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Briefing document & Podcast: E-Invoicing and E-Reporting in Slovakia

Last update: February 2, 2026

 

Executive Summary

Slovakia is implementing a comprehensive, mandatory electronic invoicing (e-invoicing) and near-real-time electronic reporting (e-reporting) framework, aligning with the EU’s “VAT in the Digital Age” (ViDA) initiative. This reform will significantly transform VAT compliance for businesses operating in Slovakia. The mandate rolls out in phases, beginning with a voluntary period in 2026, becoming mandatory for domestic B2B and B2G transactions from January 1, 2027, and extending to cross-border B2B transactions within the EU from July 1, 2030. The system utilizes structured electronic formats (EN 16931, Peppol BIS 3.0 UBL XML) and a decentralized “5-corner” model involving certified private-sector “Digital Postmen” service providers and parallel reporting to the Financial Administration. Non-compliance carries substantial penalties, including fines up to €100,000 and the denial of VAT deductions or exemptions. While presenting short-term implementation challenges, particularly for SMEs, the long-term benefits are expected to include streamlined tax administration, reduced fraud, and increased efficiency for businesses.

1. Introduction and Context

Slovakia is “overhauling its invoicing and VAT reporting system as part of a mandatory electronic invoicing (e‑invoicing) and near-real-time electronic reporting (e‑reporting) framework.” These reforms are designed to align with the European Union’s “VAT in the Digital Age” (ViDA) initiative, aiming for a modernized and digital tax administration. The framework is enshrined in the amended VAT Act (Law No. 222/2004 Coll., specifically Act No. 385/2025 Coll.).

2. Scope of the Mandate

The mandate’s scope is broad, covering most transactions involving VAT-registered entities in Slovakia:

  • Domestic Business-to-Business (B2B) and Business-to-Government (B2G):
    • Mandatory from January 1, 2027.
    • “All invoices for domestic Business-to-Business (B2B) and Business-to-Government (B2G) supplies by Slovak VAT-registered persons must be issued and received in a structured electronic format and reported to the tax authority.”
    • This includes supplies of goods and services between Slovak taxable persons (companies, entrepreneurs, sole traders) and invoices to Slovak public sector entities.
    • B2G transactions are already partially subject to e-invoicing via the IS EFA platform since April 2023.
  • Business-to-Consumer (B2C):
    • Generally excluded from the e-invoicing mandate “at this stage.”
    • Traditional receipts (via eKasa) or paper invoices can continue for B2C. Simplified invoices and cash register receipts for low-value sales are subject to specific rules.
  • Intra-EU B2B (Cross-Border within EU):
    • Mandatory from July 1, 2030.
    • “Mandatory e‑invoicing and e‑reporting will extend to cross-border B2B transactions… starting 1 July 2030.”
    • This will replace the current EC Sales List filings. Until 2030, existing VAT invoice rules and EC Sales List reporting apply.
  • Imports & Exports (Extra-EU B2B):
    • Will fall under mandatory e-invoicing and e-reporting from July 2030, expanding to “all cross-border B2B exchanges.”
  • Taxable Persons in Scope:
    • Applies to “all ‘platitelia DPH’ (VAT-registered taxpayers) in Slovakia,” including companies, SMEs, sole traders, and self-employed professionals.
  • Non-established entities (foreign VAT payers registered under §§5, 7, or 7a of the VAT Act) are included but with a deferred implementation until June 30, 2030.
    • Foreign entities not registered for Slovak VAT are entirely outside the scope.
  • Exemptions and Special Cases:
    • B2C and small transactions: Not required for B2C; simplified invoices for sales under €100 or retail receipts up to €400.
    • Sensitive transactions: Excluded for security reasons (e.g., classified government contracts).
    • Special VAT Regimes: No blanket exemptions; if an invoice is required under a special regime, it must comply with e-invoicing rules.
    • Self-Billing: Included. “Self-billed invoices are included in the e‑invoicing regime” and must be in structured electronic format. The supplier remains responsible for reporting within 5 days.
    • Triangulation & Chain Transactions: Not exempt. Any domestic leg involving a Slovak VAT-registered business must be e-invoiced and reported.
    • Summary Invoices: Will be abolished; each supply must be invoiced separately or at minimum monthly.

3. Implementation Timeline

The mandate is being rolled out in distinct phases:

  • January 1, 2026 – Pilot/Voluntary Phase: The central e-invoicing infrastructure and “delivery service” network become available for voluntary use. Businesses can “test issuing and receiving structured e‑invoices and adapt their systems.”
  • January 1, 2027 – Mandatory Go-Live (Domestic): “Mandatory electronic invoicing and real-time digital reporting come into force for domestic B2B and B2G transactions.” Paper or PDF invoices will no longer be valid for in-scope transactions.
  • July 1, 2027 – Certified Transmission Requirement: Use of only certified “Digital Postman” service providers for transmitting/receiving e-invoices becomes mandatory.
  • July 1, 2030 – Cross-Border Extension: Mandatory e-invoicing and e-reporting extend to intra-EU B2B transactions and transactions by foreign entities with Slovak VAT registrations. The domestic “Kontrolný výkaz” (VAT control statement) and EU “súhrnný výkaz” (EC Sales List) will be fully phased out. The deadline for issuing invoices will also shorten from 15 to 10 days.

The year 2026 and the first half of 2027 serve as grace periods, emphasizing an educational approach, though penalties can apply post-go-live.

4. Technical and Functional Requirements

  • E-Invoice Format: Must be a “standard structured electronic format (XML) that conforms to the European Norm EN 16931.” The planned syntax is based on “Peppol BIS 3.0 UBL XML format” or UN/CEFACT CII. Unstructured formats (PDFs, scans, paper) will not be valid.
  • E-Report Data & Contents: The e-invoice itself serves as the source for reporting data. It must contain all legally required VAT invoice data fields, with some new mandated elements like the original invoice number for credit notes and the supplier’s bank account number.
  • Validation Rules: E-invoices will undergo automated validation checks by certified “Digital Postman” service providers to ensure format and content compliance.
  • Data Authenticity & Integrity: Relies on the security of the delivery network and accredited providers, who are obligated to verify identities and guarantee data authenticity and integrity (e.g., via secure channels and encryption).
  • Real-Time (Continuous) Reporting: Slovakia employs a “continuous transaction controls (CTC) model” with “near real-time” reporting.
  • Suppliers: Must transmit invoice data “effectively at the time of issuance” or “no later than by the statutory invoice deadline” (15 days, shortened to 10 days from 2030).
  • Buyers: Must report receiving an invoice within 5 days of receipt.
  • Self-billing: Supplier must report self-billed invoice data within 5 days.

5. Transmission & Workflow

  • Transmission Model: A “decentralized ‘5-corner’ model for e‑invoice exchange and reporting.” This involves a network of authorized private-sector “Digital Postmen” using the Peppol 4-corner framework, with the tax authority acting as the 5th corner.
  • Role of Certified Service Providers: Only certified “Digital Postmen” can transmit e-invoices. They must authenticate parties, validate formats, ensure data security, and automatically forward invoice data to the tax authority. The Financial Administration will maintain a registry of accredited providers.
  • Submission Channels: The Peppol network’s secure API/Access Point infrastructure will be the primary gateway. The tax authority’s system will receive data automatically from these providers, integrating reporting into the transmission process.

6. Archiving & Retention

  • Retention Period: All invoices (including e-invoices) must be archived for 10 years for VAT purposes, counting from the end of the year in which the taxable supply occurred.
  • Format and Storage Conditions: Invoices must be archived in an acceptable format that guarantees “authenticity, integrity, and legibility throughout the retention period.” Businesses are expected to store original structured electronic invoice files (XML).
  • Location of Storage: Flexible (Slovakia or abroad), provided tax authorities are granted “immediate, online access to the stored invoices without restriction and free of charge” upon request.

7. Penalties & Enforcement

Slovakia will enforce compliance with significant penalties:

  • Fines:Up to €10,000 for first-time or occasional offenses (e.g., failure to issue in required electronic form, late transmission).
  • Up to €100,000 for repeated or serious breaches (e.g., systematic non-compliance).
  • Leniency for minor errors or technical glitches that are promptly corrected.
  • Loss of VAT Rights:From 2027, a Slovak buyer cannot claim input VAT deduction on an incoming invoice that was not issued as a compliant e-invoice.
  • Starting July 2030, failure to properly report a cross-border supply within the EU will result in the loss of the VAT exemption (zero rate) for that intra-EU supply, treating it as taxable.
  • Penalties are grounded in the amended Slovak VAT Act.

