Methodological Guidance of the Financial Market Supervision Departments of the National Bank of Slovakia of 20 April 2026 No. 3/2026 on Demonstrating the Suitability of Persons Proposed and Holding Positions under Section 7(2)(e), Section 8(2)(j) and Section 20a(11) of the Banking Act

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_________________________________________________________________________________________ Methodological Guidance of the Financial Market Supervision Departments of the National Bank of Slovakia of 20 April 2026 No. 3/2026 on demonstrating the suitability of persons proposed and holding positions under
Section 7(2)(e), Section 8(2)(j) and Section 20a(11) of the Banking Act

The National Bank of Slovakia, Financial Market Supervision Departments (hereinafter referred to as "NBS"), pursuant to Section 1(3)(a) point 3 and Section 2(9) of Act No. 747/2004 Coll. on Supervision of the Financial Market and Amending Certain Acts, as amended (hereinafter referred to as the "Supervision Act"), in conjunction with Act No. 483/2001 Coll. on Banks and Amending Certain Acts, as amended (hereinafter referred to as the "Banking Act"), issues this methodological guidance.

Chapter 1
Article 1
Introduction
(1) The purpose of this methodological guidance is to specify in more detail the procedure for assessing and demonstrating compliance with the suitability requirements for natural persons who are to perform or perform a) in a bank 1 a function
1. member of the statutory body (board of directors),
2. member of the supervisory board,
3. person holding a key function 2;
b) in a branch of a foreign bank with its registered office outside the territory of a Member State 3 (hereinafter referred to as "branch of a foreign bank") a function
1. person managing the activities of the foreign bank 4,
2. member of the management committee, if established 5,
3. person holding a key function 6;
c) in a financial holding company 7 or mixed financial holding company 8
1. member of the statutory body,
2. member of the supervisory board,
3. person holding a key function 9.
(2) This methodological guidance further specifies the scope of information and supporting documents submitted by the bank 1, foreign bank 10 and branch of a foreign bank 11 (collectively "supervised entity") for the purpose of demonstrating compliance with the suitability requirements under
Article 2(1) to (4) of this methodological guidance.
(3) Unless otherwise provided in this methodological guidance, when assessing 1 § 2(1) of the Banking Act. 2 § 5(an) of the Banking Act. 3 § 2(8)(b) in conjunction with Section 8(1) of the Banking Act. 4 § 8e(1) of the Banking Act. 5 § 8e(3) of the Banking Act. 6 § 8e(2) of the Banking Act. 7 § 33a(1)(k) of the Banking Act. 8 § 33a(1)(s) of the Banking Act. 9 § 20a(5)(c) of the Banking Act. 10 § 2(7) of the Banking Act. 11 § 2(8) of the Banking Act.

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_________________________________________________________________________________________ the suitability of the physical persons and bodies of the bank or branch of a foreign bank as a whole, the provisions of the Joint Guidelines of the European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) on the assessment of suitability of members of the management body and persons performing key functions (EBA/GL/2021/06) (hereinafter referred to as the "Suitability Guidelines") 12 shall be applied appropriately.

Article 2
Definitions
(1) For the purposes of this methodological guidance, bodies are understood as a) of a bank
1. statutory body and
2. supervisory board;
b) of a branch of a foreign bank
1. persons managing its activities 13,
2. management committee, if established 14.
(2) For the purposes of this methodological guidance, the body of a bank and the body of a branch of a foreign bank are also collectively referred to as the "body of the supervised entity". (3) Persons performing key functions are understood for the purposes of this methodological guidance as a) procurator, b) head of the internal control department 15, which is
1. head of the risk management function,
2. head of the compliance function, and
3. head of the internal audit function;
c) chief financial officer 16, d) senior employee 17, e) person ensuring the performance of tasks related to the prevention of money laundering and terrorist financing 18, f) another person identified by the supervised entity, who operates within its organizational structure, and who, based on their scope of activity and assigned tasks, has a significant influence on the management of the supervised entity and who is not a member of the statutory body of the bank or the supervisory board of the bank. (4) A senior employee managing a bank's branch abroad and persons operating in positions under paragraphs (7)(a) to (e) in a bank's branch abroad are, for the purposes of this methodological guidance, considered to be persons performing key functions under paragraph (7) of this
article, and when assessing their suitability, the procedure shall be the same as for persons performing
key functions.
(5) Suitability, for the purposes of this methodological guidance, is understood as compliance with the requirements a) reliability 19 of members of the bodies and persons performing key functions in the supervised 12 Available on the website of the European Banking Authority (hereinafter referred to as "EBA") www.eba.europa.eu. 13 § 8e(1) of the Banking Act in conjunction with point No. 14 of the Suitability Guidelines. 14 § 8e(3) of the Banking Act. 15 § 5(ap) in conjunction with § 5(ao) of the Banking Act. 16 § 5(aq) of the Banking Act. 17 § 7(21) of the Banking Act. 18 § 20(2)(h) of Act No. 297/2008 Coll. on the Prevention of Money Laundering and Terrorist Financing and Amending Certain Acts, as amended. 19 § 7(2)(e) and § 8(2)(j) and both in conjunction with § 7(15) of the Banking Act.

