Regulatory updates - Slovakia

Slovakia's Financial Directorate (FD) published an updated version of its eFaktúra FAQ on October 30, 2026, in advance of the domestic e-invoicing and digital reporting requirements (DRR) mandate taking effect on January 1, 2027. The update introduces new guidance on several key topics, including corrective documents, self-billed invoices, and voluntary e-invoicing for VAT-exempt supplies. Key updates are outlined below.

Corrective documents for unpaid receivables
A corrective document issued under VAT Act art. 25a to adjust the value-added tax (VAT) base for unpaid receivables that cannot be collected does not constitute an invoice under the VAT Act. It is therefore not subject to the mandatory e-invoicing obligation.

Late notification that an e-invoice was required
Where a buyer notifies the supplier, after an invoice has already been issued, that the transaction falls within the scope of the e-invoicing obligation and that an e-invoice should have been issued, an invoice sent by email or as a PDF does not satisfy that requirement. The VAT Act currently sets no deadline by which such a notification must be given.

In this scenario, the FAQ recommends that the supplier cancel the original invoice and issue a new e-invoice. The new invoice should include a note indicating that it was issued following the buyer's later notification, and the supplier should retain proof of when and how the buyer provided notice.

The structured part of the e-invoice must contain information on the supply
The structured XML must identify the goods or services supplied, including quantity or extent. A reference to an attached delivery note, statement of work, or PDF is not sufficient. Attachments may add detail but cannot replace this data. Not every item must be listed separately. A supply agreed and invoiced as one item may appear as a single line. However, supplies invoiced separately, or taxed at different VAT rates, require separate lines.

Buyer’s ASP reports self-billed e-invoices
The buyer's accredited service provider (ASP) is responsible for reporting the self-billed e-invoice to the Financial Administration (FA). The previous version of the FAQ attributed this responsibility to the supplier’s ASP.

Voluntary e-invoices for VAT-exempt supplies

Supplies exempt from VAT under arts. 28 to 42 of the VAT Act, such as insurance services, are not subject to mandatory e-invoicing. However, such supplies may be e-invoiced voluntarily through an ASP, provided the conditions for sending and receiving are met. In practice, the recipient must be reachable on Peppol (registered under its DIČ), and the system identifies the invoice for reporting by the supplier’s VAT ID (IČ DPH) stated on it. Invoices sent voluntarily through Peppol are handled the same way as mandatory ones, and invoice data is automatically passed on to the FA.

Further guidance on apartment buildings

The FAQ reiterates that e-invoicing changes the form of the invoice, not the rules for determining who the recipient of a supply is. The recipient must be correctly identified at the time of issuance. Owners who are taxable persons or non-taxable legal persons are expected to provide their invoicing details to the building manager or owners’ association, which can then pass them on to the supplier. The recipient is determined by the contractual arrangements and by who the supplier's contracting partner is, not merely by who holds the cost-allocation data.

Forthcoming amendment to the VAT Act
The FD draws attention to an amendment to VAT Act No. 222/2004 Coll. currently before the National Council, with adoption expected in November. It highlights the following proposed changes to e-invoicing, noting that their final wording and application will depend on the text adopted:   

• Removal of the requirement to report purchase invoice data to the Financial Administration. It should be noted that self-billed invoices must be reported by the buyer's ASP;
• Corrective invoices relating to invoices issued in 2026 may be issued either as e-invoices or in the same format as the original invoice; and
• A taxable person that is not a VAT payer will not be required to receive e-invoices for supplies in connection with a lease of real estate that is VAT-exempt under art. 38(3) of the VAT Act and not part of its business assets. However, this exemption does not apply if that person must already be able to receive e-invoices for other business activities.

Slovakia's Financial Directorate, which forms part of the Financial Administration of the Slovak Republic, continues to issue guidance in preparation for the domestic e-invoicing and digital reporting requirements (DRR) mandate taking effect on January 1, 2027. The October 2026 update to the eFaktúra FAQ provides further clarification for businesses and service providers. Key updates include the following:

Selection of an Accredited Service Provider (ASP)

Businesses select their ASP through the Financial Administration portal. If a business selects an ASP by mistake, it should contact that ASP directly to resolve the issue. To change ASP or cancel an existing Peppol registration, the business should contact its current ASP, which will explain the next steps. Businesses planning to use different ASPs for sending (accounts receivable) and receiving (accounts payable) must inform each ASP which flow it will manage.

