Who the e-invoice does not apply to, and when an invoice is not sent electronically

From 1 January 2027, only a VAT payer under Section 4, Section 4b or Section 4c is obliged to issue an electronic invoice, and only for supplies with the place of supply in Slovakia to a domestic taxable person or a domestic non-taxable legal person. It therefore does not apply to sales to consumers (B2C), invoices sent abroad or invoices sent to you by a foreign supplier. Below is a complete overview of the exceptions with their sections of the law, including situations in which you must issue an invoice but it must not, or need not, go through the delivery service.

When the obligation arises at all

Under Section 85o(2) and (3) of Act No. 222/2004 Coll. on VAT, all four conditions must be met at the same time:

• The supplier is a VAT payer under Section 4, Section 4b (VAT group) or Section 4c.
• The customer is a taxable person with its registered office, place of business, establishment or residence in Slovakia, or a non-taxable legal person with its registered office in Slovakia.
• The place of supply under Section 13, Section 15 or Section 16 is in Slovakia (or it is a payment received before such a supply).
• The supply is not exempt under Sections 28 to 43 and Section 47, and it is not a simplified invoice under Section 74(3).

If even one condition is not met, you do not have to issue a structured e-invoice.

Who does not have to issue e-invoices

Who you are	Must you issue e-invoices?	Must you be able to receive them?
VAT payer under Section 4 / 4b / 4c	Yes, for domestic B2B and B2G	Yes
Sole trader or limited company (s. r. o.) — non-VAT payer	No	Yes
Person registered under Section 7 or Section 7a	No	Yes
Foreign company with a Slovak VAT ID (IČ DPH) (Section 5)	No	No
Municipality or public authority exercising public powers	No (it is not a taxable person)	Yes
Private individual — not in business	No	No

That a foreign person registered under Section 5 has neither the obligation to issue nor the obligation to ensure receipt through a delivery service is confirmed by the FAQ of the Financial Administration (Finančná správa) (Part II, example 29). The reason is European: Directive 2006/112/EC does not allow mandatory e-invoicing to be imposed before 1 July 2030 on persons who are not established in the member state concerned.

There is no postponement based on company size. The law sets no turnover threshold and no exception for micro-enterprises — the only thing that matters is whether you are a VAT payer.

Sales to consumers (B2C)

The e-invoice does not apply to B2C, for two independent reasons. Under Section 72(1)(a), the obligation to issue an invoice arises for a supply to another taxable person or a legal person — a private individual not in business is not listed there. And Section 85o(3) defines the recipient as a taxable person or a non-taxable legal person.

So you give the customer a receipt from the eKasa cash register or an ordinary invoice — nothing more. The exceptions where you must issue an invoice even to a private individual are distance sales of goods with the place of supply in Slovakia (Section 72(1)(d)) and the supply of a new means of transport to another member state (Section 72(5)). Even in these cases, however, it is not a mandatory structured e-invoice.

Watch out for the difference between the 100 € and 400 € limits

This is the most frequently misquoted number in articles about the e-invoice. The law allows a simplified invoice under Section 74(3) to be issued within two different limits:

Type of document	Limit including tax	Provision
Ordinary document for goods or a service	100 €	Section 74(3)(a)
Receipt from the eKasa cash register	400 €	Section 74(3)(b)
Receipt from a fuel dispenser	400 €	Section 74(3)(b)

In practice: if you sell goods worth 250 € to a sole trader and issue a classic invoice instead of an eKasa receipt, it must be sent electronically — the 100 € limit has been exceeded. Anyone who has only remembered the 400 € figure will get it wrong.

Moreover, a simplified invoice is an option, not an obligation. If you choose to issue a full invoice, it falls under the e-invoice regime even for an amount below the limit.

Invoices sent abroad

Until 30 June 2030, the mandatory structured e-invoice does not apply to any cross-border supply — neither within the EU nor to third countries. This follows directly from the condition of a domestic place of supply and a domestic customer in Section 85o(2).

For foreign invoices, Sections 71 to 76 as in force until 30 June 2030 continue to apply: you may issue the invoice on paper or as a PDF, in electronic form only with the recipient's consent, and it triggers no reporting obligation towards the Financial Administration. The EC Sales List under Section 80 continues to be filed.

Technically, nothing stops you from sending an invoice abroad through Peppol today — the network is international and a customer in Belgium or Italy will process it automatically. It is, however, voluntary and does not have the legal effect of a Slovak e-invoice.

Receiving an invoice from abroad

If a supplier from Germany, the Czech Republic or a third country sends you an invoice, you do not have to receive it electronically. The obligation to receive under Section 71(5) is accessory — it arises only where the supplier is obliged under Slovak law to issue an e-invoice. A foreign supplier has no such obligation.

