The Financial Administration (Finančná správa) of the Slovak Republic has published an expanded set of frequently asked questions addressing the practical implementation of mandatory electronic invoicing, set to take effect on January 1, 2027. The guidance covers both value-added tax (VAT) and technical requirements. Key additional clarifications include:
E-invoices to the public administration: The EFA proposal was cancelled in 2024. Business-to-government (B2G) e-invoices will be distributed through the Peppol network from issuer to recipient in the same way as business-to-business (B2B) transactions.
Identifying recipients, tax identification number: Under the Slovak Peppol Authority Specific Requirements (PASR), e-invoice recipients in the Peppol network are identified through the tax identification number (Daňové identifikačné číslo, DIČ), including cases involving public administration bodies or other legal persons without a VAT number. The DIČ serves as the national unique identifier and meets the requirements of European standard EN 16931 and Peppol BIS Billing 3.0.
Recipients not connected to the Peppol network: During 2026, sending e-invoices via the Peppol network is voluntary. From January 1, 2027, it will become mandatory for transactions within scope. Every legal entity and every entrepreneur who is a taxable person must be able to receive e-invoices. Recipients will be required to receive e-invoices via Peppol. If a recipient fails to do so, the sender's obligation is considered fulfilled once the invoice has been sent through the delivery service, even if transmission results in an error.
Digital reporting requirements: Digital reporting of e-invoice data is expected to become available in Q3 2026 following the establishment of the tax authorities' SP or corner 5 (C5). The accredited service providers (ASP) are expected to generate the tax data document (TDD) and subsequently report it to the tax authority (C5).
The accreditation process of SPs is ongoing, and the list is being updated continuously.
Corrective invoices: The most common procedure via the Peppol network for correcting an issued invoice is to issue a credit note against the original invoice and then send a new, correct invoice. Alternatively, a corrective invoice may be sent, provided it contains all mandatory details in accordance with Peppol BIS Billing 3.0 and includes an unambiguous reference to the original invoice.
Self-billing: The conditions under the law remain unchanged. Self-billing is permitted subject to a written agreement between the supplier and buyer. The buyer issues the self-billing invoice in the supplier’s name, and where Peppol’s delivery service is used, the reporting obligation is considered fulfilled upon handover of the invoice to the delivery service.
Penalties: Failure to report data, submit incorrect data, or report after the deadline may result in a fine of up to 10,000 EUR. In cases of repeated non-compliance, the fine may reach up to 100,000 EUR.
Where an obvious error is identified and corrected promptly, no fine will be issued. Similarly, if it can be demonstrably proven that the contracted accredited service provider (Digital Postman) experienced a failure, and the data were then reported without delay following resolution of that failure, no fine will apply.
Technical clarifications
- Human-readable format: The XML is sufficient for transmission and archiving. A taxable person must be able, upon request and within a reasonable time, to display the e-invoice in a human-readable format;
- Attachments: Inclusion of a visual representation attachment in the XML is optional and subject to agreement between the trading parties;
- Tax Data Document (TDD): The responsibility for the technical creation of the TDD lies with the ASP contracted by the relevant entity. Under the VAT Act, the reporting obligation is deemed fulfilled by handing over the e-invoice to the delivery service; and
- Archiving: Invoice retention continues to be governed by the VAT Act and remains unchanged after January 1, 2027.
Deadlines
- January 1, 2027: Mandatory e-invoicing and digital reporting requirements for domestic B2B and B2G transactions; and
- July 1, 2030: Planned extension of the requirements to additional scenarios, including intra-EU cross-border under the ViDA requirements.
