EUTR and Timber Legality Governance in the Forestry Sector in Slovakia: From Overlooking to Overregulating

Abstract

This study examines how legal and institutional reforms associated with the European Union Timber Regulation reshaped timber legality governance in Slovakia, with particular attention to changes in actor constellations, competencies, and coordination mechanisms within the domestic forestry sector. The analysis draws on Actor-Centred Institutionalism and is based on document analysis and semi-structured interviews with key stakeholders. The results show that, although Slovakia achieved formal legal alignment and established the required institutional structures, implementation was characterised by fragmented competencies, overlapping responsibilities, and deficiencies in coordination and information exchange. While material and organisational resources were generally perceived as sufficient, these governance challenges limited the effectiveness and predictability of enforcement. These findings demonstrate that regulatory reforms may, in certain contexts, reinforce pre-existing institutional fragmentation rather than resolve it. The study provides policy-relevant insights for the ongoing transition to the European Union Deforestation Regulation, highlighting the importance of addressing coordination and institutional design at an early stage of implementation.

1. Introduction

Illegal logging represents one of the most significant and persistent threats to the world’s forests [1,2,3]. Its consequences are far-reaching, affecting biodiversity, climate change and socio-economic conditions in many regions of the world [4,5,6]. The EU has adopted several measures to combat the illegal timber trade, such as the EU Forest Law Enforcement, Governance and Trade (FLEGT) Action Plan adopted in 2003, which includes bilateral Voluntary Trade Agreements (VPAs) signed between the EU and timber-supplying countries [7,8]. These efforts reflect the EU’s broader objective to preserve global forest resources by addressing both governance shortfalls and trade dynamics.

Nevertheless, the EU recognized the need to further enhance its mechanisms to combat illegal timber trade. This led to the introduction of Regulation (EU) No 995/2010 of the European Parliament and of the Council, commonly known as the European Union Timber Regulation (EUTR), which came into force on 3 March 2013 [9]. The EUTR aims to establish an institutional framework that minimizes the risk of illegally harvested timber entering the EU’s internal market. Its scope covers operators who place timber and timber products on the market, requiring them to exercise due diligence and implement systems to ensure compliance with the legality requirements of the regulation [10], thereby requiring proactive behaviour from operators [9].

While the EUTR has succeeded in raising awareness about illegal timber trade and supply chain transparency, its effectiveness in practice remains a topic of debate. Numerous studies reveal limitations in its implementation, with inconsistent enforcement across EU Member States emerging as a critical issue. The Disproportionate application of EUTRs across Member States can represent a barrier to the regulation’s success [11,12]. Other challenges addressed in the studies include the lack of transparency in timber supply chains [13], increased administrative burdens on businesses [14], and the EU’s unilateral approach, which may fail to address the systemic issues in exporting countries [15]. Other studies emphasize the need for the EU to prioritize its efforts in regions where corruption and inefficient forest management systems exacerbate illegal logging activities [16]. In addition, the research examining to what extent the EU timber legality framework provides a transformative response to the planetary socio-ecological and justice crises supports the notion the overall transformative potential of EU timber legality policies depends largely on national institutional configurations and governance conditions [17].

The implementation procedures are not uniform across the EU Member States, which adopt different approaches when implementing EU policies and often exhibit contradictory logics [18]. In the light of the forthcoming implementation of the EUDR, these challenges underscore the importance of in-depth national case studies to better understand the practical implementation of the EU regulations and its varied outcomes across EU Member States.

Although the EUTR has been formally implemented across all EU Member States for more than a decade, existing research has predominantly focused either on its political adoption at the EU level or on comparative assessments of formal compliance across countries. Far less attention has been paid to how EUTR reshaped national institutional arrangements and actor constellations in specific domestic governance contexts.

What remains insufficiently understood is not whether Member States eventually complied with the EUTR in formal legal terms, but how the process of compliance unfolded at the national level, which institutional changes it triggered, and how these changes affected the distribution of competencies, coordination mechanisms, and interactions among public authorities and regulated actors.

This study addresses this knowledge gap by providing an in-depth actor-centred institutional analysis of timber legality governance in Slovakia. Specifically, it examines the implementation of the EUTR in Slovakia through the lens of Actor-Centred Institutionalism (ACI). This study does not aim to assess the full timber supply chain as regulated under the EUTR, nor does it analyse operators placing imported timber or timber products on the EU market. Instead, the analytical focus is deliberately limited to timber legality governance within the domestic forestry sector of the Slovak Republic. This analytical focus corresponds to the authors’ professional expertise in forest policy and governance and enables an in-depth actor-centred institutional analysis of forestry-related implementation dynamics.

The aim of this study is to examine how legal and institutional reforms driven by the EUTR reshaped timber legality governance in Slovakia within the forestry sector, with particular attention to changes in actor constellations, the distribution of competencies, and coordination mechanisms during the implementation phase.

This contribution is particularly relevant in the context of the ongoing transition from the EUTR to the European Union Deforestation Regulation (EUDR). The EUDR significantly expands reporting obligations and broadens the scope of regulated commodities, thereby increasing demands on economic operators, commodity suppliers, and control authorities. As recent research indicates, one of the most significant challenges for effective implementation at the national level is the need to strengthen the capacities of competent authorities [19]. As results of the study conducted in the Czech Republic shows, compliance with the EUDR will require improved coordination among supervisory authorities. The successful implementation of the EUDR in the Czech context will depend on institutional capacity, digital transformation, and effective cooperation of public and control authorities with the forest managers and traders [20]. These conclusions are supported by research showing that the complexity of coordination among multiple stakeholders, including public authorities, control authorities and the private sector, represents one of the main obstacles to successful implementation also on the side of developing countries [21]. In this context, understanding the institutional strengths and weaknesses revealed during EUTR implementation at the national level provides critical insights for anticipating implementation risks and governance challenges under the new regulatory framework.

