Slovakia’s Public Defender of Rights has accused lawmakers of endangering democracy with a proposed law targeting non-profit organisations, warning that the amendment could violate the country’s constitution, undermine civil society, and breach international human rights standards. In a letter to parliament dated 14 April 2025, ombudsman Róbert Dobrovodský urged MPs to reject the amendment—currently advancing under parliamentary print no. 245—which would impose sweeping financial disclosure rules, expand state oversight, and apply the label “lobbyist” to civic groups. Though legislators dropped an earlier plan to classify foreign-funded NGOs as “foreign-supported,” the new proposal, Dobrovodský argues, still threatens freedoms of association, privacy, and expression, and risks turning Slovakia’s watchdogs into state-controlled entities.
In a strongly worded letter dated 14 April 2025, Slovakia’s Public Defender of Rights, Róbert Dobrovodský, urged members of the Slovak parliament to reconsider a proposed amendment to the law regulating non-profit organisations. The proposal, which aims to change the legal framework for civic associations and NGOs providing services of general benefit, could, according to the ombudsman, severely restrict basic rights and freedoms and may even breach Slovakia’s constitution and international human rights obligations.
Dobrovodský, who serves as an independent constitutional authority responsible for defending citizens’ rights and ensuring state accountability, addressed his concerns to all parliamentary caucuses and the Constitutional and Legal Affairs Committee of the National Council of the Slovak Republic—the country’s sole legislative chamber. The letter follows two earlier communications from October and November 2024 in which he raised objections to the original draft law. The current intervention responds to a new amendment approved by the constitutional committee on 20 March 2025 and included in parliamentary print no. 245.
New Amendment Revives Old Threats to Civil Society
In his latest assessment, the ombudsman acknowledged some progress in the legislative process, notably the removal of a provision that would have required NGOs receiving foreign funding to register as “foreign-supported organisations.” He noted that such a measure would have violated Slovakia’s obligations under both European Union law and the Council of Europe’s human rights framework.
Despite this improvement, the revised amendment still includes several provisions that Dobrovodský considers highly problematic. These include the introduction of “transparency reports” obliging non-profits to disclose extensive financial information, including details about donors and transactions. He warns that such measures could violate privacy rights, place an excessive administrative burden on NGOs, and infringe on the freedom of association. Drawing on relevant case law from both the European Court of Human Rights and the Court of Justice of the European Union, the ombudsman emphasised that such reporting requirements—especially when not accompanied by adequate legal safeguards—have been found to breach fundamental rights in comparable legal contexts.
From Lobbying to Dissolution: How NGOs Are Being Cornered
The proposal also expands the legal grounds for dissolving civil society organisations and introduces a loosely defined concept of “lobbying,” which would apply primarily to NGOs. Dobrovodský warns that applying the label “lobbyist” exclusively to civil society groups may result in their unjustified stigmatisation. While he acknowledges that lobbying regulation is a legitimate policy objective—and one encouraged by the European Union—he stresses that vague or discriminatory legislation could result in unjustified restrictions on political rights, including the right to petition and freedom of expression. These concerns are particularly acute in the Slovak context, where no equivalent regulation exists for private companies or individual political actors. This imbalance, he argues, undermines the constitutional principle of equal treatment and the integrity of democratic participation.
Another point of concern is the proposed extension of Slovakia’s Freedom of Information Act to cover non-profit organisations, including those operating under private law but receiving public funding. The ombudsman argues that the original purpose of the law is to ensure transparency in public administration—not to impose state-level obligations on private entities. He further notes that existing mechanisms already allow the public to monitor how grants and subsidies are used, including through access to contracts and financial reports via Slovakia’s central register of public contracts. Imposing additional reporting obligations, he writes, not only lacks legal justification but could also interfere with the private legal autonomy of civil society actors.
Dobrovodský also criticises provisions that would subject non-profit organisations to administrative procedures typically reserved for public bodies. In particular, the amendment would oblige NGOs to comply with the legal opinions of state authorities in disputes over how public funds are used. The ombudsman describes this as a clear intrusion into the sphere of private law and warns that such a model violates the principle of legal autonomy fundamental to any democratic legal system. He argues that if the state wishes to regulate how public funds are handled, it can do so through contract law—by setting clear terms in funding agreements—not by unilaterally imposing administrative obligations on private entities.
From Watchdogs to Puppets: How the State is Hijacking Civil Society
Throughout the letter, Dobrovodský emphasises that Slovakia’s civil society plays a vital role in supporting democratic governance and complementing state services. NGOs are active in crucial areas such as healthcare, homelessness, and poverty alleviation, and often fill gaps left by public institutions. Undermining their work through overly restrictive legislation, he warns, not only damages democracy but also weakens the broader social fabric.
The letter concludes with a recommendation to abandon the current amendment and instead pursue a more comprehensive reform through the regular legislative process. This would allow for proper consultation with experts, civic actors, and international partners. Such a process, Dobrovodský argues, is essential to ensuring that the law balances the legitimate goal of transparency with the protection of rights guaranteed by Slovakia’s constitution and international commitments.
