License Audit Preparation — What the Issuer Checks
The fulfilment of license conditions by the licensee is controlled by the license issuer, unless this function is assigned by legislation to another administrative body. The Law on Licenses and Permits defines this control precisely, and preparing for a license audit means knowing these rules in advance: how a check is carried out, with what frequency, what must be prepared in the report, and where the results are kept.
An important guarantee of the law is the limitation of control to two forms: the issuer exercises control only through the selective verification of the fulfilment of license conditions and or through the regular reporting of the licensee. Monitoring of another kind — for instance, demanding facts not directly connected with the license conditions — is beyond the issuer's powers: it has no right to verify or demand the presentation of factual circumstances not directly connected with the observance of the license conditions.
Annual Reporting — from 1 April to 1 May
Unless otherwise provided by law, the licensee carries out, annually from 1 April to 1 May, reporting on the observance of the license conditions, which is done by written submission to the issuer. There is an exception: a licensee that receives the license within 6 months before the start of the reporting period is not obliged to submit the report.
Where the fact of observance of the license conditions is not clearly declared in the submitted report or is not indicated at all, the issuer is entitled to request, within a reasonable period, information confirming fulfilment. Non compliance with this request is a ground for imposing liability — the report is thus not a formality to be somehow passed over: a defect in it leads directly to a sanction.
Selective Verification — Rules and Frequency
The issuer's decision to conduct a selective verification is an administrative act which must be presented to the licensee during the verification. By decision of the issuer, representatives of another administrative body may participate in the verification. After its completion an act of verification is drawn up, which is entered into a registry specially maintained for this purpose.
The frequency is also defined: unless otherwise provided by law, the issuer may carry out the control only once within a calendar year. An exception concerns the activities provided for by the corresponding items of the law: the issuer of a license for such activities has the right to carry out the control only three times within a calendar year, and from 1 September 2026 this rule extends to a wider circle of activities. For the licensee this creates a planning horizon: checks are limited in number and predictable in form.