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_________________________________________________________________________________________ entity, which includes
1. good reputation,
2. honesty and
3. integrity,
b) professional competence 20 of members of the bodies and persons performing key functions in the supervised entity, which includes appropriate
1. professional knowledge,
2. skills and
3. experience,
c) independent thinking of members of the bodies of the supervised entity, d) sufficient time commitment and number of positions held by a member of the body of the supervised entity 21, e) formal independence of members of the bank's supervisory board 22 and f) criteria for collective suitability of the bodies of the supervised entity 23. (6) Suitability of members of the bodies of the supervised entity is understood as compliance with the requirements under paragraph (5)(a) to (d). In the case of independent members of the supervisory board, compliance with the requirement under paragraph (5)(e) of this methodological guidance is also required. (7) Suitability of the bodies of the supervised entity as a whole is understood as compliance with the requirement under paragraph (5)(f) of this methodological guidance. (8) Suitability of natural persons performing key functions in the supervised entity is understood as compliance with the requirements under paragraph (5)(a) and (b) of this methodological guidance. (9) A natural person proposed for any of the positions under Article 1(1) is also referred to as a candidate for the purposes of this methodological guidance. (10) All references to "risks" in this methodological guidance include risks of money laundering and terrorist financing, environmental and social risks, governance and management risks, and information and communication technology risks.

Article 3
General Provisions
(1) The suitability requirements for physical persons proposed and holding positions listed in Article 1(1) and bodies of the supervised entity as a whole under Article 2(5) to (8) of this methodological guidance must be met throughout the entire duration of the performance of the function. (2) The supervised entity shall proceed when integrating the candidate into its organizational structure in such a way as to prevent the emergence of conflicts of interest in accordance with applicable legal regulations. (3) The supervised entity must have at least one member of the statutory body designated as responsible for fulfilling the requirements in the area of AML 24. This member of the statutory body must have appropriate knowledge, skills and experience regarding the identification and assessment of the risk of money laundering and terrorist financing and established policies, controls 20 § 7(2)(e) and § 8(2)(j) and both in conjunction with § 7(14) of the Banking Act. 21 § 7(2)(q) and § 8(2)(o) in conjunction with § 25(6), (11) and (12) of the Banking Act. 22 § 7(2)(q) and § 8(2)(o) in conjunction with § 23(1) and § 25(6) of the Banking Act. 23 § 7(2)(q) and § 8(2)(o) in conjunction with § 24(1) of the Banking Act. 24 For example, Act No. 297/2008 Coll. on the Prevention of Money Laundering and Terrorist Financing and Amending Certain Acts, as amended, and other relevant national and international legal regulations.

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_________________________________________________________________________________________ and procedures in these areas, and must also have good knowledge of the extent to which the bank's business model is exposed to the risk of money laundering and terrorist financing. (4) The supervised entity with permission to provide investment services, investment activities and ancillary services under Act No. 566/2001 Coll. on Securities and Investment Services and Amending Certain Acts, as amended (hereinafter referred to as the "Securities Act") and investing in securities on its own account must have at least one member of the statutory body (board of directors) responsible for providing investment services, investment activities and ancillary services under the Securities Act 25. (5) A bank with permission to perform the function of depositary under Section 2(2)(m) of the Banking Act is obliged to comply with the requirements under a special regulation 26. (6) In accordance with Section 2(17) of the Banking Act, provisions concerning the assessment of suitability shall apply appropriately to an investment bank. (7) For the purposes of proceedings under Article 4(1) of this methodological guidance, NBS is entitled to request, in addition to the information and documents mentioned in legal regulations and this methodological guidance, additional information and documents. NBS may also request an interview with the candidate for the purpose of examining their suitability. (8) All information, documents and attachments submitted to NBS within the proceedings under Article 4(1) must contain the particulars specified in special regulations 27 and the Suitability Guidelines. (9) The particulars of the application and its attachments are established in Section 16 of the Supervision Act. If an official certificate of authenticity of a document or signature was issued abroad, such official certificate must be authenticated by higher verification (superlegalization), which is performed by the diplomatic or consular representation of the Slovak Republic in the relevant state, except in cases where the document was authenticated by an Apostille clause by an official person in the signatory state of the Convention of 5 October 1961 on the Abolition of the Requirement of Legalization for Foreign Public Documents, or if superlegalization or authentication by an Apostille clause is not required under an international treaty to which the Slovak Republic is bound or under a special regulation 28.

