E-invoicing is coming: what it is and who it applies to from 1 January 2027

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Category: Daňové poradenstvo

From 1 January 2027, the era of PDF invoices sent by e-mail ends in Slovakia. VAT payers will have to issue domestic invoices exclusively in a structured electronic format and deliver them through the Peppol network. The obligation to receive such invoices, however, will apply to practically every business – including those not registered for VAT.

What an e-invoice is

An e-invoice is not a PDF invoice or a scanned paper document. It is a structured XML file compliant with the European standard EN 16931 (in practice the Peppol BIS format) containing all mandatory invoice elements – number, dates, supplier, customer, line items, taxable amount and VAT – in a form that accounting software can read and process automatically. A readable view on screen or a printout is generated by the software; the “original” document, however, is the XML.

E-invoices are not delivered by e-mail but through the international Peppol network via a certified delivery service provider, commonly called a “digital postman”. It works much like the postal service: every company has its own “mailbox” (Peppol ID) and the postman delivers the invoice to the customer’s mailbox. At the same time, the postman automatically reports selected invoice data to the Slovak tax authority (Finančná správa SR). The register of certified providers is maintained by the tax authority at vpds.financnasprava.sk.

Legal basis and timeline

Mandatory e-invoicing was introduced by an amendment to the VAT Act (Act No. 222/2004 Coll.) – Act No. 385/2025 Coll. The amendment took effect on 1 January 2026, but this date mainly opened a preparatory phase: accreditation of digital postmen, adaptation of accounting software and voluntary onboarding of businesses. The obligations themselves arrive in two steps:

  • From 1 January 2027 – mandatory e-invoicing for domestic supplies of goods and services between businesses (B2B) and to the public sector (B2G), together with automatic reporting of invoice data to the tax authority.

  • From 1 July 2030 – extension to cross-border transactions, both intra-EU and with third countries. At the same time, the VAT control statement and the EC sales list are abolished, since the state will receive the data directly from invoices.

Who must issue e-invoices

The obligation to issue e-invoices applies to VAT payers registered under Sections 4, 4b or 4c of the VAT Act when they supply goods or services with a place of supply in Slovakia to another business (taxable person), to a Slovak non-taxable legal entity (e.g. a municipality or a budgetary organisation) or to the Slovak fixed establishment of a foreign entity.

The obligation does not apply to invoices issued to consumers (B2C) – PDF or paper remain acceptable there – nor, until 2030, to cross-border supplies. Specific exemptions apply to classified supplies and deliveries to state security services.

Who must receive e-invoices – the more important question

Anyone to whom a VAT payer is obliged to issue an invoice must be able to receive an e-invoice. The law makes no distinction as to whether the customer is a VAT payer. The receiving obligation therefore applies to all companies and sole traders regardless of VAT registration, to the liberal professions (lawyers, notaries, architects, doctors, artists), to self-employed farmers, to persons letting real estate, and to non-profit organisations and public bodies whenever they purchase from VAT payers.

In other words: if your energy supplier, telecom operator or office landlord – all VAT payers – sends you an e-invoice from January 2027, you must have a digital postman in place to receive it on your behalf. The supplier does not need your consent to send it.

Reporting to the tax authority and penalties

E-invoicing comes with so-called digital reporting. Data from an issued invoice is reported by the digital postman to the tax authority within 15 days of issue; data from a received invoice within 5 days of receipt. This happens automatically, but the responsibility remains with the business – it must ensure the postman is working and that the invoice was issued in the correct format and on time. Failure to report, incorrect or late reporting, or an invoice in the wrong format may be penalised by a fine of up to EUR 10,000, rising to EUR 100,000 for repeated breaches. Obvious errors corrected without delay and a proven failure of the postman are not penalised.

Conclusion: what this means for your business

  • If you are a VAT payer, from 1 January 2027 a PDF invoice to a domestic business customer will no longer be a valid way of invoicing. You need invoicing or accounting software that supports e-invoicing and a contract with a digital postman.

  • If you are not a VAT payer, you still have to be able to receive e-invoices – i.e. you need a selected and contracted digital postman. Without one, your suppliers will be unable to deliver invoices to you.

  • 2026 is the year for preparation: mapping your invoicing, checking partner master data, choosing a postman and software. Anyone who starts in December risks an invoicing outage in January.

  • Our recommendation: get in touch with us. For our clients we will assess whether and to what extent the obligation applies to them, help with the choice of a digital postman and the set-up of processes, and for clients whose accounts we keep we will handle both receiving and sending e-invoices directly in our system. The practical steps are covered in the next article.

 

Sources: Finančná správa SR (Slovak tax authority) – project website www.info-efaktura.sk and the e-invoice section at www.financnasprava.sk; Act No. 385/2025 Coll. amending Act No. 222/2004 Coll. on VAT (Sections 76a and 85o). 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