To analyse whether and how institutional reforms reshaped timber legality governance within forestry sector, this study draws on ACI, which conceptualizes policy outcomes as the result of interactions between institutional arrangements and strategic actors, and conceptualizes the policy process phases based on the Public Policy Theory. This perspective is particularly suitable for examining implementation processes, as it allows the complex analysis of actor constellations, competencies, resources, and coordination mechanisms within evolving institutional settings.

1.1. Actor-Centred Institutionalism

ACI provides a robust theoretical framework for understanding the interplay between institutions and actors in the governance process. ACI describes the ordering of a political system that determines the relationships between bounded causal mechanisms, namely institutions and actors [22]. Institutions in ACI can be perceived as regulatory instruments that shape the behaviour of actors while also being influenced by the actors themselves. Restricting the definition of institutions to specific regulatory aspects is essential to recognising that the institutional context of actors, although regulating and constraining, does not completely determine their behaviour and actions. The term “institutional setting” refers to the key factors that shape actors’ orientations, capabilities, and capacities, thereby influencing both actor constellations and the ways in which actors interact [23]. However, institutions imply more than just constraining feasible strategies. They also form a composite of actors and shape the evaluation and perception of possible outcomes [24]. Importantly, institutions do not entirely determine actors’ behaviour; instead, they create a structured arrangement within which actors operate, offering both constraints and opportunities [25].

The ACI framework emphasizes the interdependence between institutions and actors, positing that an analysis of institutions without reference to actors is as incomplete as an analysis of actors without reference to institutions [22]. Institutions influence the behaviours of actors, shaping the ways in which these actors interact with one another. However, actors, whether individuals or groups, retain significant agency, enabling them to strategically navigate institutional constraints and pursue their objectives. Group actors, such as organizations or associations, have the capacity for collective, deliberate action beyond the individual level, although their actions are ultimately shaped by the internal dynamics and interactions of their members [25].

ACI also highlights the resources and capabilities of actors as essential factors in shaping policy outcomes. These resources can include material assets, financial means, technological expertise, and privileged access to information, all of which enable actors to exert influence on policy processes. Furthermore, ACI assumes that actors operate based on perceived realities, subjective preferences, and normative beliefs about appropriate actions, rather than fully objective realities [22].

ACI particularly assumes that the bounded rationality underscores the complexity of decision-making processes in governance [25]:

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actors do not act on the basis of objective reality, but on the basis of the perceived reality operating in their world and the assumed cause-effect relationships they perceive;

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they act on the basis of preferences reflecting their interests and their normative beliefs about the right or appropriate course of action in given circumstances;

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they often do not have full information about the situations they face;

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their analytical skills are limited.

Several tools are used to manage the interaction of actors in the implementation of institutions. These tools aim to facilitate the development of more efficient policies. Coordination refers to synchronizing the strategies, procedures, and measures of different policy domains [26,27]. Specifically, coordination concerns the ways in which actors collaborate [28]. In practice, coordination can function with varying degrees of efficiency and transparency [12,25,29,30,31]. Accordingly, achieving policy coordination requires the definition of clear rules and competencies to guide actors and ensure the exchange of information. The forms of coordination vary based on the interactions among actors, ranging from informal to formal. The intensity and quality of these interactions affect the achievement of shared goals or joint decisions [28].

Sectoral coordination in forest policy refers to the processes and mechanisms by which diverse actors and institutions collaborate to align their actions related to forest management objectives [27]. Forest-related issues can be influenced by various policy sectors at the same time. Inter-sectoral coordination in forest policy refers to the process of fostering collaboration and harmonization across different sectors, such as agriculture, trade, and environment, to address forest-related challenges [26].

1.2. Public Policy Theory

For the purposes of this paper, ACI is supplemented by the Public Policy Theory. Public Policy Theory is a multidisciplinary framework for studying how collective interests are identified, articulated, and addressed through structured decision-making processes [32]. It focuses on the roles of various actors, individuals, groups, or organizations and the tools or instruments used to achieve public goals. A central analytical concept within this framework is the policy cycle, which typically includes key heuristic phases such as formulation, implementation, and evaluation of the policy process. This paper focuses on the formulation and implementation phases of the harmonization of national forest policy with the EUTR in Slovakia.

Public Policy Theory is particularly relevant for this research because it provides a structured analytical perspective for examining how policy measures are translated into institutional arrangements and practical governance processes. The public policy cycle comprises several key phases relevant to this study. The formulation phase involves defining policy problems, selecting the policy agenda, developing policy instruments and alternative solutions, and mobilizing the resources necessary to achieve collective objectives [33]. In the formulation phase, strategic responses are designed to address identified problems, in the form of laws, regulations, and programmes. This phase results in the creation of policy outputs, such as documents and legislation, which standardize measures to address identified issues [34]. In Slovakia, the formulation phase involves harmonizing national legislation with the EUTR, a process requiring competent authorities to take legislative action if necessary [35,36].

The implementation phase refers to the practical application of adopted policy decisions, during which formulated strategies and regulatory measures are translated into concrete and measurable activities [33]. The implementation phase focuses on the practical application of the chosen policy using available resources (e.g., financial, human, material) to influence societal behaviours and achieve desired outcomes. In the context of ACI, the institutional setting created by the EUTR consists of regulatory instruments that enable or constrain the actions of actors involved in its application. These actors include government agencies, businesses, forest owners and managers, non-governmental organizations (NGOs), and other stakeholders operating within the forest governance sector.

In this study, the policy cycle serves as a heuristic framework for distinguishing between the formulation phase, during which policy outputs and legal instruments are adopted, and the implementation phase, during which these instruments are applied in practice by public authorities and regulated actors. This distinction is essential for analysing how institutional reforms evolve over time and how they affect actor constellations, competencies, and coordination mechanisms.

2. Materials and Methods

This study employs an exploratory research approach. The combination of a theoretical framework, document analysis, and semi-structured interviews allows for a thorough examination of timber legality processes in Slovakia, with particular attention to institutional and actor-specific factors. By applying methodological triangulation [37,38], the study provides an empirically grounded understanding of the institutional setting and stakeholder dynamics within the Slovak timber legality framework.

