In his work, the Human Rights Ombudsman of the Republic of Slovenia (hereinafter: the Ombudsman) constantly draws attention to the rights of persons with disabilities, which also include the accessibility of facilities and services. He pays special attention to the accessibility of facilities in public use for persons with physical and sensory disabilities and notes that this is not (yet) ensured at the expected level[1]. The Ombudsman believes that enabling access to facilities in public use is an important element of ensuring equal opportunities for persons with disabilities, therefore, on the basis of Paragraph 2 of Article 9 of the Human Rights Ombudsman Act (ZVarCP), he has already discussed several broader issues in this field, which are important for the protection of human rights or legal security in the Republic of Slovenia. At the end of 2022, the Ombudsman issued a Special Report on the Accessibility of Centres for Social Work for Persons with Physical and Sensory Disabilities, and in the Annual Report for 2018 (p. 67), the Ombudsman addressed the issue of court accessibility.
In December 2023, the Ombudsman received an email from a representative of a non-governmental organisation addressed to the Ministry of Foreign and European Affairs (hereinafter: MZEZ), in which he warned that he had gone to a meeting of the Interdepartmental Commission for Human Rights, which was held at 27 Gregorčičeva Street, but he could not attend it because it was held on the first floor of the building, and the building does not have a lift or an alternative entrance for the physically challenged. He stated that the president of the commission had apologised to him and explained to him that the meeting could no longer be moved to another location, so he had to leave the meeting, where he had wanted to draw attention to the issue of ensuring accessibility for the physically challenged, even before it started.
The MZEZ sent a letter to the Ombudsman for information, in which they apologised (still in writing) to the representative of the non-governmental organisation for the unpleasant incident and took responsibility for not checking in advance whether the building in which the meeting was convened was accessible for the physically challenged. Regardless, in a specific case, the Ombudsman expressed his indignation at the fact that even in 2023, the organisers of meetings and events do not consider the potential needs of various participants and do not follow the applicable legislation and international legally binding documents, such as the International Convention on the Rights of Persons with Disabilities (MKPI). On the basis of the mentioned case, the Ombudsman recognised the issue of accessibility of the buildings of the Government of the Republic of Slovenia (hereinafter: the Government) and ministries as a broader issue, important for the protection of human rights and fundamental freedoms and for the legal security of citizens in the Republic of Slovenia.
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The Ombudsman has already mentioned the legal basis for ensuring the accessibility of the built environment in several places[2], so here we only briefly summarise the most essential: Paragraph 1 of Article 14 of the Constitution of the Republic of Slovenia (URS) guarantees everyone the same human rights and fundamental freedoms, regardless of their personal circumstances, including explicitly regardless of disability. The Constitutional Court of the Republic of Slovenia already found in its decision number U-I-156/11 of 10 April 2014 that the failure to ensure the physical accessibility of polling stations for persons with disabilities is inconsistent with Article 14 of the URS (see e.g. point 28 of the aforementioned decision).
The area of accessibility of the built environment for persons with disabilities is governed by the Convention on the Rights of Persons with Disabilities (hereafter: MKPI) (Articles 3 and 9), Act on Protection against Discrimination (ZVarD), Construction Act (GZ-1) (Articles 25 and 32), the Act on the Equalisation of Opportunities for Persons with Disabilities (ZIMI), Rules on Universal Construction and Use of Buildings (Articles 6 and 8), National Guidelines for Improving the Accessibility of the Built Environment, Information and Communications for Persons with Disabilities and the Action Programme for Persons with Disabilities 2022–2030[3].
Article 9 of the ZIMI prohibits discrimination on the grounds of disability in the accessibility of public facilities. Paragraph 2 of Article 38 of the ZIMI stipulates that the appropriate adaptation of existing buildings in public use is ensured by removing built and communication barriers from Article 9 of this law, which the investor must eliminate during the first reconstruction of the building after the entry into force of this law, but no later than 15 years after the entry into force of this law. The ZIMI entered into force on 11 December 2010. Paragraph 2 of Article 9 of the ZIMI stipulates that adaptations of buildings in public use are made with construction and technical devices, sound and light indicators, written information and other relevant technical adaptations. Paragraph 2 of Article 29 of the ZIMI stipulates: "Analytical, professional, and informational tasks regarding the use and adaptation of buildings for public use and accessibility to goods and services available to the public are performed by the Urban Planning Institute of the Republic of Slovenia."
