Selling from a machine and the rules from 2026

A machine in a production hall and a machine in a public corridor look alike, but in law they are two different worlds. One question decides it: do the goods pass to another person for consideration?

• If the machine issues the employer's property to an employee, gloves, tools or office supplies, there is no sale. Neither the sales records rules nor consumer law applies. What applies are the duties around occupational safety and records of protective equipment.
• If the machine sells goods to an end consumer for money, it is a sale with everything that belongs to it, including deposit packaging for drinks.

This guide deals with the second situation, but the fifth section belongs to the first, because in practice that is the more common case.

Act No. 289/2008 Coll. on the use of electronic cash registers, which Slovak retail relied on for nearly twenty years, no longer applies. Its last time version is listed as valid until 31 December 2025.2 It was replaced by the new Act No. 384/2025 Coll. on sales records, which took effect on 1 January 2026 and expressly repeals the old act.1

The new act recognises three kinds of eKasa till: the online cash register, the software online cash register and the virtual cash register.1 For anyone running a machine, though, the list of exemptions from the duty to record a sale matters more.

So the exemption has survived into the new act. In its next point the same provision grants it to services provided through vending machines as well. A sale from a machine is not recorded in the eKasa system.

That sentence does not mean the takings are invisible. It means only that they are not recorded in the way the act prescribes for tills. The tax and accounting duties on the sale remain, and the operator meets them from its own records, usually from the machine's dispensing system.

For cases where takings do have to be recorded, the act has tightened the penalties. Section 17 contains seven penalty bands depending on which duty was breached.1

Here too the basic legislation has changed. The last time version of Act No. 250/2007 Coll. on consumer protection is listed as valid until 30 June 2024.4 Since 1 July 2024 Act No. 108/2024 Coll. on consumer protection has applied.3

The new act deals with automated sales expressly. The long list of information a trader must give before a contract is concluded does not apply to sales from a machine.

The exemption has to be read precisely, because it is easily overrated. It does not cover the whole of consumer law, only a specific list of pre-contractual information duties. The rest of the act, above all the ban on unfair commercial practices and liability for defects, applies to sales from a machine as well.

The practical consequence is simple. A machine does not have to display before the purchase what an online shop would. It does have to sell what it offers, at the quality stated and without misleading anyone.

This act is changing too. The wording valid on the date this guide was updated is listed as effective from 31 July 2026, and the next wording takes effect on 27 September 2026.3

If a machine sells drinks in deposit packaging, Act No. 302/2019 Coll. on the deposit return of single-use drinks packaging comes into play, in the wording in force since 1 January 2023.5 The distributor's duties in Section 5 are fairly specific.

• Accounting records of the price of the goods and of the deposit are kept separately.
• The distributor registers with the administrator as a collection point for waste from deposit packaging.
• It takes back waste from deposit packaging at the premises or within 150 metres of them, with no limit on quantity and without tying the return to a purchase.
• It refunds the deposit in full, even without proof that it was paid by the end user.
• Packaging that the producer has stopped placing on the market is taken back for at least six months from the announcement.

One relief applies to smaller premises. A distributor selling drinks to end users on a sales area smaller than 300 m² may pay out the deposit as a voucher for goods at its own premises instead of in cash.5

Whether and how far these duties fall on a particular site with machines depends on how the operator's status and its sales area are assessed. It is a question worth settling before buying a machine, not afterwards.

In offices, services and sites away from production, the most common case is a machine that does not sell. It issues office and IT supplies, hygiene products, access cards or small electronics to employees, and the consumption is booked to a department or a cost centre.

In law that is simpler. There is no sale, so the act on sales records does not apply, and there is no consumer contract, so consumer law does not apply. Two things remain.

• If the machine issues protective equipment, it must be provided free of charge with records of what was issued under Section 6(2)(b) of Act No. 124/2006 Coll., the documentation kept for five years under Section 6(1)(n), and its proper use checked under Section 9(1)(d).7
• The employer bears the cost of occupational safety and may not pass it to the employee under Section 6(11) of the same act. Consumption limits and booking to a cost centre are fine; charging the employee is not.

Where an item used by several employees is issued, under Section 3(3)(b) of Government Regulation No. 395/2006 Coll. it must be available to the employee whenever it is needed.8 In continuous operation that is exactly the argument for a machine rather than a counter.

A machine is a work device, and the person restocking or repairing it is at work. Government Regulation No. 392/2006 Coll. applies to it, in force since 1 July 2006 and never amended.6

• Where the use of a device may particularly endanger safety, only an assigned employee may use it, and maintenance, repairs and modifications may be done only by an authorised person, under Section 6.
• The employer must be able to show that the employee was informed and instructed about how to use the device and, where needed, given written operating instructions, under Section 8(1).
• The device must have a clearly marked switching element for isolating it from all energy sources, and reconnection must not endanger the employee, under Annex 1, point 2.14.
• Where maintenance is prescribed, its dates must be observed, and inspection records must be available to supervisory authorities at any time under Section 5(4).

For machines installed at a customer's site, the last sentence of Section 5(4) matters. A device used away from the employer's workplace must carry the records of the last inspection at the place of use.

International prevention work outside state supervision also treats this as management rather than formality. The Vision Zero strategy, led by the International Social Security Association, sets the safety of machines, equipment and workplaces as rule five of seven.9

These duties are covered in more detail in the guide Maintenance and service teams.

The choice of model follows from what comes out of the machine and whether anything comes back.

• Small, frequently taken goods, hygiene and office items, are covered by the spiral and lift machines. The lift mechanism suits places where a falling item would damage the contents.
• Access cards, small electronics and items that come back belong in cabinet machines with lockable compartments.
• If something is collected back, packaging or used items, that is what the take-back systems with a photographic record are for.
• For remote sites it makes sense to use a decentralised terminal with one shared overview.

Whatever the model, with internal issuing the dispensing record is the only evidence of who received what. With a sale it is the only source of data on the takings, since those are not recorded in the eKasa system.

Nine questions worth answering before the order, not after it.

Legislation is cited as in force on the date this guide was updated. Sources that are not Slovak legislation are marked in the list and are informative. This text is for information and does not replace legal or tax advice.