To meet the objectives of this paper, we formulated the following hypotheses based on the theoretical framework:

H1: 

The harmonisation with the EUTR in Slovakia led to a reconfiguration of the national institutional arrangement for timber legality governance by reallocating regulatory competencies, modifying coordination mechanisms, and redistributing administrative and enforcement resources among forestry-related public authorities during the formulation phase.

H2: 

The implementation of the EUTR in Slovakia significantly affected the distribution of competencies, coordination mechanisms, and resources among forestry institutional actors involved in timber legality governance, thereby reshaping the national institutional setting during the implementation phase.

Following the basic theoretical approach and the defined hypotheses of the paper, we set out the categories, sub-categories and criteria that informed the research and are presented in

Table 1. Key elements of the ACI framework in the harmonization with EUTR in Slovakia (modified from [12]).

Key Elements	Categories	Subcategories	Criteria	Hypotheses
Actors involved in the formulation phase of harmonization with EUTR in Slovakia (2013–2018)	Group actors Individual actors	Actors involved in the policy outputs creation	Key actors Relevant actors Marginal actors	H1
Actors involved in the implementation phase of harmonization with EUTR in Slovakia (2018–2025)	Group actors Individual actors	Permitting authorities Consultative bodies Addressees of the EUTR	Key actors Relevant actors Marginal actors	H2
Institutions	Regulatory instruments	Harmonization	Compliance with EU rules Non-compliance with EU rules	H1
	Regulatory instruments	Prohibited activities Prescribed activities Sanctions	Existing Non-existing Strong Medium Weak	H1
Impact of harmonization on actors and institutional setting	Resources for implementation	Personnel Finances Material	Sufficient Insufficient None	H2
	Competence in implementation		Clear Unclear Lacking	H2
	Coordination	Sectoral Cross-sectoral	Existing Non-existing Formal Informal	H2
	Exchange of information in implementation	Among authorities Between authorities and addressees	Existing Non-existing Formal Informal Transparent Non-transparent	H2

.

In line with the theoretical framework, the evaluation of the hypotheses is based on the following theoretical and institutional preconditions. The formulation phase of the policy cycle began in 2013 with the entry into force of the EUTR and, in the Slovak context, was completed only in 2018 through the adoption of Act No. 113/2018 Coll. on Timber. ACI assumes that institutional arrangements are constituted by regulatory instruments anchored in legal documents, within which actors retain room for manoeuvre [22]. Based on this assumption, the harmonisation of Slovak national legislation with the EUTR can be considered formally completed with the adoption of a policy output. Consequently, Hypothesis H1 proposes that the institutional setting in Slovakia was formally compliant with the EUTR at the end of the formulation phase.

In Slovakia, the implementation phase of the EUTR followed the conclusion of the formulation phase in 2018 and lasted until 1 July 2025, when Act No. 81/2025 Coll. entered into force, marking the legal transition to the implementation of the EUDR. However, due to the postponement of the application of the EUDR at the EU level, the application of the EUTR-related regulatory framework continues during the transitional period at the time of finalising the manuscript.

According to ACI, new elements introduced into an institutional arrangement lead to changes in the distribution of actors, as well as in their resources, competencies, and patterns of interaction [32]. Based on this theoretical assumption, the hypothesis H2 posits that the harmonisation and subsequent implementation of the EUTR reshaped the institutional setting of timber legality governance in Slovakia by altering actor constellations, redistributing competencies, and transforming coordination structures.

For the purposes of this paper, the identification of the actors is based on the premise that actors within the policy cycle are also considered actors according to ACI theory. In Slovakia, actors involved in the formulation phase are those involved in the policy output creation following the theoretical approach. Actors involved in the implementation phase are categorized into four groups for better clarity: (1) permitting authorities responsible for overseeing compliance, (2) inspection and supervisory authorities, (3) consultative bodies providing technical and legal assistance, and (4) actors subject to authorisation and inspection procedures (addressees of regulatory instruments).

2.1. Data Collection and Data Analysis

The analysis of relevant documentation forms a fundamental part of this study. The analysed documents are divided into three main areas:

1. EU Legislative Acts:

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Regulation (EU) No. 995/2010 of the European Parliament and of the Council, which lays down the obligations of operators who place timber and timber products on the market (commonly referred to as the EU Timber Regulation, or EUTR).

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Commission Implementing Regulation (EU) No. 607/2012, which sets detailed rules regarding the due diligence system and the frequency and nature of controls by monitoring organisations.

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Treaty on the Functioning of the European Union (2007), which provides the legal foundation for the EUTR.

2. Legislative Acts of the Slovak Republic:

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Act No. 326/2005 Coll. on Forests, which governs forest management and related processes.

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Act No. 113/2018 Coll. on Timber, which specifically regulates timber-related processes in Slovakia.

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Act No. 543/2002 Coll. on Nature and Landscape Protection, which oversees non-forest land management and environmental protection.

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Decree No. 232/2006 Coll., implementing Act No. 326/2005 Coll.

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Decree No. 170/2021 Coll., implementing Act No. 543/2002 Coll.

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Other legislative norms: Thirteen additional legislative acts were partially analysed to understand their contribution to the regulation of raw wood management in Slovakia.

3. Other Relevant Documents:

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Reasoned Opinion of the European Commission (Infringement No. 2016/4139, dated 27 April 2017), which officially invited Slovakia to take measures to comply with EU law.

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Due diligence system outlines for forest managers, logging operators on non-forest land, transporters, and importers.

The aim of the document analysis was not only to review the content but also to evaluate the legislative and procedural frameworks. Document analysis in qualitative research involves examining and interpreting data to derive meaning, develop understanding, and generate empirical insights [39]. Each document was analysed in relation to the research objectives and hypotheses. Particular emphasis was placed on identifying and evaluating the intersecting competencies of the various actors involved in timber legality processes.