It is also worth mentioning the State Administration Act (ZDU-1), which states in Paragraph 1 of Article 5: "When dealing with clients, the administration must ensure respect for their personality and personal dignity and ensure that they exercise their rights and legal rights as quickly and as easily as possible benefits".
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Accessibility of the built environment for persons with disabilities is crucial in ensuring equal opportunities for this vulnerable group. Failure to ensure the accessibility of facilities for public use is in itself inconsistent with Paragraph 1 of Article 14 of the URS. In addition, it should be taken into account that the accessibility of facilities in public use for persons with disabilities is a basic assumption for the realisation of many other fundamental human rights and freedoms.
We should recall the statements of the Constitutional Court of the Republic of Slovenia from decision number U-I-156/11-29 Up-861/11-25 of 10/04/2014 that "in the last elections, only a third of all polling stations (33.99 per cent) were accessible to persons with disabilities)" and that "[i]n fulfilment of the obligation to ensure physical accessibility of facilities in public use to persons with disabilities, public legal entities (state and local communities) cannot postpone to the distant future when it comes to the realisation of one of the fundamental human rights, i.e. voting rights." Just as in the case of the accessibility of polling stations, it was a matter of the possibility of exercising one of the fundamental human rights (voting rights), in the case of the accessibility of government buildings and ministries, it is about the exercise of some other fundamental human rights, as explained below.
In particular, it should be pointed out that the premises of the Government and ministries are the premises of the highest bodies of state administration. The functions in the positions of the aforementioned bodies are elected, and in a democratic system everyone has the opportunity to run for them. In accordance with Article 29 of the MKPI, the Republic of Slovenia must enable persons with disabilities to perform tasks and public functions at all levels of government effectively. If the premises of the Government and ministries are not accessible for persons with disabilities, this can have a deterrent effect on potential officials.
In accordance with Paragraph 3 of Article 49 of the URS (freedom of work), every workplace is accessible to everyone under the same conditions. However, if the premises of the Government and ministries do not have regulated accessibility of the built environment for persons with disabilities, they cannot enforce the prohibition of discrimination based on the disability of job seekers and workers during the duration of the employment relationship from Article 6 of the Employment Relations Act (ZDR-1)). The Administration prepares for the Government proposals for laws, by-laws, and other acts as well as other materials and provides other professional assistance in the formulation of policies (Article 8, ZDU-1). As part of this, ministries often organise public consultations at their premises on planned strategies and policies in their field, to which experts, civil society, and other members of the public are invited. However, when the premises of the ministries are not accessible for persons with disabilities, this may represent an interference with their right to participate in the management of public affairs (Article 44, URS). Last but not least, ministries as administrative bodies also do business with customers. When the premises of the ministries are not accessible to persons with disabilities, this may constitute an interference with the equal protection of the rights of the parties (Article 22, URS).
Last but not least, it should not be ignored that the highest representatives of the authorities in the country have rooms in the facilities discussed here, who set an example for other authorities in their behaviour and attitude towards persons with disabilities, so it is all the more important that all aspects of accessibility are ensured in accordance with the regulations and at the highest possible level.
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The Ombudsman carried out an analysis of the accessibility of the premises of the Government and ministries for persons with disabilities and received a total of 28 completed questionnaires for the same number of buildings in which the Government and ministries have premises[4]. It is worth noting that the Government and some individual ministries have their premises in several locations, in several different facilities. On the other hand, the buildings of some ministries have the same address (e.g. Župančičeva 3 for the MF and MP, Kotnikova ulica 5 for the MGTŠ and MKRR, Masarykova cesta 16 for the MVI and MVZI, and Gregorčičeva 25 for the Government and the MZEZ). Regardless of the above, we treated each of them separately in the accessibility analysis, even though they may have some spaces in common. Within each building, each ministry has its own premises.
The Ombudsman addressed a single questionnaire to the ministries and the Government, which was divided into two sections. The questions asked were extracted from the specific provisions of the regulations relating to accessibility.
