Slovakia can be regarded as one of the laggards in the European Union as far as e-invoicing is concerned.
While there’s legislation mandating e-invoicing for government-to-government (G2G) and business-to-government (B2G) transactions, the roll-out has been delayed numerous times, with a new date pegged to the first quarter of 2024 per news from the eFaktura platform.
It appears that the Slovakian Ministry of Finance (MOF) is still fine tuning the informačný systém elektronickej fakturácie (IS EFA), the e-invoicing information infrastructure.
Presently, there are no concrete details on e-invoicing regulations concerning business-to-consumer (B2C) or (B2B), except that the country hopes to roll out e-invoicing for all transactions over time.
In this article, we’ll explore Slovakia’s current e-invoicing regulatory landscape and share tips on remaining compliant.
Is electronic invoicing mandatory in Slovakia?
Currently, mandatory e-invoicing is not yet in place for all kinds of transactions. The e-invoicing obligations for government-to-government (G2G) and business-to-government (B2G) transactions had been initially scheduled to commence in the first quarter of 2023.
However, the MOF has postponed the rollout numerous times. The new timeline for the first batch of obligations is now scheduled for the first quarter of 2024. However, many local experts expect further delays.
The use of electronic invoices in the private sector is permitted voluntarily. That said, there’s a new Continuous Transaction Controls (CTC) model in the offing with mandatory obligations likely to become active sometime in 2025.
The laws guiding e-invoicing in Slovakia are Act No. 2015/2019, “on the guaranteed electronic invoicing and the central economic system and on amendments on certain laws,” and Act No. 305/2013, “on the Electronic Form of Governance Conducted by Public Authorities and on amendments and supplements to other acts (e-Government Act).”
Requirements for e-invoicing in Slovakia
As stated earlier, current e-invoicing directives only cater to transactions involving public entities. The primary requirement is for electronic invoices to be issued for all transactions that exceed EUR 5,000.
The second requirement is for the submission of e-invoices via the IS EFA. For this, entities may submit automatically via the IS EFA API or manually through the EFA user application.
The former caters to large and medium enterprises, while the latter is for smaller companies subject to VAT collections.
For non-Slovakian entities, the process is different. All foreign suppliers must email the desired invoice to an official government email address: “foreign-invoice@firstname.lastname@example.org.”
The staff at the MOF verifies and then manually adds the content of the invoice to the online billing system. The party that sends the mail will receive a confirmation email if the invoice is approved or rejected if otherwise.
Lastly, the current mandates or rules apply to all VAT-registered or resident taxpayers in the country.
Ensure you’re using the appropriate sending and receiving e-invoice infrastructure for your business to meet regulatory requirements. With Storecove, rest assured that all e-invoices will be accurate and complete and meet the regulatory compliance threshold of the receiving country.
Required format and other requirements
All electronic invoices must be in XML format, based on the UBL 2.1 standard. Suppliers and customers must also exchange the e-invoice in the XML format.
Presently, there’s no stipulated validation method, but we reckon this may come later on as the MOF continues to harmonize the country’s e-invoicing mandates. There are also no requirements regarding sending an acknowledgment of receipt.
Additionally, suppliers may use simplified invoices if the total value is 400 euros or less.
That is, the invoice may only include the VAT rates and gross transaction value in such instances. Otherwise, if the total value exceeds 5,000 euros, you must send a full VAT invoice.
What should be included in an invoice?
As with most countries’ e-invoicing requirements, the invoice must contain:
- A unique and sequential invoice number
- The date of supply and invoice issuance
- Product/service description
- Quantity and unit price (before reduced VAT rate and other discounts)
- Customer and supplier details and their VAT registration IDs
- The VAT rate applied to the transaction and total payable VAT in euros
In addition to the above, the e-invoice should include if the customer will be paying for the VAT, if the invoice was customer-issued, and VAT exemption details where applicable.
Slovakia’s e-invoicing archiving rules
Slovakia requires companies to store e-invoices for many years—10 years for movable property and 20 years for immovable property.
The archiving timeline starts from the end of the fiscal year the transaction took place. Archiving abroad is allowed with certain conditions.
However, such archiving arrangements should make it easy to provide any invoice requested by the Slovak tax authorities.
Slovakian e-invoice implementation timeline
The new schedule for the IS EFA to become the mandatory e-invoice clearance system is in the first quarter of 2024. A progressive implementation across different cadres of public institutions is expected.
To bridge its VAT invoice collection gap, the country's Ministry of Finance (MOF) published preliminary regulations in 2019 outlining a new invoicing model.
On the 5th of February 2021, the Slovak government published a new draft law requiring entities to send specific invoice data to the Financial Administration.
That signaled the MOF's intention to plug all VAT collection gaps through real-time invoice reporting.
Consequently, there was public consultation with the view that the e-invoicing system will go live in January 2022 for B2G, G2G and G2B transactions.
However, the timeline for e-invoicing implementation in Slovakia has changed multiple times over the past two years.
The MOF announced that the IS EFA electronic invoicing information system was available for testing for a small group of public entities in April 2023. Recently, the e-Faktura platform has shown a new timeline for the involvement of government and public administration institutions in the E-invoice system.
Per the new schedule, the following entities are expected to start using the IS EFA platform:
- Q1 2024-Ministry of Finance of the Slovak Republic and Datacentrum and its suppliers
- Q1 2024-Budget organizations of the Ministry of Finance of the Slovak Republic, including the Financial Administration of the Slovak Republic
- Q1 2024-Other government and public administration entities
Within the same timeframe, the government expects to engage entrepreneurs in transacting with public institutions. The government has tentatively pegged 2025 as the year adding B2B or B2C transactions to obligatory status.
How to send e-invoice in Slovakia
The steps below only apply to suppliers working with government institutions. As of the time of this publication, sending and receiving e-invoices is voluntary for B2B or B2C transactions.
- Step 1: Register on the IS EFA portal to enjoy all e-invoicing services. Already, all taxpayers are expected to register on the eKasa platform since 2019. eKasa is an IT and communication solution that connects the government to all cash registers.
- Step 2: Create the invoice via your internal solution or on the IS EFA system. Using the former, take note to include all the requested details.
- Step 3: Convert the invoice to the required XML format with either the UBL 2.1 or CII D16B syntax.
- Step 4: Upload the invoice to the Financial Directorate. Depending on business size, you may integrate your ERP system to the IS EFA open API to send your invoice or upload manually through a dedicated EFA user application built for small companies subject to VAT. Foreign suppliers must, however, send electronic invoices to the “foreign-invoice@email@example.com” email address.
- Step 5: Wait for a confirmation or rejection email from the MOF.
Note that it has been possible to use the IS EFA since January 2022. You may view all public invoices generated and sent on the platform. However, using the platform remains voluntary for now.
What is the penalty for not adhering to Slovakia's e-invoicing rule?
The penalty for not adhering to e-invoicing stipulations may range from EUR 30 to 3,000 for non-monetary offenses. Monetary offenses, like underreporting value, may come with steeper fines.
Takeaway: Obligatory status for government transactions coming online in Q1 2024
Currently, there are no obligations to use e-invoicing in Slovakia, whether for B2B, B2C, B2G, or G2G transactions. There are, however, rules in place for B2G transactions to become mandatory.
The roll-out of obligatory B2G e-invoicing in Slovakia has suffered numerous delays. The first phase was supposed to begin in Q3 2023, with the final phase in Q1 2024.
The latest update has pegged the new timeline for the “first quarter of 2024.” It remains to be seen if these dates remain unchanged.
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