Approval of Mandatory Electronic Invoicing

The amendment introduces mandatory electronic invoicing and mandatory real-time electronic reporting of data on the supply of goods and services to the Financial Administration.

The new regulation is based on the rules of Council Directive (EU) 2025/516, which is part of the “VAT in the Digital Age” (ViDA) initiative. The main objectives of these measures are to adapt the EU VAT system to the digitalization of the economy, make combat against VAT fraud more effective, and simplify administrative obligations for businesses.

Slovakia has taken the opportunity to introduce mandatory electronic invoicing for domestic supplies of goods or services, as well as mandatory electronic reporting of data on domestic supplies of goods or services to the Financial Administration, effective from 1 January 2027.

New requirements for electronic invoices

For the purposes of the new rules, an electronic invoice will be any document or notification that contains all the mandatory invoice elements (such as invoice number, date of issue, subject of supply, recipient details, tax base, VAT, etc.) and is created, sent, and received:

• in an electronic document format that allows for automated and electronic processing, and
• in a data structure compliant with the technical standard for electronic invoicing (EN16931) and with the list of its syntaxes according to a special regulation – Commission Implementing Decision (EU) 2017/1870.

This will be a structured file in XML format. Unlike regular PDF invoices or scanned documents, an electronic invoice will contain structured data – that is, information recorded so that it can be read and processed by a system without manual retyping.

Who will be affected by the new obligations from 2027

Issuing and delivering electronic Invoices

From 2027, this obligation will apply only to domestic VAT payers (registered under §§ 4, 4b, and 4c of the VAT Act) when supplying goods or services with the place of supply in Slovakia to another domestic VAT payer, a taxable person, or a non-taxable legal person established in Slovakia, or when receiving payment before such supply.

These entities required to issue electronic invoices must ensure they can send and receive electronic invoices via a delivery service.

The recipient’s consent to issue a structured electronic invoice will not be required. Sending by other means than the delivery service will require the recipient’s consent.

Issuing an electronic invoice is prohibited if the recipient is the SIS (Slovak Intelligence Service), Military Intelligence, or if the supply is related to a classified fact, requires a classified fact, or contains a classified fact.

Receiving electronic invoices

Every person in Slovakia who receives goods or services for which the taxable person is required to issue an electronic invoice must ensure they can receive an electronic invoice sent via the delivery service.

Thus, this obligation will apply to every domestic recipient of goods or services, whether they are a VAT payer, a taxable person not registered for VAT, or a non-taxable legal person, who receives goods or services from a domestic VAT payer required to issue an electronic invoice.

Electronic data reporting

The obligation to digitally report specified data to the Financial Administration in real time will apply to supplies of goods or services for which a domestic VAT payer is required to issue an electronic invoice, which will be sent to the recipient via the delivery service.

Invoice data will be automatically reported to the Financial Administration via the delivery service. The obligation will be considered fulfilled for both the issuer and the recipient upon submitting the electronic invoice to the delivery service.

Data from electronic invoices sent by other means than the delivery service, as well as from non-electronic invoices, will not be reported.

Until the new rules take effect on 1 July 2030, data will continue to be reported in the VAT Ledger Statement and Recapitulative Statement (EU Sales List), which remain fully in force for now.

Cases where the obligation to issue an electronic invoice does not arise

The obligation to issue an electronic invoice does not arise, among others, in the case of:

• supplies of goods or services to final consumers (B2C);
• exempt supplies of goods and services under §§ 28 to 43 and 47 of the VAT Act (due to direct exemption arising from the nature of the service – e.g., financial services, insurance services, social assistance services), or cross-border supplies of goods, etc.;
• issuing a simplified invoice (document for goods or services if the price including tax does not exceed EUR 100, or a document from an e-cash register).

Sending electronic invoices – delivery service

Electronic invoices will be sent and received via certified delivery service providers in accordance with the European delivery standard – so-called “Digital Postmen.” The services of a certified provider can be used via accounting software, a web, or a mobile application. The choice of a specific certified delivery service provider will be at the discretion of each business.

The Slovak Financial Administration is to publish the European delivery standard meeting the requirements of the VAT Act as of 1 January 2026. At this stage, compliance is expected when using the Peppol network.

