Is it legal to record a meeting in Slovenia?

Kazenski zakonik Art. 137, Neupravičeno prisluškovanje in zvočno snemanje.

Paragraph 1 is the eavesdropping offence: whoever, without authorisation and using special devices, eavesdrops on a conversation or statement ki mu ni namenjena, not intended for him, or sound-records it, or transmits it to a third person, is punished with a fine or up to one year.

Paragraph 2 names the participant case directly: the same penalty applies to whoever sound-records "njemu namenjeno zaupno izjavo drugega brez njegovega soglasja z namenom, da bi tako izjavo zlorabil", a confidential statement of another that is intended for him, without that person's consent, with the intent to misuse it.

Paragraph 4's procedural split is telling: paragraph 1 is prosecuted na predlog, on proposal, while paragraph 2 is prosecuted only na zasebno tožbo, by private prosecution, which puts the burden on the aggrieved speaker rather than on the state.

One sourcing caveat: the official database serves article text only through JavaScript, so this wording was read from a consolidation built on the official consolidated text, and it should be checked against the official source before anyone relies on the exact words.

Yes, on the statutory text. Paragraph 2 requires all three of: the statement is zaupna, confidential; it is recorded brez njegovega soglasja, without the speaker's consent; and it is recorded z namenom, da bi tako izjavo zlorabil, with the intent to misuse it.

A professional recording their own meetings in order to write their own notes does not satisfy the third element, so the offence does not bite. Slovenia is the only country in this survey whose criminal code looks straight at the participant and declines to criminalise them absent an abusive purpose.

The onward-use limb is the real Slovenian risk, and a summary that omits it is misleading. Paragraph 2's second limb criminalises transmitting or playing the statement to a third person, which is where an agent workflow or a shared write-up could plausibly land. Recording is comparatively safe; passing a recording or a confidential statement on to someone else is what the provision reaches.

Two things we did not verify: the meaning of zloraba, misuse, which was not tested against Slovenian case law; and whether a verbatim transcript counts as the recorded statement for these purposes, which is a good question for a Slovenian lawyer. A tool that keeps no audio narrows the second limb, because there is no posnetek, no recording, to play to a third person once transcription is done.

Nothing is required by the criminal provision on the reading above, because absent abusive intent paragraph 2 is not engaged. GDPR transparency still applies, and it wants the information before the substance of the meeting.

Quick note before we start: I'm recording this so I can write my notes up afterwards. It transcribes on my laptop, nothing goes to the cloud, and I only keep the text. Say so now if you'd rather I didn't.

No authority was found on whether an announcement negates the intent element or supplies consent, and none on the form of soglasje under this article.

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.

The relevant data protection statute is ZVOP-2, which replaced ZVOP-1 in January 2023. Its specific provisions were not opened in our research, so we state nothing about them. ZVOP-1's Art. 77 governed workplace video surveillance and the Information Commissioner's workplace opinions were framed around it.

Employee representation: not verified. Slovenia has works councils with information and joint-consultation rights, and a general employment statute. Neither was opened, so we are not going to publish a trigger for this country.

What the regulator has actually said is the useful part, and it is in the section below.

The Informacijski pooblaščenec is the most productive regulator in this survey on this subject. Its searchable opinions database returns around 370 opinions for snemanje pogovora, recording a conversation, and it carries a standing subject category for video and audio monitoring. Titles worth following up include opinions on recording work at the workplace, audio monitoring in a room and over a telephone line, recording interviews with candidates in a public competition, and recording a municipal council session on a mobile phone.

One opinion was opened in full, and its reasoning transfers even though its facts are video: Snemanje dela na delovnem mestu, 3 January 2023, on an employer proposing that production and maintenance staff record their own work through camera glasses. The Commissioner's position is that recording an employee's work for the purpose of transferring knowledge to other employees is probably not a lawful purpose and the employer should look for a milder measure, and that even where such monitoring is lawful, regularly reviewing employees' recordings without a specific reason, and thereby monitoring their work and behaviour, is not permitted.

That second half is the sentence that matters for an always-on transcriber in a Slovenian workplace: the objection is not only to the capture but to routine review of what was captured. Note that the opinion was issued under ZVOP-1 and the page itself warns it may no longer be current under ZVOP-2.

Because the binding layer in Slovenia is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Kazenski zakonik (KZ-1), official database
• KZ-1 Art. 137, consolidated rendering
• Informacijski pooblaščenec, GDPR opinions database
• Informacijski pooblaščenec, Snemanje dela na delovnem mestu (3 January 2023)
• 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.