Chapter 2
Assessment of Suitability
Article 4
Assessment of Suitability of Candidates and Bodies of the Supervised Entity by NBS (1) NBS assesses the suitability of candidates and bodies of a bank or branch of a foreign bank as a whole within the proceedings for granting:
a) banking license for the applicant to operate as a bank 29, b) banking license for a foreign bank to conduct banking activities 25 § 7(2)(e), (m) and (q) of the Banking Act in conjunction with Section 70(1)(c) of the Securities Act. 26 For example, Article 21 of Commission Delegated Regulation 2016/438 supplementing Directive 2009/65/EC of the European Parliament and of the Council regarding the obligations of depositaries (OJ EU L 78, 24.3.2016). 27 Banking Act, Supervision Act, and special regulation on the issuance of regulatory technical standards. 28 For example, Regulation (EU) No 2016/1191 of the European Parliament and of the Council of 6 July 2016 on promoting the free movement of citizens by simplifying the requirements for presenting certain public documents in the European Union and amending Regulation (EU) No 1024/2012. 29 § 7(1) of the Banking Act.

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_________________________________________________________________________________________ through its branch on the territory of the Slovak Republic 30, c) prior consent for the election or appointment of a person to the bodies of a bank or for the establishment of a person in a key function in a bank or its branch abroad 31, d) prior consent for the appointment of a person to the body of a branch of a foreign bank or for the establishment of a person in a key function in a branch of a foreign bank 32, e) prior consent for the establishment of a bank's branch abroad 33, f) prior consent for the acquisition of a qualifying holding in a bank or for such further increase in qualifying holding in a bank, by which the share in the bank's share capital or voting rights in the bank reaches or exceeds 20 %, 30 % or 50 % or by which such bank becomes a subsidiary of the person acquiring such share in one or several operations directly or acting in concert 34, g) prior consent for the merger, consolidation or division of a bank, financial holding company or mixed financial holding company 35 and h) consent for the continuation of the performance of the function 36. (2) If NBS learns of facts that could influence the fulfillment of the suitability requirements for persons under Article 2(1) to (8) or if it has reasonable suspicion that a violation is occurring or has occurred, or that there is an increased risk of violation of the provisions of a special regulation 21, it may, in proceedings under Article 4(1)(h) of this methodological guidance, re-examine the suitability of the person or persons. In proceedings under paragraph (1) (h), the supervised entity shall submit to NBS information and documents to demonstrate the suitability of the person concerned in accordance with this methodological guidance, which NBS shall determine within the act on the basis of which these proceedings are initiated at the initiative of NBS 36. (3) In applications under paragraph (1)(c) and (d), the fee according to a special regulation 37 is paid separately for each position for which the candidate under Article 1(1) is proposed. (4) The recommended template for the application under paragraph (1)(c) is published on the NBS website. (5) An application in proceedings under paragraph (1) must also include a candidate suitability questionnaire. The recommended template for the candidate suitability questionnaire for the purpose of assessing their suitability is published on the NBS website. (6) In proceedings under paragraph (1), NBS may request the submission of documents under Section 23 (11) of the Banking Act, namely a) individual declaration of a member of the statutory body of the bank and a person holding a key function, which defines their roles and responsibilities, and b) overview of responsibilities and persons who are part of the management system and control system, including details on information flows and lines of responsibility. 30 § 8(1) of the Banking Act.
31 § 9(4) of the Banking Act. 32 § 9(5) of the Banking Act. 33 § 23(8) of the Banking Act. 34 § 28(1)(a) of the Banking Act. 35 § 28g of the Banking Act. 36 § 9(15) to (17), (19) and (22) of the Banking Act. 37 Measure of the National Bank of Slovakia No. 5/2021 of 25 May 2021 on fees for acts of the National Bank of Slovakia, as amended.