The second key method used in this study was semi-structured interviews with stakeholders. A semi-structured interview allows for flexibility in the wording and ordering of questions, enabling the researcher to adapt the interview dynamically based on the respondent’s knowledge and context [40]. This approach was particularly suitable given the diverse levels of expertise and understanding among the interviewees. The semi-structured format allowed the interviewer to adjust the phrasing and sequence of questions to ensure a clear and comprehensive dialogue, tailored to each respondent’s role and experience.

The interviews were conducted with 12 stakeholders between 1 October 2023 and 1 March 2025. Respondents were selected systematically based on the identification of key actors involved in the formulation and implementation phases of the policy cycle. Representatives of the relevant institutions were formally contacted and asked to designate persons responsible for the given agenda to participate in the interviews. In cases where more than one person was identified within the same institution, interviews were conducted with more respondents, who agreed to participate. This approach ensured that respondents possessed direct professional responsibility and practical experience relevant to the research topic. Addressees were contacted based on snowball sampling [41]. The respondents are as follows: 3 employees of the Ministry of Agriculture and Rural Development (both former and current), two of whom were directly involved in the formulation phase of the harmonisation with EUTR in Slovakia; 5 representatives of permitting authorities, including two representatives from the Slovak Forestry and Timber Inspection (SFTI), two representatives from District Offices—Land and Forestry Departments (LFDs) and one representative from the State Nature Protection authority; 4 representatives of addressees who represent the subject to permitting and inspection processes, including two forest managers and two professional forest managers. The structure of the interview questionnaire is provided in Appendix A of the manuscript.

The qualitative data analysis followed an interpretive approach, focusing on identifying patterns, and relationships in the data [39,42]. This study is based on a qualitative case study design and a purposive sample of respondents representing key institutional actors involved in timber legality governance in Slovakia. The aim was not to obtain a statistically representative sample, but to capture informed perspectives from actors directly engaged in the formulation and implementation of the regulatory framework. Consequently, the findings should be interpreted as analytically generalisable insights into institutional dynamics rather than statistically generalisable results. While the conclusions are grounded in the Slovak case, the identified approach may be relevant for other countries with similar institutional contexts.

2.2. Case Study Area

Forests cover approximately 41.4% of the territory of Slovakia, representing about 2.03 million hectares of forest land. Broadleaved species dominate, particularly European beech, oak, and, among conifers, Norway spruce.

From an economic perspective, the forestry sector represents a relatively small but structurally important part of the national economy. In 2024, the forestry sector contributed around 0.6–0.7% to Slovakia’s GDP, and it provided direct employment to about 7800 workers, with an additional 9200 self-employed persons operating in forestry-related activities [43]. Although the forestry sector accounts for a relatively small share of the national economy, it plays a strategic role in rural employment and as a key supplier of raw material for the wood-processing industry [44,45].

Institutionally, forest governance in Slovakia is characterised by a multi-actor system involving state authorities, public forest enterprises, private and communal forest owners, professional associations, and environmental organisations. The central administrative authority responsible for forest policy is the Ministry of Agriculture and Rural Development of the Slovak Republic, while responsibilities for nature conservation affecting forestry are exercised by the Ministry of Environment and its subordinate organisations. Forest ownership and management are divided between state and non-state entities, both playing a significant role in timber production and forest management [46].

3. Results

The results are presented in accordance with the analytical framework derived from Actor-Centred Institutionalism and the defined hypotheses. The findings are organised systematically around the key analytical dimensions: actors, institutional arrangements, resources, competencies, coordination mechanisms, and information exchange, allowing an assessment of changes in the institutional setting across the formulation and implementation phases.

3.1. Harmonisation with EUTR in Slovakia in the Formulation Phase

This section presents the results of the analysis of the formulation phase of the harmonisation process.

3.1.1. Actors (Formulation Phase)

To evaluate the institutional setting in Slovakia under the EUTR, actors involved in the formulation phase were categorized and identified based on their roles, competencies, and relative importance in the harmonization process. This categorizaion derived from the analysis of relevant documents and is summarized in

Table 2. Key, relevant, and marginal actors in the formulation of the harmonization with EUTR in Slovakia.

Key Actors	Relevant Actors	Marginal Actors
European Commission	Ministry of Foreign Affairs of the Slovak Republic	Legislative Council of the Government of the Slovak Republic
Ministry of Agriculture and Rural Development (SR)	Government of the Slovak Republic	Constitutional Law Committee of the National Assembly of the Slovak Republic
National Council of the Slovak Republic	Ministry of the Environment of the Slovak Republic	Committee on Economic Affairs of the National Assembly of the Slovak Republic
Unidentified Actor (complainant)	Slovak Environmental Inspectorate	Committee on Agriculture and Environment of the National Assembly of the Slovak Republic
		Department of Legislation and Approximation of Law of the National Assembly of the Slovak Republic
		Interest associations of owners, foresters
		Non-governmental organizations

.

At the supranational level, the European Commission played a pivotal role as the highest executive body of the EU, exercising its authority to monitor Member States’ compliance with EU law. The Commission’s actions directly influenced the harmonization of Slovakia’s institutional setting with the EUTR, including the initiation of the process through its inspection and infringement powers.

At the national level, the Ministry of Agriculture and Rural Development was designated as the competent authority for EUTR application pursuant to a Government Resolution on the allocation of responsibilities for the implementation of EU legislation, based on its jurisdiction over forestry and wood sector in Slovakia. The National Council of the Slovak Republic served as the legislative body responsible for adopting the Timber Act, the key legislative instrument to align Slovak law with the EUTR. Additionally, the process was initiated by an unidentified complainant, whose arguments triggered the harmonization process, making this actor a key catalyst in the formulation phase.

Relevant actors included those with significant professional or formal legal competencies. The Ministry of the Environment and the Slovak Environmental Inspectorate contributed through their technical expertise during the legislative process, particularly during the comment procedures. The Ministry of Foreign Affairs and the Government of the Slovak Republic played crucial roles in diplomatic communication and in initiating legislative processes, ensuring alignment with the EUTR.