No whitelist of organizations exempt from e-invoicing

Invoices for supplies to the Slovak Information Service (SIS), Military Intelligence, or supplies involving or connected to classified information may not be issued as e-invoices. Such supplies must be invoiced on paper or in another form. Suppliers are required to assess each supply individually, and this exception may also apply in business-to-business (B2B) transactions.

Issuance deadline and when an e-invoice is considered issued

Creating an invoice in an enterprise resource planning (ERP) system is not sufficient. The e-invoice must be submitted to the recipient within the statutory 15-day deadline.  The issue date on the invoice must match the date it was submitted, so issuers should not delay sending. The 15-day issuance deadline generally applies from the date of the supply or the provision of services, or, where VAT becomes due on receipt of payment, from the date any advance payments are received.

Updated VAT category code in the Slovak mapping

The VAT category code has been changed from “O” to "E" (VATEX-EU-79-C) for disbursements, also referred to as pass-through items, in the October version of the FAQ.

Mandate applicability for branches of foreign entities

A foreign entity's VAT status in Slovakia determines whether it falls within the scope of the upcoming e-invoicing and DRR obligations. A non-established foreign entity registered for Slovak VAT is out of scope of the e-invoicing obligations between January 1, 2027, and June 30, 2030. Where a Slovak branch is regarded as an establishment for VAT purposes, and the foreign entity is registered as a domestic VAT payer in Slovakia, the foreign entity will be subject to the e-invoicing and DRR obligations from January 1, 2027.

Handling of corrective invoices in VAT returns and control statements

A corrective invoice that only rectifies formal or identification details, with no change to the tax base or VAT amount, is not reported in the VAT return. However, as it remains a corrective invoice, it must be included in the VAT control statement for the period in which it was issued or received. Corrective invoices must reference the original invoice and are to be recorded and retained.

Invoicing to apartment and non-residential premises owners

When a building manager or owners’ association purchases goods or services in the name and on behalf of the owners, each owner is treated as the recipient of their share of the supply. If any owner is a taxable person or a non-taxable legal person, the supplier must issue each such owner a separate e-invoice for their allocated share from January 1, 2027.

The manager or owners' association may assist by maintaining and providing owner details but must not be named as the recipient on the e-invoice.

Only where all owners are private individuals (non-taxable natural persons) is no e-invoice required. In that case, the supplier may invoice the manager or owners' association as agreed between the parties.

The Ministry of Finance launched formal consultation on its VAT amendment proposal on May 27, 2026. Following that process, the draft was revised before the government submitted it to Parliament as Print 1454 on August 27, 2026. The bill proposes the following targeted changes to the domestic e-invoicing and digital reporting requirements (DRR) scheduled to take effect on January 1, 2027:

Purchase invoice reporting obligation removed

The Ministry's May consultation draft proposed deferring domestic recipients' DRR obligation for purchase e-invoices during a transitional period. The bill submitted to Parliament goes further: it would remove this reporting requirement entirely. Buyers would no longer be required to report data from electronic purchase invoices.

Transitional grace period

The bill would introduce a penalty-relief period for specified supplier-side obligations from January 1, 2027 through June 30, 2027. During this period, no penalties would apply to VAT-registered entities in scope for:

• delays in issuing an e-invoice within the prescribed deadline; and
• failures to submit, or late submission, of sales e-invoice data.

Recipient ability to receive e-invoices

The proposed penalty relief would not postpone the general obligation for recipients to have e-invoicing capabilities through the prescribed delivery service, the Peppol network, from January 1, 2027.

The bill provides a narrow exception for a taxable person that is not VAT-registered where the invoice is received solely in connection with VAT-exempt rental of privately held real estate. The exception does not apply if that person is required to receive e-invoices in relation to other supplies.

Businesses within scope of the domestic e-invoicing and DRR obligation in Slovakia should therefore continue preparing their systems and processes for compliance by January 1, 2027.

Government Bill No. 1454 remains at first reading and has not yet been enacted into law. It may still be amended during the legislative process. The expected deadline for parliamentary committees' review is November 16, 2026.