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Article 5
Assessment of Suitability of Candidates and Bodies of the Supervised Entity by the Supervised Entity (1) The supervised entity is responsible for ensuring that natural persons proposed for positions under Article 1(1) and bodies of the supervised entity as a whole meet the suitability requirements under Article 3(2), with internal suitability assessment performed by the supervised entity in accordance with the provisions set out in Title VII of the Suitability Guidelines 7 namely a) in proceedings under Article 4(1), which are initiated upon submission of an application, b) in any changes to the composition of the bodies of a bank or branch of a foreign bank, c) in the re-appointment of members of the bodies of a bank or branch of a foreign bank, if the requirements regarding the position have changed or if the given member was appointed to a different position in these bodies, d) in the initiation of proceedings under Article 4(1)(h) and e) continuously, regularly and as necessary 23. (2) The supervised entity is obliged to perform an internal suitability assessment of persons under
Article 1(1)(a) to (c) of this methodological guidance under Section 9(8) of the Banking Act,
with regular internal assessment under the aforementioned provision performed at least once a year. (3) Regarding the internal assessment of a member of the body of the supervised entity under paragraph (2), the supervised entity shall prepare a written record containing at least the following information on the current assessment and reasoned evaluation a) knowledge, skills and experience of the candidate, b) good reputation, honesty and integrity of the candidate, c) independent thinking of the candidate as a member of the body of the supervised entity, d) formal independence of the candidate, e) sufficient time commitment and number of positions held by the candidate as a member of the body of the supervised entity, f) collective suitability of the body of the supervised entity and g) conclusion that the candidate is suitable for the proposed position with regard to their role and responsibilities and conclusion on the candidate's contribution to the collective suitability of the body of the supervised entity. (4) Regarding the internal assessment of a person holding a key function under paragraph (2), the supervised entity shall prepare a written record containing at least the following information on the current assessment and reasoned evaluation a) knowledge, skills and experience of the candidate, b) good reputation, honesty and integrity of the candidate, c) conclusion that the candidate is suitable for the proposed position with regard to their role and responsibilities. (5) If a member of the body of the supervised entity is to have their term of office expire and a new term of office in the same position and in the same supervised entity is to begin immediately, the applicant may refer to the information and attachments submitted within the immediately preceding proceedings for assessment of the candidate's suitability; this applies only to information and attachments in which no changes have occurred. (6) In proceedings under paragraph (1), which are initiated upon submission of an application, the applicant is obliged to attach to the application the current record of the internal assessment under paragraphs (3) and (4).

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Chapter 3
Suitability Criteria
Article 6
Reliability
(1) The candidate must meet the reliability requirement and be considered a person with a good reputation who acts honestly and with integrity. A natural person is considered reliable if they meet the requirements under Section 7(15) of the Banking Act. (2) Reliability in proceedings under Article 4(1), which are initiated upon submission of an application, is demonstrated primarily by a) an extract from the criminal record register of the Slovak Republic, which NBS obtains based on the submitted data; the recommended template for the data required to request an extract from the criminal record register of the Slovak Republic is part of the candidate suitability questionnaire template published on the NBS website, b) a foreign criminal record extract or similar certificate of integrity issued by the competent authority of the candidate's state of usual residence 38, whereby such extract or certificate is submitted from each state in which the candidate has had or has usual residence over the last 10 years, except for the extract from the criminal record register of the Slovak Republic with reference to point (a) of this article; documents must not be older than three months, c) proof of identity and d) information provided in Part G of the candidate suitability questionnaire.

Article 7
Professional Competence
(1) The candidate must meet the professional competence requirements, which enable them to understand the activities of the supervised entity and the main risks so that they can reliably perform their function, and they must also be familiar with their role and responsibilities in the supervised entity. (2) Professional competence for members of the bodies of the supervised entity includes adequate understanding of all areas regarding which the body of the supervised entity discusses or decides. (3) Professional competence for persons performing key functions in the supervised entity includes specialization/professional qualification in the area that this person is to manage or within which they are to perform activities. The accumulation of multiple areas is possible only in cases where legal regulations do not exclude it and no conflict of interest arises, in which case the candidate must demonstrate sufficient time commitment dedicated to all functions in accordance with
Article 14 of this methodological guidance. In the event of a change in this entrusted area, such a person
must be granted prior consent before beginning to perform the function in the new area; otherwise, such a change is considered invalid. Re-granting of prior consent regarding a person performing a key function is not required if such a person has already been granted prior consent or consent for performing the same function and there has been no change in the performance of this function or the area that this person is to manage or within which they are to perform activities. (4) Professional competence under paragraph (3) of this article is demonstrated by information 38 Article 2(1)(a) of Regulation (EC) No 862/2007 of the European Parliament and of the Council on Community statistics on migration and international protection, repealing Council Regulation (EEC) No 311/76 on the compilation of statistics on foreign workers.

