Separate accounting and the prohibition of subsidizing the universal service provider are detailed in Article 36 of ZPSto-2 and the General act on separate accounting records and the prohibition of subsidizing, which was issued by the Agency on the basis of the Act.
Because of the requirements of the provisions of ZPSto-2 regarding the price of the universal service, which must be cost-based, efficient, non-discriminatory, etc., universal service providers must keep separate accounting records that clearly separate the services that are part of the universal service from those that are not. The principle of cost-base accounting must be strictly adhered to.
The system of separate accounting must be compliant with the provisions of ZPSto-2. The Agency verifies compliance in cooperation with an independent organization, such as an auditor. The Agency occasionally publishes reports on compliance.
On 17 July 2015 the Agency published an independent report from the auditor KPMG Slovenija, d.o.o., that the cost-based model of Pošta Slovenije is compliant with the Act on Postal Services and the General act on separate accounts and prohibition of subsidies.
With this review the Agency established whether:
- the cost-based model is a compliant system with the requirements of ZPSto-2,
- the model described in sufficient detail, and that it fully, in all aspects follows the calculation part of the model,
- the model ensures the prevention of subsidizing postal and other services with the universal service,
- the model is an appropriate data source for calculating the net cost of the universal service,
- the model makes it possible to make a cost-based calculation of own service price from the range of universal service,
- the model is a suitable basis for dividing costs into fixed and variable,
- the model has the correctly calculated value of fixed and variable costs, and whether the description of fixed and variable costs is sufficiently detailed,
- the model is an appropriate foundation for calculating and monitoring the special fees and/or discounts and
- the model is an appropriate foundation for calculating and monitoring the prices for network access.
The review established that Pošta Slovenije, d.o.o., has managed to prepare a cost-based model that meets all the above requirements.
The review was made in two steps and was concluded on 7 July 2015.
Prohibition of subsidizing
One of the more significant elements that the system of separate accounting of a universal service provider must ensure is monitoring any potential subsidization of other postal and other services with the services that are part of the universal service range.
Net cost obligation of the universal service is any cost that is required for the provision of the universal service and is related to the service. It is calculated as the difference between net costs of the appointed universal service provider, which operates with universal service obligations, and the net costs that same provider would have if it operated without the obligation of the universal service.
If the obligation of providing the universal service causes net costs and imposes an unjust financial burden on the universal service provider, it is entitled to a fee for providing the universal service from the compensation fund. On the basis of the calculated net costs of the universal service obligation, the Agency establishes whether they trully are an unfair financial burden.
The Agency has received applications for calculating the net cost for providing the universal postal service and the payment of compensation for providing the universal postal service from the compensation fund because of unjust financial burdens in the years 2016, 2017, and 2018. The Agency has rejected the application for 2016, because it did not receive all the elements the application should have included for a proper evaluation. The Agency is currently reviewing the applications for 2017 and 2018.
Following a request from the universal service provider and under the conditions listed in Article 19 of ZPSto-2 the universal service is paid a compensation for universal service provision from the compensation fund established and administered by the Agency.
The compensation fund is established by the Agency by opening a special bank account, and separate accounting records are kept for it. All universal service providers and all providers of interchangeable services must contribute to the compensation fund, and keep separate accounting for this purpose.
The Agency has detailed the method of financing the net costs in the General act on the accounting information and the calculation of the net cost of the universal postal service obligation.