Peppol is a European network for the secure electronic exchange of business documents between participating entities. It is a decentralized solution that can have an unlimited number of service providers.

Electronic invoice delivery will be ensured by certified Peppol access providers, who will also provide selected invoice data to the Financial Administration.

From 1 January 2026, the Slovak Financial Administration will publish a list of certified delivery service providers that meet the conditions set by the relevant legal regulations.

Deadline for issuing an electronic invoice

The deadline for issuing an electronic invoice will be 15 days:

• from the date of supply of goods or services,
• from the date of receipt of payment before the supply of goods or services,
• from the end of the calendar month in which the event decisive for correcting the tax base occurred under the relevant provisions of the VAT Act,
• from the end of the calendar month for which a summary electronic invoice is issued.

The deadline will be considered met if the VAT payer issues the electronic invoice within 15 days from the date of subsequent notification by the recipient that they are a person to whom the payer was required to issue an invoice for the supply of goods or services or for receipt of payment before the supply.

Regarding summary invoices, the new regulation removes the possibility of issuing a summary invoice in the form of an agreement on payments for the supply of electricity, gas, water, or heat, as the European standard for electronic invoicing does not allow such an agreement.

Deadlines for electronic data reporting

The obligation to report invoice data will be fulfilled at the time of issuing the electronic invoice. If the electronic invoice is issued by the recipient on behalf of and for the account of the supplier, this must be done no later than five days from the date of issuing the electronic invoice or from the expiry of the deadline for issuing the electronic invoice.

For the recipient, the obligation must be fulfilled within five days from the date of receipt of the electronic invoice.

Sanctions

For failure to report data, late reporting, incomplete reporting, or incorrect reporting of data, the tax office may impose a fine of up to EUR 10,000. In the case of repeated breaches, the fine may reach up to EUR 100,000. When imposing a sanction, the seriousness and duration of the unlawful situation will be taken into account.

In the case of an obvious error with subsequent correction, or if it is demonstrable that a malfunction occurred on the part of the digital postman, a fine should not be imposed.

Transitional period – year 2026

In 2026, it will be possible to issue electronic invoices and send them via the delivery service on a voluntary basis. The Financial Administration’s portal will continuously publish a list of certified digital postmen.

Issuing an electronic invoice (regardless of compliance with the EU standard) that is not sent via the delivery service will require the recipient’s consent in 2026. If the recipient is also connected to the electronic invoice delivery system (has a digital postman), this will be considered as implied consent to the issuance of an electronic invoice.

The transitional arrangement during 2026 does not include electronic reporting of invoice data.

Further expected changes from 1 July 2030

Due to the obligation to transpose Article 5 of Directive 2025/516 into the VAT Act, from 1 July 2030, taxable persons (including those not established in Slovakia) will be required to issue and receive invoices in a structured electronic format also for cross-border supplies of goods or services, as well as to digitally report data on such supplies.

Data on such cross-border supplies will be centralized across the EU. Centralization will occur immediately after the creation and sending of the electronic invoice to the Financial Administration. Supplies and acquisitions within the EU will be compared. The obligation to submit the VAT Ledger Statement and Recapitulative Statement (EU Sales List) will also be abolished.

The deadline for issuing electronic invoices will be shortened to 10 days from the relevant event according to the relevant provisions of the VAT Act.

There will also be certain adjustments to the system provisions related to changes in invoicing rules.

Next steps

It is important to keep in mind that the new electronic invoicing obligations in Slovakia will take effect from 2027, and it will be possible to participate in the new invoicing system voluntarily from 2026.

Similar rules have already been introduced in various forms in some EU Member States and will apply to all EU Member States in the coming years.

These are major changes in tax administration and business communication. Companies operating across borders should pay attention to related obligations not only in Slovakia but throughout the EU. This includes, for example, analyzing and mapping invoicing processes, verifying system compatibility, ensuring necessary conversions, setting up validation processes, choosing a delivery service, and so on, to avoid the risk of tax penalties or loss of the right to deduct VAT.

In several areas of our services, we are ready to help you not only to navigate the new rules, but also, based on our experience with projects abroad, to assist in integrating with your existing systems and transitioning to electronic invoicing. Our teams are available for further assistance.