Slovakia: Updated eFaktura FAQ Clarifies Peppol Delivery, Self-Billing and VAT Codes for 2027

Slovakia’s Financial Directorate has updated its eFaktura FAQ ahead of the January 1, 2027 mandate, clarifying invoice timing, failed Peppol delivery, factoring, VAT groups, self-billing and VAT coding. Retailers and software providers should test these workflows before go-live.

Slovakia’s Financial Directorate has updated its official eFaktura FAQ with practical guidance for taxpayers, accounting and ERP software providers and E-Invoicing service providers preparing for the mandatory domestic regime from January 1, 2027. The Financial Administration’s document register marks the FAQ as updated on August 26, 2026.

This is not a new E-Invoicing mandate. The legal obligation already follows from the amended Slovak VAT Act, including Act No. 385/2025 Coll. The August FAQ is an administrative and technical clarification of how the 2027 rules should work in practice. Slovak VAT payers must issue structured electronic invoices for defined domestic supplies to Slovak taxable persons and non-taxable legal entities, while persons within the recipient scope must be able to receive them.

The statutory deadline remains 15 days from the supply of goods or services or, where payment is received before supply, from receipt of that payment. The FAQ makes an operational distinction relevant to ERP and invoicing systems: merely generating an invoice inside accounting software is not enough. It must be sent or made available to the customer within the deadline.

Where Peppol is used, businesses need to ensure that their internal “invoice created” status is not mistaken for legal issuance if transmission occurs later. Slovak guidance provides that the related reporting obligation is treated as fulfilled when the electronic invoice is handed to the delivery service.

The FAQ also addresses cases where Peppol delivery cannot be completed because the recipient has not registered with a delivery service provider. Timely submission of the compliant invoice to the certified delivery service fulfils the supplier’s statutory sending obligation. If the supplier also sends the same structured invoice by email or another out-of-network method, that is secondary delivery rather than a new invoice and requires the recipient’s consent.

Failed Peppol delivery does not automatically remove the customer’s right to deduct input VAT. Deduction still depends on the substantive and formal conditions of the Slovak VAT Act, including the normal invoice and input-VAT requirements.

Assignment of a receivable does not automatically require a replacement or corrective eInvoice. If factoring is known when the invoice is issued, relevant payment and factor information may be included. If the receivable is assigned afterwards, the debtor is notified separately under civil-law rules and the original invoice data is not changed solely because the creditor changes.

For members of the same Slovak VAT group, internal supplies remain outside the scope of VAT because the group is treated as a single taxable person. They do not create a statutory invoice or Peppol-delivery obligation. If members nevertheless exchange documents voluntarily through Peppol, category “O” – Not subject to VAT applies and validation rule BR-O-02 prevents seller and buyer VAT identification numbers from appearing in the relevant fields.

Self-billing also remains possible. Slovak VAT rules permit the customer to issue an invoice in the supplier’s name and on the supplier’s behalf where a written agreement sets the acceptance conditions. For self-billed eInvoices, the updated guidance highlights a five-day reporting window for the supplier, calculated from issuance or, where relevant, from expiry of the applicable invoice-issuance deadline.

A technical part of the update concerns mapping Slovak VAT treatment to Peppol VAT Category Codes and VAT Exemption Reason Codes (VATEX). The main point is that a zero VAT amount does not determine the correct code by itself. Software must identify the legal reason why VAT is zero or not charged.

Taxable domestic supplies use category S; exempt domestic supplies use E; intra-Community supplies use K; exports outside the EU use G; domestic reverse-charge transactions use AE; and transactions outside the scope of VAT use O. Where required, the appropriate VATEX code or permitted exemption text must also be carried in the structured data. Peppol validation can reject technically inconsistent combinations even if the visible invoice appears understandable.

For retailers, the update does not change eKasa fiscalization or create a new Fiscal Receipt requirement. The 2027 E-Invoicing regime is a separate invoicing process, and official Slovak guidance excludes certain simplified invoices, including relevant eKasa documents, from mandatory electronic invoicing. The practical impact is therefore concentrated on B2B and B2G invoicing flows generated through POS, ERP, e-commerce or central accounting systems when those transactions fall within scope.

From a retail compliance perspective, the more difficult implementation issue is likely to be data mapping rather than XML generation itself. Systems must distinguish taxable, exempt, reverse-charge, out-of-scope and other VAT treatments before selecting Peppol codes. The same applies to exception workflows such as failed delivery, self-billing, VAT-group transactions and receivable assignment.

What should businesses prepare before January 2027?

Retailers, ERP providers and E-Invoicing solution providers should review whether the legal invoice-issuance date in their systems is tied to actual transmission rather than document creation, and test how failed delivery is handled without generating duplicate invoices. They should also validate self-billing workflows, VAT-group treatment and factoring scenarios against the updated FAQ.

Businesses should separately review VAT-code mapping and Peppol validation rules, especially for transactions where no VAT amount appears. This is a professional preparation recommendation rather than a new legal obligation created by the August FAQ; the underlying obligation is to issue compliant electronic invoices under the VAT Act from January 1, 2027.

The main source for the article above is updated eFaktura FAQ of the Slovak Financial Directorate’s. Source

Mirko Bijeljanin, Junior Legal Consultant at Fiscal Solutions 

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