The Slovak Republic’s Financial Directorate has updated its eFaktúra FAQ with guidance on e-invoice timing, failed Peppol deliveries, factoring, VAT group transactions, self-billing and VAT category codes ahead of the mandatory e-invoicing regime from 1 January 2027.

RF Report

The Slovak Republic’s Financial Directorate updated its eFaktúra FAQ in August 2026, providing businesses and service providers with practical clarifications on the domestic e-invoicing requirements. The update also adds guidance on Peppol VAT Category Codes and VAT Exemption Reason Codes (VATEX) applicable in Slovakia ahead of the mandatory e-invoicing regime taking effect on 1 January 2027.

Starting January 1, 2027, businesses and legal entities in Slovakia must transition to a structured XML format for domestic transactions to enhance automation and reduce administrative errors. This new system utilises the Peppol network and certified service providers, known as Digital Postal Workers, to securely transmit and receive data in real time.

While B2B and B2G transactions are the primary focus, the guide clarifies that consumers and certain classified government entities remain exempt. Taxpayers can enter a voluntary transition period throughout 2026 to test their systems before full enforcement begins.

Below is a detailed summary of the key updates:

E-Invoice issuance and timing

An e-invoice must be sent or made available to the customer within 15 days of the supply or payment receipt. Creating it in an accounting system alone does not meet the deadline. An invoice is considered issued when submitted to the Peppol delivery service. The issue date is when the invoice is sent or made available to the recipient.

Peppol non-registration: Issuance, email delivery, and VAT deduction

  • Fulfilment of the e-invoice obligation: Submitting a compliant XML e-invoice to an Accredited Service Provider within the statutory deadline discharges the supplier’s issuance and sending obligation, regardless of whether the recipient has registered with Peppol or secured a digital postman. The obligation is satisfied at submission to the ASP.
  • Email as secondary delivery: When Peppol delivery fails, the supplier may resend the same standard-compliant XML invoice via email. This constitutes re-disclosure of an already-issued invoice, not a new issuance. The recipient’s consent is required for out-of-network transmission (email, for example), though consent carries no rigid formality requirement—written agreement, email confirmation, contractual language, or even implied acceptance (such as payment of the emailed invoice) all suffice.
  • VAT deduction remains available: Recipients may claim input VAT deduction on the emailed invoice provided it complies with Section 85o of the VAT Act and meets the substantive and formal requirements under Sections 49 to 51. Email delivery following a failed Peppol attempt does not, by itself, disqualify the deduction.

Factoring (receivable assignment)

The Slovak Republic’s VAT Act does not contain a specific mechanism for factoring or the assignment of receivables (regulated under Sections 524 to 530 of the Civil Code). Instead, businesses must follow the European EN 16931 standard and standard Civil Code requirements.

  • Scenario A (Assignment known at issuance): The supplier may include the factor’s details, payment information and assignment notes on the e-invoice. Invoice type 380 or 393 may be used.
  • Scenario B (Assignment occurs after issuance): A new e-invoice or corrective document is not issued solely because a receivable is assigned after the fact. Instead, the supplier must notify the debtor under standard Civil Code rules, which is a separate communication process completely outside the Peppol network and does not change the original XML data.

VAT group internal transactions

  • Treatment of supplies: Supplies between members of the same registered VAT group are treated as internal supplies within a single taxable person. They are not subject to VAT and do not trigger any statutory invoice obligation under Section 72 or Section 85o of the VAT Act.
  • No Peppol exchange obligation: There is no legal obligation to exchange these documents via Peppol, although doing so voluntarily is permitted. Members may also exchange these documents via email or internal systems, and doing so does not require DPH-compliant consent rules.
  • Voluntary Peppol rules for group transactions: Group members exchanging documents voluntarily via Peppol must use each member’s unique DIČ as the EndpointID with prefix 0245 and apply VAT Category “O”. Under BR-O-02, the invoice must omit the Seller’s and Buyer’s VAT IDs (IČ DPH), including the group’s common VAT ID, to pass validation.

Self-billing reporting deadline and clarification

Self-billed invoices remain permitted under the draft law when a written agreement establishes predefined conditions between supplier and customer.

Unlike standard e-invoices, which require real-time reporting to the tax authority upon issuance, self-billed invoices (issued by the customer on the supplier’s behalf) grant the supplier a five-day reporting window.

This deadline begins either from the date the self-billed invoice is issued or, where an invoice-issuance deadline applies, from its expiry—recognising that suppliers may not have immediate visibility into when customers generate the documents.

New VAT category code and VATEX mapping section

The updated guide introduces a Slovakia-specific mapping for Peppol VAT Category Codes (BT-118/BT-151) and European VATEX exemption codes (BT-121). The VAT category must be chosen based on the actual legal VAT regime, not simply on whether the VAT amount is zero (since DPH 0 EUR can represent various legal regimes).

The core mapped categories for Slovakia are:

  • Standard rate (S): Taxable domestic supplies under Section 27, covering basic and reduced rates (23%, 19%, or 5%). No VATEX code is used.
  • Exempt from tax (E): Domestic VAT-exempt supplies under Sections 28 to 42 (such as postal, healthcare, social services, education, sports, cultural, financial, insurance, real estate, and other exempt supplies).
  • Intra-community supply (K): VAT-exempt supply of goods from Slovakia to another EU member state (Section 43).
  • Export outside the EU (G): VAT-exempt export of goods outside the EU (Section 47).
  • Reverse charge (AE): Transactions under Section 69 where the customer accounts for the tax.
  • Not subject to VAT (O): Transactions outside the scope of VAT, including certain internal transactions between members of the same Slovak VAT group.
  • Zero-rated goods (Z): Applies only to goods with a legally established zero rate. No VATEX.

Earlier, the Slovak Republic’s Financial Administration updated its FAQs on mandatory e-invoicing, providing further guidance on VAT treatment and technical requirements ahead of the 1 January 2027 mandate.