Issued implementing regulation of 31 March this year. for the time being only extends the deadlines referred to in the Accounting Act. First of all, the deadlines for payment service providers were extended by 2 months for: preparation and approval of annual financial statements and consolidated financial statements of the capital group and reports on operations. The deadlines for closing the books of account, drawing up the statements of turnover and balances of the general ledger accounts and the deadline for stocktaking assets for the financial year were also extended accordingly (by 2 months for monthly periods and by 60 days for daily periods).
The Regulation is based on Article 15zzh (1) “Anti-crisis shield";. We are still waiting for the ordinance of the minister in charge of financial institutions, pursuant to Article 15zzg ust. 1 point 1 of “the shield" which would extend the deadlines referred to in the Payment Services Act. Until then, it does not seem that ”the lifebelt" for payment service providers could be an Article Art. 15zzr (1) point 6 of the shield, which suspends the course of time limits provided for by administrative law for the performance by entities or organizational units subject to registration in the relevant register of obligations arising from the provisions on their system. In principle, in the case of payment service providers that are incorporated companies under commercial law, their structure is governed by the Commercial Companies Code and not the Payment Services Act. Although it cannot be clearly predicted that this provision will not apply, it is better not to count on its favourable interpretation, but to await an additional implementing regulation.
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