Response to the Green Paper: Interconnection of business registers
                      Slovak Republic
        At the outset it is important to mention that the Ministry of Justice of the
Slovak Republic (hereinafter the "Ministry") is currently finishing the internal process
concerning the application for EBR membership. After unsuccessful effort to find an
entity that might become a member of the EBR EEIG on behalf of the Slovak
Republic, the informal Working group, established by representatives of the relevant
Ministry departments, has decided to submit the application only with regard to the
membership in the EBR ISA.

        The response of the Slovak Republic was elaborated after the consultation
within the Ministry taking into account the views of the judiciary (Registry Courts). In
general and in the light of the aforementioned, we generally prefer the EBR/BRITE as
the optimal solution for the enhanced partnership and interconnection of business
registers across the EU.

Question 1: ... whether an improved network of the business registers of the
Member States is necessary?

       Yes

Question 2: ... whether the details of such cooperation could be determined by a
"governance agreement" between the representatives of the Member States and
the business registries?

       The answer to the abovementioned question depends on the preferred solution
of the interconnection of business registers. If the first solution is chosen (to use the
results of the BRITE project and the connection to the EBR, i.e. the solution
preferred by the Slovak Republic) we would consider as an ideal tool an adoption of
the EU legal act which would provide for the closer cooperation/interconnection,
whereas the details with respect to the technical realisation of the
cooperation/interconnection could be dealt with e.g. a multilateral agreement
concluded among respective parties.

Question 3: ... whether we see any added value in connecting, in the long term,
the network of business registers to the electronic network set up under the
Transparency Directive storing regulated information on listed companies?

       We believe that that such interconnection might help to make the access of the
persons concerned (i.e. non-residential shareholders and creditors) to information
needed for the exercise and protection of their rights and legitimate interests easier.

Question 4: ... which solution or a combination of the solutions we favour to
facilitate communication between business registers in the cases of cross-border
mergers and seat transfers?

       The Slovak Republic prefers the EBR/BRITE solution. Taking into account
increased demands on the information exchange (e.g. the exchange of information
about branches of the enterprises of the foreign persons) we are of the opinion that
there is a need for the constant interconnection and automated control/check and
comparison as regards the content of the register of the branch and register of the
respective foreign person. IMI is currently not able to provide this functionality,
although we can imagine the use of IMI as a transitional solution.

Question 5: ... whether we support the proposed solution on the disclosure of
branches?

        It is the task (and in the interest) of every business register to maintain data
concerning registered entities correct and up to date. The same applies with respect to
branches. However, we would prefer to deal with the interconnection only in one
European legal instrument. The exchange of data concerning branches would be a
logical consequence of the interconnection, which would be achieved probably
without a need to create a formal obligation in another legal instrument.
