E-invoicing and the non-VAT payer from 1 January 2027

In short

• From 1 January 2027 only VAT payers are obliged to issue e-invoices. This duty does not concern a person not registered for VAT.
• Every domestic taxable person, including non-VAT payers, and also every domestic legal person that is not a taxable person must be able to receive an e-invoice delivered through the Peppol network.
• In practice this means choosing a digital postman on the Financial Administration portal. Your Peppol ID will be 0245:DIČ.
• If you send an e-invoice voluntarily, it has VAT category O and contains neither the supplier’s nor the customer’s VAT ID.
• With us: receiving without the archive is free up to 1,000 invoices a month (sent and received together).

You need not issue e-invoices

The duty to issue an electronic invoice is imposed by § 85o(2) of the VAT act on a VAT payer registered under § 4, 4b or 4c that supplies goods or services with the place of supply in Slovakia to a domestic taxable person or a domestic non-taxable legal person. The Financial Administration says so directly for non-VAT payers: with effect from 1 January 2027 the duty to issue an electronic invoice under § 85o does not apply to a taxable person that is not a VAT payer (FS FAQ, part I, question 57).

You are a non-VAT payer if you are not registered for VAT under § 4, § 4b or § 4c of the VAT act (FS FAQ, part I, question 54). You may therefore keep issuing invoices to your customers as before, for example in PDF. When you become a VAT payer by law is explained in the article on e-invoicing for sole traders.

You must be able to receive them

The second duty concerns recipients. Under § 71(5) of the VAT act every person to whom goods or services are supplied in Slovakia, where the taxable person is obliged to issue an electronic invoice, is obliged to ensure that it can receive an electronic invoice sent through the delivery service. To whom the VAT payer issues an e-invoice is defined by § 85o(3): a taxable person with its registered office, place of business, establishment or residence in Slovakia (or that usually stays in Slovakia) and a non-taxable legal person with its registered office in Slovakia. The recipient’s VAT payer status is irrelevant here.

Your consent to the e-invoice is not required (FS FAQ, part I, question 12). The Financial Administration expressly states that taxable persons without VAT payer status must also be able to receive such invoices if a VAT payer is obliged to issue them for a domestic supply (FS FAQ, part I, question 54).

The duty to issue an e-invoice, and with it your duty to ensure its receipt through the delivery service, does not arise in particular for these supplies:

• a supply exempt from tax under § 28 to 43 and 47 of the VAT act (FS FAQ, part I, questions 51 and 55),
• a simplified invoice under § 74(3)(a) or (b), that is, a document up to EUR 100 or an eKasa cash register receipt up to EUR 400 including tax (FS FAQ, part I, questions 51 and 66).

In these cases too the supplier may send you an e-invoice voluntarily; the network delivers it in the same way as a mandatory one (FS FAQ, part I, question 55).

It also applies to legal persons that are not taxable persons

Domestic legal persons that are not taxable persons must also be able to receive an e-invoice. In its guide for non-governmental organisations the Financial Administration gives as examples state administration bodies, municipalities, their budgetary and contributory organisations, non-profit organisations and civic associations. The network identifies them too by DIČ. According to the same guide, the Financial Administration will in most cases assign a DIČ automatically to non-governmental organisations that did not have one. Whoever has no DIČ and has not received a registration decision asks the tax administrator for registration for income tax; the DIČ is assigned within 30 days at the latest (FS FAQ, part I, question 70). The procedure for associations, foundations and owners’ associations is discussed in the article on e-invoicing for non-profits, associations and homeowners’ associations.

Voluntary sending and what a non-VAT payer’s invoice looks like

You can also join the network for sending. This does not oblige a non-VAT payer to send all invoices through the network; every e-invoice sent must, however, meet the validation rules of Peppol BIS Billing 3.0 (FS FAQ, part I, question 63).

A non-VAT payer’s supply is not subject to VAT, so according to the Financial Administration VAT category code “O” (Not subject to VAT) is used. With it, under rule BR-O-02, neither the supplier’s nor the customer’s VAT ID may appear on the invoice, and you identify the customer without a VAT ID, for example by IČO or DIČ (FS FAQ, part II, question 42). The Financial Administration’s mapping assigns the reason code VATEX-EU-O to a supply outside the scope of VAT (FS FAQ, part III).

A ready-made valid document in this form is available as sample no. 2: the issuer is not a VAT payer. If the customer insisted that its VAT ID appear on the invoice, according to the Financial Administration such an invoice cannot be issued in compliance with the Peppol BIS 3.0 rules and another delivery method outside the network must be chosen (FS FAQ, part II, question 42). Reporting of data to the Financial Administration does not concern you with such an invoice: the sender’s provider reports only invoices on which the issuer has a VAT ID (FS FAQ, part I, question 44).

DIČ, VAT ID and your Peppol ID

A non-VAT payer has a DIČ (tax ID) but as a rule no VAT ID (the exception is registration under § 7 or § 7a, for example because of services from a foreign person from the EU, which does not make you a VAT payer). For the Peppol network this is no problem: a Slovak entity is identified in it by its DIČ, even when it has no VAT ID assigned (FS FAQ, part I, question 39). The address in the network has the form 0245:DIČ (FS FAQ, part I, question 70), digits only, without the “SK” prefix. Details are in the article on Peppol ID.

In our portal, in the company details, untick the field “We are a VAT payer (we have a VAT ID assigned)”. When sending from the form, the portal then issues the invoice in category O with reason VATEX-EU-O, without VAT rates and with your DIČ instead of a VAT ID, and shows the DIČ also next to the company and in the invoice visualisation.

A landlord that is not a VAT payer

The Financial Administration gives a landlord of real estate that is not a VAT payer as a typical example: it need not issue e-invoices but must be able to receive them if a VAT payer is obliged to issue them to it for a domestic supply (FS FAQ, part I, question 54). For real estate in the joint ownership of spouses, the spouse who will receive e-invoices in the position of a taxable person registers in the network (FS FAQ, part I, question 56).

The government bill (print 1454), status on 30 September 2026 in first reading, proposes an exception in § 71(5): the duty to be able to receive an e-invoice would not apply to a non-VAT payer for invoices relating to a lease of real estate exempt from tax under § 38(3), if the real estate is not included in business assets. The exception would not apply if the person is obliged to receive e-invoices for its other supplies. The proposed effective date of this change is 1 January 2027. It is a proposal, not law in force; until parliament passes it, § 71(5) applies in its current wording, that is, without this exception.

What it costs with us

Receiving without the Data archive is free up to 1,000 invoices a month (sent and received together). New companies have the archive switched on by default; whoever wants only to receive free of charge switches it off on the company detail, and the content of documents is then deleted with us 14 days after delivery. The fee of €2 excluding VAT (€2.46 including VAT) per month per IČO (company registration number) is billed only for a month in which the company sent at least one invoice or had the Data archive switched on at the end of the month. Each invoice above the limit costs €0.01 excluding VAT, even if the company only receives. Nothing is billed until 31 December 2026. Details are on the page receiving e-invoices.

For suppliers to be able to deliver e-invoices to you, it is enough to register and confirm the selection of Verteco on the Financial Administration portal. If your DIČ does not yet have a postman, we register you in the network within a few minutes and you will see received invoices in the portal.

Frequently asked questions