On 9 August 2025, the Agency of the Republic of Slovenia for Public Legal Records and Related Services (AJPES) restricted public access to data on beneficial owners of legal entities in the Beneficial Owner Register (RDL). This change implements amendments to the Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2C) and aligns Slovenia with a landmark 2022 ruling of the European Court of Justice (ECJ).
Background: ECJ Ruling On 22 November 2022, the ECJ ruled that open public access to EU member states’ beneficial owner registers is invalid. The Court found such unrestricted access to be a serious interference with the fundamental rights to privacy and data protection under Articles 7 and 8 of the EU Charter of Fundamental Rights.
Under the Fourth Anti-Money Laundering Directive (AMLD), access to these registers was limited to those with a legitimate interest. The Fifth AMLD, adopted in 2018, removed this limitation and mandated full public access. The ECJ decided that while the fight against money laundering and terrorist financing is an objective of general interest, unrestricted public access was neither necessary nor proportionate to achieve that goal. Access must again be based on proving a legitimate interest.
New Access Rules in Slovenia Following the legislative change, the following groups may now obtain beneficial ownership data in Slovenia:
Obliged entities under Article 4 of ZPPDFT-2 (such as financial institutions and certain professionals)
Law enforcement authorities, courts, parliamentary investigative commissions, and supervisory authorities
Individuals and legal entities that demonstrate a legitimate interest as defined in Articles 51 and 51a of ZPPDFT-2
Access is granted through an application process with AJPES.
Impact for Businesses and Compliance Companies and professionals relying on open access for due diligence will now need to adjust procedures. Access will depend on meeting the legal requirements for legitimate interest and submitting formal requests. While the ECJ reaffirmed the importance of anti-money laundering measures, it also emphasized the need to balance transparency with privacy and data protection.
SIBIZ advises all businesses, investors, and compliance officers to review their internal KYC and due diligence processes in light of the new rules. Our team supports corporate clients and business professionals in navigating Slovenian and EU compliance requirements.
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