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January 5, 2026

Approximately 5 minutes

Slovakia Act No. 362/2011 §103: Authorized Representative Registration and Notification Requirements

Slovakia Act No. 362/2011 §103: Authorized Representative Registration and Notification Requirements

Section 103 requires any person established in Slovakia intending to act as an authorized representative for a manufacturer not established in the European Union to:

  • Register with the State Institute for Drug Control (ŠÚKL) prior to commencing activities
  • Notify ŠÚKL of any changes in registration particulars
  • Annually confirm continuation of the authorization

This provision transposes MDD Article 10 obligations for local representation. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

2. Who Must Register

Registration is mandatory for:

  • Natural or legal persons with registered office or place of business in Slovakia
  • Acting as authorized representative for non-EU manufacturers
  • Representing any class of medical devices (I to III, including custom-made)

Foreign-based ARs without Slovak establishment are not covered by this section. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

3. Registration Process and Content

The registration application to ŠÚKL must include:

  • Identification of the authorized representative (name, address, company registration)
  • List of represented non-EU manufacturers
  • Scope of represented devices (classes, types)
  • Contact details for vigilance and technical documentation

ŠÚKL issues a registration confirmation upon compliance. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

4. Notification of Changes

The authorized representative must notify ŠÚKL without undue delay of:

  • Changes in identification, address, or legal form
  • Addition or removal of represented manufacturers
  • Changes in scope of represented devices
  • Termination of authorization for any manufacturer

Failure to notify may lead to sanctions or deregistration. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

5. Annual Confirmation Requirement

Each year, the authorized representative must submit to ŠÚKL:

  • Confirmation that the authorization continues for each represented manufacturer
  • Updated list of manufacturers and device scopes if changed
  • Statement of compliance with AR obligations

This serves as ongoing verification of active representation. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

6. MDR Transition Application

For legacy devices under MDD transitional provisions (MDR Article 120):

  • §103 registration and notification duties continue until MDD certificate expiry
  • After transition, MDR Article 11 requires similar but more detailed AR registration in EUDAMED
  • Slovak ARs must prepare for dual compliance during transition

Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

7. Practical RA Guidance for ARs

  • Maintain a dedicated Slovak registration file with all submissions to ŠÚKL
  • Set calendar reminders for annual confirmation (typically by end of Q1)
  • Implement change control process for manufacturer additions/removals
  • Keep evidence of ŠÚKL confirmations and notifications for audits
  • Coordinate with non-EU manufacturers to ensure timely updates
  • Prepare for potential ŠÚKL verification audits

Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

8. Common Compliance Issues

  • Failure to notify manufacturer termination promptly
  • Incomplete annual confirmation submissions
  • Outdated registration details after company changes
  • Missing documentation of ŠÚKL confirmations
  • Delays in notifying scope expansions

Source: Act No. 362/2011 Coll. §103 practical notes (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

9. Enforcement and Risks

Non-compliance with §103 may result in:

  • Administrative fines
  • Order to cease representing manufacturers
  • Deregistration as authorized representative
  • Potential impact on market access for represented devices

Source: Act No. 362/2011 Coll. enforcement provisions (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

10. Alignment with MDR AR Registration

While §103 implements MDD AR registration, MDR Article 11 introduces:

  • Mandatory EUDAMED registration for ARs
  • Stricter verification of manufacturer compliance
  • Person responsible for regulatory compliance requirement
  • Enhanced annual reporting obligations

Authorized representatives should align Slovak duties with MDR expectations. Source: Act No. 362/2011 Coll. §103 (https://www.slov-lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2011/362/#paragraf-103)

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