Slovenia’s new statutory right to winter allowance

New employee right and employer obligation  

Employers will be required to pay a mandatory winter allowance to employees by 18 December 2025 in the amount of 50% of the minimum wage in the Republic of Slovenia.

The new Act on the Payment of Winter Allowance and the Reform of Determining the Tax Base Considering Flat-Rate Expenses (Zakon o pravici do zimskega regresa ter prenovi ugotavljanja davčne osnove z upoštevanjem normiranih odhodkov; hereinafter: Winter Allowance Act) entered into force on 20 November 2025.

1. Beneficiaries

Who is entitled to receive the winter allowance under the Winter Allowance Act? Every natural person who is in an employment relationship based on an employment contract. Employees whose employment relationship has terminated during the year are also entitled to a pro rata winter allowance regardless of the reason for termination.

2. Amount of the winter allowance

2.1 Full-time employment

Employees are entitled to a winter allowance in the amount of 50% of the minimum wage in the Republic of Slovenia, which must be paid in cash. In 2025, the minimum wage amounts to EUR 1,277.72 gross, so the winter allowance will be EUR 638.86.

2.2 Employment period shorter than one year

Employees who enter into an employment relationship or whose employment relationship ends during the calendar year – and whose period of employment in that year is shorter than one year – are entitled to a pro rata winter allowance calculated based on the duration of their employment with each individual employer.

2.3 Part-time employment

Employees with part-time employment contracts are entitled to a pro rata winter allowance based on the working hours agreed to in the employment contract. In cases where an employee works part-time under Article 67 (part-time work in special circumstances due to employees’ entitlements arising from social security regulations) or Article 67.b (part-time work prior to retirement) of the Employment Relationships Act, they are entitled to the winter allowance in the same amount as employees working full time.

3. Payment of winter allowance due on 18 December 2025

The winter allowance must already be paid for the year 2025. The deadline for payment is no later than 18 days after the end of the payroll period for the November salary of the current calendar year.

Possible delays in payment

In exceptional cases, if provided by a sector-level collective agreement, an employer facing liquidity issues may set a later payment deadline, but no later than 31 March of the following calendar year.

For 2025, an exception applies: an employer may, in case of liquidity issues, set a later payment date for the winter allowance, but no later than 31 March 2026, even if this is not permitted under the applicable sector-level collective agreement.

An employer who, in 2025 or by 31 March 2026, has not distributed profits, purchased its own shares or equity interests, paid management bonuses or performance-related bonuses to management nor incurred obligations to do so, may pay ¼ of the winter allowance by 18 December 2025 and the remaining amount no later than 31 March 2026.   

4. Tax aspects

The winter allowance, amounting to 50% of the minimum wage, is exempt from income tax and social security contributions for pension and disability insurance. If the winter allowance is paid above the minimum amount, the excess may also be tax-exempt as a performance-related bonus, provided that the conditions and limits set out in the Income Tax Act are met.

The maximum combined non-taxable amount of the winter allowance and performance-related bonus in a single tax year is 100% of the average monthly gross salary of employees in Slovenia. If the combined amount exceeds this limit, the excess is included in the taxable base as employment income.

For 2025, the tax treatment is more favourable. Even if an employee has already received the maximum tax-exempt performance- related bonus, the statutory minimum winter allowance will still be exempt from income tax. We recommend monitoring the positions and official interpretations of the Financial Administration of the Republic of Slovenia (FURS) regarding this exemption.

5. Sanctions

Fines for failure to pay the winter allowance range from EUR 3,000 to EUR 20,000 for a legal entity and from EUR 450 to EUR 2,000 for the responsible person of a legal entity. Compliance with the Winter Allowance Act will be monitored by the Labour Inspectorate of the Republic of Slovenia and the Financial Administration of the Republic of Slovenia (FURS).

Given the media coverage of the right to winter allowance, it is to be expected that in the event of non-payment, employees would initiate legal proceedings against the employer, the inspection authorities or the courts.

6. How Wolf Theiss can assist you?

Wolf Theiss offers comprehensive and tailor-made solutions to ensure compliance both in terms of employment law and other regulations, including:

• a review of the existing internal policies or preparation of new employer policies;
• a review of existing employment contracts or drafting of new ones; and
• an experienced team of lawyers specialised in employment law, available to address specific questions or represent employers before inspection authorities or courts.

Our advantage, in addition to having leading employment law experts, lies in our extensive international experience and efficient cross-border cooperation, particularly when advising corporations with affiliated companies across the Central, Eastern and Southeastern Europe.