8. Impact on SMEs and Startups

  • No SME Exemption: The mandate applies to “all sizes of businesses” that are VAT-registered; there is no exclusion based purely on company size or turnover.
  • Voluntary Adoption & Phased Approach: The 2026 voluntary phase and the 6-month transition for certified delivery services are particularly beneficial for SMEs to prepare.
  • Cost of Compliance: SMEs will need to invest in software/services to produce EN 16931-compliant XML invoices, potentially involving updating ERP systems or subscribing to e-invoicing services.
  • Administrative Burden vs. Simplification: Short-term increased administrative burden for implementation, but “in the medium to long term the reform is expected to reduce administrative overhead” through automation and reduced errors.
  • Government Support: The Financial Directorate offers guidance, FAQs, and webinars, encouraging SMEs to leverage available solutions.

9. Pre-Filled VAT Returns

  • Slovakia does not currently offer pre-filled VAT returns, nor has it explicitly announced plans to introduce them as part of this rollout.
  • The system’s real-time data will “replace the current ‘Kontrolný výkaz’ (control statement) and EU sales summary” by 2030. Taxpayers will still file periodic VAT returns, potentially with expanded fields for information not captured by e-invoicing (e.g., retail cash sales, simplified invoices).

10. Official References

The framework is supported by:

  • Legislation: Amendment to the VAT Act (Law No. 222/2004 Coll., Act No. 385/2025 Coll.), aligning with EU Directive 2014/55/EU and anticipating ViDA.
  • Government & Tax Authority Publications: Ministry of Finance and Financial Directorate (Finančná správa) provide guidance, including an official FAQ document (“Najčastejšie otázky a odpovede k eFaktúre”, document 9/DPH/2025) and dedicated informational portals (e.g., financnasprava.sk, info-efaktura.sk).
  • Technical Specifications: Detailed standards (schema definitions, code lists, API specifications for Peppol) are expected to be issued via a “generally binding regulation of the Ministry of Finance.”

Key Takeaways and Next Steps

Slovakia’s e-invoicing initiative represents a significant shift towards digital tax administration. Businesses must:

  • Assess current invoicing systems and identify necessary upgrades for EN 16931/UBL XML compatibility.
  • Engage with certified “Digital Postman” service providers to ensure compliant transmission and reporting.
  • Train staff on new processes and requirements.
  • Leverage the 2026 voluntary phase for testing and adaptation.
  • Be aware of critical deadlines (Jan 2027 for domestic, July 2030 for cross-border) and the severe penalties for non-compliance.

The long-term goal is to enhance VAT compliance, reduce fraud, and ultimately streamline business operations through automated data exchange.

 


INDEPTH ANALYSIS

E‑Invoicing and E‑Reporting in Slovakia – Comprehensive 2026 Update

Slovakia is overhauling its invoicing and VAT reporting system as part of a mandatory electronic invoicing (e‑invoicing) and near-real-time electronic reporting (e‑reporting) framework. The reforms align with the EU’s “VAT in the Digital Age” (ViDA) initiative and involve a phased implementation through 2027 and 2030. Below is a detailed analysis of the Slovak e‑invoicing/e‑reporting mandate, compiled from the latest legislation, official publications, and expert tax advisories (with sources cited):

1. Scope of the Mandate

Transactions in Scope: As of 1 January 2027, all invoices for domestic Business-to-Business (B2B) and Business-to-Government (B2G) supplies by Slovak VAT-registered persons must be issued and received in a structured electronic format and reported to the tax authority. This includes supplies of goods and services between Slovak taxable persons (companies, entrepreneurs, sole traders etc.), as well as invoices issued to Slovak public sector entities (B2G), which are already subject to e‑invoicing requirements under existing law. Key in-scope transaction categories are: [pwc.com], [vatupdate.com]
  • Domestic B2B: All business-to-business transactions between VAT-registered persons established in Slovakia must be invoiced electronically and reported from 2027. This covers sales of goods and services where both supplier and customer are Slovak taxable persons. (Notably, B2B e-invoicing has been voluntarily available since 1 January 2026, allowing businesses to prepare for the mandate.) [pwc.com] [flick.network]
  • Domestic B2G: Business-to-government invoices are also within scope. In fact, Slovakia already mandates e‑invoicing for many B2G transactions: since April 2023 the IS EFA (Informačný Systém Elektronickej Fakturácie) platform has been used for electronic invoices in public procurement, and B2G e-invoicing has been required for invoices over €5,000 to public entities. The new law integrates B2G into the overall e‑invoicing system and ensures all public authorities can receive and process e‑invoices (public bodies must accept structured e-invoices, with public contract invoices requiring a procurement reference number). Government-to-Government (G2G) invoicing is also handled via the IS EFA platform. [edicomgroup.com], [globalindi…gement.com] [snitechnology.net] [edicomgroup.com]
  • Domestic B2C: Consumer (business-to-consumer) transactions are generally excluded from the e‑invoicing mandate at this stage. The use of structured e‑invoices will not be compulsory for sales to private individuals (e.g. retail sales), and traditional receipts (via Slovakia’s electronic cash register system “eKasa”) or paper invoices can continue to be used for B2C. However, simplified invoices and cash register receipts for low-value sales are subject to certain rules (see Section 7 and Section 8), and their aggregated data will still ultimately be reported for VAT purposes through existing systems or periodic tax returns. [financnasprava.sk], [vatupdate.com] [snitechnology.net], [bdo.global]
  • Intra‑EU B2B (Cross‑Border within EU): **Mandatory e‑invoicing and e‑reporting will extend to cross-border B2B transactions (intra‑Community supplies and acquisitions between Slovakia and other EU member states) starting 1 July 2030. This is in line with the EU’s digital reporting requirements timeline under ViDA, which aims for harmonized electronic reporting of intra‑EU transactions by 2030. From that date, structured e‑invoices will become required for B2B supplies of goods and services across EU borders, and the data will be shared with tax authorities in near-real-time, replacing the current EC Sales List (European Sales Listing) filings. Until 2030, cross-border B2B invoices are not yet mandated to be in Slovakia’s e-invoicing system – they remain subject to existing VAT invoice rules and must still be reported via the summary EC Sales List in the interim. [edicomgroup.com], [taxadvisory.sk] [edicomgroup.com], [globalindi…gement.com] [accace.com], [bdo.global]
  • Imports & Exports (Extra‑EU B2B): Cross-border B2B transactions involving non-EU countries (e.g. export sales from Slovakia to a third country business, or imports of goods/services by Slovak businesses from non-EU suppliers) are treated similarly to intra-EU B2B for purposes of the e‑invoicing mandate. These will fall under the mandatory e‑invoicing and e‑reporting requirement from July 2030 (the point at which Slovakia’s system expands to all cross-border B2B exchanges). Prior to 2030, such transactions are outside the domestic e‑invoicing platform; exports continue to be zero‑rated with traditional invoice process, and imports continue to be handled via customs declarations and VAT accounting (with relevant documents outside the e‑invoice system). After 2030, however, data on inbound and outbound cross-border B2B transactions will be captured electronically to meet EU-wide “Digital Reporting” obligations. (Note: Cross‑border B2C transactions are not addressed by this mandate; consumer sales to or from abroad will follow existing rules for e‑commerce or OSS/IOSS schemes as applicable.) [snitechnology.net], [globalindi…gement.com] [edicomgroup.com], [globalindi…gement.com]
Special Inclusions and Scenarios: The Slovak e‑invoicing law encompasses various scenarios to ensure comprehensive coverage:
  • Self‑Billing: Yes. Self-billed invoices are included in the e‑invoicing regime. Slovakia’s VAT Act has long permitted self-billing (where the buyer issues an invoice on the supplier’s behalf with prior agreement), and under the new system these invoices must also be in the structured electronic format and reported via the platform. The law clarifies that if an invoice is issued by the customer (buyer) on behalf of the supplier, the supplier remains responsible for ensuring the invoice data is reported to the Financial Administration within 5 days (see Section 6 for details). In practice, the buyer’s certified service provider will transmit the e-invoice to the supplier and tax authority, and the supplier’s subsequent acknowledgment/receipt via the system effectively serves as the approval of the self-billed invoice. [sovos.com], [taxadvisory.sk] [sovos.com]
  • Triangulation & Chain Transactions: Yes. Complex multi-party transactions (such as triangulations or chain transactions) are not exempt from e‑invoicing. Any domestic leg of a transaction involving a Slovak VAT-registered business must be e‑invoiced and reported if it falls under the mandate’s timing and scope. For example, if multiple parties in Slovakia are involved in a chain of supplies, each transaction between Slovak VAT payers requires a compliant e‑invoice and reporting. For triangulation involving an EU or third-country intermediary: once cross-border e‑invoicing is in effect (2030), the invoice issued to the Slovak buyer in a triangular deal must follow Slovak e‑invoice requirements, even if an earlier party in the chain is established outside the EU. (In other words, a Slovak business cannot escape the e‑invoicing obligation simply because an intermediate supplier is abroad.) The law also aligns the tax timing for intra‑EU supplies to facilitate these workflows – as of 2030 the VAT tax point for EU cross-border supplies and acquisitions will shift to the 10th day of the month following the transaction (shortened from the 15th) to support prompt reporting. [accace.com] [accace.com], [bdo.global]
  • Special VAT Regimes: Yes. No blanket exemptions are provided for supplies under special VAT schemes (e.g. the margin scheme for travel agents or second-hand goods). If a taxable person is required to issue an invoice under any special VAT regime, that invoice must still comply with the e‑invoicing rules when the transaction falls in scope of B2B/B2G mandates. The invoice must include all legally required particulars (such as any references that indicate the special VAT treatment) in the electronic format. Notably, Slovakia does limit the use of “simplified invoices” (which omit some mandatory fields) – such invoices are permitted only for sales under €100, or retail receipts (e-kasa) up to €400. Above those small values, full e‑invoices must be issued, even for transactions under special schemes, to ensure all necessary data is reported. [snitechnology.net]
(In summary, the mandate’s scope is broad: from 2027 it captures all domestic B2B and B2G invoices between VAT-registered persons, with cross-border B2B to be added in 2030. B2C consumer transactions remain outside the e‑invoicing requirement. The regime explicitly covers self-billing and does not exclude complex scenarios like triangulations or margin schemes, aside from narrow exemptions such as invoices for state-security sensitive transactions.) [financnasprava.sk]

