Ľubomír Zlocha – Tomáš Gábriš – Ondrej Kobyda
Slovak Academy of Sciences, Institute of State and Law, Bratislava, Slovak Republic
Slovakia currently finds itself at a critical juncture in the digital age, navigating a landscape where the benefits of global connectivity are frequently overshadowed by the proliferation of harmful content. Recent data underscores the country’s unique vulnerability: surveys from 2022 indicated that up to 54% of respondents in Slovakia believed in various conspiracy theories, and although more recent data from 2025 suggest a refinement of these figures to approximately 37%, the core susceptibility remains high. This environment, characterized by a “suspicious mindset trap” where disinformation erodes trust in state institutions, has necessitated a transition from reactive, fragmented national measures to a harmonized European digital space.[1]
For years, Slovakia’s approach to regulating internet content was defined by temporary and often controversial tools. A prime example was the National Security Authority’s (NBÚ) power to block websites disseminating “harmful content,” a mechanism that was used briefly following the invasion of Ukraine but ultimately faced criticism for its lack of transparency and legal clarity. This “regulatory lag” became starkly apparent during the 2023 parliamentary elections, when an AI-generated deepfake targeting political figures exposed the inadequacies of existing national tools to handle rapid-response digital threats.[2]
In response to these challenges, Slovakia has moved to implement a robust legal framework anchored in two pillar EU regulations: Regulation (EU) 2021/784 on Terrorist Content Online (TCO) and the Digital Services Act (DSA). The primary vehicle for this transformation is the Media Services Act (No. 264/2022 Coll.), which was specifically amended to integrate these European standards into the domestic legal order. By adopting the TCO Regulation, Slovakia has institutionalized the “one-hour rule,” requiring hosting providers to remove terrorist content within sixty minutes of a formal order – a significant shift toward proactive prevention of online radicalization.
Furthermore, the implementation of the Digital Services Act (DSA) represents a move toward a “new constitution for the internet”. This regulation seeks to replace the previous patchwork of national rules with a unified set of obligations for online intermediaries, focusing on the principle that “what is illegal offline should also be illegal online”. By designating the Council for Media Services (RPMS) as the national Digital Services Coordinator, Slovakia is not only aiming to tackle illegal content and hate speech more effectively, but also to protect the internal market and the fundamental rights of users, including freedom of expression and data protection. This transition marks the end of isolated national experiments in content moderation and the beginning of a coordinated, trans-European effort to ensure a safer and more transparent online environment.[3]
The cornerstone of Slovakia’s strategy against online radicalization is the implementation of Regulation (EU) 2021/784 on addressing the dissemination of terrorist content online (TCO). This regulation introduces a stringent legal obligation known as the “one-hour rule,” which mandates that hosting service providers remove or disable access to terrorist content within exactly sixty minutes of receiving a formal removal order from a competent national authority. This obligation is universal, applying to all providers offering services within the European Union, regardless of where their main headquarters are located. To ensure compliance, Slovak law has been amended to allow for significant administrative fines or even criminal liability for providers that fail to meet this deadline.[4]
The enforcement of this regime in Slovakia is built on a dual-authority model involving the Police Force of the Slovak Republic and the Council for Media Services (RPMS). While the Police Force is the body responsible for issuing the actual removal orders, the process is highly formalized to prevent abuse. A formal order must include a detailed statement of reasons explaining why the content is classified as terrorist, along with precise technical data – such as exact URLs or screenshots – to help the provider locate it. On the other hand, the RPMS acts as a strategic regulator, cooperating with global prevention initiatives like the Christchurch Call and the Global Internet Forum to Counter Terrorism (GIFCT) to monitor and mitigate threats on a broader scale.[5]
Despite the existence of this “hard” legal power, the Slovak approach is characterized by a preference for informal cooperation, treating the formal one-hour order as a “tool of last resort”. Official transparency reports from the RPMS for the years 2022 and 2023 reveal a striking statistic: zero formal one-hour removal orders were issued during this period. Instead, authorities have found greater success through rapid, voluntary notifications. A primary example of this occurred following the 2022 terrorist attack in Bratislava, where the RPMS identified 26 URLs hosting the attacker’s manifesto; the platforms removed the content voluntarily and immediately after being notified, without the need for a formal judicial order.[6]