Marginal actors, although formally competent, played limited or peripheral roles in the legislative process and did not significantly influence the policy output. These included entities like various committees in the National Assembly, interest associations, and non-governmental organizations. Despite their formal inclusion in the institutional process, their contributions were minimal in this case.

3.1.2. Institutions

Following the date of general applicability of the EUTR in EU Member States, the Ministry of Agriculture and Rural Development, acting as the national competent authority, amended the Forest Act in 2014. This amendment expanded the scope of the Act to include EUTR implementation, obligating forest managers and timber purchasers to apply due diligence systems in accordance with Articles 6 and 8 of the EUTR and Commission Implementing Regulation (EU) No 607/2012. This administrative and legislative process represented the Slovak Republic’s initial action in the harmonisation with the EUTR.

From a formal legal perspective, the amendment of the Forest Act, together with the existing comprehensive national forestry legislation, was expected to ensure compatibility with the EUTR. However, a complaint lodged with the European Commission on 3 February 2015 regarding Slovakia’s delayed implementation triggered an investigation. Subsequently, the European Commission issued a Reasoned Opinion (Infringement No. 2016/4139) on 27 April 2017, formally calling on Slovakia to align its national legislation into full compliance with the EUTR. The harmonization process culminated in the adoption of Act No. 113/2018 Coll. on Timber, which addressed the European Commission’s concerns and de facto expanded Slovakia’s institutional framework for timber legality.

The Timber Act introduced several regulatory instruments aimed at ensuring compliance with timber legality requirements, including the prohibition of placing illegally harvested timber or timber products on the market. In addition, the Act specifies a range of prescribed obligations for operators, transporters, and traders. Transporters are required to provide clear documentation of the origin of timber. Operators and traders must maintain records documenting timber provenance, and operators are further obliged to establish, evaluate, and apply a due diligence system.

The Timber Act establishes monetary sanctions ranging from EUR 200 for minor offences to EUR 200,000 for severe offences, such as selling illegal timber. In comparative terms, and relative to other EU Member States with similar historical, social, and economic backgrounds, these sanctions can be considered relatively strong [11]. Additionally, non-monetary sanctions include the seizure and forfeiture of timber, with revenue from forfeited timber directed to the state budget.

The adequacy of these sanctions was subsequently reviewed by The European Commission, particularly in response to concerns raised in the infringement procedure and was deemed sufficient to ensure compliance with the objectives of the EUTR.

3.1.3. Stakeholders’ Insights

Interviews with stakeholders provided diverse perspectives on Slovakia’s compliance with the EUTR following the adoption of the Timber Act.

The majority of respondents (I1–I9) confirmed that, after the enactment of Act No. 113/2018 Coll. on Timber, Slovakia can be regarded as formally compliant with the EUTR requirements. However, five respondents noted that EUTR compliance had already been addressed by pre-existing Slovak legislation, suggesting that the adoption of the Timber Act may have been potentially redundant in achieving its stated objectives (I2, I3, I6, I7, I9).

One respondent specifically pointed out that Slovakia’s regulatory framework is not only compliant but sufficiently robust to serve as a model for implementing EUTR requirements in some of the other countries, as recommended by the European Commission (I1). In contrast, two respondents pointed to a broader limitation of the EUTR, arguing that while national compliance in Slovakia is evident, the regulation’s overall effectiveness remains constrained by enforcement challenges in non-EU countries where illegal logging and illicit timber trade persist (I2, I4). Taken together, the findings from legislative analysis, stakeholder interviews, and the outcomes of the European Commission’s infringement procedure indicate that Slovakia’s institutional setting for timber legality is formally compliant with the EUTR. The adoption of the Timber Act and the resulting expansion of regulatory instruments provide evidence in support of Hypothesis H1. At the same time, stakeholder perspectives reveal that the necessity and added value of the Timber Act remain contested, given the existence of relatively comprehensive timber legality provisions prior to its adoption.

3.2. Implementation of the EUTR in Slovakia

This section presents the results of the analysis of the implementation phase of the EUTR in Slovakia.

3.2.1. Actors (Implementation Phase)

Actors participating in timber legality processes within implementation phase at the national level were identified and categorised based on document analysis and semi-structured interviews. The resulting categorisation is summarised in

Table 3. Key, relevant, and marginal actors in the implementation of harmonization with EUTR in Slovakia.

Actors
Permitting Authorities	Inspection and Supervisory Authorities	Consultative Bodies	Actors Subject to Authorisation and Inspection Procedures (Addressees)
Slovak Forestry and Timber Inspection—K District Office, Land and Forestry Department—K District Office, Department of Environmental Protection—K Local government (cities and municipalities in their territorial jurisdiction)—R	Slovak Forestry and Timber Inspection—K District Office, Land and Forestry Department—K District Office, Department of Environmental Protection—R Local government (cities and municipalities in their territorial jurisdiction)—R Police SR—R Forest Guard—R Nature Guard—M	District Office, Land and Forestry Department—K District Office, Department of Environmental Protection—K State Nature Protection SR—R Local government (cities and municipalities in their territorial jurisdiction)—R	Owners of forest and tree-covered land—R Forest managers—K Professional forest managers—K Non-state forest owners’ associations—R Contractors—M Timber buyers and sellers—M Timber transporters—R Timber processors—M

Note: K denotes key actors, R relevant actors, and M marginal actors.

.

The institutional setting for timber legality in Slovakia has evolved significantly following the adoption of the Timber Act, most notably through the establishment of the Slovak Forestry and Timber Inspection (SFTI) as a new sectoral actor under the Ministry of Agriculture and Rural Development. Due to its dedicated resources and statutory enforcement powers, the SFTI emerged as a key actor responsible for supervising compliance with timber legality requirements. Meanwhile, the District Office—Land and Forestry Department (LFD) has also become a key actor in the implementation phase, regarding timber originating from forest land within existing legal structures and competencies. Other actors, such as consultative bodies, and local governments, contribute primarily through advisory, administrative, or compliance-related functions, while their capacity to shape implementation outcomes is more limited relative to the key supervisory authorities. Among the addressees of the regulatory framework, forest managers and professional forest managers emerge as key actors, as they are directly responsible for operational decision-making related to timber harvesting and handling, while owners of forest land typically assume a more limited role relating day-to-day compliance with timber legality requirements (I1–I3).