As part of the first set of questions, the Ombudsman was interested in how the accessibility of the facilities of the Government and ministries is ensured. The Ombudsman first asked the addressees how the requirement from the second sentence of Paragraph 3 of Article 32 of the GZ-1, which stipulates that the number of parking spaces for persons with disabilities near the main entrance of a building in public use must be sufficient. We found that parking spaces for the disabled are mostly provided, namely this applies to 23 cases, while in 5 cases parking for persons with disabilities is not provided (MF, MP, MNVP, MSP, and MORS). We were also interested in whether everyone is guaranteed entry to the building at the same place or close to it (requirement from the first indent of the Paragraph 1 of Article 6 of the Rules on Universal Construction and Use of Buildings (hereinafter: the Rules)) and found that this is guaranteed in 25 cases, but not in three (Government building at Gregorčičeva 27, MF, and MP[5]). The Ombudsman further asked whether the entrance to the facility is designed and equipped in such a way that even persons with visual impairments can easily find and use it (requirement from the first indent of Paragraph 1 of Article 6 of the Rules) and concluded that this requirement was met in 17 cases, but not in 11 cases[6]. Furthermore, the Ombudsman asked whether the accesses, passages, connecting paths, doors, and vertical connections (stairs, ramps, personal lifts, and other mechanical lifting devices) in the facility allow persons with individual functional disabilities to use them independently (requirement from the first sentence of Paragraph 3 of Article 32, GZ-1). We found that this requirement is fulfilled in half of the cases[7]. Under the note, the Government and MK stated that independent movement around the facility is not allowed and that visitors are always accompanied. The Government also explained that visitors are only allowed to enter when accompanied by an employee, who "can also provide assistance in the case of a person with disabilities". Related to this, it should be emphasised that escorting people cannot replace the removal of structural and functional obstacles in the building. This applies, for example, especially to cases where a person with disabilities is carried on the stairs, as this is problematic both from the point of view of ensuring the dignity of the person with a disability and from the point of view of possible injuries to the person with a disability or their wheelchair (more details on p. 69 of the Ombudsman's Annual Report for 2018). In addition, ensuring accessibility is not only important for visitors to facilities, but also for (potential) officials and/or employees, which is why accompanying persons with disabilities cannot replace the fulfilment of the requirement for accessibility of facilities and their adaptation for independent use by persons with individual disabilities.
The Ombudsman was also interested in whether the accesses, passages, connecting paths, doors, and vertical connections are equipped with the necessary signalling and equipment for the smooth movement, communication, and orientation of persons with individual disabilities (requirement from the first sentence of Paragraph 3 of Article 32, GZ-1). In this regard, we found that the requirement is fulfilled only in 9 cases[8], and in 19 cases the said requirement is not fulfilled. Regarding the fulfilment of this requirement, the Government once again referred to the house rules, according to which the movement of visitors is allowed only when accompanied, but here, too, it is worth repeating that the escort of persons cannot replace the elimination of structural and functional obstacles in the building. Furthermore, we were interested in whether the facilities in question have a lift that can be used by people with mobility impairments (within this question, the Ombudsman was interested in how the requirement from the Paragraph 3 of Article 32, GZ-1 and the fifth indent of Paragraph 1 of Article 6 of the Regulations is met). We found that this requirement was met in 20 cases and not in 7 cases[9]This requirement was found to be met in 9 cases[10] and not in 18 cases. We were also interested in whether the sanitary facilities in the facilities under consideration are accessible to persons with disabilities (requirement from Paragraph 3 of Article 32, GZ-1 and the second and fifth indents of Paragraph 1 of Article 6 of the Rules). We found that this requirement is fulfilled in half of cases[11]. The same was found in the question of whether the stairs or staircases are designed in such a way that a good visual perception of the edge is enabled (requirement from the third indent of Paragraph 1 of Article 6 of the Rules). Regarding the question of whether staircases in systems of complex tactile guidance are also equipped with floor tactile markings (requirement from the third indent of Paragraph 1 of Article 6 of the Rules[12], it was found that none of the buildings in question meets the requirement for floor tactile markings. We further asked whether the alarm devices are equipped with a light and sound signal (e.g. flashing lights that indicate the direction of exit from the facility in the event of an alarm) (requirement from the sixth indent of the Paragraph 1 of Article 6 of the Rules and the seventeenth indent of Objective II of the National guidelines for improving accessibility of the built environment, information and communications for persons with disabilities (hereinafter: NS)) and found that this requirement was met in 15 cases, and in 13 cases not[13]. We also asked whether the facility provides an induction loop for communication with persons with a hearing impairment (lectures, consultations, communication with clients) (requirement from the twelfth indent of Objective II of the NS) and found that none of the ministry buildings in question provides this. Regarding the question of whether an electronic magnifier or a magnifying glass for persons with a visual impairment is available in the facility (requirement from the fifth indent of Objective II of the NS), it was found that this requirement was met in 4 cases[14], but not in 24 cases.
