Is it legal to record a meeting in Slovakia?

Trestný zákon § 377, Porušenie dôvernosti ústneho prejavu a iného prejavu osobnej povahy: "Kto poruší dôvernosť neverejne prednesených slov alebo iného prejavu osobnej povahy tým, že ho neoprávnene zachytí záznamovým zariadením a takto zhotovený záznam sprístupní tretej osobe alebo ho iným spôsobom použije a inému tým spôsobí vážnu ujmu na právach, potrestá sa odňatím slobody až na dva roky."

All three limbs must be made out: unauthorised capture with a recording device, and making the record available to a third person or otherwise using it, and thereby causing another serious harm to their rights. Recording alone does not complete the offence.

How it is framed matters. Around recording another person's words rather than around eavesdropping on a conversation you are not part of. The protected object is non-publicly spoken words or another expression of a personal nature, and in a meeting those words belong to the other participants. In that respect § 377 sits with Germany's StGB § 201 rather than with the Polish or Dutch interception offences.

Two siblings are worth knowing. § 196 punishes violating the secrecy of a closed letter, of information transmitted by an electronic communications service, or of a non-public transmission of computer data, with up to three years. § 197 is a separate section for revealing or making use of such a secret "ktoré neboli určené jemu", which were not intended for them. § 376 covers unauthorised violation of the secrecy of a document, an audio recording, a video recording or another document kept in another's privacy.

On § 196 and online meetings: a participant in a Teams or Zoom call is a lawful party to the transmission, so capturing its audio does not violate the secrecy of the transmitted information as against them, and § 197 reinforces that by speaking of a secret not intended for them.

Yes on the criminal layer, and the honest way to put it is yes, with consent, because the civil provision does the real work.

Občiansky zákonník § 12(1) is the binding Slovak constraint, and its wording is stronger than the criminal code's: "Písomnosti osobnej povahy, podobizne, obrazové snímky a obrazové a zvukové záznamy týkajúce sa fyzickej osoby alebo jej prejavov osobnej povahy sa smú vyhotoviť alebo použiť len s jej privolením." Documents of a personal nature, portraits, images and audio-visual and audio recordings concerning a natural person or their expressions of a personal nature may be made or used only with that person's consent.

Note vyhotoviť alebo použiť, made or used. Consent is required for the making, not only for the use. That is the opposite of § 377's structure, and it is why the criminal code alone gives the wrong answer here.

§ 12(2) dispenses with consent only for official purposes on the basis of a statute, and § 12(3) for scientific and artistic purposes and for press, film, radio and television reporting, and then only in a reasonable manner and never contrary to the person's legitimate interests. None of the three exceptions covers taking better meeting notes. § 13 gives the remedies: an injunction, removal of consequences, appropriate satisfaction, and monetary compensation for non-pecuniary harm where that is insufficient.

One accuracy note. The 1964 promulgated wording of § 12(1) said only použiť, used. The word vyhotoviť was added by later amendment, so anyone citing an old edition or a pre-amendment summary will state the Slovak position too permissively.

And the criminal margin is thinner than the three-limb structure suggests: sending a span to an agent, exporting it, or pasting a quote into an email is plausibly "otherwise using" the record, leaving serious harm to rights as the only thing between an ordinary workflow and a completed offence. That is a thin margin to rely on.

The defence is privolenie, consent, under § 12(1), and secondarily the removal of neoprávnene from § 377(1).

The statute prescribes no form. Whether consent may be implied from continuing to speak after an announcement: no authority found, and we opened no Slovak case law and no regulator position on the point. The general Slovak private-law rule that a legal act may be performed by conduct points towards implied consent being possible, but that is an inference. Whether a calendar-invite line is enough: also no authority, and doubly uncertain because an invite reaches only the invited while an always-on recorder also captures whoever walks up to the desk.

So the safe formulation, offered as drafting advice rather than as a legal finding: say it out loud at the start, name the tool, say the audio is transcribed on the device and never uploaded, say what is kept is text only, and ask whether anyone objects. Silence after a clear question is a much better record than silence after a line in an invite nobody opened.

Before we start: I record my meetings so I can write up notes afterwards. It runs on my laptop, the audio is transcribed on this machine and never uploaded, and the audio itself is not saved anywhere, only the text, in a file I keep. Is everyone alright with that? If anyone would rather I didn't, say so now and I'll turn it off.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

Zákonník práce § 13(4) requires prior notice, vopred upozorniť, plus informing employees of the scope, manner and duration of the monitoring. Employee representation is a prerokovanie, a duty to discuss the scope, manner and duration with the employees' representatives. That is a consultation duty, not a consent right, so a Slovak rollout is not blocked by a refusal.

The hardest local obstacle is not the employment code but § 12(1): consent to make as well as to use, with only official, scientific, artistic and press exceptions, none of which fits meeting notes.

Úrad na ochranu osobných údajov, the Slovak data protection authority. Nothing specific on meeting recording or on the application of Občiansky zákonník § 12 to a participant was opened in our research, so we state nothing about its position. That is a gap.

Start with what does not help, because it is what our own positioning tempts us into claiming. Earkeep transcribes on your own device, never writes the audio to disk and sends nothing anywhere. On the criminal layer in Slovakia that changes nothing at all. A recording made without the other speakers' consent is the same act whether it was processed on your laptop or uploaded to somebody's cloud, because the provision is about making the recording rather than about where it ends up.

Where the architecture genuinely helps is data protection: no transfer, no third party in the chain, no processor agreement to sign, and nothing to reconcile if someone asks you to delete what was said. And in the conversation itself, "it stays on my laptop and the audio is never saved" is a shorter thing to explain than what a cloud notetaker requires, which makes the agreement easier to actually obtain.

Earkeep announces itself to nobody. There is no bot in the participant list and no banner on anyone else's screen, so where the announcement is what makes the recording lawful, the whole of it depends on you saying something. What the app gives you is somewhere to go when the answer is no: a pause from the live edge that releases the microphone and the system audio stream, so the operating system's own recording indicator visibly goes dark; a never-record marking for a meeting on a connected calendar; and a purge that takes the lines out of the file on your own disk with no server copy anywhere. It does not make any recording lawful, and no tool can.

• Trestný zákon, Act 300/2005 (§§ 196, 197, 376, 377), slov-lex
• Občiansky zákonník, Act 40/1964, consolidated (§§ 11 to 13), slov-lex
• Trestný zákon, consolidated cross-check
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.