This preference for voluntary action over formal mandates is partly due to the complex legal safeguards surrounding the TCO Regulation. In Slovakia, removal orders are subject to post-removal judicial review. This means a court assesses the legality and proportionality of the removal only after the content has been suppressed, which, while providing a check against state overreach, also places a high burden of proof on authorities to justify their actions. By leaning on informal notifications, authorities can achieve the same goal – removing dangerous content rapidly – while avoiding the lengthy and potentially contentious legal battles associated with formal state-mandated censorship. This creates a hybrid enforcement environment where the threat of a formal one-hour order serves as a powerful deterrent that encourages platforms to cooperate voluntarily and swiftly.[7]
The implementation of the Digital Services Act (DSA) in Slovakia represents a paradigm shift in how digital space is governed, often referred to as the “new constitution of the internet”. The primary legal vehicle for this transition is the Media Services Act (No. 264/2022), which was significantly amended on July 24, 2024, to formally integrate DSA obligations into the Slovak legal order. This framework is built upon the fundamental principle that “what is illegal offline should also be illegal online”, extending beyond content to also include goods and services offered over the internet.[8]
A critical component of this regulation is the tiered approach to obligations, with the strictest requirements reserved for Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs). Under the amended Slovak law, these entities must comply with a rigorous transparency and accountability regime, including:
To ensure these rules are more than mere suggestions, the law introduces a “stick” for non-compliance. For serious violations – such as mishandling transparency reporting or failing to conduct risk assessments – the Council for Media Services (RPMS) is empowered to impose administrative fines reaching up to 6% of the global annual turnover of the service provider. This ensures that even multinational tech giants face significant financial incentives to maintain a safe and transparent digital environment in Slovakia.[9]
The transition to the DSA has fundamentally reshaped Slovakia’s regulatory landscape by designating the Council for Media Services (RPMS) as the national Digital Services Coordinator (DSC). This designation, finalized through the 2024 legislative amendment, grants the RPMS a central role in the new European “cooperative enforcement architecture”. As the DSC, the RPMS is not merely a domestic observer but a proactive regulator with the power to monitor compliance, conduct inspections, and impose penalties within the DSA framework.
The RPMS’s mandate extends beyond national borders. It is a full member of the European Board for Digital Services, where it contributes to the consistent application of rules across the EU and participates in working groups focused on managing systemic risks. A unique feature of the Slovak implementation is the move toward a “delegated supervision” model. Recognizing that a state body cannot handle every individual moderation complaint, the RPMS has begun certifying independent private entities, such as the Centre for Alternative Dispute Resolution (CEAH), to provide out-of-court settlements for users whose content has been restricted by platforms like Meta or TikTok.
Slovakia’s institutional choice is notable when compared to its neighbors. The country opted for a centralized approach, housing the DSC within its existing media authority. In contrast:
By centralizing these powers within the RPMS, Slovakia aims for a more streamlined and specialized regulatory structure capable of addressing the complexities of modern content moderation and algorithmic transparency.[10]
The implementation of the Digital Services Act (DSA) has introduced a novel “hybrid supervision” architecture in Slovakia, moving away from a purely state-centric model of oversight. A central element of this new framework is the emergence of the Centre for Alternative Dispute Resolution (CEAH), which in October 2025 became the first independent, private entity certified by the Council for Media Services (RPMS) to handle out-of-court settlements. This institution represents a significant shift toward a “delegated supervision” model, where the state regulator certifies and empowers private bodies to manage the high volume of individual content moderation complaints that would otherwise overwhelm public institutions.
This system provides a practical and accessible path for everyday users to challenge the decisions of tech giants like Meta or TikTok. When a platform removes content or restricts an account, users can turn to CEAH’s panel of six specialized “arbitrators” to review whether the platform’s action was consistent with both its own terms of service and the legal requirements of the DSA. The effectiveness of this model is already being tested; in its first month of operation alone, CEAH received approximately 100 complaints. Furthermore, CEAH operates on a cross-border basis, handling submissions from users in both Slovakia and the Czech Republic, which showcases a streamlined regional approach to digital rights enforcement.
