State accountability and transparency of non-governmental organizations

Abstract

The article addresses the issue of transparency of non-governmental organizations (NGOs) in the context of the growing importance of civil society and current security challenges. It highlights the phenomenon of so-called proxy organizations, which may represent the interests of states, corporations, or other actors, while their links often remain hidden or deliberately disguised. The author analyzes contemporary forms of these organizations, including shell companies, front organizations, and astroturfing efforts, emphasizing the risks their activities pose to the integrity of democratic processes and state security. The focus is placed on the legislation adopted in the Slovak Republic in 2025, its objectives, shortcomings, and the response of both domestic and international stakeholders. The analysis takes into account the case law of the European Court of Human Rights and the Court of Justice of the EU, as well as the recommendations of FATF and OECD, which emphasize the need for increased financial transparency of NGOs. The author provides a detailed description of the legislative process, proposed obligations, issues of proportionality, and interference with fundamental rights and freedoms. The conclusion points to persisting doubts regarding the adequacy of the adopted law, assuming that the final position on its compliance with constitutional and international law will be delivered by the Constitutional Court of the Slovak Republic.