The Better Regulation Center as a representative of the Slovak Business Agency in the Permanent Working Commission of the Legislative Council of the Government of the Slovak Republic for Assessing Selected Impacts expressed strong disapproval in reaction to the upcoming proposal made by the Ministry of Culture of the Slovak Republic, which amends Act No. 340/2012 Coll. on Payments for Public Services provided by the RTVS. The two controversial points of the proposal were:
- Raising the rate of RTVS payments by 50% imposes additional burden on SMEs equalling 3.5 million €.
- Stipulation of legal authority for the Ministry of Culture of the Slovak Republic to adjust the rate of RTVS payments in future by a ministerial decree.
Therefore, the BRC in accordance with its mission to reduce excessive regulatory burden on SMEs and thereby improve business environment in Slovakia, proposed, among other alternatives, an absolute exemption for SMEs from the payment of those charges and the full state financing to the RTVS budget.
According to BRC and based on historical experience, rate adjustment of RTVS payments by form of a ministerial decree could lead to regular rate rises of RTVS payments exactly like in 1995 and 1997, when the ministerial decree stipulated the rate, which increased twice in a short period of 4 years. Furthermore, this process wouldn't be any longer subjected to the standard legislative procedure, on the contrary, the Minister of Culture could take such a change directly „from the table“, without the involvement of the public in the consultation and parliamentary debate. As a result, consultations with businesses as well as the SME Test, based on the Uniform Methodology for Assessing Selected Impacts, would be completely ignored.
The BRC participated in consultations with business entities, in which the aforementioned objections, as well as alternative proposals, were presented. BRC has also carried out an SME Test, which is a mandatory part of the Impact Analysis on the Business Environment, to quantify the financial costs of the regulation.