The Slovak Financial Administration has released updated guidance on its mandatory electronic invoicing system, addressing key questions about VAT treatment, exemptions, and technical requirements. The eFaktura mandate takes effect on 1 January 2027, requiring B2B and B2G invoices to be sent as structured XML files through certified intermediaries via the Peppol network.
The Slovak Republic’s Financial Administration has published further updates to its frequently asked questions on mandatory electronic invoicing in April 2025, adding new clarifications on VAT treatment and technical implementation requirements ahead of the 1 January 2027 mandate.
The implementation of the eFaktura mandate on 1 January 2027 introduces significant changes to both VAT compliance and technical workflows. eFaktura is a structured XML format designed for automated processing in B2B and B2G transactions.
These documents are distinct from standard PDFs and must be transmitted through certified intermediaries known as Digital Postmen via the secure European Peppol network. While a voluntary testing phase begins in 2026, the new system aims to eliminate manual data entry, reduce errors, and eventually replace traditional tax reporting statements by 2030.
Business entities, including freelancers and landlords, must ensure they can receive these electronic documents and comply with specific Slovak and EU standards. Failure to report required invoice data to the Financial Directorate can result in significant financial penalties.
Other key additions include:
Non-VAT payers
Entities that are not registered as VAT payers (e.g., small businesses, certain freelancers, or those exempt under § 4) do not have the obligation to issue electronic invoices in the mandated format.
However, these entities must be able to receive e-invoices. This is because a VAT-registered supplier is legally obligated to issue an e-invoice for domestic supplies to any taxable person, including non-payers.
To fulfil this receiving obligation, non-VAT payers must contract a “Digital Postman” (a certified delivery service provider) to ensure they can receive and process these documents.
Non-VAT payers can choose to join the Peppol network voluntarily to send invoices, but doing so does not force them to send all their B2B invoices through the system.
VAT-exempt supplies
The obligation to issue e-invoices does not apply to supplies exempt from VAT under § 28 to 43 and § 47 of the VAT Act (e.g., insurance services, or the rental of real estate exempt under § 38). While not mandatory, a payer can still send these through the delivery service if the recipient has a Peppol ID.
Standard Peppol rules for category “O” (Out of scope) prohibit the inclusion of VAT IDs for either party. For invoices that mix taxable and exempt items, the sources suggest using category “E” (Exempt) and specifying “outside the scope of tax” in the text field BT-120 to pass system validation rules.
Archiving
Electronic invoices must be archived in their original XML format for 10 years following the end of the calendar year they were issued. These are ensured technically via the Peppol network’s use of the AS4 protocol, unique identifiers (UUIDs), and timestamps. Taxpayers are not required to store a PDF version alongside the XML. However, they must have a mechanism (e.g., a software tool) that can render the XML into a human-readable format on demand (on a monitor or via print) during the entire retention period.
Incorrect e-invoices and corrections
Simply receiving an e-invoice does not constitute legal acceptance; if it is incorrect (e.g., wrong amount), the recipient should handle it similarly to a paper invoice by contacting the supplier. The recommended approach in the Peppol environment is to issue a Credit Note (dobropis) for the original invoice and then send a new, correct invoice. For errors that do not affect the price or VAT, a specific document type (384 – Corrective Invoice) is expected to be supported by autumn 2026. Certified systems will perform automated validation checks before sending to flag formatting or data errors immediately.
EDI (EDIFACT)
Invoices sent solely in EDIFACT format will no longer meet the legal definition of an e-invoice for VAT purposes starting 1 January 2027. To continue using EDI data, the information must be converted into a structured XML file compliant with the EN 16931 standard (using UBL or CII syntax). If you choose to send these compliant files via EDI instead of the national certified delivery service, you must obtain the recipient’s consent. Additionally, invoices sent this way do not trigger the automatic data reporting to the Financial Directorate.
Foreign companies registered in the Slovak Republic
Foreign entities registered for VAT in the Slovak Republic under § 5 (those not established in the country) are exempt from the mandatory e-invoicing regime during the initial phase (2027 to mid-2030). This exemption applies even if they are performing domestic transactions under their Slovak VAT ID; they are not required to issue or receive invoices through the certified delivery service for these transactions until the cross-border phase begins, currently planned for 2030.
Earlier, the Slovak Republic’s Financial Administration published detailed guidance addressing the practical implementation of mandatory electronic invoicing (eFaktura), which will require businesses to adopt the system for domestic B2B and B2G transactions from 1 January 2027.
