supporting documentation.
5. Request a deferral of tax payment or an instalment payment schedule if a lump-sum payment is unrealistic. Do not wait for a tax enforcement notice.

Deferral of tax payment and instalment plans

If a company lacks sufficient funds for a lump-sum payment, it may apply for a deferral of tax payment or an instalment payment schedule. Applications are decided on an individual basis. Recognized grounds include a drop in revenue following an extraordinary event, substantial restriction of business activity, threat to basic subsistence, or other serious and provable reasons. Financial statements and cost documentation must accompany the application, along with a realistic instalment schedule. Approval may be conditional on providing security for the debt amount. The application is submitted electronically, and the administrative fee is 7 euros.

A deferral or instalment plan may be granted for a maximum of 24 months from the original due date, and interest of at least 3% per annum is payable during this period. Companies with a high tax reliability index do not need to prove the specific conditions.

If an instalment or deadline is not met, the entire unpaid balance becomes due as of the original due date. Default interest is then charged, and the law requires tax enforcement proceedings to begin within 30 working days. An instalment payment schedule must therefore be based on realistic cash flow rather than optimistic projections.

Prevention of tax arrears

Most problems can be prevented through simple control mechanisms: designating a responsible person for each tax, maintaining a calendar of deadlines, and verifying payments after dispatch. For larger sums, it is advisable to check the bank's daily transfer limit in advance. Review the Saldokonto particularly after filing a tax return, paying tax, and receiving a tax decision.

A company should clearly designate who prepares the payment, who approves it, and who verifies that it has been properly recorded. A double check before the due date identifies errors before penalties arise. If arrears have already arisen, discuss them as soon as possible with your accountant, tax advisor, and tax administrator.

Frequently asked questions about tax arrears

How do I find out if I have tax arrears?

You can find your account balance in the Personal Internet Zone of the Financial Administration under the Saldokonto section. Data is displayed reflecting the status as of the previous day and includes unallocated payments. You may also verify the status directly with the competent tax administrator.

At what amount can tax enforcement begin?

The law does not set a minimum amount. The sum of 170 euros represents the threshold for publication on the list of tax debtors and for temporarily unenforceable arrears, not for initiating enforcement. Practical experience indicates that the risk increases significantly for arrears exceeding 1 000 euros.

Must the Financial Administration warn me before tax enforcement?

No. Issuing a demand for payment of tax arrears is an option for the tax administrator, not a statutory obligation. If a demand is sent, an additional period of at least 15 days is granted. Relying on receiving a prior reminder involves significant risk.

Can the Financial Administration freeze an account without prior notice?

The decision on the commencement of tax enforcement proceedings is not served on the debtor; it is served on parties such as the bank. Freezing funds on an account can therefore occur before you receive a tax enforcement notice.

Is interest charged under an instalment payment schedule?

Yes. Interest is at least 3% per year for the entire approved period. This is substantially lower than default interest of at least 15% per year.

^{The content of this article is for informational purposes only and in no way replaces professional legal, tax, or accounting advice. The company Dravecký & Partner bears no responsibility for any decisions made based on the information provided herein, nor for any potential damage that might arise from such actions. Before applying any information to your specific situation, we strongly recommend consulting with a qualified expert.}