Legal Updates for Businesses in the Czech Republic – September 2026

The Minimum Wage Will Increase Your Costs by CZK 2,500 Per Head from January

On 26 August 2026, Communication of the Ministry of Finance No. 150/2026 Coll. was published in the Collection of Laws, predicting the average gross monthly nominal wage for 2027 to be CZK 55,627. The government followed up on this on 7 September 2026 with a regulation setting the coefficient for calculating the minimum wage: 0.446 for 2027 and 0.458 for 2028. According to the indexation mechanism in Section 111 of the Labour Code, the minimum wage is calculated as the product of the prediction and the coefficient, rounded up to the nearest hundred crowns.

The result: the minimum wage for 2027 is CZK 24,900 per month, or CZK 148.30 per hour for a 40-hour work week. Compared to this year's CZK 22,400, this is an increase of CZK 2,500, or 11.2%. For 2028, the forecast based on the approved coefficient is CZK 26,900. The Ministry of Labour and Social Affairs must still formally announce the specific amount in a communication in the Collection of Laws by 30 September 2026.

For next year's budgets, this means only one thing: there is no point in waiting for the communication, as the figure is already known. The impact is not limited to employees on minimum wage—the lowest levels of guaranteed salary in the public sector and the range of supplements for work in a difficult working environment are derived from the minimum wage, and in the private sector, the lowest wage bands above the minimum are also usually adjusted. You should also check your salary assessments, collective agreements, and agreements for work performed outside an employment relationship where remuneration is linked to an hourly rate.

The Funds Amendment is Effective from 1 September and Changes Delegation Rules

Act No. 130/2026 Coll., approved on 8 July and promulgated on 23 July 2026, entered into force on 1 September. This is an extensive amendment to the Act on Investment Companies and Investment Funds—with more than two hundred points of change. It transposes Directive (EU) 2024/927 (the so-called AIFMD II) and affects four areas: delegation of activities, liquidity risk management, reporting for supervisory purposes, and the provision of depositary and custody services. Also new are the rules for loan-originating alternative funds, which is directly relevant for funds financing development projects. The implementing Decree No. 147/2026 Coll. came into force concurrently.

Beware of a common misconception: the general conditions for delegation in Section 23 of the Funds Act—prior notification to the Czech National Bank, the ability to justify the delegation, careful selection of the delegate, and the requirement for the fund's articles of association to define the activity as delegable—were valid even before the amendment and remain unchanged. A new element, on the other hand, is Section 26a, effective from 1 September 2026, entitled "Delegation of Management of a Customer's Assets, Acquisition of Fund Loans and Management of Special Purpose Vehicles". This extends the regime of Sections 23 to 25 to the delegation of portfolio management and simultaneously exempts specified activities from the scope of Sections 23 to 26.

In practice, this means reviewing delegation agreements and their links to the articles of association, the setup of reporting to the regulator, and, for loan-originating funds, the investment strategy. The staggered effective date is a trap: 16 April 2027 is not the only other deadline—the amendment also contains deadlines for adapting documentation and transitional regimes for some existing funds, which must be verified for the specific structure. It therefore makes sense to create a remediation plan all at once, not in waves.

Good Faith in a Supplier Won't Justify Your Expenses

In its judgment of 20 August 2026, Ref. No. 22 Afs 37/2026-85, the Supreme Administrative Court dismissed a cassation complaint from a company whose expenses from six suppliers were disallowed as tax-deductible by the tax authorities. The result: an assessed corporate income tax for 2018 of CZK 903,640 and a penalty of CZK 180,728. The court explicitly stated that in the cassation proceedings, it only dealt with procedural issues, as the complainant had only raised procedural objections—thus, it did not re-examine the tax administrator's factual findings.

The decisive moment was this: the persons registered as the executive directors of the declared suppliers denied any knowledge of the company, the issuance of the tax documents, and the authenticity of the signatures on them. This invalidated the very documents the company used to support its claims. The court concluded that the tax administrator did not require anything beyond the company's sphere of influence—only that it credibly document who performed the services for it and whom it paid (Section 92 of the Tax Code). And it added a sentence that everyone who relies on an extract from the commercial register should read: good faith in the belief that the persons acting on behalf of the supplier are authorised to do so does not, in itself, substitute for proof of the actual course of the transaction.

In the same judgment, the court also confirmed three procedural conclusions. The tax administrator is not obliged to invite the submission of a supplementary tax return under Section 145(2) of the Tax Code before initiating a tax audit if it only has indications and not a reliable conclusion about the incorrectness of the tax. The right to inspect the file does not mean that the authority must postpone its decision—the company failed to arrange a timely appointment before the end of the preclusive period and lost its opportunity. And a proposed witness must be identified and it must be stated what specifically they are to prove; the authority will not search for them on behalf of the tax subject.

What's Still Running from the Summer

Three items from previous issues are still live. Providers of AI systems generating synthetic audio, image, video, or text that were placed on the market before 2 August 2026 must add machine-readable labelling to their outputs by 2 December 2026, in accordance with the AI Act—the obligation is aimed at providers, not every company that uses generative AI. The Packaging and Packaging Waste Regulation (PPWR) has been applicable since 12 August, and we recommend that companies complete an inventory of their packaging and the roles in which they place it on the market. And for critical infrastructure, implementing regulations and a portal have been available since August, so there is no longer any reason to delay self-assessment. In HR, the regime of Act No. 323/2025 Coll. continues: employees must be registered in the records before they start work.

Deadlines That Won't Wait Until the End of September

What to Do About It Now

September has two distinct levels. The minimum wage and the funds amendment are planned work—the figure for the 2027 budget is known, and the amendment's staggered effective date can be used to review the documentation all at once, with a view beyond April 2027. The August judgment of the Supreme Administrative Court, on the other hand, is a warning that also concerns companies with no connection to funds: vetting a supplier is not a procurement formality, but a tax defence. An extract from the commercial register and a stamp on an invoice will not hold up if the supplier's executive director says in an interrogation that they do not know you.

In practical terms, this leads to one task for the autumn: review how you document who you negotiated with, who accepted the performance, and to what extent for larger contracts. This is the weakest point for marketing, consulting, and construction subcontracts. And include the higher wage costs in your 2027 budget immediately—there is no need to wait for the formal announcement in the Collection of Laws.

The ARROWS law firm combines fund and capital regulation, tax disputes, corporate agenda, and labour law into a single perspective, so that the client receives not several separate opinions, but one decision with business sense. We will ensure the review of fund documentation according to the amendment, set up supplier due diligence, represent you during a tax audit and in subsequent proceedings, and prepare wage bands for 2027. Thanks to the ARROWS International network, we also coordinate cases with a cross-border element; for professional liability cases, the ARROWS law firm is insured with a limit of CZK 400,000,000.

If you want to know which of these changes actually affect your company, contact the ARROWS law firm at consultation@arws.cz—we will go through your specific situation with you and propose the next steps.