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_________________________________________________________________________________________ provided in the candidate suitability questionnaire, specifically regarding the candidate's education, professional experience, and previous positions held, demonstrating their ability to perform the duties of the proposed position. (5) The supervised entity shall ensure that candidates for key functions possess the necessary qualifications and experience relevant to the specific functions they are to perform, taking into account the complexity of the supervised entity's activities and risks. (6) In assessing professional competence, NBS shall consider the candidate's overall profile, including their career path, achievements, and any relevant certifications or licenses required by law or regulation.

Article 8
Independent Thinking
(1) Members of the bodies of the supervised entity must demonstrate the ability to think independently and form their own opinions on matters submitted to the body for decision. (2) Independent thinking is assessed based on the candidate's past professional conduct, their ability to challenge decisions constructively, and their willingness to express dissenting views when necessary. (3) For members of the supervisory board, formal independence is a prerequisite for suitability. Formal independence means that the member has no economic, family, or other ties to the bank or its management that could compromise their independent judgment.

Article 9
Time Commitment
(1) Members of the bodies of the supervised entity must dedicate sufficient time to perform their duties effectively. (2) The number of positions held by a member of the body of the supervised entity in other entities shall be taken into account when assessing their time commitment. (3) The supervised entity shall ensure that members of its bodies have adequate time to prepare for meetings, review documents, and engage in ongoing supervision and management activities. (4) If a member of the body holds multiple positions, the supervised entity shall assess whether the cumulative time commitment allows for effective performance of all duties.

Article 10
Formal Independence of Members of the Supervisory Board (1) Members of the supervisory board must be formally independent from the bank's management and major shareholders. (2) Formal independence is compromised if the member:
a) is or has been an employee of the bank or a group company within the last three years, b) has close family ties with members of the statutory body or senior management, c) has significant business relationships with the bank or its management.

Article 11
Collective Suitability of the Bodies of the Supervised Entity (1) The bodies of the supervised entity as a whole must possess the necessary knowledge, skills, and experience to effectively oversee the bank's activities and manage its risks. (2) The composition of the bodies shall reflect a balance of skills, experience, and diversity of backgrounds. (3) The supervised entity shall regularly assess the collective suitability of its bodies and make adjustments as necessary to ensure effective governance.

Article 12
Suitability of Persons Performing Key Functions (1) Persons performing key functions must meet the requirements of reliability and professional competence. (2) The supervised entity shall ensure that persons performing key functions have the necessary qualifications and experience to perform their duties effectively. (3) The suitability of persons performing key functions shall be assessed in the context of their specific roles and responsibilities.

Article 13
Documentation and Reporting
(1) The supervised entity shall maintain comprehensive records of all suitability assessments performed. (2) Records shall include the basis for the assessment, the conclusions reached, and any actions taken. (3) The supervised entity shall submit suitability assessments to NBS upon request.

Article 14
Time Commitment for Persons Holding Multiple Positions (1) Candidates holding multiple positions shall demonstrate sufficient time commitment to perform all duties effectively. (2) The supervised entity shall assess the cumulative time commitment of candidates holding multiple positions. (3) If a candidate holds multiple positions, the supervised entity shall ensure that the cumulative time commitment does not compromise the effective performance of any duty.

Article 15
Changes in Suitability
(1) The supervised entity shall monitor changes in the suitability of persons holding positions. (2) If a change occurs that affects the suitability of a person, the supervised entity shall inform NBS without delay. (3) NBS may require the supervised entity to take corrective actions if a person's suitability is compromised.

Article 16
Sanctions for Non-Compliance
(1) Failure to comply with the suitability requirements may result in sanctions imposed by NBS. (2) Sanctions may include fines, orders to remove the person from the position, or other measures. (3) The supervised entity shall cooperate with NBS in the enforcement of sanctions.

Article 17
Transitional Provisions
(1) This methodological guidance shall apply to all proceedings initiated after its entry into force. (2) Proceedings initiated before the entry into force of this methodological guidance shall be concluded in accordance with the previous regulations.

Article 18
Entry into Force
(1) This methodological guidance shall enter into force on the day following its publication in the Official Journal of the National Bank of Slovakia.

Annex 1
Template for Candidate Suitability Questionnaire (See NBS website for the recommended template)

Annex 2
Template for Internal Assessment Record
(See NBS website for the recommended template)

Annex 3
List of Key Functions
(See NBS website for the recommended template)

Annex 4
List of Supporting Documents
(See NBS website for the recommended template)

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_________________________________________________________________________________________ and documents listed in Articles 8 and 9, which in addition to the required details contain information on the professional competence of the person holding a key function in the area that this person is to manage or within which they are to perform activities.

