The contact person handles FAÚ communication and suspicious-transaction reporting. Separate the duty to designate the person from the duty to notify their details. Your customer or its managing director is not your firm’s contact person.
Who may hold the role
Section 22(1) envisages an employee or governing-body member. A sole trader may designate themselves where justified by the scale of activity. An external AML supplier does not become an employee merely by providing services.
Credit and financial institutions have specific restrictions: governing-body members, transaction staff and staff involved in internal audit may hold the role only within the statutory exception justified by the scale and nature of activity. The contact person needs access to management communication.
Read exemptions precisely
Lawyers and notaries under Section 2(1)(g) are exempt from Section 22(2) notification; this does not itself remove designation. Entities under the limited Section 28 regime and cross-border Section 29b regime do not automatically inherit all of Section 22.
The national administrator has an express designation duty under Section 29a(2)(d). Do not interpret a summary “Section 29a exemption” as removing the role entirely. Assess any additional obliged activity separately.
Current deadlines and details
Section 22(2) notification is due within 30 days of becoming obliged, and changes within 15 days. Older 60- and 30-day deadlines are not the current general contact-person rule.
Notify name, position, telephone and electronic contact, contact hours and obliged-entity type. Contact hours must reflect the service or transaction operation. Where several categories apply, include all relevant types in the current form.
Correct form and delivery evidence
Use the current FAÚ form under Decree No. 420/2024 Coll. and submit the required XML through the obliged entity’s data box. A PDF printout or saved draft-form data is not a valid filing. The official submission or manual-submission-document function creates the final file.
Retain the submitted file and delivery receipt. Check the entire form when updating: FAÚ instructions state that new notification replaces previous details. Test contact availability and trigger updates on personnel changes.
Practical steps
- Identify the exact category and separate designation from notification.
- Choose an eligible person, contacts and availability.
- Complete the current form and submit final XML through the data box.
- Retain delivery evidence and track changes against the 15-day deadline.
Illustrative scenario
A sole-trader accountant designates herself where justified by her activities. After changing her phone number, she sends complete updated notification within 15 days.
When the situation differs
A practice submits a PDF printout and assumes compliance. FAÚ requires the prescribed XML format.
What to document
- Internal designation and any exemption reasoning.
- Final XML, data message and delivery receipt.
- Detail history and dates of changes.
Common pitfalls
- Using old deadlines or ordinary email.
- Sending only the changed phone number and omitting other categories or details.
Frequently asked questions
Is the customer the contact person?
No. This is the person in your operation responsible for FAÚ communication.
Is saving the form enough?
No. Saving draft data is not final submission. Verify the required file and delivery.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
Complete client information online
Where to go next
- Am I an obliged entity? Activities matter, not just a business ID — Map actual services to the Czech AML Act and identify conditions, authorisations and exemptions.
- Who is responsible for AML in a company? — Assign management, contact-person, staff and supplier roles without leaving a gap before a transaction.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 22, § 28, § 29a odst. 2 písm. d), § 29b · accessed 2026-10-04 - FAÚ — Oznámení kontaktní osoby ↗
§ 22; aktuální lhůty · accessed 2026-10-04 - FAÚ — Často kladené dotazy k podání ↗
Formát XML; nahrazení údajů; předepsaná datová schránka · 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.