The Financial Administration (Finančná správa) of the Slovak Republic has further updated its frequently asked questions on mandatory electronic invoicing in April 2025, providing additional clarifications on both VAT and technical implementation aspects ahead of the January 1, 2027 mandate. Key additions include:
Non-VAT payers
According to the guidance, a taxable person who is not a VAT payer has no legal obligation to issue electronic invoices under the VAT Act, even if they voluntarily join the Peppol network from January 1, 2027. This means they are free to decide on a case-by-case basis whether to issue an e-invoice or use another invoicing form; their voluntary participation in the system does not create any additional statutory obligation. Note that non-VAT payers who conduct business or perform income-earning activities still fall under the obligation to receive e-invoices via an Accredited Service Provider from January 1, 2027.
VAT-exempt supplies
A VAT payer conducting tax-exempt supplies under Sections 28 to 42 of the VAT Act has no obligation to issue an invoice for such supplies. While they may still voluntarily send an e-invoice through the (delivery service), neither the issuer nor the recipient is bound by the sending, receiving, or reporting obligations.
Archiving
Based on the rules imposed by the Slovak governmentfrom the end of the calendar year to which the invoice relates. Since an e-invoice is defined as a document issued, sent, and received in a structured electronic format compliant with the relevant technical standard, archiving must be done in XML format. Conversion into another format is not sufficient to meet this obligation.
Incorrect e-invoices
Receiving an e-invoice does not automatically mean accepting it. If the recipient identifies an error such as a wrong amount, they should treat it similarly to a paper invoice: contact the supplier and request a corrective document or credit note. If the supplier cannot be reached, it is advisable to notify the tax. Tax administration must also be notified in the case of suspected fraudulent invoices.
EDI
From January 1, 2027, businesses using EDI systems such as EDIFACT must convert their invoicing data into an EN 1693-compliant format to meet the electronic invoicing obligation. The default method of compliance remains appointing an Accredited Service Provider (digital postman) and exchanging e-invoices via the Peppol network (delivery service). Deviation is permitted only with the buyer's consent. A compliant EN 16931 e-invoice may be sent outside the Peppol network (delivery service), for example, via EDI or email. However, the invoice must still be in the required structured electronic format.
Foreign companies registered in Slovakia
Foreign companies registered in Slovakia without a permanent establishment are not subject to the e-invoicing obligations that apply from January 1, 2027. The mandate applies to domestic VAT payers and covers only domestic transactions. As a result, registered foreign company is neither obliged to issue electronic invoices nor required to be able to receive them through the accredited service provider (Digital Postman) during the period from January 1, 2027 to June 30, 2030.