Article 8
Professional Knowledge
(1) The candidate must have completed higher education; in justified cases 39, completed full secondary education or full secondary vocational education is sufficient. Suitable education is education mainly in the field of economics, law, financial analysis and quantitative methods. (2) The candidate's professional knowledge should, depending on the position for which they are proposed, cover one or more of the following areas a) banking and financial markets, b) regulatory framework and legal requirements in the field of banking or financial markets, c) prevention and combating of money laundering and terrorist financing, d) strategic planning, understanding the business strategy or business plan of the supervised entity and its implementation, e) risk management (identification, assessment, monitoring, control and mitigation of main types of risks of the supervised entity including environmental, social risks and risks in the field of governance and management (ESG risks) and risks of information and communication technologies), f) accounting and audit, g) assessment of the effectiveness of mechanisms implemented by the supervised entity to ensure effective governance, supervision and control, h) interpretation of financial information of the supervised entity, identification of main shortcomings arising from this information and adoption of appropriate measures, i) requirements in the field of personal data protection and their implementation according to prudential requirements and j) ability to present their views, discuss strategies and business objectives. (3) Professional knowledge is demonstrated mainly by a) a certificate of the highest achieved education, b) a curriculum vitae and c) information listed in points I., V., VI. and VII. in part D of the candidate's suitability questionnaire. (4) For documents of education completed abroad, it is necessary to provide an official certificate stating that it is education comparable to education under Section 7(14) of the Banking Act 40. (5) The curriculum vitae must contain the following details:
a) first name, surname and maiden name of the candidate, b) date of birth, place of birth, permanent residence and nationality, if these information does not follow from the identity document or from the data submitted under Art. 6(2)(a) of this guidance, which form the attachments to the submitted application, c) details of achieved education and other relevant training and certifications, d) name and area of activity of all entities for which the candidate worked, and the nature and duration

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_________________________________________________________________________________________ of functions performed.

Article 9
Skills and Experience
(1) The level of skills and experience is assessed mainly on the basis of previous professional practice of the candidate, including the length of its performance, scope and relevance of acquired experience. (2) A candidate for a member of the statutory body of a bank, who has completed higher education, must have at least three years of experience and three years of management experience in the field of banking or another financial area. A candidate for a member of the board of directors, who has completed full secondary education or full secondary vocational education or comparable foreign education, must have at least seven years of professional experience in the field of banking or another financial area, of which at least three years of management experience. Suitable management experience for a candidate for a member of the board of directors is experience obtained in institutions similar to the supervised entity usually at least at a senior management position and in the period of up to 10 years before submitting the application. (3) A candidate for a member of the supervisory board of a bank must have appropriate experience in the field of banking or another financial area. A candidate for a member of the supervisory board usually must have at least three years of experience and three years of management experience in the field of banking or another financial area. Suitable management experience for a candidate for a member of the supervisory board is experience usually obtained at least at a senior management position and in the period of up to 10 years before submitting the application. In justified cases, it is possible to consider suitable experience also experience obtained in the public or academic sector. (4) A candidate for a person holding a key function in the supervised entity must have appropriate experience in the field of banking or another financial area and usually must have at least three years of experience and three years of management experience in the field of banking or another financial area. A candidate for a person holding a key function must have at least three years experience in the area they are to manage or within which they are to perform tasks or other appropriate experience. (5) A candidate for a member of the body of a branch of a foreign bank, who has completed higher education, must have at least three years of experience and three years of management experience in the field of banking or another financial area. A candidate for a person who manages the activity of a foreign bank or a member of the management committee in a branch of a foreign bank, who has completed full secondary education or full secondary vocational education or comparable foreign education, must have at least seven years of professional experience in the field of banking or another financial area, of which at least three years of management experience. Suitable management experience for a candidate for a person who manages the
activity of a foreign bank or a member of the management committee in a branch of a foreign bank is experience obtained in institutions similar to the supervised entity usually at least at a senior management position and in the period of up to 10 years before submitting the application. (6) For the purposes of this methodological guidance, management experience is understood as management experience at a) a senior management position, which are experiences obtained at a position directly subordinate to the statutory body of a legal entity (level B-1) or b) a high management position, which are management experiences obtained at the second level of subordination to the statutory body of a legal entity (level B-2). (7) A candidate for a member of the body of the supervised entity and for a person holding a key

