Running a business does not automatically make you an obliged entity. AML may nevertheless cover a secondary service. Your conclusion must reflect the exact statutory category, authorisation and capacity in which you act.
Translate business labels into actual services
“Administrative services” may mean sorting mail or providing a registered office to another legal entity. “Corporate consulting” may include company formation, acting on behalf of companies or advising on acquisitions of interests. These activities have different legal implications.
For registered offices and company formation examine Section 2(1)(h); for capital-structure or share-acquisition advice also examine point 12 of Section 2(1)(b). A ready-made company is not a statutory exemption. Assess the services involved in preparing and transferring the company rather than just the product name.
Read the whole category
Some categories depend on authorisation, others on the service or transaction value. External accountants are linked to authorisation for the specified regulated trade; do not assume that inactivity in one month automatically removes status. Consider suspended authorisation separately.
Estate agency for rental, subletting or lease arrangements requires at least EUR 10,000 in monthly payments or the statutory monthly equivalent of proceeds. An ordinary business may become obliged for a cash transaction of at least EUR 10,000. Specified art and precious-metal activities have their own conditions rather than a universal cash test.
Check capacity and special provisions
Section 2(3) generally excludes persons who do not perform the activity as their business, subject to statutory exceptions. Selling a private home therefore differs from property development as a business. For non-business legal entities examine Section 2(2)(d).
Tied agents in specified financial categories have a Section 2(4) exemption retaining an information duty. Cross-border providers, branches and Czech firms have distinct regimes. Establishing status does not mean every obliged entity must comply with every provision; Sections 26–29b also determine the scope.
Write and update the conclusion
Record the service description, provision, value or other conditions and evidence. If the agreement or authorisation is missing, the result should be “further information required”, not an automatic exemption. A new service, resumed trade or changed business model requires reassessment.
Practical steps
- List primary and secondary services and authorisations.
- Read the entire relevant Section 2 category for each service.
- Check exemptions in paragraphs 3–4 and special provisions.
- Retain the conclusion and define changes triggering an update.
Illustrative scenario
A firm provides registered-office addresses for CZK 400 a month. The small fee alone does not exempt it from Section 2(1)(h), point 3.
When the situation differs
An online store selling ordinary new goods without large cash transactions does not become an obliged entity merely because it has a business ID. Additional services require separate assessment.
What to document
- Services, contract terms and public-law authorisations.
- Reasoned map of provisions and exemptions.
- Missing-information record and reassessment date.
Common pitfalls
- Relying on a trade label without checking the statutory condition.
- Treating all professions identically or overlooking a secondary activity.
Frequently asked questions
Is a professional title enough?
No. Some categories depend on authorisation, others on actual activity and specific conditions. A profession is a starting point.
Can a firm fall into several categories?
Yes. Assess each service; an exemption for one activity does not automatically cover another.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- Practice obligations map · PDF / Word
- Registered offices, formation and company services including shelf companies →
- Financial services and virtual assets →
- Investment services, markets and record keepers →
Complete client information online
Where to go next
- AML duties in Czechia: where to start — First steps for an obliged entity: legal scope, customer measures, responsibilities and demonstrable records.
- Company, sole trader and customer: distinct AML roles — Distinguish the obliged entity, its staff and the customer asked for documents by a bank or adviser.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2, § 28–29b, § 54 odst. 1 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.