The Ministry of Finance of the Slovak Republic is preparing an amendment to the VAT Act introducing mandatory electronic invoicing for all VAT payers, from 1 January 2027. A taxable person will be required to issue invoices exclusively in electronic form and to report the data from such invoices to the Financial Administration in real time. The purpose of the amendment is to digitalise the invoicing process and reduce administrative burden, enhance transparency of the tax system and, above all, improve the efficiency of combating VAT fraud in the digital age (ViDA).
A brief overview of the planned changes and new measures is provided below. The forthcoming amendment precedes the European development of e-invoicing, which Slovakia will approved in advance.
Who is subject to electronic invoicing
The proposed amendment will introduce a new system into the invoicing process and into the flow of invoices issued or received by VAT payers. The new process will be possible only in accordance with the requirements of the Act, which primarily and mandatorily focuses on:
- taxable persons established in the Slovak Republic (e.g., legal and private company in position of VAT payer, freelancers, layers, tax advisors, architects, artists, etc).
- transactions with the place of supply within the territory of the Slovak Republic
- advance payments received prior to the supply of goods or services
During the transitional period until 30 June 2030, mandatory e-invoicing will apply only to domestic transactions. Subsequently, the Slovak system will be interconnected with the European EU DRR system, into which Slovak VAT payers will also report cross-border EU transactions.
Main instrument of electronic invoicing
The Financial Administration is working on an electronic invoicing project aimed at providing the infrastructure for receiving, processing and verifying invoices issued by VAT payers. All VAT payers will be required to invoice exclusively through the new electronic system known as “Digital Post Provider” through PEPPOL BiS 3.0 (Pan-European Public Procurement On-Line).
A unified structured electronic format (XML) for preparing, sending and receiving invoices according to the common European standard is being introduced concurrently (a sample of the standardised data message is currently available at the following link). It means that PDF format will be no more accepted for such purposes.
The entire electronic invoicing process is based on the technical standard STN EN 16931, which can be downloaded at the end of this article. It means that persons who issue and receive invoice should have access or account in Digital Post Provider. This Provider will be secured by specified software or incorporated into accounting system.
Time frame for issuing an invoice
Taxable persons are obliged to issue an electronic invoice within the following deadlines:
| Deadline | Activities covered by the deadline |
| 15 days e-Invoice | from the date of supply of goods or servicesfrom receipt of an advance payment prior to supplyfrom the moment the adjustment of the tax base becomes necessary |
| 15 days Summary e-Invoice | from the end of the calendar month in which multiple supplies were carried out |
There is important the specific deadline for all recipients of e-invoice that are required to report invoice data within 5 days of receiving the invoice towards the Slovak Financial Authority (via Digital Post Provider).
Non-compliance with the notification or reporting the data from invoice may lead to issuance of penalty up to EUR 10 000 EUR (repeated omission up to EUR 100 000).
How the entire system will operate
The news system will replace the current scheme in which taxable persons issued or received invoices:
- in paper form by post or email
- by creating invoice templates in Excel or online applications
- by choosing which issuing format to use (paper / electronic) given archiving obligations
The preliminary process should operate as follows:
- invoice is generated in accounting or invoicing software that has access to Digital Post Provider connected to PEPPOL BiS 3.0
- the software sends the invoice directly to the customer via Digital Post Provider system at the moment of issuance.
After the transitional period, from 1 July 2030, data from cross-border EU invoices will be sent directly to the central EU system – VIES – for validation against data uploaded by the purchaser’s or supplier’s country.
- the invoice recipient is not authorised to give consent to the issuing of an invoice
- recipient of invoice (customer) report the invoice data via Digital Post Provider to Financial Authority
- if invoice does not contain structured data or does not match the invoice uploaded to the system by the recipient, the Financial Administration may initiate a tax audit
Possible disadvantages and risks of introducing e-invoicing
Although the introduction of digital electronic invoicing brings several advantages in terms of automation and transparency, it also indirectly introduces a number of practical risks and drawbacks. These may particularly affect small and medium-sized enterprises that lack the capacity for rapid technical adaptation.
An overview of the disadvantages of introducing electronic invoicing is shown in the following table:
| Disadvantage | Description |
| Technical issues | The risk of outages in the state system may disrupt the continuity of business transactions. |
| Initial costs | Costs related to modifying or replacing invoicing software and adjusting internal processes. |
| Security risks | Concerns regarding the leak or misuse of company data sent to the Financial Administration. |
| Reduced flexibility | Loss of the possibility to use proprietary invoicing solutions. |
| IT skill requirements | The need for technical knowledge or cooperation with an accountant when working with the e-invoice system. |
| Corrective invoices for minor errors | The obligation to issue new invoices even for small clerical errors, which may overload the system. |
Practical implications and recommendations
In this context, we recommend that businesses take the following steps:
- Verify software compatibility – businesses will need invoicing or accounting software capable of generating invoices in the structured format required by the state (e.g. XML) and interconnected with PEPPOL BiS 3.0.
- Take advantage of direct interconnection with the Financial Administration – invoices will be automatically recorded, removing the need for subsequent reporting or manual submission during inspections.
- Provide staff training – we recommend preparing the accounting and administrative teams for new procedures and work with structured data.
Changes after 1 July 2030
After the transitional period, the state system will be linked to the European EU DRR system. At the same time, due to mandatory invoicing, the following will be abolished:
- the control statement (its function will be replaced by data reporting via PEPPOL)
- the European Country Sales Lists (its function will be replaced by reporting cross-border EU invoices through the PEPPOL system)
From this day, the invoice data will be automatically reported to Financial Authority which lead to less administrative burden with invoice evidence and reporting obligations.
The information provided is based on the draft amendment submitted to Parliament. The final wording of the legislation, as well as the technical aspects of mandatory electronic invoicing, may naturally change during the parliamentary approval process. Our company will continue to monitor legislative developments in this area.
Important!
