Slovakia E-Invoicing: Proposed Penalty Grace Period Until June 30, 2027

Slovakia’s VAT amendment bill proposes temporary penalty relief for late electronic invoices and supplier-side reporting failures until June 30, 2027. The invoicing and receiving obligations would still begin on January 1, while mandatory reporting of received invoices could be removed.

Slovakia has proposed temporary penalty relief for certain electronic invoicing and digital reporting failures in the first half of 2027. Government Bill No. 1454 would amend the VAT Act ahead of mandatory domestic electronic invoicing from January 1, 2027.

Submitted to Parliament on August 27, 2026, following a May consultation, the bill remains at the first-reading stage and has not been enacted. It proposes supplier-side penalty relief and removal of recipient-side invoice reporting.

Under the proposed transitional provision, VAT payers covered by the domestic electronic invoicing mandate would not be fined for specified failures occurring between January 1 and June 30, 2027.

The relief addresses electronic invoices issued after the statutory deadline and failures relating to the communication of sales invoice data to the Financial Administration. These may include reporting that is missing or submitted late. The ordinary invoice-issuance deadline generally remains 15 days, and merely generating an invoice inside an accounting system does not mean that it has been issued through the required delivery process.

It is essential to distinguish penalty relief from postponement of the underlying obligation. Slovakia’s E-Invoicing rules are still scheduled to apply from January 1, 2027. Suppliers should issue structured electronic invoices and report the relevant data from that date, despite the proposed temporary limits on fines.

The measure is not a general exemption from electronic invoicing, blanket immunity from penalties or an extension of invoice deadlines.

If Parliament adopts the current proposal, the special relief would expire on June 30, 2027. Starting July 1, the normal sanction provisions would apply to the covered failures, subject to the legislation in force at that time.

The second proposed change concerns recipients rather than suppliers. The May consultation draft considered delaying the obligation for businesses to report data from electronic purchase invoices. Bill No. 1454 goes further by proposing to delete that recipient-side reporting requirement.

In practical terms, buyers would no longer need to submit a separate report of data extracted from electronic invoices they receive. Supplier-side reporting would remain, reducing duplicate reports and related technical work. The proposed deletion concerns reporting data extracted from received invoices; it is not the same as removing the duty to check whether an incoming invoice is accurate.

For retail chains, accounts payable teams receiving invoices for merchandise or services could avoid building a purchase-invoice reporting workflow. Their supplier-side outgoing reporting would remain.

This proposed reporting simplification would not remove normal VAT accounting, recordkeeping or electronic invoice reception duties.

Yes. The proposed penalty relief does not delay the general requirement for businesses within scope to receive structured electronic invoices from January 1, 2027. The planned exchange infrastructure is based on the Peppol network and certified delivery service providers, often referred to in Slovakia as digital postmen.

VAT-registered businesses must prepare to issue and receive electronic invoices for transactions covered by the mandate. Other domestic businesses, including businesses not registered for VAT, may still fall under the obligation to receive them. The applicable scope and any exceptions should be assessed against the VAT rules.

Businesses should not wait until July to arrange their receiving channel. Retailers should verify provider connectivity and confirm that incoming invoices reach their accounting team or software. A separate receiving process matters even for businesses that issue relatively few invoices of their own.

For retailers, the first implementation question is which sales require electronic invoices and how those documents are generated. An ordinary eKasa Fiscal Receipt and a structured business invoice are not interchangeable merely because both concern the same purchase. POS providers should identify connections to invoicing or accounting systems rather than assume every checkout transaction needs this workflow.

Where a retailer issues business invoices, its systems may need to transfer invoice details to the delivery provider and support the supplier-side reporting process. The proposed removal of purchase reporting would simplify the incoming side, but it would not remove the need to receive, read and retain electronic invoices as required. For retail groups using external accountants, the allocation of responsibility for those documents should be settled before rollout.

From our perspective, the main risk is a mistaken implementation timetable. A retailer could interpret the reference to June 30 as permission to delay its Peppol connection or software changes. In fact, the bill addresses selected penalties, while the operational start date remains January 1. Businesses should also avoid removing purchase-reporting functionality from their implementation plans before the amendment is adopted.

What should affected businesses do next?

Retailers and software providers should continue testing invoice generation, delivery and reception against the January 2027 mandate. They should confirm responsibility for supplier-side data reporting, review how failed transmissions and late invoices will be detected, and ask their invoicing provider whether the proposed removal of buyer reporting affects planned development.

The legislative status also requires attention. Parliament received Bill No. 1454 on August 27, and the parliamentary materials identified November committee consideration as part of its review timetable. Further amendments are possible before approval and publication. Businesses should base final configuration decisions on the legislation that is actually enacted, not only on the consultation text or professional commentary.

The principal primary source is the Slovak Parliament’s Government Bill No. 1454: Laws : Search in Bills : Details of Bills - National Council of the Slovak Republic. Source Source

Mirko Bijeljanin, Junior Legal Consultant at Fiscal Solutions

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