Slovenia - Financial Administration

(Section: "Markets and Jurisdictions")

1) Slovenia in a nutshell

Slovenia is a member of the EU and the eurozone, a compact market with a sustainable tourist component (ski resorts, thermal spas, lakes). Gambling is allowed in the form of "classic" (lotteries, sweepstakes) and "special" games (casinos, slots, tables), and online formats are tied to the concession system. The tax control function is concentrated in the Financial Administration of the Republic of Slovenia - FURS (Finančna uprava RS), under the auspices of the Ministry of Finance.

2) Map of regulators and roles

Parliament/Government - set the framework through the Gambling Act and by-laws.
Ministry of Finance - policy, coordination, concession announcements.
FURS (Financial Administration) - administration of taxes and fees of the industry, desk/field inspections, collection. Interaction channel - eDavki portal.
Oversight of AML/CFT - in conjunction with the national financial intelligence unit; compliance with the requirements - by the operator, control - by FURS and specialized bodies.
Bank of Slovenia/Payment providers - compliance with PSD2, local payment features, blocking by decisions of the authorities.
Consumer protection and advertising bodies - control of labeling, promotional restrictions, age barriers.

3) Admission model: types of games and online

Classic games: state-controlled lotteries/sweepstakes under a separate concession.
Special games: Casino and gaming parlors by concession (usually via tender/tender, with limits on numbers and locations).
Online games: offered by holders of existing concessions (or their affiliated structures) when meeting technical and tax requirements. There is no free "passporting" of EU licenses - there is a national tolerance system.

4) Payments to the budget: how taxation works

• Gaming fee/tax on GGR (separately by game type - casino/slots/tables, online; method: GGR = bets − winnings).
• Concession payments/contributions - fixed/formula part, sometimes linked to turnover/result.
• Corporate income tax is the standard CIT rate applicable to legal entities in Slovenia.
• VAT is usually an "exemption" for bets/winnings, but the taxability of related services (marketing, IT, hosting) is assessed separately.
• Taxation of individuals' winnings - depends on the type of game and threshold; the operator must know the holding/reporting mode.
• Fees - registration/administrative fees, publications, apostilles, etc.

Reporting base and periods

The tax base for GGR is maintained for each type of game and channel (online/offline).
Frequency - typically monthly settlement submission via eDavki + annual summary reporting and audited financials.
Primary registers: billing, sessions, RNG/certification logs, jackpot registers, player deduction tables.

5) Administration via eDavki (FURS)

Registration: tax number, registration, issuance of a qualified signature for eDavki.
Forms: special game declarations, CITs, deductions from winnings, reports on employees and counterparties.
Control: automatic desk checks (comparison of reports and payments), clarification requirements, possible adjustments.
Payments: SEPA/bank transfers, hard deadlines; late fees.
Storage: registers and primary within the prescribed period (usually 5-10 years), protected storage of logs.

6) AML/CFT and responsible gaming

KYC/KYB: multi-level identification (remote with video verification is allowed when executing local rules), verification of PEP/sanctions, source of funds for triggers.
Transactional monitoring: limits, atypical patterns, connection with anti-fraud and payment gateways.
Responsible play: self-exclusion (local lists), deposit/bet/time limits, forced "timeouts," visible warnings and links to help.
Reporting: suspicious transactions in FIU, storage of KYC dossier and audit logs.

7) Technical requirements and certification

RNG/game engines: certificates from recognized laboratories, periodic recertification.
Infrastructure: reliable hosting/cloud with logging, unchanging logs, backup, DR plan.
Integration: if necessary - online access of the regulator to reporting showcases/logs, uploads in a given format, API for GGR control.
InfoBase: data encryption at rest/in transit, secret management, regular penetration tests and vulnerability scans.

8) Advertising, promo and communications

Age restrictions and "responsible" markings are mandatory.
Prohibitions: aggressive offers, the promise of "guaranteed winnings," targeting minors, misleading mechanics.
Bonuses: transparent T & Cs, wagers, limits and deadlines; net gross/net accounting in the tax base.
Affiliates: contracts, creative control, clear KPIs and compliance evidence logs.