Nor do you have a reporting obligation towards the Financial Administration. Section 85o(10) ties it to your having received the invoice through a delivery service — an invoice delivered by e-mail does not meet this condition. The reverse charge, acquisition of goods from the EU and imports are reported as usual until 30 June 2030 through the VAT return, the VAT control statement and the EC Sales List.

This changes from 1 July 2030. Under the new Section 80(2), the customer will also have a reporting obligation on the acquisition of goods from another member state and on receiving a supply under the reverse charge — within 5 days of receiving the electronic invoice. At the same time, the VAT control statement and the EC Sales List are abolished.

When an invoice is not sent electronically even within Slovakia

• Exempt supplies. There are two different scopes here that are commonly confused: for supplies exempt under Sections 28 to 42 no invoice needs to be issued at all (Section 72(8)); for Sections 28 to 43 and Section 47 you must issue an invoice, but it does not have to be electronic (Section 85o(2)). In practice: for intra-Community supplies and exports you issue an invoice, but not a structured one; for insurance, financial services or an exempt property lease you issue nothing.
• Proforma invoice and payment request. It does not contain the particulars of an invoice under the VAT Act and no tax liability arises from it — it is not sent through the system. But note: an invoice for a payment received under Section 72(1)(f) and (g) is a tax document and must be sent as an e-invoice.
• Corrective document under Section 25a for an irrecoverable receivable — Section 71(2) expressly states that it is not an invoice.
• Internal accounting documents — depreciation, exchange rate differences, payroll postings. They are not invoices under Section 71.
• Supplies within a single VAT group under Section 4b are not subject to tax, so no obligation to invoice arises either.
• Classified supplies and supplies to intelligence services. For a supply connected with classified information and for a supply to the Slovak Information Service or Military Intelligence, the e-invoice is actually prohibited (Section 85o(2), last sentence).
• Customer without an assigned Tax ID (DIČ). The Slovak rules use the identifier 0245:DIČ. Without a Tax ID (DIČ) the entity cannot be registered in the SMP, so there is nowhere to deliver an e-invoice to.

On the other hand — these must be sent electronically

Credit notes and debit notes are often wrongly regarded as an exception. Under Section 85o(5), any document or notice that amends the original e-invoice is also deemed to be an electronic invoice, and it must be sent through the same delivery service. The deadline is 15 days from the end of the month in which the fact decisive for correcting the tax base occurred. The exception is a correction of an invoice for a supply made by 31 December 2026 — under Section 85o(23) the same conditions apply to it as to the original invoice, so you issue a paper credit note for a paper invoice from 2026.

A change that will catch landlords and leasing companies off guard

From 1 January 2027, the option of a payment agreement under Section 75(2) ceases to exist — that is, a rent payment schedule or an agreement on payments for electricity, gas, water and heat for a period of up to 12 months. The European standard for electronic invoicing does not recognise such an arrangement, so a separate e-invoice is needed for each recurring supply. One agreement a year becomes twelve e-invoices a year for each customer. A summary invoice remains possible, but for no more than one calendar month (Section 85o(7)).

Far more entities must receive than must issue

Even if you do not issue e-invoices, you will almost certainly have to be able to receive them — it is enough that a VAT payer supplies you with something. This applies to sole traders, the liberal professions, self-employed farmers, property landlords, non-profits and municipalities. We cover it in detail in the article Who must receive e-invoices from 2027, and an overview for non-VAT payers is on the page Non-VAT payers and the e-invoice.

A practical condition that is underestimated: the entity must have an assigned Tax ID (DIČ). Anyone who has only a Company ID (IČO) — typically civic associations, owners' associations or newly founded non-profits — must apply to the tax administrator for income tax registration. The Financial Administration has 30 days for this and recommends getting it done by autumn 2026.

What to do now

If you fall under one of the exceptions, it does not mean you do not have to do anything — receiving e-invoices almost certainly applies to you. 2026 is the voluntary phase; use it for a dry run. You can check whether your company is in the network with the free Peppol checker by Company ID (IČO), and the whole connection process is in the guide how to connect your company to the e-invoice.

Sources: Act No. 222/2004 Coll. on VAT as in force from 1 January 2027 (Sections 71, 72, 74, 85o), Act No. 385/2025 Coll., methodological information of the Financial Directorate of the Slovak Republic No. 1/DPH/2026/I and the FAQ of the Financial Directorate of the Slovak Republic No. 9/DPH/2025/IM on the eInvoice as amended on 7 July 2026. This article is for information only and is not a substitute for tax advice — in borderline cases, consult your accountant.