By shifting individual disputes to certified private bodies, Slovakia is creating a multi-layered oversight system. While the RPMS maintains strategic oversight and handles systemic risks, bodies like CEAH – and NGOs like Demagog.sk, which partners with Meta for fact-checking – provide the technical and human-centric capacity needed to protect user rights in real-time. This hybridity ensures that the “new constitution of the internet” is not just a set of high-level rules, but a functional system where users have a real chance to defend their digital presence without necessarily resorting to lengthy and expensive court proceedings.[11]
Despite the robust framework of the DSA and TCO Regulation, the move toward rapid content removal has sparked a profound debate regarding the potential for “over-removal” and state-mandated censorship. Civil society organizations, notably VIA IURIS, have warned that strict regimes – such as the “one-hour rule” for terrorist content – might pressure platforms to err on the side of caution. This creates a risk of “collateral censorship,” where legitimate, lawful speech is suppressed simply because platforms fear the massive administrative fines associated with non-compliance.[12]
To counter these risks, the Slovak legal framework integrates several essential safeguards to ensure that digital regulations remain proportionate:
The ongoing challenge for Slovakia lies in balancing these constitutional protections under Article 26 of the Constitution of the Slovak Republic – which explicitly prohibits censorship – with the need to respond to modern digital threats. This “proportionality trilemma” is further complicated by public opinion: while legal experts warn against overreach, surveys show that 74% of the Slovak population supports state restrictions on media outlets that spread disinformation. The 2023 deepfake incident highlighted the danger of a “regulatory lag” where the lack of rapid response tools left the democratic process vulnerable. As Slovakia moves forward, the goal is to refine a legal system that is fast enough to stop digital harm but robust enough to ensure that the fundamental political right to free expression remains the cornerstone of its democratic society.[14]
[1] Hajdu, Dominika – Klingová, Katarína – Kazaz, Jana – Kortiš, Michal (2022): GLOBSEC Trends 2022: Väčšina ľudí na Slovensku stále verí konšpiráciám a cíti sa ohrozene. Globsec. (online). (cited 2026-30-05). Available at : https://www.globsec.org/what-we-do/press-releases/globsec-trends-2022-vacsina-ludi-na-slovensku-stale-veri-konspiraciam; (cited 2026-30-05). Available at: https -//demagog.sk/prva-rozsiahla-europska-studia-odhalila-kde-sa-na-socialnych-sietach-siri-najviac-nepravdivych-informacii.
[2] Hlatky, Roman: Nations in Transit 2023, Slovakia. Freedom House. (online). (cited 2026-30-05). Available at:https://freedomhouse.org/country/slovakia/nations-transit/2023; TASR (2024): Šimečka zároveň na tlačovej konferencii uviedol, že vládni politici zneužívajú atentát na premiéra Roberta Fica (Smer-SD), aby dosiahli svoje politické ciele. Teraz.sk. (online). (cited 2026-30-05). Available at: https://www.teraz.sk/najnovsie/simecka-navrhy-koalicnej-sns-su-z/799613-clanok.html.
[3] Slovakia: Amendments to Media Services Act designating Slovak competent authority and Digital Services Coordinator under the DSA were adopted by National Council. Digital Policy Alert. (online). (cited 2026-30-05). Available at:https://digitalpolicyalert.org/event/27021-act-2642022-z-z-on-media-services-and-on-amendments-to-certain-acts-media-services-act-designating-slovak-competent-authorities-and-coordinator-under-the-digital-service-act-dsa-could-was-implemented.