The Ombudsman addressed a special set of questions to the Government and ministries regarding the fulfilment of requirements for premises intended for clients (requirements from Article 8 of the Rules). As part of these requirements, facilities must have, for example, a counter for working with customers designed in such a way that it is protected against noise and allows access, use, and communication for everyone, and an induction hearing loop must be built into it. Furthermore, the information desk must be marked in such a way that it is well lit and visible from the direction of the entrance, and in customer areas, where information is conveyed via sound system, it must also be provided via an induction hearing loop and visible, with the possibility of re-reading. Information boards, orientation signs, and other information must be easy to understand and in a place that is accessible to everyone.
The Government did not answer the Ombudsman's questions regarding the fulfilment of the requirements from the previous paragraph. It explained that it “does not do business directly with clients” and that citizens can "communicate with the Government via letter or e-mail and telephone. Letter mail is collected in the main office after a preliminary anti-bomb inspection carried out by the police, where only authorised persons have access, including, e.g., couriers of other authorities. A citizen can therefore hand in letter mail to the security service...".
The ministries reported that a space intended for business with customers, which has at least one desk for working with customers, designed in such a way that it is protected from noise and that allows access, use and communication for everyone (Paragraph 1 of Article 8 of the Rules) is provided only in the case of 7 buildings[15] mostly, i.e. in 17 buildings, this requirement is not fulfilled.
As part of these questions, we would like to point out, above all, the great difficulties in installing an induction hearing loop at the desk for dealing with clients (Paragraph 1 of Article 8 of the Rules), providing an induction loop in discussion halls (Paragraph 3 of Article 8 of the Rules) and ensuring the transmission of visible information in meeting chambers, with the possibility of re-reading (Paragraph 3 of Article 8 of the Rules). None of the facilities of the ministries meet these requirements, with the clear exception of the Ministry of Agriculture, Forestry and Food, which replied that it provides an induction hearing loop at the desk for dealing with clients and also provides
From the data obtained on the basis of the self-assessment of the ministries, it also follows that information boards, orientation signs, and other information are provided in an easy-to-understand format and in all accessible places (Paragraph 4 of Article 8 of the Rules) in 19 cases, but not in the cases of 5 buildings[16]
Based on the answers received, the Ombudsman concluded that the accessibility of the buildings of the Government and ministries is not at a satisfactory level. The data on the accessibility of toilets for persons with disabilities is already telling enough (provided in only half of the analysed buildings). In only half of the considered buildings, the requirement for a good visual perception of the edge of the stairs is met and provides accesses, passages, connecting paths, doors, and vertical connections that enable people with individual functional disabilities to use them independently. It is even worse in terms of meeting the requirement for accesses, passages, connecting paths, doors, and vertical connections, equipped with the necessary signalling and equipment for smooth movement, communication, and orientation of persons with individual disabilities. This is fulfilled only in 9 out of 28 cases.
Even otherwise, it appears that persons with sensory disabilities are catered for worse than persons with mobility disabilities. If, for example, a lift suitable for persons with mobility impairments is accessible in 20 buildings, lifts for people with sensory impairments are accessible in only 9. Furthermore, none of the buildings considered meet the requirement for tactile floor markings and do not provide an induction loop for communication with persons with hearing impairment. An electronic magnifier or magnifying glass for persons with visual impairments is provided in only 4 buildings.
As mentioned above, some buildings are used by two ministries (or the Government) at the same time (for example, the buildings at Kotnikova 5, Masarykova 16, Župančičeva 3, and Gregorčičeva 25). As a rule, different addressees gave the same answers to the Ombudsman's inquiries in such cases regarding the same buildings, but in some cases the addressees gave conflicting assessments, which indicates a non-uniform approach to assessing compliance with the requirements.
It is worrying that, despite the obvious shortcomings in ensuring accessibility, until the first inquiry by the Ombudsman (January 2024), they did not recognise the problems in this area and conducted detailed analyses and prepared a plan to ensure accessibility.
In particular, it should be noted that the legal (fifteen-year!) deadline for the adaptation of facilities in public use expires on 11/11/2025, which is why the fulfilment of requirements for the accessibility of facilities should be approached quickly and efficiently. At the time the Government was informed of the Ombudsman's findings in the present case, only 1 year and 4 months remained until the fulfilment of the legal requirements for the accessibility of facilities for public use.
