E-invoicing penalties from 2027 and the tolerance period

In short

• For failing to report, or for late, incomplete or incorrect reporting of e-invoice data, a fine of up to €10,000 applies, for repeated breaches up to €100,000.
• Failure by a VAT payer to issue an e-invoice is a breach of a non-monetary obligation under the Tax Procedure Code.
• The recipient is responsible for ensuring receipt of e-invoices, even if it is not a VAT payer.
• The penalty for reporting is not imposed in the case of an obvious error that you correct, or of a demonstrable fault at the digital postman.
• The government bill (print 1454), in first reading on 30 September 2026, proposes a tolerance period from 1 January to 30 June 2027. It does not affect the duty to receive.

What penalties apply and for what

Penalties for reporting are imposed by the tax office under § 85o(12) and (13) of the VAT act as amended by Act No. 385/2025 Coll.; exceptions are governed by paragraph 14. The amounts given are upper limits: when setting the amount, the office takes into account the seriousness and duration of the unlawful state. Sources: FS FAQ, part I, question 18, and the FS guide for non-governmental organisations (the section on sanctions and on what happens if an organisation cannot receive e-invoices).

Under the wording in force, a customer that is a VAT payer also has a reporting duty: it is to report the data from an e-invoice received through the delivery service within five days (§ 85o(10)) and it too faces a fine. The government bill (print 1454) proposes deleting this duty of the customer.

What the statutory deadline is

A VAT payer must issue the e-invoice within 15 days of the supply of the goods or services, or of receiving a payment before the supply (§ 85o(6)). For an e-invoice sent through the delivery service, the date of issue is the day it was handed to the delivery service for sending. An invoice stored only in the accounting software is not considered issued, so you should send it on the day you issue it (FS FAQ, part I, question 74).

You report the invoice data to the Financial Administration at the time of its issue through the digital postman. The duty is considered fulfilled by handing the e-invoice to the delivery service (§ 85o(11) in the wording in force, quoted in FS FAQ, part II, question 20). The five-day deadline applies only to self-billing, where the customer issues the invoice on behalf of the supplier (FS FAQ, part II, question 53).

Tolerance period 1 January to 30 June 2027 (government bill, print 1454)

Status on 30 September 2026: the government bill amending the VAT act was delivered to the National Council of the Slovak Republic on 27 August 2026 as print 1454. According to the website of the National Council it is at the first reading stage and has not yet been voted on in plenary. The Speaker of the National Council proposed as committees the Constitutional and Legal Affairs Committee, the Finance and Budget Committee and the Economic Affairs Committee with a deadline of 13 November 2026, and as the lead committee the Finance and Budget Committee with a deadline of 16 November 2026. It is therefore not law in force and its wording may still change.

The bill adds to the VAT act a transitional provision § 85q, under which in the period from 1 January 2027 to 30 June 2027:

• the tax office will not impose a fine on a VAT payer that does not issue an e-invoice within the deadline under § 85o(6) (§ 85q(2) of the bill; this is the fine under § 155(1)(e) of the Tax Procedure Code),
• the tax office will not impose a fine under § 85o(11) in the wording of the bill, that is, for failing to report data or for late, incomplete or incorrect reporting (§ 85q(3) of the bill).

The explanatory memorandum expressly states that the tolerance period concerns exclusively failure to meet the deadline for issuing an e-invoice. The duty itself to issue an e-invoice, the duty to arrange a digital postman and the duty to be able to receive e-invoices sent through the delivery service are not affected by it. The bill also proposes deleting the customer’s duty to report data from a received e-invoice (§ 85o(10)) and the penalties associated with it.

From when the sanctions apply

Both the obligations and the sanctions are effective from 1 January 2027. In 2026 participation is voluntary (FS FAQ, part I, questions 14 and 15), so there is no fine for not yet sending e-invoices. The date of issue of the invoice decides: if a VAT payer issues it from 1 January 2027, it must be an e-invoice even if the supply took place in December 2026.

If parliament approves the government bill as submitted, no fines will be imposed in the first half of 2027 for late issue of an e-invoice and for errors in reporting data. If it does not approve it or changes it, the sanctions apply from 1 January 2027 as laid down by Act No. 385/2025 Coll. The duty to receive e-invoices applies from 1 January 2027 in any case.

When you avoid the penalty

For penalties for reporting, the act envisages two situations in which the penalty is not imposed: the VAT payer corrects the incorrect data and it follows from the nature of the matter that it was an obvious error, or it did not report the data within the deadline because of a demonstrable technical fault on the part of the certified provider and reported them without delay after it was remedied (FS FAQ, part I, question 18).

A supplier that correctly issues the e-invoice and sends it through the delivery service has fulfilled its duty even if the recipient is not ready. Readiness to receive is the recipient’s responsibility. The biggest risk is therefore not an individual typo but a missing process: if in January 2027 a company can neither receive nor send e-invoices, the problem concerns every invoice it is to issue or receive.

How to avoid penalties in practice

1. Join during 2026. Test receiving and sending while participation is voluntary.
2. Check invoices before sending. The document should comply with EN 16931 and the Peppol BIS Billing 3.0 rules. You can verify it free of charge in our validator, and samples for common situations are on the page e-invoice samples.
3. Choose a provider that handles reporting automatically. What to ask is summarised in the checklist for choosing a postman.
4. Check your counterparties. Whether a customer is in the Peppol network can be found free of charge via checking a company in the Peppol network.
5. Set up sending on the day of issue. Do not leave invoices lying in the software awaiting approval beyond the 15-day deadline.

With us nothing is billed before 1 January 2027. After that, receiving without the archive is free up to 1,000 invoices a month (sent and received together) and the service costs €2 excluding VAT per IČO (company registration number) and month in which the company sent an invoice or had the Data archive switched on at the end of the month; above the limit €0.01 excluding VAT per invoice. Reporting data to the Financial Administration is part of the service. Details are in the price list.

Official sources

Binding information is published by the Financial Administration of the Slovak Republic in the e-invoicing section, including the Slovak document “Najčastejšie otázky a odpovede k eFaktúre” (9/DPH/2025/IM, version of 15 September 2026). The progress of the legislative process on print 1454 is published by the National Council of the Slovak Republic. This article is for information only and does not replace legal or tax advice; consult your specific situation with your accountant or tax adviser.

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