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_________________________________________________________________________________________ function in the supervised entity should have appropriate skills necessary to perform their function. In assessing the appropriateness of skills, the supervised entity may use a demonstrative list of skills, which is listed in Annex II of the Guidance on Suitability. (8) Experience is demonstrated mainly by a) a certificate of the candidate's professional experience achieved, b) information listed in points I. to VII. in part D of the candidate's suitability questionnaire. (9) A certificate of professional experience achieved is issued by the entity in which the professional experience was acquired and contains mainly a) identification of the entity, b) main subject of activity of the entity, c) name of the position and length of inclusion of the candidate in the given position, d) main tasks and responsibilities of the candidate, e) number of subordinate persons and f) period of activity of the candidate in the entity. (10) Skills are demonstrated mainly by a) a record of internal assessment under Article 5(3) or (4), b) a certificate of the candidate's professional experience achieved and c) information listed in points I. to VII. in part D of the candidate's suitability questionnaire.

Article 10
Collective Suitability
(1) The bodies of the supervised entity must, through a sufficient number of their members with sufficient knowledge from each area, as a collective body cover all areas necessary for the management of the bank's activities including its main risks. (2) For the purposes of assessing the collective suitability of the body of the supervised entity as a whole 41, the supervised entity must state in the application mainly a) a list of names of members of the relevant body of the supervised entity and a brief description of their tasks and functions, b) information on what is the position of the candidate within the overall suitability of the relevant body of the supervised entity, including the areas they cover within the relevant body as a whole, c) a description of how the overall composition of the relevant body of the supervised entity reflects a reasonably wide range of experience and mutual synergy of members of the relevant body of the supervised entity and d) information on shortcomings or weaknesses, including measures imposed to address them. (3) Collective suitability is demonstrated mainly by submitting an assessment of collective suitability prepared by the supervised entity, which must contain information according to paragraph 2. The recommended template for this assessment forms Annex I of the Guidance on Suitability 7 - matrix for assessing the collective suitability of the body of the supervised entity.

Article 11
Independent Thinking and Formal Independence of Supervisory Board Members The supervised entity, when assessing independence, must distinguish between the concept of independent

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_________________________________________________________________________________________ thinking 42, which concerns all members of the body of the supervised entity, and the principle of formal independence, which is required in the case of certain members of the supervisory board 43.

Article 12
Independent Thinking
(1) Members of the bodies of the supervised entity must have independent thinking and in performing their functions and duties must be able to make informed, objective and independent decisions based on their own judgment. (2) When assessing independent thinking, the supervised entity assesses the necessary behavioral skills 44 and the existence of conflicts of interest of all members of the bodies of the supervised entity, whether internal or external. (3) For the purposes of assessing the independent thinking of a member of the body of the supervised entity, the supervised entity must state in the application mainly a) all objective facts that demonstrate that the candidate for a member of the body of the supervised entity will have or has independent thinking 45 in the performance of their activity, b) all current and potential conflicts of interest and an assessment of the significance of their risk and c) measures taken in the case of current and potential conflict of interest. (4) Fulfillment of the requirements for independent thinking is further demonstrated mainly by information listed in part H of the candidate's suitability questionnaire for all candidates and in part F of the candidate's suitability questionnaire for members of the body of the supervised entity.

Article 13
Formal Independence of Supervisory Board Members (1) In the supervisory board of a bank, certain members must be formally independent, i.e. they do not have current or past relationships or connections of any kind with the bank or its management, which could influence the objective and balanced judgment of the member, and which could weaken their ability to make independent decisions. (2) When determining the sufficient number of independent members, the bank takes into account the principle of proportionality, whereby the bank must have at least 1 formally independent member of the supervisory board. (3) For the purposes of assessing the formal independence of supervisory board members, the bank must state in the application information on which members of the supervisory board are formally independent and provide an evaluation of the assessment of their formal independence mainly according to the details established in Article 9.3 of the Guidance on Suitability 7. (4) Fulfillment of the requirements for formal independence is further demonstrated mainly by information listed in parts F and H of the candidate's suitability questionnaire.

