Electronic Invoices in Slovakia: How to Use the Transition Period and Save on Sending Them

From 1 January 2027, a new electronic invoicing system will come into effect in Slovakia. All VAT payers will need to be able to issue invoices in a structured electronic format, and businesses in general must be able to process such documents.

At the same time, the law provides for a transition period until 30 June 2030, during which entrepreneurs, under certain conditions, will be able to send invoices by other means, including by email.

What is an electronic invoice

It should be noted that the new rules require the use of not just an electronic document, but a structured electronic invoice. In practice, this refers to the XML format, which allows computer systems to automatically process data from the invoice.

This is an important distinction from the familiar PDF files — such documents will no longer be considered electronic invoices. If an entrepreneur uses the electronic format provided by law, the document must comply with the requirements established by law.

The obligation to issue electronic invoices applies to all VAT payers. A standardised European Peppol infrastructure is provided for their sending and receiving. In Slovakia, its operation is linked to so-called “digital postmen” — service providers through which electronic delivery of documents will be carried out.

According to the Ministry of Finance, from January, the new rules for sending electronic invoices will affect more than 225,000 entities.

Why is a “digital postman” needed

The services of “digital postmen” will have to be used even if an entrepreneur intends to use the exceptions provided by the transition period — at least to be able to receive invoices from outside.

Currently, the Financial Administration lists 59 certified “digital postmen” who are authorised to operate in Slovakia. Their list is updated on the administration’s website.

The conditions of these services vary. Most of them offer free receipt of electronic invoices or a certain number of free sendings. This means that a small entrepreneur who sends few invoices does not need to immediately purchase an expensive tariff with a large document limit.

How can invoices be sent by e-mail

Until the end of June 2030, an entrepreneur can send a structured electronic invoice (document in XML format) not through “digital postmen” if the recipient agrees to it.

In practice, this means that for about three and a half years, the parties can agree on another method of document delivery, such as sending an XML file by email.

However, the very existence of such an exception does not cancel the requirements for the content and format of the document. That is, it will still not be possible to send a regular PDF by email — the electronic invoice must be formatted in the structured format required by law (XML).

Is it necessary to obtain the client’s consent in writing? According to the explanations of the Financial Administration, the law does not establish a specific form for such consent. For example, it can be included in the contract itself or made by email.

Even a so-called conclusive method of consent is possible — it does not require an oral or written statement, but an action — in the specified case, it may be the payment of the invoice.

However, for the entrepreneur, it is safer to obtain confirmation in advance and in a form that can later be used in a contentious situation or during a tax audit.

Where is the saving here?

As mentioned above, connecting to a “digital postman” may be mandatory, but the entrepreneur does not necessarily have to pay for an expensive package with a large number of outgoing invoices.

If a company agrees with its clients to send invoices by another method, then not a single outgoing one may pass through it. In this case, the entrepreneur may be satisfied with a basic or free tariff that ensures presence in the Peppol system and a simple ability to send and receive documents.

Thus, the transition rule gives entrepreneurs the opportunity to save if most of their clients agree to receive XML invoices by another method. However, the specified exception may be significantly less useful for companies that work with government bodies and municipalities.

Formally, the law does not prohibit agreeing on another method of delivery with a government or municipal customer. However, in practice, it may be difficult for businesses to obtain such consent. Therefore, companies working mainly with the private sector will be the first to take advantage of the exception.

Control

However, even the ability to use transition period exceptions does not cancel the need to connect to a “digital postman”. The Financial Administration will check its presence through the SMP system, which is used for routing electronic invoices in the Peppol network.

The system allows determining by tax identification number whether a specific supplier or recipient is capable of sending and receiving electronic invoices through the appropriate service.

For the absence of a concluded contract with a digital postman, an entrepreneur may face a fine from 100 to 10,000 euros. An important detail for accountants — during the transition period from January 2027 to the end of June 2030, electronic invoicing will exist in parallel with the current VAT control report (kontrolný výkaz k DPH). Its cancellation is planned only after the completion of the transition and exceptional period.