2. Taxable Persons in Scope

Covered Taxable Persons: The mandate applies to all “platitelia DPH” (VAT-registered taxpayers) in Slovakia, which includes all businesses and persons registered for VAT in the Slovak Republic – e.g. Slovak companies, SMEs and sole traders, self-employed professionals, partnerships, VAT-registered landlords, etc.. In the initial phase (2027), the requirement targets VAT-registered persons that are established in Slovakia (i.e. those with a Slovak seat or fixed establishment) and engage in in-scope transactions. By design, unregistered businesses (below the VAT threshold) and non-VATable persons (e.g. private individuals who are consumers) are not subject to the e‑invoicing obligation. [sovos.com], [financnasprava.sk] [taxadvisory.sk], [bdo.global]
Non-Established and Foreign Entities: Foreign or non-established entities that are registered for VAT in Slovakia (for example, via a tax representative or VAT registration under Slovak law) are included in the scope of the mandate, but with a deferred implementation. The law provides a transitional exclusion until 30 June 2030 for:
  • “Foreign VAT payers” registered under §5 of the VAT Act (i.e. businesses with no seat or fixed establishment in Slovakia but who have a local VAT registration), and [accace.com]
  • Taxable persons registered for VAT under §§7 or 7a (these typically are non-established entities or specific limited registrations, e.g. businesses identified for VAT only due to making intra-EU acquisitions or certain financial persons). [accace.com]
Starting 1 July 2030, these non-established VAT-registered entities will also be required to use e‑invoicing and e‑reporting for their cross-border B2B transactions. Until that date, foreign companies without a fixed establishment in Slovakia are not obliged to use the domestic e‑invoicing system for their supplies – they may continue issuing invoices under the general EU VAT rules (e.g. standard PDF or paper invoices) for cross-border sales, with Slovak VAT reporting accomplished via existing means (the control statement and summary EC Sales List). [accace.com] [accace.com], [bdo.global]
Importantly, foreign entities that are not registered for Slovak VAT at all (no Slovak VAT number) remain entirely outside the scope of this regime. For instance, if a foreign company sells to a Slovak business without registering for Slovak VAT (e.g. under reverse-charge mechanisms or distance selling thresholds), the foreign supplier is not directly covered by Slovakia’s e‑invoicing rules. In such cases the Slovak buyer’s VAT obligations (like reverse-charge accounting or simplified invoice self-issuance) continue under existing rules until the EU-level reporting system is in place. [bdo.global]
Exemptions & Special Cases: The e‑invoicing legislation defines a few limited exemptions and special cases for particular taxpayers or transactions:
  • B2C and small transactions: As noted, invoices to non-taxable persons (consumers) are not required to be e‑invoices, and “simplified invoices” (with reduced information) can be issued in lieu of full e‑invoices for sales under €100, or retail cash register receipts up to €400. These small or cash transactions do not have to be transmitted through the e‑invoicing system. (Data from cash registers will be captured via the e‑Kasa system and ultimately reflected in VAT returns instead.) [financnasprava.sk] [snitechnology.net] [bdo.global]
  • Sensitive transactions: Certain sensitive supplies are excluded from e‑invoicing for security reasons. For example, invoices related to classified government contracts or defense and security agencies (e.g. Slovak Information Service, military intelligence) must not be issued as e‑invoices; in such cases traditional paper invoices or other appropriate forms are used. [financnasprava.sk]
  • Sector-specific rules: No broad sector-based exemptions (e.g. no industry is categorically excluded from the mandate). All businesses — including SMEs, large enterprises, and public entities — must comply if they are VAT-registered and engaging in covered transactions. One notable clarification in the law is that buyers can no longer refuse electronic invoices: the prior requirement to obtain customer consent for e‑invoicing is removed (e-invoices become the default invoicing method once the law is in effect). [sovos.com] [bdo.global]
  • Voluntary Participation: During 2026, taxable persons have the option to participate in a pilot/voluntary phase to adopt the new e‑invoicing system early. This allows businesses (particularly those not immediately mandated or those seeking to test their systems) to opt in before 2027. Additionally, even after 2027, businesses not yet obligated (such as foreign VAT-registered suppliers prior to 2030, or those issuing B2C invoices) may choose to use the e-invoicing system on a voluntary basis to streamline operations or meet trading partners’ demands. The Financial Administration has encouraged early adoption by providing guidance and a transitional period with no penalties in 2026. [flick.network] [taxadvisory.sk]

