Slovakia clarifies Peppol and VAT coding rules for 2027 e-invoicing mandate

Slovakia's Financial Directorate updated its eFaktúra FAQ in August 2026 with guidance on Peppol delivery, VAT category codes, and e-invoicing timing ahead of the mandatory regime starting 1 January 2027.

The Slovak Financial Directorate has released updated guidance on e-invoicing requirements, Peppol compliance, and VAT coding ahead of the mandatory e-invoicing regime taking effect on 1 January 2027. The FAQ clarifies rules on invoice timing, failed Peppol deliveries, factoring, VAT group transactions, and self-billing.

Slovakia’s Financial Directorate updated its eFaktúra FAQ in August 2026 with practical guidance on e-invoicing requirements. The update addresses Peppol VAT Category Codes, VAT Exemption Reason Codes (VATEX), and other technical rules ahead of the mandatory e-invoicing regime starting 1 January 2027.

From that date, businesses and legal entities in Slovakia must use structured XML format for domestic transactions. The system uses the Peppol network and certified service providers called Digital Postal Workers to transmit and receive data in real time. B2B and B2G transactions are the primary focus. Consumers and certain classified government entities remain exempt. Taxpayers can enter a voluntary transition period throughout 2026 to test their systems.

Invoice timing and Peppol delivery

An e-invoice must be sent or made available to the customer within 15 days of the supply or payment receipt. Creating it in an accounting system alone does not meet the deadline. An invoice is considered issued when submitted to the Peppol delivery service.

When a recipient has not registered with Peppol, the supplier may resend the same XML invoice via email after a failed Peppol delivery. This counts as re-disclosure of an already-issued invoice, not a new issuance. The recipient’s consent is required for email transmission. Consent carries no rigid formality requirement. Written agreement, email confirmation, contractual language, or even implied acceptance (such as payment of the emailed invoice) all suffice.

Recipients may claim input VAT deduction on the emailed invoice provided it complies with the VAT Act and meets substantive and formal requirements. Email delivery following a failed Peppol attempt does not disqualify the deduction.

Factoring and receivable assignment

Slovakia’s VAT Act does not contain a specific mechanism for factoring or receivable assignment. Businesses must follow the European EN 16931 standard and standard Civil Code requirements.

If the assignment is known at invoice issuance, the supplier may include the factor’s details, payment information, and assignment notes on the e-invoice. Invoice type 380 or 393 may be used.

If the assignment occurs after issuance, a new e-invoice or corrective document is not issued solely because a receivable is assigned. Instead, the supplier must notify the debtor under standard Civil Code rules. This is a separate communication process outside the Peppol network and does not change the original XML data.

VAT group internal transactions

Supplies between members of the same registered VAT group are treated as internal supplies within a single taxable person. They are not subject to VAT and do not trigger any statutory invoice obligation.

There is no legal obligation to exchange these documents via Peppol, although doing so voluntarily is permitted. Members may exchange documents via email or internal systems without requiring Peppol-compliant consent rules.

Group members exchanging documents voluntarily via Peppol must use each member’s unique DIČ as the EndpointID with prefix 0245 and apply VAT Category “O”. Under BR-O-02, the invoice must omit the Seller’s and Buyer’s VAT IDs, including the group’s common VAT ID, to pass validation.

Self-billing and VAT category codes

Self-billed invoices remain permitted when a written agreement establishes predefined conditions between supplier and customer. Unlike standard e-invoices, which require real-time reporting to the tax authority upon issuance, self-billed invoices grant the supplier a five-day reporting window. This deadline begins either from the date the self-billed invoice is issued or, where an invoice-issuance deadline applies, from its expiry.

The updated guide introduces a Slovakia-specific mapping for Peppol VAT Category Codes (BT-118/BT-151) and European VATEX exemption codes (BT-121). The VAT category must be chosen based on the actual legal VAT regime, not simply on whether the VAT amount is zero.

Core mapped categories for Slovakia are:

Standard rate (S): Taxable domestic supplies under Section 27, covering basic and reduced rates (23%, 19%, or 5%). No VATEX code is used.
Exempt from tax (E): Domestic VAT-exempt supplies under Sections 28 to 42 (postal, healthcare, social services, education, sports, cultural, financial, insurance, real estate, and other exempt supplies).
Intra-community supply (K): VAT-exempt supply of goods from Slovakia to another EU member state (Section 43).
Export outside the EU (G): VAT-exempt export of goods outside the EU (Section 47).
Reverse charge (AE): Transactions under Section 69 where the customer accounts for the tax.
Not subject to VAT (O): Transactions outside the scope of VAT, including certain internal transactions between members of the same Slovak VAT group.
Zero-rated goods (Z): Applies only to goods with a legally established zero rate. No VATEX.

Businesses should review the updated FAQ to ensure compliance with the January 2027 deadline.