E-invoicing: 10 real-life situations as interpreted by the tax authority

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Category: Tax Advisory

The Slovak tax authority (Finančná správa SR) keeps updating its guidance document “Frequently asked questions on e-invoicing” – the latest version of 26 August 2026 runs to 53 pages and answers dozens of questions from businesses. In this article we have selected the situations most relevant to our clients and added the current state of preparation in OMEGA (KROS) and POHODA (STORMWARE), the software in which we keep our clients’ accounts.

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1. Cash-register receipt up to EUR 400 – no e-invoice required

If you sell goods or services to a business and issue an eKasa cash-register receipt for up to EUR 400 including VAT, this is a simplified invoice and no e-invoice is needed. Above EUR 400, a sale to a domestic business requires an e-invoice, and the cash register only records the payment of the invoice (receipt type “UF”). For retail and services with cash sales to companies, this is the key threshold.

2. VAT-exempt supplies – no e-invoice and no reporting

For supplies exempt from VAT under Sections 28 to 42 of the VAT Act (e.g. exempt letting of real estate, financial and insurance services, healthcare, education), the VAT payer is not obliged to issue an invoice at all, and therefore no e-invoice either. Such invoices are neither subject to delivery via a digital postman nor to data reporting to the tax authority. Caution, though: if you voluntarily send such an invoice via Peppol, the system will process it and report the data – it does not distinguish the legal reason for issuing.

3. Proforma invoice versus invoice for a received payment

A proforma invoice or a request for payment is not an invoice under the VAT Act and is not sent through the e-invoicing system. However, as soon as you receive a payment before the supply, you must issue an invoice for the received payment – and from 1 January 2027 that invoice must be an e-invoice sent via a digital postman. Anyone working with advance payments needs to separate payment requests from tax documents correctly in their accounting software.

4. Rent, leasing and payment schedules – the end of the “payment agreement”

Today many landlords and leasing companies issue a single annual payment schedule containing all invoice elements. The tax authority has confirmed that under mandatory e-invoicing this is no longer possible from 1 January 2027: a VAT payer must issue a separate e-invoice for each recurring supply – i.e. monthly for each rent or lease instalment. Exempt letting (point 2) remains the exception. For landlords who are VAT payers this is a significant process change.

5. The key identifier is the tax ID (DIČ), not the company ID or VAT ID

In the Slovak configuration of the Peppol network, the recipient of an e-invoice is identified by its tax identification number (DIČ). An entity without a tax ID – for example some civic associations, owners’ associations or non-profits registered only under a company ID (IČO) – cannot receive an e-invoice. The tax authority therefore urges such entities to apply for a tax ID by autumn 2026. Equally: if a partner’s tax ID in your database is wrong or missing, the e-invoice will not be generated.

6. The customer is not ready – what then?

If from January 2027 you send an e-invoice via your digital postman and the customer has no postman in place, delivery will fail – but your legal obligation is fulfilled. The recipient’s consent to e-invoicing is not required and the deadline for issuing an invoice remains 15 days from the supply. Sending the invoice other than via the delivery service (by e-mail or EDI) is possible only with the recipient’s consent, and such an invoice is not reported to the tax authority.

7. Incorrect or unsolicited e-invoice

Delivery of an e-invoice does not mean its acceptance. If you receive an invoice with a wrong amount, or one you never ordered, you proceed as before: contact the supplier and request a credit note or a corrective invoice referencing the original document. The Peppol network has no “reject” function – it is always resolved directly between the partners. A sent e-invoice cannot be edited; every correction is a new document, which is again reported to the tax authority.

8. One postman for receiving, several for sending

The tax authority has confirmed the Peppol rule: for receiving e-invoices, a company may have only one digital postman registered for its tax ID. For sending, it may contract several (e.g. its accounting software and an invoicing app). Choosing the postman for receiving is therefore a decision that is hard to change later – and is made once.

9. Selecting the postman on the tax authority portal – the most common snag

The digital postman for a company is selected by its representative on the tax authority’s portal. The FAQ shows that managing directors often see only their own sole-trader business, not the company – because they lack authorisation to act for the legal entity in the portal’s personal internet zone. User registration and authorisation for the company are two separate steps. For clients we represent, we can complete this step under a power of attorney.

10. Archiving: XML, ten years

The tax authority has confirmed that a VAT payer must retain e-invoices in their original XML format for ten years from the end of the calendar year to which they relate. Converting them to PDF only is not sufficient. The same rule applies to issued and received documents.

State of preparation in OMEGA (KROS) and POHODA (STORMWARE)

In September 2026 KROS confirmed that the e-invoicing function, including the digital postman and the Peppol connection, will be released in OMEGA, ALFA plus and KROS Invoicing in autumn 2026; the tax authority lists KROS’s planned go-live for generating Peppol invoices as September 2026. The first visible step for users was the switch to logging in via a KROS account (e-mail) over the summer – a prerequisite for connecting to the postman. Receiving e-invoices will be free of charge, and issuing up to 50 e-invoices per month is included in the software licence. For our clients: as soon as the function is released, we will register the postman, set up the connection and run a test operation before January.

We keep part of our clients’ accounts in POHODA. Its developer STORMWARE is an accredited digital postman with its own access point, integrated directly in POHODA and in the mPohoda invoicing app – no exports and no additional application. The tax authority lists POHODA’s live operation for generating Peppol invoices from June 2026. Sending and receiving e-invoices up to a higher limit is included in the price of the SERVIS service or the mPohoda subscription. For clients whose accounts we keep in POHODA, the procedure is the same as with OMEGA – we select the STORMWARE postman on the tax authority portal and set up the connection.

Conclusion: what this means for your business

  • Review your invoicing relationships: rent, leasing, advance payments and cash sales to companies above EUR 400 are the areas where invoicing changes most from January 2027.

  • Check the tax IDs of your customers and suppliers. If you trade with organisations that have no tax ID, alert them that they need to apply for one this year.

  • Make sure you are authorised to act for your company on the tax authority portal, or grant us a power of attorney – without it, you cannot select a postman.

  • If you issue invoices yourself in your own software, read our next article – it gives an overview of the options, from a software upgrade to invoicing by our office.

Our recommendation: our office offers clients a short “e-invoicing readiness check” – we go through your invoice types, exemptions, partner data and the OMEGA set-up so that January 2027 passes without an invoicing outage. Contact us, especially if you let real estate, work with advance payments or sell to companies through a cash register.

Sources: Financial Directorate of the Slovak Republic – Frequently asked questions on e-invoicing, 9/DPH/2025/IM, version of 26 August 2026; www.info-efaktura.sk; Act No. 222/2004 Coll. on VAT as amended by Act No. 385/2025 Coll. (Sections 76a and 85o); KROS a. s. – www.kros.sk/efaktura and blog (September 2026); STORMWARE s. r. o. – www.stormware.sk/e-fakturacia/peppol. Information on OMEGA and POHODA is based on the vendor’s publicly announced plans as of 11 September 2026. This article is for information purposes only and does not replace individual tax advice.

[Translate to English:] Ing. Ján Polóny, PhD.
Ing. Ján Polóny, PhD.
Managing Director, Tax Advisor, Statutory Auditor