3. Implementation Timeline

Legislative Development: Slovakia’s e‑invoicing initiative has been under discussion for several years. A voluntary B2B e‑invoicing system was first proposed in 2022 (though its rollout was delayed). The concrete push came in late 2024, when a draft amendment to the VAT Act (Law No. 222/2004 Coll.) was introduced to establish a mandatory e‑invoicing and e‑reporting framework in line with the EU’s upcoming ViDA rules. After public consultation in mid-2025, the Slovak government approved the proposal on 24 September 2025. The National Council (parliament) passed the amendment in December 2025, and the law was signed and published as Act No. 385/2025 Coll. (amending the VAT Act) by the end of 2025. [edicomgroup.com] [edicomgroup.com], [edicomgroup.com] [globalindi…gement.com] [taxadvisory.sk] [sovos.com]
Phased Rollout: The mandate is being implemented in phases to give businesses time to adapt: [flick.network]
  • 1 January 2026 – Pilot/Voluntary Phase: The central e‑invoicing infrastructure and “delivery service” network (see Section 5) are made available for voluntary use by all VAT-registered businesses in 2026. During this period, companies can test issuing and receiving structured e‑invoices and adapt their systems ahead of the mandate. [taxadvisory.sk]
  • 1 January 2027 – Mandatory Go-Live: Mandatory electronic invoicing and real-time digital reporting come into force for domestic B2B and B2G transactions. From this date, Slovak VAT-registered suppliers must issue, and their business/government customers must receive, all B2B/B2G invoices in the prescribed electronic format via certified channels. Each invoice’s data must be reported to the Financial Administration as it is issued (details in Section 5). Traditional paper or PDF invoices will no longer be considered valid for in-scope transactions. (Notably, as of this date electronic archiving of invoices also becomes obligatory – see Section 8.) [taxadvisory.sk], [pwc.com] [edicomgroup.com], [taxadvisory.sk]
  • 1 July 2027 – Certified Transmission Requirement: By mid-2027, the use of only certified “Digital Postman” service providers for transmitting/receiving e‑invoices becomes mandatory. (This implies a 6-month transition at the start of 2027 during which businesses can continue calibrating their systems and providers finalize accreditation. After July 2027, all e‑invoices must be exchanged through a certified delivery service provider as part of the official network.) [accace.com]
  • 1 July 2030 – Cross-Border Extension: Mandatory e‑invoicing and e‑reporting extend to cross-border intra-EU B2B transactions (supplies and acquisitions involving EU counterparties). At this point, the system will also cover transactions by foreign entities with Slovak VAT registrations (end of the transition period for §5/§7 registrants – see Section 2). The domestic “Kontrolný výkaz” (VAT control statement) and the EU “súhrnný výkaz” (EC Sales List) will be fully phased out from mid-2030, since the new system will automatically capture the necessary data from e‑invoices and digital reports. [edicomgroup.com], [taxadvisory.sk] [accace.com] [globalindi…gement.com], [financnasprava.sk]
Grace Periods: The timeline above inherently provides grace periods. The entire year 2026 is a grace period (pilot phase) with no obligation to comply, giving businesses time to prepare and opt in early. The first half of 2027 can be viewed as a further grace period for transmission methods – businesses are expected to issue e-invoices from January 2027, but only by July 2027 do they must use an officially certified service provider for transmission. This allows additional time for companies (and service providers) to get certified solutions in place. No general extension of the go-live date by company size or sector is provided – the 2027 mandate applies to all sizes and sectors uniformly, rather than staggering (unlike some other countries’ phased approaches). However, as noted, non-established taxable persons have until 2030 before they are required to comply, and purely B2C businesses remain outside the mandate. The Financial Administration has indicated a flexible, educational approach during the transition – focusing on helping taxpayers comply – but after go-live, penalties can be enforced for non-compliance (see Section 9). [taxadvisory.sk] [accace.com] [financnasprava.sk]

4. Technical & Functional Requirements

E‑Invoice Format: Slovakia’s e‑invoices must be issued in a standard structured electronic format (XML) that **conforms to the European Norm EN 16931 (the EU standard for e‑invoicing). The planned syntax is based on the Peppol BIS 3.0 UBL XML format (Universal Business Language XML) as specified in EU Directive 2014/55/EU and its implementing regulations. This means supported formats will include UBL 2.1 or UN/CEFACT CII (Cross-Industry Invoice) structured data following the semantic data model of EN 16931. In practice, an invoice must contain all legally required VAT invoice data fields and be presented in a machine-readable XML structure that can be processed automatically by the parties’ software and the tax authority’s systems. Unstructured formats (PDFs, scans, paper) will no longer count as valid invoices for transactions in scope once the mandate is active. [pwc.com], [snitechnology.net] [snitechnology.net], [taxadvisory.sk] [snitechnology.net] [pwc.com], [flick.network] [flick.network], [financnasprava.sk]
E‑Report Data & Contents: Slovakia’s model is a combined e‑invoicing and e‑reporting system – the electronic invoice itself effectively serves as the source of the reporting data to the tax authority. Thus, the e‑reporting “format” is essentially the data elements extracted from the e‑invoice. Each required invoice field (buyer/seller details, tax identification numbers, invoice date/number, line-item details, tax base, VAT amount/rate, etc.) is defined by the EN 16931 standard and national specifications. The Ministry of Finance will issue a detailed technical regulation specifying the mandatory data elements and structure for Slovak e‑invoices (built on the EU standard). Key fields will include all those currently required on paper invoices by the VAT Act, with some new elements introduced by the amendment – for example, the original invoice number on credit notes and the supplier’s bank account number are explicitly mandated fields under the new rules. [flick.network] [pwc.com] [accace.com]
Validation Rules: E‑invoices will be subject to automated validation checks. The law establishes that certified “Digital Postman” service providers must perform formal checks on each invoice to ensure it meets the required format and content rules (e.g. all required fields present, correct structure) before forwarding it to the recipient and authorities. This automated verification helps prevent common errors or missing information, thereby improving data quality and reducing the need for manual corrections. [sovos.com]
Data Authenticity & Integrity: Ensuring the authenticity of origin and integrity of e‑invoices is paramount. Instead of requiring each invoice to be individually signed by the issuer, Slovakia’s system will rely on the security of the delivery network and providers. Only accredited e‑invoice service providers can transmit invoices, and they are obligated to verify the identities of senders/recipients and guarantee the authenticity and integrity of the transmitted data (for example, through secure channels and encryption). The use of the Peppol network – which uses secure protocols and accredited Access Points – is explicitly recognized as meeting the required European delivery standards for security. Additionally, invoices archived electronically must maintain integrity and legibility for the full retention period, e.g. via reliable storage with audit logs or electronic signatures ensuring the content has not been altered. [snitechnology.net] [snitechnology.net], [snitechnology.net] [basware.com]
Real-Time (Continuous) Reporting: The Slovak system is a continuous transaction controls (CTC) model with “near real-time” reporting of invoice data. Businesses will be required to transmit invoice data to the Financial Administration effectively at the time of issuance. In practice, when a supplier issues an e‑invoice, their certified service provider will simultaneously or immediately thereafter send the invoice data to the tax authority’s system. This is a clearance-like model without a central storage: instead of the tax authority pre-approving each invoice, the invoice is delivered directly to the buyer through the Peppol-based network while the data is reported to the tax authority in parallel. The law specifies that suppliers must report invoice data at issuance or no later than by the statutory invoice deadline (which remains 15 days after the taxable supply until 2030). If the buyer issues the invoice (self-billing), the supplier must report its data within 5 days. On the recipient’s side, buyers must report receiving an invoice within 5 days of receipt – this effectively means the platform will capture confirmation of receipt, serving as a double-check for the tax authority. These tight deadlines ensure the tax authority has visibility of transactions almost in real time, greatly shortening the reporting cycle compared to the monthly or quarterly VAT return system. [sovos.com] [edicomgroup.com], [edicomgroup.com]