9) Checks, coercive measures and sanctions

Office: on discrepancies in e-form, GGR anomalies, player complaints.
Field: audit of cash desk/systems, accounting of jackpots, sample survey of staff.
Sanctions: fines, additional charges, penalties; in case of gross violations - suspension of activities, revocation of permits, blocking of payment channels and domains.
Mitigating factors: self-correction, notification of identified errors, implementation of corrective measures.

10) Payments and localization

EUR as account and reporting currency.
Methods: cards, bank transfers, local fintech channels, electronic wallets; compliance with PSD2/SCA.
Anti-chargeback: strict verification, 3-DSecure, accounting for "friendly" chargebacks, storage of evidence.

11) Market Entry Roadmap

1. Pre-evaluation: game model, channel (offline/online), group structure, beneficiaries.
2. Concession strategy: monitoring tenders, partnership with the concession holder, preparation of an application package.
3. Legal entity and bank account: charter, authorized capital (if required), KYC beneficiaries.
4. Tax statement and eDavki: issue of EDS, appointment of responsible persons.
5. Tech circuit: RNG/game certification, reporting showcases, logging, integration with payments.
6. Politicians: AML/KYC, RG, advertising/affiliates, complaint handling, DPA/GDPR.
7. Pilot and UAT: test reports in FURS formats, checking GGR formulas.
8. Go-Live: cut-off for migrations, freezing configurations, communications with FURS.
9. First 90 days: monthly declarations, internal controls, adjustments.

12) Compliance checklists

Financial Administration (FURS)

• Tax number and access to eDavki
• Tax representative/contacts assigned
• GGR uploads debugged by game type
• Declaration and Payment Calendar
• Auditor/Accounting Contracts

AML/KYC & RG

• Policies, monitoring scripts, triggers
• Data Providers (Sanctions/PEP) and SLAs
• Identification logs, document hashes
• List of self-exclusions and limits
• FIU Incident and Reporting Procedures

Equipment and information base

• RNG/Game Module Certifications
• Backup Plan and DR Tests
• DLP/encryption, key rotation
• Role-Based Access Models (RBAC)
• Non-replaceable logs (WORM/Write-Once)

Marketing & Affiliates

• Age filters and geo-targeting
• T&C Rebate Revision
• Approved Creative Directory
• Partner Audit Trail
• Creative Feedback Procedure

13) Frequent mistakes and how to avoid them

Mixing databases: offline/online and different types of games in one tax line. → Separate registers and reports.
Incorrect accounting of bonuses: there is no transparent logic for "gross/net." → Fix the policy and reflect it in the GGR.
Late declarations: penalties and blocking. → Keep a calendar, automate reminders.
Weak RG showcase: fines for promo without warning. → Update UX, add limits/timeouts.
Lack of tech logs: difficulties in checks. → Non-changeable logging and time stamps.

14) KPI and control metrics

Fiscal: the share of adjustments from FURS, the accuracy of GGR (discrepancy <0.5%), the timeliness of declarations (≥99%).
AML/KYC: verification SLA, false positives fraction, average escalation time.
RG: coverage limits, proportion of self-excluded, support response time.
Information base: MTTR on incidents, pentest coverage, percentage of closed vulnerabilities on time.
Marketing: the share of compliant creatives, the speed of reviews, the share of verified affiliates.

15) Launch FAQ

Is it possible to come with an external EU license?
No, work is required through the national concession/admission system.

Is B2B allowed without concession?
Technological B2Bs can operate under civil contracts, but all "B2C-face" requires concession level and tax reporting in Slovenia.

How to file reports?
Through eDavki, on time, with a breakdown by type of games and channels.

Do I need a local legal entity?
For concession/operations, yes; for pure B2B integrator - depends on the model (taxes, permanent establishment, contracts).

Important

Tax rates, calculation formulas and lists of documents are periodically updated by resolutions of the Ministry of Finance/FURS. Before submitting claims and first reporting, review the current requirements and form templates in eDavki and current bylaws.