From 1 January 2027, mandatory electronic invoicing takes effect in Slovakia. The change does not concern only those who issue invoices – obligations also arise on the side of those who receive them. So that businesses and individuals can prepare in time, it is important to know exactly who the new rules apply to.
The answers are based primarily on § 85o of Act No. 222/2004 Coll. on value added tax.
Who will have to issue e-invoices?
From 1 January 2027, the obligation to issue electronic invoices will apply to VAT payers registered under § 4, § 4b or § 4c of the VAT Act – that is, domestic taxable persons, including group registrations.
Specifically, this will cover situations where a VAT payer supplies goods or a service with the place of supply in Slovakia, or receives a payment before such a supply. The obligation to issue an e-invoice arises only if the recipient is:
- a taxable person who has their seat, place of business, fixed establishment, residence or habitual abode in Slovakia,
- a non-taxable legal person that has its seat in Slovakia or a place with a sufficient degree of permanence – that is, one with the human and technical resources needed to carry out its activity.
The obligation to issue e-invoices applies exclusively to VAT payers and exclusively to domestic transactions directed at the defined persons. For example, a Slovak VAT-registered company that supplies goods to another Slovak company – even one that is not a VAT payer – must issue an e-invoice.
When does the obligation to issue an e-invoice not arise?
The VAT Act also defines cases to which this obligation does not apply. These are:
- supplies of goods or services exempt from tax under § 28 to 43 and § 47 of the VAT Act – for example postal services, healthcare or social-assistance services,
- situations where the payer issued a simplified invoice in line with the Act – for example a receipt from e-Kasa (the Slovak electronic cash-register system) of up to EUR 400.
A separate category covers cases where the payer must not issue an e-invoice – specifically where the recipient of the supply is the Slovak Information Service or Military Intelligence, or where the supply is connected with classified information.
Who will have to receive e-invoices?
The obligation to receive electronic invoices follows directly from the obligation to issue them. Everyone to whom a VAT payer is required to issue an e-invoice must be able to receive one.
From 1 January 2027, this obligation will apply to:
- domestic taxable persons,
- domestic non-taxable legal persons.
Who is a taxable person?
The definition of a taxable person is set out in § 3 of the VAT Act. It is any person who independently carries out any economic activity – regardless of its purpose or results.
Economic activity means any activity that generates income – including the business of sole traders, commercial companies, liberal professions, intellectual creative activity and sporting activity. Renting out real estate or other property for the purpose of generating income is also an economic activity.
Taxable persons are therefore typically sole traders, limited liability companies, joint-stock companies and other business entities – regardless of whether or not they are registered for VAT. An employee performing work under an employment relationship, by contrast, is not considered a taxable person.
“At first glance it may not be obvious — a taxable person is not only the classic sole trader or limited company. For instance, an artist who paints pictures on commission and uses a studio for their work is carrying out an economic activity. That means their energy supplier for the studio will be obliged to send them an e-invoice from 2027 — and the artist must be able to receive it. The same principle applies to renting out real estate.”
Who is a non-taxable legal person?
The second group of entities that will have to ensure they can receive e-invoices are non-taxable legal persons – that is, legal persons that do not carry on business but have their seat in Slovakia or a place with a sufficient degree of permanence and dispose of the relevant human and technical resources. Typical examples are civic associations, foundations or other non-profit legal persons seated in Slovakia.
Summary
Mandatory electronic invoicing from 1 January 2027 will affect a broad range of entities in Slovakia:
- Issuing e-invoices will be required of VAT payers in domestic transactions directed at taxable persons and non-taxable legal persons.
- Receiving e-invoices will be required of domestic taxable persons and domestic non-taxable legal persons.
This change is part of a broader digitalisation of accounting and tax administration that will, over the coming years, touch virtually every company in Slovakia. If you are unsure how it fits your situation, timely tax advisory can help you map your obligations. The sooner you start preparing, the less stress the change will cost you.
Not sure whether mandatory e-invoicing applies to you, or how to prepare for it properly? We’ll be glad to help.
Frequently asked questions
From when and for whom does mandatory e-invoicing apply in Slovakia?
Mandatory electronic invoicing applies from 1 January 2027. VAT payers will have to issue e-invoices in domestic transactions directed at taxable persons and non-taxable legal persons seated in Slovakia. Domestic taxable persons (for example sole traders and limited companies, regardless of VAT registration) and domestic non-taxable legal persons will have to be able to receive them.
When does the obligation to issue an e-invoice not arise?
The obligation does not arise for supplies exempt from tax under § 28 to 43 and § 47 of the VAT Act (for example postal services, healthcare, social assistance) and where the payer issued a simplified invoice, such as an e-Kasa receipt of up to EUR 400. Conversely, the payer must not issue an e-invoice where the recipient is the Slovak Information Service or Military Intelligence, or where the supply is connected with classified information.
Does e-invoicing also affect non-VAT payers?
Yes, on the receiving side. Every domestic taxable person – including a sole trader or limited company that is not a VAT payer – must be able to receive an e-invoice if a VAT payer is required to issue one to them. A taxable person is anyone who independently carries out an economic activity, including, for example, renting out real estate for income.