5. Transmission & Workflow

Transmission Model: Slovakia is adopting a decentralized “5-corner” model for e‑invoice exchange and reporting. Rather than a single central government platform that ingests and forwards all invoices, the system relies on a network of authorized private-sector e‑invoicing service providers (known as Digitálni poštári or “Digital Postmen”) to facilitate invoice exchanges and data reporting. The Slovak Financial Administration (Finančná správa) will act as the national Peppol Authority supervising this network. The Peppol 4-corner framework has been chosen as the backbone, meaning each business can select an accredited Access Point provider to send/receive invoices, and all providers must interoperate using Peppol standard protocols. An additional “5th corner” is the tax authority, which receives the invoice data in parallel. In summary, when a supplier issues an invoice from its ERP or billing system (or via a provider’s platform), the invoice is sent in structured form through the Digital Postman service to the buyer (who receives it via their own provider or software), and simultaneously the data is transmitted to the government for compliance reporting. [edicomgroup.com] [financnasprava.sk], [sovos.com] [edicomgroup.com], [financnasprava.sk] [basware.com], [basware.com] [edicomgroup.com], [basware.com]
Role of Certified Service Providers: Only certified delivery services can be used to transmit e‑invoices once the system is live. These providers/Access Points must meet strict criteria set by the Financial Directorate, including the ability to authenticate senders and recipients, perform format/contents validation, ensure data security (confidentiality, integrity, authenticity), and automatically forward the invoice data to the tax authority’s systems. The government will maintain a registry of accredited e-invoicing service providers and digital delivery standards; a formal accreditation (“certification”) process is in place to approve providers by early 2027. Businesses may either use a certified third-party e‑invoicing platform or ensure their in-house ERP/accounting software is updated and certified to connect to the system. During 2026, the Ministry of Finance is expected to publish the technical specifications and a list of certified “Digital Postman” providers, so companies can choose a provider and configure their systems in time. [accace.com] [sovos.com], [snitechnology.net] [accace.com], [basware.com] [taxadvisory.sk] [basware.com]
Submission Channels: For B2G invoices (up to 2026), the existing central platform “IS EFA” is used – suppliers send structured invoices (UBL/CII) either via the IS EFA web portal or through Peppol to reach public entities. (Foreign suppliers to Slovak public bodies have been allowed to send e-invoices via email if they cannot access IS EFA, with confirmation by the authority via email.) For B2B and future flows, the new model will be Peppol-based. In essence, the Peppol network’s secure API/Access Point infrastructure will serve as the gateway for all invoices: providers will connect either through Peppol APIs or their platforms to route invoices. The tax authority’s system will receive the data automatically from the providers – there is no separate manual portal upload to the tax authority for each invoice, as reporting is integrated into the transmission process by the service providers. [edicomgroup.com], [basware.com] [basware.com], [basware.com] [snitechnology.net]
Reporting Deadlines: The Slovak system imposes tight deadlines for sending invoice data:
  • “Real-time” for suppliers: Suppliers must send the invoice data to the Financial Administration essentially at the time of issuance (immediately upon issuing the invoice). The law permits at latest sending by the statutory invoice issuance deadline (which is generally 15 days from the taxable supply, to be shortened to 10 days in 2030). In practice, compliant software will trigger the reporting automatically when the invoice is generated. [sovos.com] [taxadvisory.sk], [accace.com]
  • T + 5 days for buyers: Customers (invoice recipients) must report the data from received e‑invoices within 5 days of receipt. This so-called buyer side reporting is also automated by the system – when the buyer’s Digital Postman receives the invoice, it will notify the tax authority or prompt the buyer’s system to acknowledge receipt within five days. This requirement ensures that the tax authority can cross-match sales and purchase records quickly (and detect any unreported invoices). [sovos.com] [financnasprava.sk], [sovos.com]
  • Self-billing timeline: In a self-billing scenario, where the customer issues the invoice, the law also effectively imposes a 5-day reporting window for the supplier on whose behalf the invoice was issued. (This aligns with the buyer-side requirement above – essentially, the supplier, as “recipient” of a self-billed invoice, would need to acknowledge/report it within 5 days of receiving it via the system.) [taxadvisory.sk]
  • Periodic summaries: The Slovak system prioritizes transaction-by-transaction reporting over periodic summaries. No monthly or quarterly invoice listing is required for e‑invoiced transactions, since each invoice is individually reported in near-real-time. However, certain transactions that are outside the e‑invoice system (e.g. retail cash sales, simplified invoices, some exempt supplies) will still be aggregated and reported via periodic VAT returns or existing systems until 2030. By July 2030, even intra-EU transactions will be reported per invoice, enabling elimination of monthly/quarterly summary filings (the control statement and EU sales list). [bdo.global] [financnasprava.sk]

6. Self‑Billing

Allowance and Requirements: Slovak VAT legislation permits self-billing, and this remains true under the e‑invoicing mandate. Self-billed invoices (where the buyer issues the invoice in the name of the supplier) are allowed but must comply with all the new e‑invoicing requirements. In practice, the buyer’s accounting system or service provider will generate a compliant e‑invoice (in the required XML format) and route it through a certified delivery service just like any other invoice. The invoice will be delivered to the supplier via the platform and simultaneously reported to the tax authority. The e‑invoice data must include all standard mandatory fields (including those identifying the supplier and buyer) and should clearly indicate that it is a self‑billed invoice, as required by VAT law (e.g. by stating “Self-billing” on the invoice, which the EN16931 format supports via a specific indicator). [sovos.com] [snitechnology.net]
Reporting and Validation: The obligation to report a self-billed invoice’s data to the Financial Administration lies with the supplier (the VAT-registered person on whose behalf the customer issued the invoice). However, the technical process is largely automated: when the buyer issues the e‑invoice through the system, the certified service provider ensures the data is sent to the tax authority and the invoice is delivered to the supplier. The supplier then has up to 5 days to “acknowledge” or report the invoice data – in practice, this is expected to occur automatically when the supplier’s system receives the e‑invoice copy and validates it. The dual reporting (by buyer at issuance and by supplier upon receipt) creates a double-check, ensuring both parties are aware of and agree with the invoiced amount. [taxadvisory.sk]
Buyer’s Responsibilities: If you are a buyer using self-billing, you must have a prior agreement with the supplier to issue invoices on their behalf (as per general VAT rules). Under the e‑invoicing regime, you will also need to use an accredited e‑invoicing solution to generate the invoice data and send it through the official network (you cannot simply send a paper or PDF invoice to the supplier). The buyer’s certified provider will perform the same validations on a self-billed invoice as on any other invoice to ensure it meets the schema and content rules before it is forwarded. There is no separate “approval” step mandated beyond the supplier’s acknowledgment via the system – the supplier’s receipt and processing of the self-billed e‑invoice in their system effectively serves as confirmation of acceptance. Both the buyer and the supplier then include the transaction in their respective e‑reporting obligations (with the buyer reporting upon issuance, and the supplier reporting upon receipt) so that tax authorities are informed from both sides. [sovos.com] [taxadvisory.sk], [sovos.com]
Content and Notifications: A self-billed e‑invoice must contain all information required by the VAT Act just like any other invoice, including an explicit statement that it is issued by the customer (this is usually achieved by the presence of the self-billing indicator or a text note on the invoice). The platform will handle notification requirements: for instance, the supplier will automatically be notified that an invoice was issued on their behalf via their chosen Digital Postman service. No special manual notification to the tax authority is needed beyond the standard e‑reporting, as the data is automatically transmitted through the system. [pwc.com]
In summary, self-billing is permissible under Slovakia’s e‑invoicing regime but does not bypass the system – such invoices must be electronic and reported just like any other, with the buyer’s provider facilitating transmission and the supplier taking responsibility for timely reporting/acknowledgment of the invoice data. [taxadvisory.sk]