3.2.2. Resources

Resources constitute a critical component for the implementation of any regulatory framework. While document analysis provided contextual information on the institutional allocation of resources, the assessment of resource sufficiency is based primarily on semi-structured interviews. No significant shortage of personnel, material, or financial resources were reported by respondents with respect to the implementation of the EUTR in Slovakia; resources were therefore generally perceived as sufficient (I2–I7). The presence of multiple authorities involved in control and inspection activities related to timber legality, as identified in Table 3, indicates a relatively dense institutional structure for enforcement. Interviews with institutional actors further supported this assessment, as none of the respondents suggested a need for additional resources. Instead, interviewees emphasised challenges related to the allocation, coordination, and effective use of existing resources (I4–I8).

3.2.3. Competencies

A significant challenge identified through the analysis is the overlapping of competencies between SFTI and LFD. According to the legislative framework, both authorities share 16 overlapping competencies, including conducting state supervision, performing field inspections of harvesting operations, addressing offences and administrative violations, and deciding on timber forfeiture. This overlap contributes to institutional ambiguity and operational inefficiencies.

From an ACI perspective, institutions fundamentally influence the repertoire of actions of the actors involved. The unclear institutional anchoring of the competencies between SFTI and LFD expands actors’ room for manoeuvre in applying strategic and tactical approaches during implementation. Combined with conditions of bounded rationality, where actors operate with incomplete information and limited cognitive capacity to process complex institutional environments, this ambiguity creates challenges for the effective enforcement of legal obligations.

Interviews with stakeholders supported these findings. Representatives of state administration described the overlapping competencies as “legislative nonsense”, emphasising the lack of clear and transparent jurisdictional boundaries not only for public authorities themselves but also for actors subject to permitting and inspection procedures (I6). Representatives of forest managers noted that the duplicated competencies among state authorities render the institutional setting opaque and difficult to navigate in day to day practice (I9–I12). These findings indicate that overlapping and unclear redistribution of competencies between SFTI and LFD create significant impediments to the effective implementation of timber legality governance in Slovakia.

3.2.4. Sectoral Coordination

The extensive overlap of statutory competencies between the SFTI and the District Office—Land and Forestry Department (LFD) is further compounded by sectoral coordination challenges. Formally, communication between the two authorities is required and is guided by established methodological instructions. Coordination is primarily conducted through formal channels, including requests for data, information, and other procedural inputs. In practice, however, coordination between the two entities exhibits significant shortcomings.

While both authorities operate substantively within the forestry policy domain under the responsibility of the Ministry of Agriculture and Rural Development, they are administratively managed by different ministries: the SFTI by the Ministry of Agriculture and Rural Development and the LFD by the Ministry of the Interior. This dual administrative structure has contributed to interaction problems and uncoordinated enforcement actions.

Empirical evidence from interviews illustrates these coordination failures. One respondent reported being subjected to inspections by both the SFTI and the LFD on the same matter within a short time frame (I10), while representatives of the LFD were reportedly unaware that an inspection had already been carried out by the SFTI. Such coordination deficiencies have prompted attempts by affected stakeholders to address the issue. In particular, non-state forest owners’ associations sought to organise a conference aimed at improving coordination among authorities (I6). However, this initiative was ultimately not realised due to the COVID-19 pandemic and was not subsequently pursued, partly in anticipation of a new legislative framework associated with the transition from the EUTR to the EUDR.

Overall, although sectoral coordination between the two key actors formally exists, interview evidence suggests that its practical effectiveness is undermined by overlapping competencies (I4–I7), mutual mistrust, and informal rivalry (I6). These coordination deficits not only constrain effective enforcement but also contribute to uncertainty and reduced confidence among regulated actors regarding the coherence of the timber legality governance framework (I6, I10–I11).

3.2.5. Cross-Sectoral Coordination

In the context of timber legality governance, the ACI framework emphasises that compliance outcomes emerge from the interaction between institutional arrangements and the strategic behaviour of actors operating across different policy sectors. The regulation of timber legality in Slovakia involves multiple ministries and overlapping jurisdictions, contributing to institutional opacity and ambiguity. For example:

Timber originating from forest land is regulated under Act No. 326/2005 Coll. (the Forest Act) and falls within the competence of the Ministry of Agriculture and Rural Development. Timber harvested in military districts is subject to the jurisdiction of the Ministry of Defence, while timber from non-forest land is governed by Act No. 543/2002 Coll. (the Nature and Landscape Protection Act) under the Ministry of the Environment. This sectoral fragmentation is further compounded by the organisational arrangement of district offices, which are administratively subordinated to the Ministry of the Interior but substantively managed by their respective line ministries.

A particularly salient source of ambiguity arises from discrepancies between the “C” and “E” land parcel registers, which complicate the classification of land as forest or non-forest. As a result, determining the legal status of tree-covered land, and consequently the applicable regulatory regime, often becomes unclear. Yet, the precise identification of the land category from which timber originates is a critical issue for both timber legality enforcement and cross-sectoral coordination.

Interview evidence suggests that elements of this fragmentation existed prior to the adoption of the Timber Act. However, respondents indicated that the introduction of the Timber Act, as part of the EUTR-induced reform process, further complicated cross-sectoral relationships by adding new regulatory layers without resolving existing jurisdictional ambiguities (I6, I10–I11). As a consequence, effective and transparent cross-sectoral coordination mechanisms remain largely absent, significantly constraining the practical enforcement of timber legality regulations.

