Briefing document: E-Invoicing and E-Reporting in Slovenia

Slovenia is in the process of implementing significant changes to its invoicing and tax reporting systems, moving towards mandatory electronic practices for businesses. Draft legislation proposes mandatory Business-to-Business (B2B) e-invoicing and mandatory electronic submission of VAT records. While Business-to-Government (B2G) e-invoicing has been mandatory since 2015, the new drafts extend the digital mandate to the B2B sector. The initial timeline for mandatory B2B e-invoicing, originally set for April 1, 2026 (later shifted to July 2026), has been postponed to January 1, 2027. A key change in the most recent draft is the removal of a real-time reporting obligation to the tax authority (FURS), shifting the focus to exchange through accredited service providers, including Peppol. Mandatory electronic VAT record submission is scheduled to begin earlier, in July 2025. The draft laws are currently under review by the National Assembly.

Key Themes and Important Ideas/Facts:

1. Mandatory B2B E-Invoicing:

The core of the proposed legislation is the introduction of mandatory electronic invoicing for transactions between businesses within Slovenia and those trading with Slovenian partners.
This marks a “significant shift towards digital invoicing in Slovenia’s B2B sector.”
The mandate is currently set to take effect on January 1, 2027. This is a postponement from earlier proposed dates of April 1, 2026, and July 2026.
The mandate “will apply to all taxable entities engaging in B2B transactions,” including cross-border transactions.

2. E-Invoicing Formats and Interoperability:

The draft law permits several formats for e-invoices:
The national e-SLOG standard.
Any syntax compliant with the European Standard EN 16931.
Other internationally recognized standards, provided there is mutual agreement between the issuer and the recipient.
“Interoperability is the default model,” with exchange occurring through Peppol or accredited service providers.
The recipient’s e-invoice provider will be responsible for conversion when different standards are used.

3. Exchange Mechanism and Service Providers:

In a significant change from earlier drafts, the direct reporting obligation to the Slovenian Tax Authority (FURS) has been removed.
Businesses will exchange e-invoices “through registered providers, the Peppol network, or directly through their own systems.”
However, a later draft specifies that businesses “will have to contract service providers accredited in Slovenia,” including “Peppol-accredited service providers.”
Direct exchange between buyer and seller is permitted if there is “consent… that must comply with EN-16931 standards.”
Crucially, “E-mail may not be used for invoice exchange.”

4. Certified E-Invoicing Service Providers:

The draft law emphasizes the need for secure and reliable data exchange.
Only “certified service providers will be authorized to facilitate e-Invoicing.”
Service providers are required to obtain ISO/IEC 27001 certification and undergo external security audits.

5. Peppol Integration:

The draft law explicitly recognizes the Peppol network “as a valid platform for B2B e-Invoice exchange,” ensuring compatibility with other systems.

6. B2C E-Invoicing and Consumer Rights:

The mandatory B2B mandate does not extend to Business-to-Consumer (B2C) transactions.
Consumers retain “the flexibility to choose between receiving electronic or paper invoices.”
Businesses can only send electronic invoices to consumers if they have provided consent.
Consumers have the right to withdraw consent for e-invoices and request paper invoices.
When issuing e-invoices to consumers, businesses must include a visual representation in a standard format like PDF or TIFF for accessibility.

7. Mandatory Electronic VAT Reporting (e-Reporting):

Separate from the B2B e-invoicing mandate, Slovenia is introducing mandatory electronic submission of VAT records to FURS starting in July 2025.
This applies to “all companies registered for VAT purposes in Slovenia.”
This “e-poročanje” system aims to “facilitate tax collection,” “simplify procedures,” and “increase transparency.”

8. B2G E-Invoicing:

Electronic invoicing with the public administration has been mandatory in Slovenia since 2015.
E-invoices for the public sector must be exchanged through the Public Payments Administration (UJP) using the e-Slog 2.0 or UBL 2.1 (Peppol BIS 3.0) formats.

9. Implementation Timeline and Preparation:

Businesses have until January 1, 2027, to prepare for the mandatory B2B e-invoicing transition.
Key preparation steps include understanding requirements and formats, ensuring system compatibility, partnering with certified providers, and adjusting internal processes.
Mandatory electronic VAT reporting begins earlier, in July 2025.

10. Penalties:

Fines ranging from 100 to 3000 EUR are proposed for non-compliance, including issuing e-invoices without consumer consent, refusing EN-compliant formats, and failing to manage/retain transmitted data.

11. Current Status:

The latest draft law on e-invoicing was submitted in February 2025 and is currently with the National Assembly for review and approval.
Technical specifications for the B2B e-invoicing system have not yet been published.
Technical specifications for the e-Reporting system are available.

Implications for Global Businesses:

Businesses operating in or trading with Slovenia must adapt to the upcoming mandatory e-invoicing requirements for B2B transactions by January 2027.
Compliance requires adopting compatible e-invoicing solutions that support permitted formats (e-SLOG, EN 16931, agreed international standards).
Partnering with certified service providers, including those accredited for Peppol, will be essential for exchanging e-invoices.
Businesses registered for VAT in Slovenia must prepare for the mandatory electronic submission of VAT records starting in July 2025.
The removed real-time reporting requirement reduces the immediate technical burden on businesses compared to earlier proposals, but the need for compliant exchange through accredited providers remains.
The timeline provides time for preparation, but it is crucial to monitor the final version of the bill and published technical specifications.

Conclusion:

Slovenia is moving forward with its plans to digitise invoicing and tax reporting. The mandatory B2B e-invoicing mandate, though postponed, is a significant development. The shift to exchange through accredited service providers and the recognition of Peppol indicate an alignment with broader European e-invoicing trends. Businesses should proactively prepare for both the B2B e-invoicing mandate in 2027 and the mandatory electronic VAT reporting in 2025 to ensure compliance and avoid penalties. Continued monitoring of the legislative process and technical guidance is essential.

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