7. Triangulation & Special Scenarios

Slovakia’s e‑invoicing law and forthcoming regulations address various complex transaction scenarios to ensure comprehensive VAT reporting:
  • Triangulation Transactions (Three-Party Cross-Border Trades): Triangulation typically involves a chain of successive supplies among three parties in different countries for a single movement of goods. Under the Slovak system, triangulation involving a Slovak VAT-registered business will be subject to e‑invoicing/reporting requirements for the portion of the transaction that involves the Slovak entity. In practice, this means that whenever a Slovak business is the seller or buyer in a multi-party transaction, the invoice it issues or receives must comply with the e‑invoicing mandate (if the transaction is within Slovakia or, after 2030, within the EU). For example, if a Slovak company is the final recipient in a triangular deal where the first supplier and intermediate buyer are abroad, the invoice issued to the Slovak company (for the movement of goods into Slovakia) will need to be an e‑invoice compliant with Slovak rules once cross-border e‑invoicing is in effect. The law specifically notes that in a triangular scenario where the “first buyer” is from a third country (non-EU), the invoice to the Slovak recipient must follow Slovak VAT Act requirements, including the e‑invoicing obligations. This ensures that even complex chains cannot be used to circumvent domestic reporting – any taxable supply received by a Slovak business will be captured. [accace.com]
  • Chain Transactions (Multiple Domestic Parties): In chain transactions entirely within Slovakia (e.g. A sells to B, then B resells to C, with goods passing directly from A to C), each invoice between Slovak VAT payers must be electronic and reported. There is no special exemption for chain transactions; they are treated as successive domestic B2B supplies. Each supplier in the chain (A’s sale to B, and B’s sale to C) must issue a compliant e‑invoice to their customer and report it. The timeline and deadlines (real-time reporting) apply to each of those invoices individually. The system will allow the tax authority to cross-link such chain transactions if needed (via matching of invoice references, etc.), improving transparency across supply chains.
  • Cross-Border Reverse Charge Scenarios: For cross-border services or other reverse-charge situations (where a foreign supplier does not charge VAT and the Slovak recipient must self-account for VAT), these transactions will fall under the e‑reporting mandate once cross-border phase is active (from 2030). At that point, both the outbound invoice (if issued by a Slovak supplier to an EU customer) and the inbound transaction (if a Slovak buyer acquires services/goods from an EU supplier) will be reported digitally. The new system is intended to replace the current summary reporting: data on cross-border EU supplies and purchases will be shared automatically, eliminating the need for separate EC Sales Listings. Until 2030, reverse-charge scenarios continue to be handled via existing mechanisms (e.g. the Slovak buyer must still create accounting documents for any required self-charge of VAT, and report these via the VAT return and control statement, rather than through the e‑invoice system). [globalindi…gement.com], [bdo.global]
  • Zero-Rated & Exempt Supplies: Domestic transactions that are VAT-exempt or zero-rated are generally still subject to the e‑invoicing obligation if an invoice is issued (for example, a VAT-exempt supply to another business must be e‑invoiced, just with the appropriate “VAT exempt” indication in the data). However, there are simplified reporting rules for some of these cases. According to the proposed framework, certain wholly-exempt domestic supplies may be excluded from the real-time reporting requirement. Also, as noted above, sales recorded via electronic cash registers (e.g. typical retail sales which are often VAT-exempt or include VAT but to consumers) and sales documented by simplified invoices will not each be individually reported; instead their aggregated totals will be accounted for through periodic VAT returns. This ensures that the e‑reporting system focuses on the most critical transactions (B2B and high-value invoices) while simpler transactions are handled by existing systems. Importantly, if a taxpayer chooses to issue a full e‑invoice even for a transaction that could be treated as simplified (for instance, a B2C sale where the customer requests a VAT invoice), then that e‑invoice would be sent through the system like any other. [snitechnology.net] [bdo.global]
  • Local Nuances: The Slovak implementation includes some unique local provisions. For example, as mentioned, summary invoices (consolidated invoices for periodic or multiple supplies) will be abolished – businesses can no longer issue a single summary invoice covering numerous transactions over a period (e.g. a monthly summary invoice for utility bills or rentals). Instead, each supply must be invoiced (and e‑reported) separately or on a monthly basis at minimum. This change ensures more granular, timely reporting of each transaction. Additionally, the deadline for issuing invoices will be shortened from 15 days to 10 days as of 1 July 2030, as part of aligning with “real-time” reporting – this means a supplier must issue (and report) an invoice within 10 days of the taxable supply (down from the current 15-day rule). The law also contains anti-fraud measures tied to reporting compliance: for instance, starting 2030, failure to timely report an intra-EU supply will result in loss of the VAT exemption for that supply (the transaction would be treated as taxable). This creates a strong incentive to comply with the new reporting deadlines in special scenarios like cross-border trades. [accace.com] [accace.com], [bdo.global]

8. Archiving & Retention

Retention Period: All invoices (including e‑invoices) must be archived for 10 years for VAT purposes, counted from the end of the year in which the taxable supply occurred. This 10-year retention requirement remains the same under the new e‑invoicing law, aligning with the standard VAT record-keeping period. [snitechnology.net], [basware.com]
Format and Storage Conditions: Invoices must be archived in an acceptable format that guarantees their authenticity, integrity, and legibility throughout the retention period. Given that invoices will be issued and received electronically, businesses are expected to store the original structured electronic invoice files (XML) in a secure manner. The law permits invoices to be converted from paper to electronic form for storage (e.g. scanning a paper invoice to PDF/XML) provided that the conversion ensures the data’s credibility and integrity – typically by using a qualified electronic signature or other approved controls. In practice, since the mandate requires invoices to be natively electronic, businesses will likely archive the EN 16931-compliant XML files along with human-readable renderings if needed, using either their own IT systems or archiving services. [basware.com]
Location of Storage: Slovak regulations are flexible regarding storage location – invoices may be archived within Slovakia or abroad (including in other EU or third countries), as long as certain conditions are met. Tax authorities must be ensured immediate, online access to the stored invoices without restriction and free of charge if they request them for audit. This typically means using electronic archiving solutions that allow prompt retrieval and presentation of invoices to authorities. If using a third-country (non-EU) storage service, businesses should ensure this access and integrity requirement is not compromised. The use of reputable, secure archiving platforms (including those offered by certified e‑invoicing service providers) is advisable. [basware.com], [basware.com] [basware.com]
Integrity & Readability Requirements: The archived invoices must remain unaltered, accessible, and readable for the full 10-year period. This ties into requirements of data integrity and authenticity – companies need to safeguard e‑invoices against modification or loss. The use of digital timestamps or signatures, audit trails, and secure storage environments is expected to fulfill these requirements, as is compliance with EU standards on electronic record-keeping. Upon audit, tax inspectors should be able to obtain human-readable invoices on request and verify their electronic authenticity (e.g. via the signature or electronic seal). Businesses must organize their e-archive such that invoices can be readily retrieved and exported in a legible format. Failure to maintain proper archiving can itself result in penalties under Slovak law (as a breach of record-keeping obligations). [basware.com]

9. Penalties & Enforcement

Enforcement Approach: The Slovak authorities have indicated an initial focus on education and support during the transition (2026 and early 2027), but once mandatory phases begin, non-compliance with e‑invoicing and e‑reporting obligations will be subject to significant penalties. The law introduces specific fines for failures related to the new system: [snitechnology.net]
  • Failure to issue an invoice in the required electronic form, or to transmit the invoice data as required, can result in a penalty of up to €10,000 for a first-time or occasional offense. This could apply to scenarios such as continuing to use paper/PDF invoices for B2B transactions after 2027, or not routing invoices via a certified provider, or neglecting to send the data to the tax authority on time. [snitechnology.net]
  • Repeated or serious breaches (e.g. systematic non-compliance) can incur fines up to €100,000. This elevated penalty can be applied if the offense is repeated or if the omission is deemed intentional/grossly negligent. [snitechnology.net]
  • Late reporting or data errors: If invoice data are reported past the deadline or contain inaccuracies, penalties may also apply (up to the same €10k/€100k limits). However, the law provides for leniency in cases of minor errors or technical glitches – if a mistake is clearly unintentional and is corrected without delay, or if a certified provider’s system outage caused a delay which is resolved promptly, no fine will be imposed. This encourages taxpayers to fix issues immediately once identified. [financnasprava.sk], [financnasprava.sk]
  • Apart from financial fines, a significant punitive measure involves the VAT treatment of unreported sales. Starting **July 2030, if a taxpayer fails to properly report a cross-border supply of goods within the EU, they will lose the right to apply the VAT exemption (zero rate) for that intra‑EU supply. In practice, this means that not reporting the details of an EU sale could lead to that sale being treated as taxable (with Slovak VAT due on it) instead of zero-rated. Similarly, from 2027, a Slovak buyer cannot legally claim an input-VAT deduction on an incoming invoice that was not issued as a compliant e‑invoice. These provisions create strong incentives for both suppliers and customers to use the e‑invoicing system – failing to do so not only risks fines but also tax consequences (denial of VAT recovery or zero-rating). [accace.com] [taxadvisory.sk], [bdo.global]
  • Platform misuse or data tampering: The certified “Digital Postmen” are also regulated entities – they must ensure proper functioning of the system. Any attempt to bypass the system or tamper with invoices can trigger enforcement action. While specifics are in the law, businesses should assume that issuing fake or fraudulent invoices, altering invoice data after issuance, or failing to maintain secure records will carry penalties consistent with existing tax fraud and bookkeeping offenses.
All penalties are grounded in Slovak law (amended VAT Act) and can be enforced by the tax authority. Taxpayers should note that these fines are similar in scale to those seen in other countries with e-invoicing mandates (e.g. Italy or Poland) and underscore the importance Slovakia is placing on compliance and accurate reporting. The Financial Administration has published an FAQ document outlining these penalties and the circumstances for relief, indicating an emphasis on helping businesses comply but also a readiness to penalize deliberate or persistent non-compliance. [financnasprava.sk], [financnasprava.sk]

10. Pre‑Filled VAT Returns

Current Status: Slovakia does not currently offer pre-filled (pre-populated) VAT returns to taxpayers, nor has it explicitly announced a plan to introduce pre-filled VAT return forms as part of the e‑invoicing rollout. The ongoing e‑invoicing and e‑reporting reform is primarily focused on real-time transaction reporting and the elimination of separate VAT listings, rather than on providing taxpayers with automatically pre-completed tax returns. In other words, the new system will supply the tax authority with detailed invoice data, but taxable persons must still file periodic VAT returns in the usual way (albeit with some modifications in content – see below). [bdo.global]
Future Outlook: By capturing most invoice data in real time, the Financial Administration will have a more complete dataset of sales and purchase transactions. This could lay the groundwork for eventual services like pre-filled VAT declarations, but no such feature has been implemented or officially planned yet. The immediate benefit of e‑invoicing data will be to replace the current “Kontrolný výkaz” (control statement) and EU sales summary: once intra-EU reporting is live in 2030, those supplementary filings are abolished. Instead, the VAT return will be slightly expanded to include any residual information not captured by e‑invoicing – for example, totals of retail cash-register sales, simplified invoices, and certain adjustments that are not individually reported via the system. Taxpayers will need to continue submitting VAT returns, incorporating these additional details. [financnasprava.sk] [bdo.global], [bdo.global]
In summary, **the Slovak system aims to simplify VAT compliance by automating data collection and removing extra filings, but it stops short of providing fully pre-filled tax returns. Taxpayers will still review and submit their VAT returns, although with less manual compilation of data once e‑invoicing is in place. The focus is on increased accuracy and efficiency of reporting rather than shifting to authority-prepared returns at this time.