3.2.6. Exchange of Information

Effective information exchange between institutional actors is a prerequisite for enforcing timber legality. Interview evidence indicates, however, that the exchange of information between SFTI and LFD remains limited, and is largely confined to formal communication. The transparency of this communication is however questioned. Respondents identified mutual mistrust and the absence of systemic technical interconnectivity as key barriers to effective information sharing (I4, I6–I7). Representatives of the LFD pointed primarily to the lack of shared information systems and logistical connectivity (I6, I7). According to these respondents, such localised relationships may compromise the principle of impartiality in enforcement practices.

By contrast, actors subject to regulation, such as forest managers and timber transporters, did not report significant difficulties in information exchange with public authorities (I9–I12). These respondents acknowledged the use of both formal and informal communication channels, particularly for consultation and problem-solving aimed at preventing non-compliant practices.

Nevertheless, interview evidence suggests that the combination of fragmented competencies, duplicated procedures, and limited trust between key institutional actors creates persistent risks of miscommunication (I6–I12). These shortcomings in information exchange further reinforce the overall opacity of the timber legality governance system and undermine the consistency and predictability of enforcement outcomes.

3.3. Synthesis of Results

Table 4. Evaluation of key elements of the ACI framework in the harmonization with the EUTR in Slovakia.

Key Elements	Categories	Subcategories	Analytical Interpretation
Actors involved in the formulation phase (2013–2018) of harmonization with EUTR in Slovakia	Group actors	Actors involved in the policy output creation	4 key actors 4 relevant actors 7 marginal actors	Competent authorities and the unidentified complainant → decisive role in the policy output creation.
Actors involved in the implementation phase (2018–present) of EUTR in Slovakia	Group actors	Permitting authorities Inspection and supervisory authorities Consultative bodies Addressees of the EUTR	3 key actors 1 marginal actors 2 key actors 3 relevant actors 2 marginal actors 1 key actors 2 relevant actors 2 key actors 2 relevant actors 3 marginal actors	High number and variability of actors → reduced transparency and fragmented implementation.
Institutions	Regulatory instruments	Harmonization	Compliance with EUTR	National legislation → formally harmonised with EUTR.
	Regulatory instruments	Prohibited activities Prescribed activities Sanctions	Existing prohibited activities Existing prescribed activities Strong sanctions	Regulatory instruments structured to meet EUTR.
Impact of harmonization on actors and institutional setting	Resources for implementation	Personnel Finances Material	Sufficient	Resources generally perceived as sufficient for implementation.
	Competencies in implementation		Unclear	Overlapping competencies and unclear mandates reduce institutional clarity.
	Coordination	Sectoral Cross-sectoral	Existing Formal Non-existing	Sectoral coordination formal but weak in practice; effective cross-sectoral coordination absent.
	Exchange of information	Among authorities Between authorities and addressees	Existing Formal Non-transparent Existing Formal Informal	Limited information exchange among state authorities. Communication between authorities and regulated actors efficient at the formal level.

synthesizes the main findings across the analytical categories, summarizing the observed changes in actors, institutions, and governance mechanisms. The summary presented is based on a qualitative evaluation of documentary evidence and semi-structured interviews. While sufficient resources and institutional structures are in place, challenges such as overlapping of competencies, limited sectoral coordination, and absent cross-sectoral coordination reinforce the framework’s implementation gaps.

The findings strongly support Hypothesis H1, as the formulation phase resulted in formal legal harmonisation, the establishment of new regulatory instruments, and the reconfiguration of institutional competencies governing timber legality within the forestry sector.

With regard to Hypothesis H2, the findings confirm that the implementation phase reshaped the institutional setting. Importantly, this transformation was not characterised by resource shortages. On the contrary, additional financial and personnel resources were allocated to establish a new supervisory authority and expand the institutional framework. However, rather than enhancing coherence, this expansion increased institutional complexity and overlapping mandates. As a result, implementation challenges arose not from insufficient capacity, but from governance fragmentation and the multiplication of actors and competencies, which constrained coherent enforcement.

4. Discussion

This study contributes to the literature by providing an in-depth analysis of how EUTR-related reforms reshaped actor constellations, competencies, and coordination mechanisms within a specific national context. By applying this perspective, the analysis identifies the institutional mechanisms through which implementation gaps emerge, particularly overlapping competencies, fragmented administrative structures, and coordination constraints. These findings complement existing research by explaining not only whether implementation problems occur, but also how and why they arise in practice, offering insights relevant for the forthcoming implementation of the EUDR.

The use of ACI provides a suitable analytical lens for examining institutional settings and actor interactions in EU environmental policy implementation. The findings align with previous applications of ACI in forest governance and EUTR-related research [12,47,48,49]. Comparative policy analyses have shown that expert-based forest information exchange and coordination are shaped by institutional constraints and actor constellations [47], including the role of trust within governance networks [48]. Similarly, research combining ACI with path dependency highlights how actor constellations influence policy outcomes [21]. The Slovak case confirms these insights, as mistrust and informal rivalries between supervisory authorities constrained effective coordination and information exchange. The methodological approach, which combines qualitative document analysis and semi-structured interviews, corresponds with approaches used in other EUTR-focused research [50,51]. The classification of actors into categories (key, relevant, marginal) also mirrors the methodological strategies applied to analyze actor constellations in the implementation of forest-related EU policies in France, Germany, the Netherlands and Sweden [51]. Similarly, our study finds that marginal actors often have limited influence on decision-making processes, despite their formal inclusion in governance structures. This reinforces the importance of analyzing power dynamics and actor roles in studying institutional frameworks.

