Ecommerce in Slovenia

Slovenian consumers increasingly prefer the convenience of online shopping. After the pandemic, there was a significant increase in purchases made through e-commerce channels. Slovenian consumers are increasingly using smartphones for online shopping and mobile commerce is expected to dominate the Slovenian e-commerce market, with companies adapting by developing mobile-friendly websites and applications.

Sustainability and ethically sourced products have also become a critical factor in the Slovenian e-commerce landscape. Slovenian consumers are demonstrating heightened awareness of environmental issues, prompting businesses to adopt more sustainable practices, which include offering eco-friendly products, using environmentally conscious packaging and promoting greener delivery options.

Slovenian consumers do not limit themselves to purchasing exclusively from domestic online sellers. While the majority of online purchases are made from domestic online sellers, Slovenian consumers are increasingly shopping from international e-commerce sites, especially within the EU. While online payment options are gaining popularity, cash on delivery is still a preferred payment method for many Slovenian consumers.

Fashion and electronics remain the largest segments in the Slovenian e-commerce market, followed by home equipment and furniture, beauty and wellness products and online grocery shopping, which is gradually gaining popularity among Slovenian consumers. There is also a growing demand for locally sourced/produced goods, with Slovenian consumers showing a strong preference for supporting local businesses.

Slovenia is already up to date in terms of shopping habits: businesses entering or already operating in this sector can utilise this to their advantage. We can offer you support and guidance through the regulatory framework for e-commerce and make your endeavours to digitise your business a lot less demanding.

The established local presence of a foreign company is not required to start selling online as products and services can be sold from abroad. However, foreign companies can establish a subsidiary or branch in Slovenia. Selling from abroad may require tax registration even without an established presence.

If commercial activities are targeted at Slovenian consumers, e.g. if advertising or marketing is directed at consumers in Slovenia or the website is in Slovenian, the activity must comply with Slovenian consumer legislation, even if the business entity does not have an established presence in Slovenia.

No specific licence or permit requirements apply to e-commerce businesses. However, the sale of some products/services does require the relevant authorisation or licence (e.g. online pharmacy).

Even if a brick-and-mortar business is already established, the e-commerce business requires several additional agreements to be concluded, e.g. agreements for IT-services, services related to the design and maintenance of the website, agreement with payment services provider. As the logistics of online sales differ from the brick-and-mortar business, adequate shipping and logistic agreements should be in place.

Product-specific restrictions (national and EU) should be complied with. Some restrictions apply only to the online sale of certain products (e.g. the online sale of tobacco products is prohibited), while the sale of some products, both in brick-and-mortar stores and online, is generally strictly regulated (e.g. medicines and medical devices, alcoholic beverages).

It is important to properly check all the requirements regarding the online sale of the relevant products/services before the online store is launched.

Yes, the decision as to whether an e-commerce website addresses consumers (B2C) and/or professionals/legal entities (B2B) should be made upfront.

If the e-commerce website is intended for consumers, consumer protection legislation should be complied with and all consumer rights should be observed. For example, consumers should be provided with all mandatory information at every step of the purchase process and be given a cooling-off period.

If the online store is only intended for legal entities or professionals, access should be restricted to these groups of customers only.

While the layout of the website may be set out freely, mandatory information should be provided to customers. The scope of mandatory information is narrower if the online store is intended for professionals/legal entities only, as consumer protection legislation does not need to be complied with.

The following information should be available:

• Information obligation: Information about the seller and information necessary to decide on the purchase should be provided (required product information, price, information on charges, delivery costs, costs of return, complaint policy, etc.). Usually, general terms and conditions include such mandatory information. Depending on the product category, there may be additional requirements as to what product information must be provided (e.g. food, electronics etc.).
• Cookies: If cookies are used on the website, customers should be provided with adequate information on cookies and appropriate consents should be obtained. All the required information on cookies is usually included in a cookie policy and opt-in for non-necessary cookies is usually obtained through cookie banners.
• Privacy: The processing of personal data should comply with the GDPR rules and data protection legislation. An easily accessible privacy policy should include all required information regarding the processing of personal data.

Companies registered in Slovenia should provide website information to consumers and B2B customers in Slovenia in Slovenian language. This is not the case only if they deal exclusively with customers outside Slovenia.

If the company publishes customer reviews, it should provide information on (i) whether it ensures that the published reviews are from consumers who have actually used or purchased the product and (ii) how it ensures this. The company should implement reasonable and proportionate measures to verify that the reviews are indeed from customers who have actually used or purchased the product. Falsifying reviews (e.g. publishing fake customer reviews or commissioning others to do so) or manipulating reviews (e.g. publishing only positive reviews and deleting the negative ones) is prohibited by consumer protection legislation. Personal data protection rules must also be complied with when publishing customer reviews.

Elements of the store interface that could be considered as dark patterns include, but are not limited to:

• adding additional products to customers’ shopping carts without their consent or otherwise automatically opting customers into additional purchases or subscriptions without their explicit consent;
• hidden costs that are only revealed to the customer at the checkout stage (e.g. taxes, delivery charges, additional service fees etc.);
• countdown timers and limited time messages, which indicate to customers that a deal or sale is about to expire;
• low-stock and high-demand messages, which indicate to customers that there are limited quantities of a product available, or that a product is in high demand and likely to sell out soon, creating a misleading sense of urgency;
• informing the customer about the activity on the website (e.g. “this product has been purchased by 10 users in the last hour” or “this product is currently being viewed by 5 users”);
• making it easy for a customer to sign up for a service but difficult to unsubscribe or cancel it;
• false customer testimonials and reviews;
• using visuals to attract or dissuade customers from making certain choices (e.g. subscription offer is visually more prominent and emphasised than the non-subscription offer, the option to opt out of marketing communications is greyed out, making it seem as if it is not available, even though it can be clicked);
• using language and emotion to steer users away from making a certain choice, e.g. displaying a message asking for customer’s email address in exchange for benefits, where refusal of this offer is portrayed as a shameful act (e.g. “no, I don’t want a discount” or “I like full price”).