11. Impact on SMEs and Startups

The e‑invoicing mandate in Slovakia is broad in scope – it covers all sizes of businesses (there is no exclusion based purely on company size or turnover for VAT-registered entities). As such, small and medium-sized enterprises (SMEs) and startups that are VAT-registered will need to comply by 2027 just like larger companies. This transformative change brings both opportunities and challenges for smaller businesses: [sovos.com]
  • No SME Exemption, but Existing Thresholds Apply: There is no special turnover threshold to exempt SMEs from mandatory e‑invoicing – if a business is required to be VAT-registered (standard threshold in Slovakia is €49,790 annual turnover), it falls under the e‑invoice mandate. Very small businesses below the VAT registration threshold (and thus not registered) remain outside the system, but they also cannot charge VAT. So essentially any SME that is a VAT payer must adopt e‑invoicing, regardless of size. Unlike some countries, Slovakia is not staggering the rollout by company size – 2027 is the go-live for all domestic VAT payers, giving SMEs the same deadline as large companies. On the positive side, a universal mandate avoids competitive disadvantages for compliant SMEs and encourages broad digitalization. [bdo.global] [taxadvisory.sk]
  • Simplified Regimes for Small Transactions: To ease the burden on businesses (often smaller retailers) dealing with many low-value transactions, the law continues to allow “simplified invoices” or receipts for small sales. As noted, invoices under €100 and cash register receipts up to €400 do not have to be handled through the e‑invoicing platform. These can be considered part of a simplified regime for micro-transactions. However, this is transaction-based relief rather than an exemption by entity size; it primarily benefits small shops or businesses handling low-value sales. SMEs engaged primarily in B2B transactions above these low thresholds will still need full e‑invoicing capabilities. [snitechnology.net]
  • Voluntary Adoption & Phased Approach: The year-long voluntary phase in 2026 is particularly beneficial for SMEs and startups, as it provides extra time to prepare and adjust before e‑invoicing becomes compulsory. Smaller companies are encouraged to participate early, allowing them to test their systems in a lower-risk environment and iron out issues. This phased approach, along with the 6-month transition for using certified delivery services (until mid-2027), mitigates the impact on businesses that may need more time to adapt. [taxadvisory.sk]
  • Cost of Compliance: SMEs will need to invest in updating or acquiring appropriate software or services to issue and receive e‑invoices. Many small businesses currently issue invoices via basic software or even manually; these processes will need to be upgraded to produce EN 16931-compliant XML invoices. For some, this could involve updating their accounting or ERP systems, or subscribing to an e‑invoicing service provided by a certified vendor. There may be costs for software updates, integration, and possibly transaction fees from service providers. The law’s requirement to use accredited intermediaries ensures a secure system but also means businesses might have to pay for a certified “postman” service if their current software doesn’t support Peppol exchanges. [flick.network]
  • Administrative Burden vs Simplification: In the short term, SMEs face an increased administrative burden to implement the new system – e.g. training staff, changing invoice workflows, ensuring reliable internet and IT support, and maintaining digital archives. However, in the medium to long term the reform is expected to reduce administrative overhead. By automating invoice processing and reporting, SMEs can save time on monthly/quarterly VAT compliance (no more compiling control statements or manual sale/purchase ledger summaries). Accounting processes like invoice entry and reconciliation will be faster and less error-prone, which can particularly benefit small businesses with limited administrative staff. Moreover, the tax authority’s access to data means less frequent ad-hoc information requests or audits for invoice verification. [pwc.com], [bdo.global]
  • Cash-Flow and Compliance Effects: Real-time reporting could lead to faster detection of errors or omissions, allowing SMEs to correct issues promptly and avoid large penalties down the line. Over time, the Financial Administration’s improved oversight might also translate into faster VAT refund processing and fewer lengthy audits, improving cash-flow certainty for compliant businesses (though this is an anticipated benefit; it is not yet formalized). On the other hand, SMEs must be mindful that failing to comply (e.g. missing a report or using an improper invoice format) can result in denied VAT deductions or adjustments, which would adversely affect cash flow. For example, if a small business mistakenly pays VAT on a purchase invoice that wasn’t properly reported, it may not be able to reclaim that VAT until the issue is resolved. [bdo.global], [accace.com]
  • Digitalization and Market Impacts: The mandate is expected to accelerate digitalization among Slovak businesses, including SMEs. This could spur innovation in fintech and business software tailored to small business needs (as providers compete to offer affordable, user-friendly e‑invoicing solutions). Early adopters may gain efficiencies in invoicing and bookkeeping that improve their competitiveness. On the flip side, businesses that rely on manual or outdated invoicing processes will need to modernize, which could be challenging for those with limited IT resources. Connectivity and interoperability will also be critical – SMEs will have to ensure their chosen software or provider can communicate via Peppol and handle the required data. The good news is that Slovakia’s use of open EU standards (Peppol, EN 16931) means a wide range of compliant solutions should be available, including some tailored for SMEs, minimizing custom IT development needs. [basware.com], [basware.com]
  • Support for SMEs: The Slovak authorities have recognized the importance of supporting smaller businesses through this transition. The Financial Directorate has been offering guidance, FAQs, and even dedicated webinars for SMEs to educate them on how to prepare for e‑invoicing. While there are no direct subsidies or tax breaks announced specifically for e‑invoicing costs, the government’s messaging emphasizes that the long-term benefits (automation, reduced errors, less paperwork) will outweigh the upfront costs, even for small firms. Additionally, by making the system compatible with existing international standards, SMEs can leverage solutions and service providers that operate in multiple countries, potentially lowering costs through competition and scale. As 2027 approaches, it’s expected that more low-cost or even free e‑invoicing tools (possibly including a basic government-provided interface) will become available to micro-entrepreneurs to ensure no one is left behind. [info-efaktura.sk], [info-efaktura.sk] [financnasprava.sk], [financnasprava.sk]

