E-invoicing Q&A 3: VAT Act, VATEX and archiving
VAT Act amendment, penalties, VAT categories, VATEX codes and e-invoice archiving. Watch the final part of our Q&A webinar series on e-invoicing.
Note: some of the rules are based on a draft amendment to the Slovak VAT Act currently before Parliament. Where the article relies on the draft, we say so explicitly.
Throughout the article, "digital postman" (digitálny poštár) refers to a certified Peppol service provider that delivers e-invoices on a company's behalf.
Not significantly. The mandatory content of an invoice is still set out in Section 74 of the VAT Act. As before, invoices may also contain voluntary details, such as the due date, bank details or an order number, which the customer needs to approve and pay the invoice.
For invoices sent through a digital postman, only the data specified by law is reported to the tax authority, not the whole invoice. This mainly includes:
The data is reported not by the supplier but by its digital postman, so the supplier's obligation is fulfilled once the invoice is sent to the postman. The current wording of the law also imposes a reporting obligation on the customer, but the draft amendment, proposed by the Ministry of Finance, abolishes it.
Under the tax authority's current interpretation, the issue date equals the date the invoice is sent through the digital postman. Many postmen therefore plan to fill in the issue date themselves, while others will set a daily cut-off time for same-day sending. When choosing a postman, ask how they will ensure this requirement is met.
Describe the goods or services as agreed in the contract or order. According to the tax authority and the Ministry, under a contract for work it is enough to state that the invoice covers part of the work under the contract. A breakdown of unit prices can go into an attachment, which is not reported to the tax authority.
If you invoice by units of measure, for example per square metre, each item must be listed on a separate line with its unit price.
Yes, with limits. The Peppol network should handle messages of up to about 100 MB, but individual postmen may set lower limits. Peppol also accepts only certain file formats: PDF, images or Excel files are allowed, for example, while Word documents are not. If you need attachments, check the size limit and format with your postman in advance.
The tax authority has published a page visualising an e-invoice. For each part of the invoice it shows the PDF view alongside the corresponding XML, highlights the data required by the VAT Act, and for each field lists its mapping to the European standard, whether it is mandatory and how many times it may occur. It is a useful reference for the IT specialists setting up your e-invoicing.
Peppol is a European infrastructure for the secure exchange of electronic documents between businesses (B2B) and between businesses and public authorities. In Slovakia, the Financial Directorate acts as the Peppol Authority. It certifies service providers, i.e. digital postmen, and sets the rules for using the Peppol standard.
From January 2027, domestic e-invoices sent via Peppol must go through this network. Cross-border e-invoicing will only become mandatory from 1 July 2030 under the EU ViDA Directive.
In the public Peppol Directory you can look up your own company and your business partners by tax ID (DIČ) or by full name including Slovak diacritics. Every registered entity is assigned a Peppol ID.
Also check the list of supported document types. Invoices and credit notes are assigned automatically. However, if you or your customer use self-billing, your postman must add these document types manually. Without them you can neither send nor receive self-billed invoices.
Yes, on a voluntary basis. Peppol is used in other countries too, which is why the list of Slovak digital postmen includes foreign providers. Cross-border e-invoicing must, however, be agreed with your business partner in advance, and you need to confirm that your postman supports it.
The rules in the VAT Act remain the same. A customer may issue an invoice in the name and on behalf of the supplier only under a written agreement. The invoice is governed by the rules of the country where the supply takes place, and the supplier remains responsible for its accuracy and timeliness.
What is new is the technical process:
The supplier does not send the invoice back to the customer, as that would create a duplicate. The recipient's postman reports it to the tax authority. A more lenient deadline applies to self-billed invoices: the data must be reported within five days of the e-invoice being issued.
An e-invoice that has been sent can no longer simply be swapped for another one. Nor can the customer reject it in Peppol: every invoice is received, even an incorrect one or one sent by mistake. The customer then proceeds as before, contacting the supplier and asking for a correction or cancellation.
The supplier then issues a corrective document in one of two ways:
A corrected invoice with code 384 does not change the tax liability or the VAT return, but as a corrective document it must be included in the VAT control statement. A similar code is already used in Germany.
The reference goes in field BT-25, which is mandatory and reported to the tax authority. If a corrective document covers several invoices, BT-25 can be repeated for each of them.
For volume rebates that cover all invoices in a period, such as the fourth quarter, the tax authority accepts stating the last invoice in BT-25 and the period in the text. If the rebate covers only some invoices, each one must be referenced.
It depends on how the original invoice was sent. If it did not go through a digital postman, the corrective document can be issued the old way, and e-invoicing is optional. If it was sent via Peppol, even as part of testing in 2026, the corrective document must also go through a postman.
From January 2027, every customer that is a VAT payer, a taxable person or a legal entity that is not a taxable person must be able to receive e-invoices. If the supplier properly issues the e-invoice and sends it through its postman, it has met its obligation even if the customer cannot receive it for technical reasons. Responsibility shifts to the customer.
If the supplier then sends the same invoice by e-mail, for example, the tax authority considers that no new invoice is created; it is simply made available another way. The customer can still deduct VAT if the invoice complies with the law and the conditions in Sections 49 to 51 of the VAT Act are met. We therefore recommend checking your customers' readiness before the launch and reminding them of their obligation.
The change mainly affects payment schedules. Until now, for recurring supplies such as rent or leasing, a payment schedule or payment agreement could replace an invoice. From January 2027 this will no longer be possible, and a summary invoice may only cover recurring supplies within a single month.
The concept of recurring supplies under Section 19(3) of the VAT Act remains, however. If you have agreed, for example, quarterly payments for energy or rent, you can continue issuing four invoices a year.
A payment request, i.e. a pro forma or advance invoice, is not a tax document and is outside e-invoicing. However, if from January 2027 you receive an advance payment from a domestic customer, a tax liability arises and you must issue an e-invoice for the payment received. Review your processes for receiving advance payments in particular.
The draft amendment to the VAT Act provides for a grace period from January to June 2027. During this period, the tax authority would not penalise:
Penalties will still apply, however, if you fail to choose a digital postman or do not issue invoices in XML format.
The third part of our Q&A series eFaktúra v praxi will take place on 5 November 2026 at 10:00. If you need help setting up e-invoicing or with a specific situation in your company, the experts at Forvis Mazars in Slovakia are here to help. Follow us on LinkedIn so you don't miss invitations to future webinars and events.
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