There are no legal minimum requirements for the content of price promotion announcements. Usually, price promotion announcements include information on the type of goods on sale, the percentage of price reduction and the duration of the sale. There are also no restrictions on the timing of the announcement of a promotion – it is up to the individual business decision. In Slovenia, there are no official seasonal sales periods as of 2017.

For running price promotions, there are certain requirements regarding the displayed prices. As a general rule, prices must be visibly indicated in EUR and they must include the value added tax (VAT) if the company is liable for VAT. As the goods are being sold online, it must also be clearly and unambiguously stated whether the price includes the delivery charges.

The goods on sale must be visibly indicated with prior price and reduced price and, if applicable also with prior unit price and reduced unit price. The prior price is the lowest price that the company applied during the 30 days prior to the application of the price reduction. In case of a continuous progressive price reduction the prior price is the lowest price at least 30 days before the first reduced price in the continuous progressive price reduction (and not the current reduced price). In case the percentage of price reduction is indicated in a range, the maximum percentage of reduction must cover at least ¼ of the value of all the goods that are on sale.

The company may also indicate other reference prices (other than the prior price) when announcing a price promotion (e.g. if the company reduces the prices more often than once every 30 days), provided that such additional reference prices are clearly explained in a way that neither causes confusion nor diverts the consumer’s attention from the indication of the prior price.

There are also specific rules in this regard for new goods that are placed on the market, goods before their expiry date and perishable goods.

Sending marketing communications via electronic (e.g. emails) and telephonic means (e.g. SMS) requires opt-in consent from customers, meaning the company can only send messages if they obtain a prior consent from a recipient for the specific channel of communication.

GDPR standards should be complied with when drafting marketing opt-in (the consent should in a form of freely given, specific, informed and unambiguous statement or a clear affirmative action). A separate consent is required for telemarketing and for marketing content sent by electronic means.

In Slovenia, authorities scrutinise promotion activities such as:

• misleading sales practices, where prices are artificially inflated before a sale to make discounts appear more significant and the rules on indicating the prior price and reduced price are not complied with, thus misleading consumers;
• misleading advertising, such as providing false or deceptive information about products and services;
• promotional activities targeting children and minors, especially the sale of tobacco and related products and alcoholic beverages to minors.

Consumers have the right to withdraw from an agreement made online within 14 days of takeover of a product or, in the case of services, of the conclusion of the contract, without giving a reason. If the company does not properly inform the consumer of this right, the consumer may withdraw from the agreement within 12 months of the expiry of the initial 14-day period.

If the consumer decides to withdraw from the agreement, the consumer will bear only the costs of returning the goods, unless those costs are borne by the company or unless the company did not inform the consumer in advance that they would bear those costs. Regarding the mandatory guarantee for technical products and sellers’ warranty for defects, the same rules apply to both brick-and-mortar and online sales.

In general, Slovenian competition law reflects and implements EU legislation. Therefore, the main aspect is to keep the market and access to it as open as possible to promote competition. However, selective distribution represents a valuable mechanism through which manufacturers can arrange the resale of their products to consumers. From an economics standpoint, the application of selective distribution may give rise both to efficiencies and competition risks. The European Commission itself acknowledges that selective distribution may lead to a number of efficiencies, in particular by requiring the same or similar investments and marketing activities from all authorised retailers, and selective distribution agreements, which may help solve free-rider problems and create a brand image for the product in question. Additionally, regardless of the distribution channels, hard-core restrictions, e.g. resale price maintenance, are not permitted.

In general, regular e-commerce business does not fall under financial services regulations. However, the processing of customer payments constitutes a regulated activity, and the chosen provider of payment services should have adequate licences to perform the payment services.

As with brick-and-mortar stores, e-commerce businesses in general fall under the authority of the Market Inspectorate. Among others, the Market Inspectorate carries out administrative inspection and minor-offence procedures regarding consumer protection, unfair commercial practices involving consumers and the use of the Slovenian language. The Market inspectorate is also responsible for the general safety of products.

The Information Commissioner is the competent authority in the field of data protection. Depending on the services/products sold, other authorities such as Agency for Medicinal Products and Medical Devices and Health inspectorate may have authority over the products/services in an online store. The Slovenian Competition Protection Agency is the competition authority in Slovenia.

Consumers in Slovenia can enforce their rights before a civil court, either individually or through a class action. Class actions were introduced in 2018 but have only recently become more popular.

Alternative dispute resolution (ADR) in Slovenia is used to resolve consumer disputes that have not been resolved based on a prior consumer complaint directly to the seller. The participation of the parties in the proceedings is voluntary. Either party may withdraw consent to participate in the proceedings at any time. A link to an online dispute resolution platform should be provided on a website.

Traditionally, the Slovenian Consumers’ Association (Zveza potrošnikov Slovenije) plays an important role in drafting laws regarding consumer protection issues, promoting the interests of consumers regarding providers of goods and services and, in particular, regarding large systems such as banks, insurance companies, healthcare, utilities, etc.

Amendments to legislation in Slovenia mostly follow legal developments at the EU level. Some of the EU acts which will be transposed into Slovenian legislation are:

• Directive on Empowering consumers for the Green Transition (Directive 2024/825), which will probably be transposed into Slovenian Consumer Protection Act. The deadline for transposition is 27 March 2026;
• Right to Repair Directive (Directive 2024/1799), which will probably be transposed into Slovenian Consumer Protection Act. The deadline for transposition is 31 July 2026.

No draft bill is yet available.