12. Official References

Slovakia’s e‑invoicing and e‑reporting framework is supported by a number of official resources and publications:
  • Legislation: The legal basis is the amendment to the VAT Act (Law No. 222/2004 Coll.) approved in late 2025. This amendment (commonly cited as part of Act No. 385/2025 Coll.) incorporates e‑invoicing and digital reporting obligations into national law. It aligns Slovak law with EU Directive 2014/55/EU (on electronic invoicing in public procurement) and anticipates the forthcoming EU directives under the VAT in the Digital Age package. The full text of the amended VAT Act and its implementing regulation (detailing technical e‑invoice requirements) are published on the official Slov-Lex legal portal and the Finance Ministry’s website. [taxadvisory.sk], [bdo.global] [edicomgroup.com]
  • Government & Tax Authority Publications: The Ministry of Finance of the Slovak Republic and the Financial Directorate (Finančné riaditeľstvo) have released public materials to guide businesses. Notably, a detailed FAQ document (“Najčastejšie otázky a odpovede k eFaktúre”, document 9/DPH/2025) was published in December 2025 on the Financial Administration’s website. This official FAQ addresses the definition of e‑invoices, scope (confirming B2B/B2G only, not B2C), how the “Digital Postman” system works, exceptions (e.g. for state security), and compliance obligations (including penalties). The Financial Administration also maintains an informational portal (e.g. the “eFaktúra” section on financnasprava.sk, and the dedicated site https://www.info-efaktura.sk), where official announcements, technical guidelines, and user instructions are provided. This includes sections for technical documentation, certification requirements for service providers, and educational webinars for businesses (including SMEs). Taxpayers are encouraged to refer to these official sources for up-to-date instructions, technical specs, and contact points for support. [sovos.com] [financnasprava.sk] [info-efaktura.sk], [info-efaktura.sk]
  • Technical Specifications: Detailed technical standards (such as schema definitions for the e‑invoice format, code lists, and API specifications for connecting to the Peppol network) are expected to be issued via a “generally binding regulation of the Ministry of Finance” in advance of the 2027 launch. This will likely outline the use of the Peppol BIS 3.0 UBL format and any Slovak-specific extensions or business rules. (As of this writing, draft technical documentation is being developed in consultation with industry; providers and software developers are preparing for certification in 2026.) [pwc.com] [accace.com]
  • External Newsletters and Analysis: Professional services firms and technology providers have published analyses that summarize and interpret the Slovak e‑invoicing framework. These can be useful to understand practical implications:
    • PwC Slovakia Tax News (15 Aug 2025): Announced the 2027 e‑invoicing mandate and summarized key obligations for businesses (e.g. requirement to issue/receive structured e‑invoices for domestic B2B/B2G). [pwc.com]
    • Sovos Compliance Update (15 Dec 2025): Reported the Parliamentary approval of the e‑invoicing law and highlighted important details such as scope (including self-employed persons and landlords), the combined e‑invoicing + e‑reporting model, and the real-time reporting timelines. [sovos.com], [sovos.com]
    • BDO Indirect Tax News (2025): Provided an overview of pending VAT changes, confirming the e‑invoicing rollout schedule (2027 domestic, 2030 cross-border) and describing exceptions (e.g. for simplified invoices and certain export scenarios), as well as planned changes to invoice deadlines and the VAT return process. [bdo.global], [bdo.global]
    • SNI (August 2025) and EDICOM (May 2025) articles: Offered early summaries of the mandate, including specifics like the 10-year archiving requirement, €10k/€100k penalties, required use of UBL/CII formats, and the inclusion of prepayments, VAT group transactions, etc., in the mandate. [snitechnology.net], [snitechnology.net]
    • Accace News Flash (Nov 2025): Detailed the phased implementation and practical changes (e.g. introduction of the delivery service concept in 2026, elimination of summary invoices, new data fields, and penalty provisions). [accace.com], [accace.com]
    • Basware Compliance Brief (2025): Summarized Slovakia’s e‑invoicing compliance, noting archival rules (10-year retention, flexibility in storage location with access for authorities) and distinguishing B2G versus B2B aspects. [basware.com], [basware.com]
    • Numerous other advisories (Deloitte, Rödl & Partner, Mazars, etc.) and EU sources (European Commission eInvoicing Country Factsheet) are available, providing additional confirmation of these requirements. [vatupdate.com]
Authoritative information is available on public websites (e.g. the Financial Administration’s portal and EU Commission pages), ensuring businesses and stakeholders can verify the above details first-hand. All links provided in this analysis point to official or reputable sources for further reading.

13. Summary

Slovakia is implementing a sweeping electronic invoicing and reporting mandate that will significantly transform how businesses issue invoices and report VAT. In terms of scope, the mandate covers all VAT-registered businesses and organizations in Slovakia and requires that from 1 January 2027 all domestic B2B and B2G invoices be electronic, in a standardized (EN 16931) format, and transmitted through a certified digital system with near real-time reporting to the tax authority. Consumer (B2C) sales are excluded from mandatory e‑invoicing, and certain special cases (e.g. state-security transactions, low-value receipts) are exempt from the digital reporting requirement. The mandate will expand on 1 July 2030 to cover cross-border B2B transactions within the EU (intra-Community supplies and acquisitions), aligning with the EU’s VAT in the Digital Age timeline. At that point, the system will replace the existing VAT control statement and EU sales list, fully modernizing VAT reporting in Slovakia. [pwc.com], [edicomgroup.com] [financnasprava.sk], [financnasprava.sk] [edicomgroup.com] [financnasprava.sk]
Key obligations for businesses include: using structured e‑invoices (XML/UBL) that meet all legal data requirements; transmitting invoices via accredited Peppol-based service providers (Digital Postmen) instead of email or paper; and reporting each invoice’s data to the Financial Administration at the time of issuance (or within days). Recipients must be able to receive e‑invoices and are required to acknowledge/report them within 5 days. Self-billing, credit notes, and other special invoice types are also subject to these requirements (with proper indicators in the e‑invoice data). **Invoices not issued in the mandated format (or not reported) will not be considered valid for VAT purposes, preventing VAT deduction or zero-rating until corrected. Businesses will need to maintain electronic archives of invoices for 10 years, ensuring tax authorities can access them on request. [pwc.com] [financnasprava.sk] [sovos.com] [taxadvisory.sk], [accace.com] [flick.network], [bdo.global] [basware.com]
The timeline is phased: 2026 is a pilot phase for voluntary onboarding; 2027 marks the mandatory go-live for domestic B2B/B2G; and 2030 sees the inclusion of cross-border EU transactions. There is no extended deferral by industry or company size – the requirement applies broadly to all VAT payers, with the expectation that even SMEs will prepare in time (aided by government guidance and certified service providers offering accessible solutions). The main risks of non-compliance include hefty fines (up to €10k or €100k), potential loss of VAT rights (e.g. denial of input credits or zero VAT rating), and operational disruptions if invoices are not processed or reported correctly. However, the reform also promises benefits: it should streamline tax administration, reduce fraud and errors, and eventually lessen routine paperwork for businesses by automating VAT data collection. [taxadvisory.sk], [edicomgroup.com] [info-efaktura.sk], [basware.com] [snitechnology.net] [accace.com] [pwc.com], [edicomgroup.com]
Implications for SMEs are a particular focus. Smaller businesses will face short-term challenges – such as IT upgrade costs and process changes – but in the long run they stand to gain from faster invoicing, fewer mistakes, and reduced compliance burdens (e.g. no more monthly statements). The government has highlighted the advantages of digitization (efficiency, cost savings, accuracy, fraud reduction) and is actively supporting businesses through this transition with information campaigns and by ensuring a competitive market of compliant service providers. [pwc.com], [bdo.global] [financnasprava.sk], [info-efaktura.sk]
Critical dates to note:
  • 1 January 2026: Voluntary adoption phase begins – e‑invoicing platform and “Digital Postman” services available for testing and early use. [taxadvisory.sk]
  • 1 January 2027: Mandate takes effectelectronic invoicing and real-time reporting become mandatory for all domestic B2B and B2G transactions between Slovak VAT taxpayers. From this date, only structured e‑invoices are considered valid for in-scope transactions. [taxadvisory.sk] [edicomgroup.com]
  • 1 July 2027: Certification requirement – only accredited delivery service providers may be used for transmitting e‑invoices (all businesses should have onboarded with a certified Peppol access point by this date). [accace.com]
  • 1 July 2030: Expanded scopemandatory e‑invoicing and e‑reporting extends to cross-border (intra‑EU) B2B transactions, and corresponding VAT control statements and EU sales listings are abolished. New invoice deadlines (10 days) and cross-border risk measures (e.g. linkage of intra-EU VAT exemption to reporting compliance) also take effect. [globalindi…gement.com], [financnasprava.sk] [accace.com], [accace.com]
Slovakia’s e‑invoicing initiative is a major step toward digital tax administration. Businesses should promptly assess their invoicing systems, engage with certified solution providers, and train staff to ensure readiness for 2027. By embracing the change, companies can not only avoid penalties and compliance risks but also benefit from a more efficient, transparent, and modern invoicing process. The combination of structured e‑invoices and real-time reporting is expected to improve VAT compliance and streamline the preparation of VAT returns (eventually making VAT compliance less burdensome for all). With the legal framework now in place and a clear timeline set, the next steps for businesses are to implement the necessary technical solutions and take advantage of the transition period to ensure a smooth adoption of Slovakia’s new e‑invoicing and e‑reporting era. [edicomgroup.com], [edicomgroup.com]
Sources:

Source Full text of the gazetted bill, signed by the President on 16 December 2025 and published in the Collection of Laws on 19 December 2025 under No. 385/2025 Coll.,


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