Article 14
Sufficient Time Commitment and Number of Functions of a Member of the Body of the Supervised Entity (1) A member of the body of the supervised entity must be able to devote sufficient time

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_________________________________________________________________________________________ to performing their functions and duties in the bank, taking into account the subject of its activity, its main risks and the strategy of their management. (2) When assessing the sufficient time commitment of a candidate for a member of the body of the supervised entity, the candidate's concurrent functions are also taken into account, namely the number of functions that the candidate holds and the time devoted to performing these individual functions. All functions of the candidate are taken into account, regardless of whether remuneration is provided for their performance. (3) When counting the number of functions that the candidate holds simultaneously, the restrictions under Section 25(11), (12), (15) and (16) of the Banking Act 46 are also taken into account. (4) If, according to Section 25(12) of the Banking Act, several functions are counted as one, this function is considered a function of a member of the statutory body, provided that at least one of these functions is a function of a member of the statutory body. In the case where several functions are counted as one, whereby all these functions are considered functions of a member of the supervisory board, this function is counted as a function of a member of the supervisory board. (5) The procedure according to paragraph 4 applies in the case where a candidate for a member of the body of the supervised entity or a person already serving in the body of the supervised entity holds in companies that are part of the same institutional protection system according to a special regulation 47, if they are legal entities belonging to the same group 48 or if they are legal entities in which the supervised entity, which is the applicant, has a qualified participation 49. (6) An exception to the permitted concurrent performance of functions under Section 25(11) of the Banking Act must not affect the obligation of the candidate to devote sufficient time to performing the proposed function under Section 25(6) of the Banking Act. (7) The number of functions and the candidate's ability for a member of the body of the supervised entity to devote sufficient time to performing their functions is demonstrated mainly by information listed in part D of the candidate's suitability questionnaire. (8) Sufficient time commitment and number of functions of a member of the body of the supervised entity are demonstrated mainly by a) information listed in part F of the candidate's suitability questionnaire and b) information listed in part G of the record of internal assessment of the candidate.

Chapter 4

Article 15
Human and Financial Resources for Training of Members of the Bodies of the Supervised Entity (1) All newly appointed members of the bodies of the bank and persons holding key functions must receive information necessary to begin performing their function no later than one month after they assume office and their training should be completed within six months 50. The bank must state information on training in the application, mainly a) content of the training,

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_________________________________________________________________________________________ b) identification of the training provider 51, c) duration 52 and d) time period. (2) The supervised entity a) must have appropriate human and financial resources allocated for training and professional training of members of the bodies of the supervised entity 53, b) continuously educates members of the bodies of the supervised entity in the field of risks 53, and c) has established policies and procedures for training and professional training of members of the bank's bodies, which are part of the overall suitability policy according to the details established mainly in Chapter IV and Chapter VI of the Guidance on Suitability 7.

Chapter 5

Article 16
Diversity of Bodies of the Supervised Entity and Succession Policy (1) In accordance with Section 25(8) to (10) of the Banking Act, the supervised entity must have established diversity policies for its bodies, which take into account the established succession policies of members of the bodies of the supervised entity, whereby both are part of the overall suitability policy according to the details established mainly in Chapter V and Chapter VI of the Guidance on Suitability 7 and in the Guidelines of the European Banking Authority on internal governance (EBA/GL/2021/05). (2) The supervised entity must have established procedures to prevent a situation where the number of members of the body of the supervised entity falls below the minimum number set by law 54 or the statutes.

Chapter 6

Article 17
Financial Holding Companies and Mixed Financial Holding Companies (1) Financial holding companies and mixed financial holding companies are obliged to ensure that natural persons who perform the function of a member of the statutory body, a member of the supervisory board and a person holding a key function of this financial holding company or mixed financial holding company, meet the requirements according to a special regulation 55. (2) The suitability requirements under Articles 3, 5 to 10, 12 and 14 to 16 of this methodological guidance apply mutatis mutandis to natural persons who perform the function of a member of the statutory body, a member of the supervisory board of a financial holding company or mixed financial holding company. The suitability requirements under Articles 5 to 9 of this methodological guidance apply mutatis mutandis to natural persons holding a key function in a financial holding company or mixed financial holding company.

Chapter 7

Article 18
Transitional and Final Provisions
(1) Proceedings initiated and not finally terminated before the entry into force of this methodological guidance shall be completed according to the previous regulations. (2) The Methodological Guidance of the Supervisory Departments of the Financial Market of the National Bank of Slovakia of 7 October 2024 No. 4/2024 on proving the suitability of persons proposed for and holding positions under Section 7(2)(e) and Section 8(2)(c) of the Banking Act is repealed. (3) This methodological guidance enters into force on 1 June 2026. Legal regulations related to the subject of this guidance are listed on the website of the National Bank of Slovakia and on the website of the Official Journal of the European Union.

Vladimír Dvořáček s.r. member of the Banking Board and Executive Director for the Supervision and Financial Stability Sector of the National Bank of Slovakia

Júlia Čillíková s.r.
Executive Director for the Supervision and Financial Consumer Protection Sector of the National Bank of Slovakia