Previous research has demonstrated that EU Member States have adopted differing approaches to the implementation of the EUTR, reflecting variations in economic structure, governance capacity, and domestic market conditions [52]. In particular, studies indicate that implementation of the EUTR was weaker in Southern and Eastern European countries, where lower GDP levels and economic constraints limited administrative capacity and enforcement [53]. In line with this, studies on Slovenia and Croatia [11,12] have identified insufficient resources and administrative capacity as key constraints in the implementation of the EUTR. On the contrary, the Slovak case reveals a different pattern. The findings of this study indicate that resources were generally perceived as sufficient in the Slovak context, and that implementation was instead characterised by the expansion and increasing complexity of the institutional framework, including overlapping competencies and coordination challenges. Based on evidence from the interviews, Slovakia’s proactive approach to EUTR compliance was driven by external pressure from the European Commission through the infringement procedure, which contrasts with the compliance strategies adopted by other studied countries [11]. This research, therefore, contributes to the literature by demonstrating that implementation gaps may arise not only from resource shortages but also from institutional fragmentation and governance complexity, which are shaped by specific national administrative conditions [54].

While this study provides valuable insights into the implementation of the EUTR in Slovakia, several limitations should be acknowledged. The analysis focuses on a single national case, and the findings may therefore not be fully generalizable to other EU Member States, particularly those with different institutional traditions or economic conditions. At the same time, understanding the Slovak case requires situating the reform within its pre-existing institutional baseline. Prior to the adoption of the Timber Act, timber legality was already regulated through existing forestry and environmental legislation, and respondents indicated that key control mechanisms were formally in place. The EUTR-related reform did not emerge in an institutional vacuum; rather, it layered additional regulatory instruments and established a new supervisory authority atop an already structured governance framework. While this expansion strengthened formal compliance, it simultaneously increased institutional density and overlapping mandates.

Nevertheless, some key insights may be transferable to other post-socialist governance contexts. In Slovakia, as in several other post-socialist countries, forest governance still largely follows traditional hierarchical “command-and-control” models [55]. More recent approaches to forest governance emphasise cooperation among diverse actors and the use of soft governance instruments, such as incentives and supportive mechanisms, as confirmed by several studies [49,56,57,58,59]. The transition from hierarchical command-and-control approaches to governance models that foster collaboration and incentivise sustainable practices has been identified as a crucial factor in improving policy effectiveness [56].

Under these conditions, the implementation of regulations that rely on such governance mechanisms and on coordinated action among multiple actor groups becomes more complex in systems where these collaborative arrangements are not yet fully institutionalised within national administrative structures. This is particularly relevant in some post-socialist contexts, including Slovakia. In such settings, effective implementation requires carefully designed institutional arrangements and well-functioning coordination mechanisms to ensure that new regulatory frameworks lead to the intended outcomes [16,60].

In addition to these contextual considerations, the study primarily concentrates on the immediate institutional and actor-related dynamics following the adoption of the Timber Act, while longer-term effects, such as changes in actor behaviour, institutional learning, or market responses, remain beyond its scope. The role of external pressures, such as the European Commission’s complaint-driven enforcement, proved to be a critical driver of compliance in the Slovak case. However, the study does not systematically examine how similar enforcement mechanisms operate across other Member States.

By addressing these limitations, future studies could expand the geographic scope of analysis, adopt longitudinal designs, and employ mixed-methods approaches to capture the longer-term evolution of institutional arrangements and actor behaviour. In particular, comparative studies examining how different national governance systems respond to the EU policies implementation would offer valuable insights into the conditions under which EU environmental regulations are effectively implemented.

The Slovak case provides several lessons relevant for policy-makers and for other EU Member States. First, the findings demonstrate the importance of clearly defined institutional mandates and the avoidance of overlapping competencies, as ambiguity in the allocation of responsibilities may reduce the effectiveness and predictability of enforcement. Second, the results indicate that implementation challenges may persist even where financial and organisational resources are perceived as sufficient, suggesting that institutional design and coordination mechanisms are equally critical. Third, the Slovak experience illustrates how reforms driven primarily by external pressures, such as infringement procedures, may lead to the rapid expansion of institutional arrangements without fully addressing underlying governance weaknesses. Finally, these findings may be particularly relevant for Member States with similar administrative and governance traditions, as well as for policy-makers involved in the institutional design of EUDR implementation, where clear allocation of responsibilities and effective coordination mechanisms will be essential. The Slovak experience with EUTR implementation underscores the importance of addressing institutional fragmentation, coordination failures, and trust deficits at an early stage of EUDR transposition. Analyses of this type can thus inform the design of more coherent governance arrangements, contributing to more effective implementation of the EUDR and to broader efforts to combat illegal logging and deforestation.

5. Conclusions

In the initial phase of the harmonization process with the European Union Timber Regulation, Slovakia, following minor legislative amendments, formally declared the compliance of its institutional framework with the Regulation. However, a formal complaint submitted by an unidentified domestic entity to the European Commission, followed by an infringement procedure, ultimately triggered the adoption of new legislation and the expansion of the institutional setting. This process led, inter alia, to the establishment of the Slovak Forestry and Timber Inspection as a new actor within the timber legality governance system. In the Slovak case, the formulation phase of harmonization resulted in a formal expansion and reconfiguration of the institutional framework, providing empirical support for Hypothesis H1.

The already existing institutional fragmentation was further exacerbated through the introduction of additional regulatory instruments, and redistributed competencies among public authorities. Key responsibilities were allocated across multiple ministries, and overlapping competencies between the Slovak Forestry and Timber Inspection and the District Office’s Land and Forestry Departments further complicated the institutional landscape. The absence of clearly delineated institutional boundaries created opportunities for strategic behaviour, and reliance on informal relationships. Trust deficits between authorities, insufficient communication regarding inspections, and coordination deficiencies contributed to information asymmetries, ultimately undermining the effectiveness and predictability of timber legality supervision. These findings confirm the assumptions formulated in Hypothesis H2, indicating that the implementation phase significantly affected the distribution of competencies, coordination mechanisms, and resources, thereby reshaping the institutional setting.

The Slovak experience with harmonization offers valuable insights in light of the ongoing transition to the EU Regulation on Deforestation, during which the shortcomings and implementation gaps identified in this study become particularly relevant. The findings provide lessons not only for policymakers in Slovakia, but also for the EU Member States with similar institutional backgrounds, highlighting the importance of addressing fragmentation, coordination failures, and trust deficits when designing governance arrangements for implementation.