Slovakia's Mandatory E-Invoicing from 2027: Which Foreign-Owned Set-Ups Are In, Which Are Out
If you own a Slovak s.r.o. or run a Slovak branch that is registered for VAT, then from 1 January 2027 every invoice it sends to a Slovak business customer must be a structured e-invoice. It has to go out through a certified delivery provider, and its data has to reach the tax authority within five days. If your foreign company only holds a Slovak VAT number, with no office in Slovakia, the first phase does not apply to you.
That split, established versus merely registered, is the question foreign owners ask most often, and most local guides skip it. They are written for Slovak companies, where the answer is always “yes”.
The test: where are you established, not who owns you
The obligation to issue e-invoices falls on a VAT payer registered under § 4, § 4b or § 4c of the VAT Act (§ 85o(2)). Section 4 covers a taxable person with its seat, place of business or fixed establishment in Slovakia. Section 5 covers a foreign person with none of these, and § 5 is not on the list.
Nationality of the shareholders is irrelevant. A Slovak s.r.o. owned 100% by a German or US parent is a Slovak company.
| Your set-up | Must issue e-invoices from 2027 | Must be able to receive them | Reports data to the tax authority |
|---|---|---|---|
| Slovak s.r.o. registered for VAT, any owner | yes, on domestic B2B supplies | yes | yes, as seller and as buyer |
| Branch (organizačná zložka) of a foreign company with staff and premises in Slovakia, VAT-registered there | yes, as a fixed establishment | yes | yes |
| Slovak s.r.o. not registered for VAT | no | yes | no |
| Foreign company with a Slovak VAT number only (§ 5), no establishment | no | no | no, until 1 July 2030 |
The third row catches people out. Under § 71(5), every person supplied in Slovakia by a seller who must e-invoice has to be able to receive e-invoices through a delivery service, whether or not it is a VAT payer. A small holding or IT s.r.o. below the €50,000 registration threshold still needs an inbox for invoices from its landlord and accountant.
Which invoices are covered
Covered: supplies of goods and services with their place of supply in Slovakia, and advance payments for them, where the customer is a taxable person established in Slovakia or a Slovak-established non-taxable legal entity (§ 85o(2)–(3)). Domestic reverse-charge invoices, for example construction work, are included too. The reported data explicitly carries the “reverse charge” wording.
Not covered in the first phase:
- invoices to customers abroad, including intra-group recharges to a foreign parent,
- sales to consumers,
- VAT-exempt supplies under § 28 to 43 and § 47, such as financial services,
- simplified invoices: receipts up to €100 including VAT, and eKasa receipts up to €400.
Deadlines and fines at a glance
| What | Deadline or amount | Where in the Act |
|---|---|---|
| Issue the e-invoice | within 15 days of the supply or the advance payment | § 85o(6) |
| Summary e-invoice | covers one calendar month at most, issued within 15 days after month-end | § 85o(7) |
| Seller reports invoice data | on issue, within 5 days at the latest | § 85o(9) |
| VAT-registered buyer reports received invoice | within 5 days of receipt | § 85o(10) |
| Keep the e-invoice | 10 years from the end of the year | § 85o(15) |
| Missing, late or wrong data | fine up to €10,000 | § 85o(12) |
| Repeated breach | fine up to €100,000 | § 85o(13) |
Reporting is not a separate return. The Act treats it as done once the e-invoice is handed to the delivery service (§ 85o(11)). The provider transmits the data automatically. The real exposure is an invoice that never enters the network, such as a PDF emailed from a foreign group ERP. No fine is imposed for an obvious error that is corrected, or for a proven outage at the certified provider, provided the data is sent as soon as the fault is fixed (§ 85o(14)).
A worked example in euros
A Slovak s.r.o. in Bratislava, 100% owned by a Dutch parent and registered for VAT, has three transactions in February 2027:
- Consulting for a Slovak client: €8,000 + 23% VAT = €9,840. This is a domestic B2B supply, so an e-invoice is mandatory. Issued on 12 February, its data must be reported by 17 February, which happens automatically through the provider.
- Management fee charged to the Dutch parent: €5,000, reverse-charged in the Netherlands. This is a cross-border supply, so it is outside the mandate and the group’s usual PDF invoice still works.
- Office rent from a Slovak landlord: €1,500 + VAT = €1,845. The s.r.o. is the buyer. It must receive the e-invoice through its own provider and, as a VAT payer, report it within five days of receipt.
Now suppose invoice 1 goes out as a PDF from the parent’s billing system. The seller’s reporting duty is unmet, which exposes the s.r.o. to a fine of up to €10,000. If that is standard practice and happens every month, the ceiling rises to €100,000.
Choosing a provider when head office uses its own system
Only providers entered in the Financial Directorate’s register may operate the delivery service in Slovakia (§ 76a(7)). The list published on 14 September 2026 has 72 names, and a provider must be based in the EU. Many international Peppol access points are already listed, so a group-wide provider may cover Slovakia. Check two things:
- The provider is on the Slovak list, not just certified by OpenPeppol.
- It will still be listed on 1 January 2027. Any provider that has not proven by 15 December 2026 that it can transmit the reporting data will be deleted from the register on that date (§ 85o(19)).
Until the end of 2026 you can send e-invoices through the delivery service without the customer’s consent, provided the customer can receive them that way (§ 85o(22)). Use October and November for a live test with your largest Slovak customer.
What changes in July 2030
In the version of the VAT Act in force from 1 July 2030, data reporting under § 80a also covers VAT payers registered under § 5. That brings foreign companies holding only a Slovak VAT number into the reporting regime, and the current control statement (kontrolný výkaz) disappears from the Act. If your Slovak exposure is a VAT registration without an entity, 2030 is your date. The rest of the Slovak VAT basics are covered in our Slovak VAT guide. Every other recurring filing is in the compliance calendar for foreign owners.
FAQ
Does Slovak e-invoicing apply to a foreign-owned s.r.o.? Yes. Ownership does not matter. A VAT-registered Slovak s.r.o. must issue e-invoices on domestic B2B supplies from 1 January 2027 and report their data within five days.
We only have a Slovak VAT number, no company or branch. Are we affected in 2027? No. The 2027 obligation covers VAT payers registered under § 4, 4b and 4c, meaning those established in Slovakia. Payers registered under § 5 come into the data-reporting regime from 1 July 2030.
Our Slovak company is not VAT-registered. Do we need anything? Yes. You must be able to receive e-invoices through a certified delivery service from Slovak suppliers who are required to issue them. You do not issue or report anything.
Can we keep sending PDF invoices to our foreign parent? Yes. Cross-border invoices are outside the 2027 mandate.
Foreign-owned companies usually hit the problem in the group billing system, not in Slovak law. As part of our accounting services in Slovakia, we map which invoice flows fall under the mandate and connect the Slovak entity to a listed provider. Tax office notices will arrive in the company’s electronic mailbox, so someone has to read it.