The Ombudsman found outstanding deficiencies in ensuring accessibility at the premises of the Ministry of Health, which is responsible for tasks in the areas of public health, health care, health insurance, medical activities, and medicines and medical aids, which is why special attention must be paid to the accessibility of the building for persons with disabilities. There, out of all the 13 above-mentioned requirements from the first set of the questionnaire, only two are fulfilled – i.e. a parking space for persons with disabilities and a lift adapted for persons with mobility impairments. Access to the buildings is provided, for example, by means of a mobile device that is placed as needed. Persons with disabilities must register in advance to enter the building, and then someone must also set up the mobile device for them. The Ombudsman assesses that such a solution is only acceptable as a temporary measure, but it cannot fully comply with the prohibition of discrimination on the basis of disability, as it does not allow persons with disabilities to use the building independently. In connection with this, the MJU announced[17] that the Ministry of Health building is in the design phase of the arrangement of sanitary facilities adapted to persons with disabilities, and the user will be asked to arrange the equipment and markings for persons with sensory impairments. They admit that "the premises of the ministry are not optimal", the co-ownership and the nature of the facility are also a problem, "therefore, in the medium term, the relocation of the Ministry of Health to another, already identified, more suitable location, which will be fully arranged and also suitable from the point of view of accessibility for persons with mobility and sensory disabilities."
Regarding the provision of independent use of the building, we emphasise once again that the accompaniment of persons with disabilities, which is supposed to be provided in the building and was referred to in the questionnaire by some ministries and the Government, cannot replace the fulfilment of the requirement for the accessibility of buildings and their adaptation for independent use by persons with individual disabilities.
On the basis of the findings, the Ombudsman proposed that the Government form a working group to ensure the accessibility of Government facilities and ministries and to also include in it representatives of non-governmental organisations of persons with sensory and mobility disabilities and the Urban Planning Institute of the Republic of Slovenia; that the above-mentioned working group should as soon as possible carry out an analysis of the state of accessibility of the facilities of the Government and ministries for the disabled and, within this framework, determine uniform criteria for verifying the fulfilment of the requirements for the accessibility of the mentioned facilities and verify their actual fulfilment in each facility with field visits, while in the analysis of the state, it is taken into account that the escort of persons with disabilities, which may be provided in the facility, cannot replace the fulfilment of the requirement for adaptation of facilities for independent use by persons with disabilities. The Ombudsman also proposed that, based on the analysis of the situation, the working group should propose concrete measures to ensure accessibility, where it is not yet guaranteed, and, taking into account the rapidly expiring legal deadline for the adaptation of facilities, determine a clear timeline for the implementation of the proposed measures. The Ombudsman further proposed that the Government provide sufficient funds in the budget for the implementation of measures to ensure accessibility, and that special attention should be paid to improving the accessibility of the facility of the Ministry of Health.
The Government replied that the MJU had already carried out an internal analysis at the headquarters of the ministries at the time of the Ombudsman's first inquiry (January 2024) and that this analysis showed "that access to all buildings representing the headquarters of the ministries are properly regulated, which means that the requirements regarding of accessibility from the questionnaire and that the headquarters of all ministries managed by the MJU meet the basic requirement for accessibility to facilities, with regulated access to the reception of the ministries and lifts, and to the room for hearings and providing services for persons with disabilities”. They further explained that at that time, the MJU found that the three facilities that represent the headquarters of the ministries did not have sanitary facilities that would be suitably adapted for the use of persons with disabilities (MZ, MKRR and MGTSŠ), therefore adaptations were carried out in all three facilities, which should be completed by autumn 2024 at the latest.
They also drew attention to a certain spatial limitation of the offices of the ministries in the city centres, “where the dimensions of the buildings are limited by public (road) infrastructure and the nature of the buildings in the city centres is such that it does not guarantee the possibility of arranging a special parking place for persons with disabilities in all locations, but certainly follows such requirements in cases of new placements, i.e. when searching for new locations of state administration bodies and long-term strategic placements, which, due also to such circumstances, dictate a change of location of the body which operates in such a facility.”
With regard to the Ombudsman's recommendation that a working group be formed to ensure the accessibility of facilities of the Government and ministries, they explained that based on Paragraph 2 of Article 29 of the ZIMI, analytical, professional, and informational tasks regarding the use and adaptation of facilities for public use are performed by the Urban Institute of the Republic of Slovenia, which has established a national advisory information point, which is a centralised "on-line" platform where comprehensive information, materials, and data are available regarding all aspects of the obligation to ensure the accessibility of facilities. The purpose of the information point is to provide easy access to key information about the accessibility of facilities, which is helpful to both institutions and individuals.