[4] Gesley, Jenny (2022): European Union: Law on the Obligation to Remove Online Terrorist Content Within One Hour Enters into Force. Library of the Congress. (online). (cited 2026-30-05). Available at: https://www.loc.gov/item/global-legal-monitor/2022-08-14/european-union-law-on-the-obligation-to-remove-online-terrorist-content-within-one-hour-enters-into-force/; Regulation on addressing the dissemination of terrorist content online. Rada pre mediálne služby. (online). (cited 2026-30-05). Available at: https://rpms.sk/en/regulation-addressing-dissemination-terrorist-content-online; Node. Council for media services. (online). (cited 2025-09-05). Available at: https://rpms.sk/en/node.
[5] Nariadenie o riešení šírenia teroristického obsahu online. Rada pre mediálne služby. (online). (cited 2026-30-05). Available at:https://rpms.sk/nariadenie-o-rieseni-sirenia-teroristickeho-obsahu-online.
[6] 2022 Annual transparency report on activities of the Council for Media Services under Regulation 2021/784 of the European Parliament and of the Council on addressing the dissemination of terrorist content online. (online). (cited 2026-30-05). Available at: https://rpms.sk/sites/default/files/2023-04/TCO_report_CMS.pdf.
[7] National courts and other non-judicial bodies. European e-Justice Portal. (online). (cited 2026-30-05). Available at: https://e-justice.europa.eu/topics/your-rights/fundamental-rights/where-can-i-get-help/list-relevant-courts-and-bodies/national-courts-and-other-non-judicial-bodies/sk_en; Portaru, Adina (2025): How the EU Digital Services Act (DSA) Affects Online Free Speech in 2025. ADF International. (online). (cited 2026-30-05). Available at: https://adfinternational.org/commentary/eu-digital-services-act-one-year.
[8] Slovakia: Amendments to Media Services Act designating Slovak competent authority and Digital Services Coordinator under the DSA were adopted by National Council. Digital Policy Alert. (online). (cited 2026-30-05). Available at: https://digitalpolicyalert.org/event/27021-act-2642022-z-z-on-media-services-and-on-amendments-to-certain-acts-media-services-act-designating-slovak-competent-authorities-and-coordinator-under-the-digital-service-act-dsa-could-was-implemented.
[9] Hill, Jeremy (2025): Media Services Council imposes fines and halts proceedings. Rádio Slovakia international. (online). (cited 2026-30-05). Available at: https://enrsi.stvr.sk/articles/news/389589/media-services-council-imposes-fines-and-halts-proceedings.
[10] Cunningham, Francine – Sasdelli, Paolo (2024): Which countries have appointed their Digital Services Coordinators under the DSA?. Bird&Bird. (online). (cited 2026-30-05). Available at: https://www.twobirds.com/en/insights/2024/global/which-countries-have-appointed-their-digital-services-coordinators-under-the-dsa.
[11] (cited 2026-30-05). Available at: https -//demagog.sk/meta-na-slovensku-pridava-demagog.sk-medzi-partnerov-do-svojho-programu-overovania-faktov%C2%A0.
[12] Portaru, Adina (2025): How the EU Digital Services Act (DSA) Affects Online Free Speech in 2025. ADF International. (online). (cited 2026-30-05). Available at: https://adfinternational.org/commentary/eu-digital-services-act-one-year.
[13] Decision of the Constitutional Court of the Slovak Republic, file no. II. ÚS 7/96. (online). (cited 2026-30-05). Available at: https://merit.slv.cz/PL.%C3%9AS7/96.
[14] (cited 2026-30-05). Available at: https -//cedmohub.eu/cedmo-trends-slovakia-the-14th-wave-as-seen-by-ipsos/; ÚS SR Nález Ústavného súdu Slovenskej republiky, sp.zn. II. ÚS 28/96 z 12. mája 1997. (online). (cited 2026-30-05). Available at:https://www.slov-lex.sk/sudne-rozhodnutia/judikaty/69f1db73-8d19-4c96-b7f0-74b41f43a3f9; De Nadal, Lluis – Jančárik, Peter (2024): Beyond the deepfake hype: AI, democracy, and “the Slovak case”. Misinformation review. (online). (cited 2026-30-05). Available at: https://misinforeview.hks.harvard.edu/article/beyond-the-deepfake-hype-ai-democracy-and-the-slovak-case/.