Regulatory updates - Slovakia

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.

Slovakia's Financial Directorate, part of the Financial Administration of the Slovak Republic, updated its eFaktúra FAQ in August 2026 with practical clarifications for businesses and service providers. The update also introduces a new section clarifying Peppol VAT Category Codes and VAT Exemption Reason Codes (VATEX) applicable in Slovakia ahead of the domestic e-invoicing mandate effective January 1, 2027. Key updates include:

Invoice timing and the date an e-invoice is considered issued

For an e-invoice to be considered issued on time, it must be sent to or made available to the customer within the statutory 15-day period, not simply created in the accounting system. For Peppol delivery, the invoice is considered issued when it is submitted to the service provider. For other delivery methods, it is considered issued when the invoice is sent or made available to the recipient.

Recipient not registered in Peppol and VAT deduction

If the supplier submits the e-invoice to its Accredited Service Provider within the statutory deadline but the recipient is not registered in Peppol to receive it, the supplier has fulfilled its issuance obligation. Where delivery via Peppol was not possible, the same invoice may subsequently be sent by email. The FAQ takes the view that this constitutes further disclosure rather than a new issuance, noting that the law does not expressly address this scenario.

Consent is required for e-invoice exchange outside the Peppol network through alternative means. The recipient may still claim input VAT deduction if it holds a valid e-invoice compliant with Article 85o of the VAT Act and all other VAT deduction conditions are met.

Factoring

If factoring is known at the time of issuance, the invoice may include factor and payment details as well as assignment information, using either invoice type code 380 or factoring invoice type code 393. Type 393 is optional, not mandatory. If assignment occurs after issuance, no replacement or corrective e-invoice is required solely for that reason. The customer should instead be notified separately.

VAT group internal transactions

Supplies between members of the same VAT group are treated as internal supplies within a single taxable person for VAT purposes. They are not considered a supply of goods or services subject to VAT, and no invoice obligation under the VAT Act arises. Accordingly, there is no obligation to exchange such documents via Peppol, though doing so voluntarily is permitted. Each member's unique tax identification number (DIČ) should be used as the EndpointID/Participant ID for routing. VAT category O (Not subject to VAT) applies. Under Peppol rule BR-O-02, seller and buyer VAT IDs must not appear on an invoice using category O. The VAT-law consent rule for sending mandatory e-invoices outside Peppol does not apply to these internal documents.

Self-billing reporting deadline and clarification

Under the latest version of the draft law, customers will continue to be permitted to issue self-billed invoices, provided the existing written agreement conditions are met. The FAQ also clarifies that the five-day deadline for reporting e-invoice data applies specifically to self-billed invoices and runs from the invoice issue date or, where applicable, from the expiry of the invoice-issuance deadline. This accounts for the fact that the supplier may not immediately be aware that the customer has issued the invoice. 

New VAT category code and VATEX mapping section

A new Slovakia-specific mapping guide for Peppol VAT categories and VATEX exemption and special-regime codes has been introduced. The guidance clarifies that VAT treatment must be selected based on the applicable legal VAT regime, not simply on whether the VAT amount is zero. The categories are as follows:

• Standard rate (S): Taxable domestic supplies, including invoices subject to the 23%, 19%, or 5% VAT rates;
• Exempt from tax (E): Domestic VAT-exempt supplies, including postal, health, social welfare, education, membership, sports, cultural, insurance, financial, and certain real-estate supplies;
• Intra-community supply (K): VAT-exempt supplies of goods from Slovakia to another EU member state;
• Export outside the EU (G): VAT-exempt exports of goods to destinations outside the EU;
• Reverse charge (AE): Transactions subject to the reverse-charge mechanism, where the customer accounts for the VAT;
• Not subject to VAT (O): Transactions that fall outside the scope of VAT, including certain internal transactions between members of the same Slovak VAT group; and
• Zero-rated goods (Z): Use only where Slovak legislation provides for a genuine 0% VAT rate. A VAT amount of zero EUR is not, on its own, sufficient to determine that category Z applies.

The FAQ recommends using the applicable VATEX code in business term BT-121 and, where necessary, adding explanatory text in BT-120 of the structured e-invoice. It also provides examples of Slovakia-specific mappings, showing the relevant VAT category and VATEX codes.