Regarding the provision of sufficient funds, they explained that within the framework of the Development Programme Plan for the project 3130-21-0013 – Arrangement of Access for Persons with Disabilities in the Buildings of the Republic of Slovenia, EUR 684,953 is available in 2024, EUR 800,000 in 2025, EUR 800,000 in 2025, and in 2026 EUR 2,300,000. They explained that the dynamics of the funds are designed in accordance with the expectations of the financial consequences of the implementation of measures at the end of the 2025 budget year and the implementation of measures that do not only relate to the ZIMI. Regarding the Ministry of Health building, they explained that the ministry is moving to a new location, namely to premises on Hajdrihova Street in Ljubljana, expectedly in 2026. 1.2-2/2024
[1] The deadline for adapting facilities in public use expires on 11/12/2025 (Paragraph 2 of Article 38 of the Act on the Equalisation of Opportunities for Persons with Disabilities (ZIMI))
[2] For example, on p. 54 of the above-mentioned Special Report on the Accessibility of Centres for Social Work for Persons with Physical and Sensory Disabilities.
[3] Document number 14100-5/2021/3 of 14/10/2021.
[4] As part of the consideration of the matter, the Ombudsman received answers for four Government facilities in Ljubljana (Gregorčičeva 20, 25, 25a and 27) and for 16 facilities in Ljubljana that are managed by the Ministry of Public Administration – these are facilities of sixteen ministries, namely: Ministry of Natural Resources and Spatial Planning (MNVP, Dunajska 48), Ministry of the Environment, Climate and Energy (MOPE, Langusova 4), Ministry of Justice (MP, Župančičeva 3), Ministry of Finance (MF, Župančičeva 3), Ministry of Solidarity-Based Future (MSP, Dunajska 21), Ministry of Education (MVI, Masarykova 16), Ministry of Higher Education, Science and Innovation (MVZI, Masarykova 16 ), Ministry of Health (MZ, Štefanova 5), Ministry of Labour, Family, Social Affairs and Equal Opportunities (MDDSZ, Štukljeva 44), Ministry of Digital Transformation (MDP, Davčna 1), Ministry of Economy, Tourism and Sport (MGTŠ, Kotnikova 5), Ministry of Cohesion and Regional Development (MKRR, Kotnikova 5), Ministry of Public Administration (MJU, Tržaška 21), Ministry of Culture (MK, Maistrova 10), the Ministry of Agriculture, Forestry and Food (MKGP, Dunajska 22) and the Ministry of Infrastructure (MI, Tržaška 19). We also received answers for the facilities of 4 ministries in Ljubljana: the Ministry of Defence (MORS, Vojkova 55), two facilities of the Ministry of the Interior (MNZ, at the addresses: Litostrojska 54 and Štefanova 2) and five buildings of the Ministry of Foreign and European Affairs (MZEZ, at the addresses: Gregorčičeva 25, Grad Jable, Šubičeva 10, Šubičeva 11 and Prešernova 25).
[5] It did not comment on this issue, but the MF, which is based at the same address, said that they do not provide adequate access, so we considered that neither does the MP.
[6] It concerns 5 buildings of the MZEZ, buildings of the MF, MP, MSP, MZ, MNZ and MORS.
[7] We considered that the requirement was not fulfilled in the cases of buildings of the Government (4X), MZEZ (5x), MF, MP, MK, MZ and MORS.
[8] Facilities of the MVI, MVZI, MGTŠ, MDDSZ, MDP, MK, MKGP, MSP, MNZ.
[9] In two Government facilities and five of the MZEZ.
[10] In two Government facilities, and in addition, facilities of the MGTŠ, MDDSZ, MJU, MK, MKGP, MOPE, MNZ.
[11] The requirements are not fulfilled in two Government facilities, five facilities of the MZEZ, MF, MP, MKRR, MGTŠ, MZ, MNZ and MORS.
[12] The requirements are not fulfilled in five facilities of the MZEZ and in facilities of the MF, MVI, MVZI, MDDSZ, MDP, MK, MNVP, MZ and MORS.
[13] These are two Government buildings, five MZEZ buildings and buildings of the MDP, MK, MNVI, MZ, MNZ and MORS.
[14] They are provided in two Government facilities, as well as in facilities of the MVI and MVZI.
[15] MP, MVI, MVZI, MDDSZ, MK, and two facilities of the MNZ.
[16] MF, MSP, MORS, two facilities of the MZEZ.
[17] Letter no. 352-4/2024-3130-10 of 11/04/2024.