eFaktúra 2027 — Slovakia's mandatory e-invoicing: full compliance report

Researched 2026-07-19. Sources listed at the bottom.

TL;DR — the one fact that shapes everything

You cannot push XML directly to the tax authority, and you cannot push it directly to your customer either. Slovakia chose a decentralized 5-corner Peppol model. Every invoice must travel: your system → your accredited service provider ("Digitálny poštár" / Digital Postman) → Peppol network → recipient's provider → recipient's system, with the Financial Administration sitting at corner 5 receiving reported tax data from the providers. So "pushing the XML directly" means one of two legal paths:

Integrate the ERP backend with the API of one (or several) accredited Digital Postmen — you generate the compliant XML, they deliver it and handle the tax-authority reporting. This is what virtually every ERP vendor is doing.
Become an accredited service provider yourself — a Peppol-certified Access Point plus Slovak Financial Administration accreditation. Real option for an ERP company long-term, but it's a regulatory undertaking, not a coding task (details below).

There is no direct taxpayer→tax-authority channel like Poland's KSeF or Italy's SdI. That's the deliberate design.

1. Legal framework

Act No. 385/2025 Z.z., approved by the National Council on 9 December 2025, amends the VAT Act (new § 76a on electronic invoices) and transposes Articles 1 and 5 of Council Directive (EU) 2025/516 (ViDA). In force 1 January 2026; obligations bite 1 January 2027.
The Financial Administration of the SR (Finančné riaditeľstvo) is the national Peppol Authority — it accredits providers, publishes the certified-provider list, and operates corner 5.
The legal definition of "invoice" is redefined around EN 16931 (STN EN 16931): a structured electronic file enabling automatic processing. PDF, scans, and EDIFACT legally cease to be invoices for in-scope transactions.
A draft amendment (LP/2026/282, May 2026) proposes a penalty-free grace period 1 Jan–31 Mar 2027 and deferring buyer-side reporting to 1 July 2030. As of mid-2026 it is under consultation, not enacted — build for the strict version, treat the grace period as a bonus.

2. Timeline

Date	What happens
1 Jan 2026	Law in force; voluntary phase begins; provider accreditation starts (rules published 14 Jan 2026)
Spring–Q3 2026	Voluntary testing; corner-5 digital reporting system projected live ~Q3 2026
1 Jan 2027	Mandatory: structured e-invoicing + near-real-time reporting for all domestic B2B (and B2G) transactions between Slovak VAT payers
1 Jul 2030	Extends to cross-border intra-EU transactions and to foreign VAT-registered non-established businesses (ViDA DRR); súhrnný výkaz (ESL) and kontrolný výkaz (VAT control statement) are abolished — invoice data reporting replaces them
1 Jan 2035	ViDA deadline for all national regimes to be harmonized with the EU standard

3. Who is obligated, and for what

Must issue e-invoices (from 1 Jan 2027):

Slovak-established VAT payers, for domestic B2B and B2G supplies with place of supply in Slovakia.
Foreign businesses VAT-registered in Slovakia without establishment are out of scope until 30 June 2030, then pulled in.

Must be able to receive e-invoices:

Every legal entity and entrepreneur — including non-VAT payers. This is the widest net: even a small non-VAT company must be reachable (registered with a provider, identified by its DIČ in the Peppol directory). Recipient consent is not required — a compliant e-invoice sent to your Peppol address is legally delivered.

Out of scope: B2C invoices; supplies involving classified information (SIS, Military Intelligence); simplified invoices/cash-register receipts stay under the eKasa regime.

Deadlines written into the regime:

Issue the e-invoice within 15 days of the tax event (tightened from the general rule, per ViDA alignment).
Buyer side: report data from received invoices within 5 days (this is the piece proposed for deferral to 2030).

Self-billing remains permitted with written agreement. Corrective invoices (credit/debit notes) follow the same structured-format and reporting rules.

4. Format — what the XML must be

EN 16931 semantic model, in UBL 2.1 or UN/CEFACT CII syntax. In practice Slovakia runs on Peppol BIS Billing 3.0 (UBL), which is the EN 16931-compliant Peppol profile.
Slovakia has stated it uses EN 16931 without a national CIUS/extension so far — but a Slovak Peppol ruleset is materializing through the Peppol Authority: Peppol Code Lists v9.5 already define scheme 0245 (SG:DIC) — the 10-digit Slovak tax ID — as the participant identifier for addressing Slovak entities.
The XML must pass EN 16931 business rules (BR-*) validation plus Peppol BIS validation artifacts, and carry correct Slovak VAT content (DIČ/IČ DPH of both parties, VAT breakdown per rate, correct tax category codes, etc.).

5. Reporting (the "e-reporting" half)

For every invoice, the accredited provider extracts a Tax Data Document (TDD) — a subset of the invoice data — and sends it to the Financial Administration in near real time. Reporting does not block delivery (no clearance model — the invoice isn't pre-approved by the state, unlike KSeF/SdI).
Supplier-side reporting happens at issuance via your provider; buyer-side reporting (within 5 days, possibly deferred to 2030) via the buyer's provider.
From July 2030 this reporting fully replaces the ESL and control statement.

6. Archiving and integrity

Retain invoices 10 years (immovable property: 20 years), in the structured electronic form, guaranteeing authenticity of origin, integrity of content, and legibility for the whole period. Storage abroad is permitted (must be accessible to the tax authority).

7. Penalties

Up to €10,000 per violation (not issuing/receiving properly, wrong or late reporting); up to €100,000 for repeated violations.
Statutory defenses: promptly corrected honest errors; and provider technical outages if data is reported without delay after resolution — one reason the provider contract and failover matter legally.

8. Other countries this affects

Two distinct senses of "affects":

Directly, via the same ViDA directive — from 1 July 2030 every EU member state must run digital reporting for intra-EU B2B transactions, and structured e-invoicing becomes the default EU-wide; Slovakia's mandate is simply an early national implementation. If ERP customers trade intra-EU, the 2030 wave hits all of them regardless of country.

Practically, for an ERP serving the region — neighboring/EU mandates customers may fall under:

Country	Mandate	Model
Belgium	1 Jan 2026, all VAT businesses	Peppol 4-corner (BIS 3.0) — closest to Slovakia
Poland	KSeF: 1 Feb 2026 (large), 1 Apr 2026 (rest), 2027 (micro)	Centralized clearance via state platform, FA(3) XML
Croatia	1 Jan 2026 (Fiskalizacija 2.0)	Decentralized exchange + fiscalization reporting
France	Sep 2026 receive + large issue; Sep 2027 SMEs	PDP (certified platform) model
Germany	Receive since 2025; issue 2027 (>€800k), 2028 all	No network mandate; EN 16931 (XRechnung/ZUGFeRD)
Hungary, Romania, Italy	Already live	RTIR / RO e-Factura / SdI clearance
Slovenia	1 Jan 2028	e-SLOG/EN 16931, provider-based
Latvia	B2G reporting 2026; B2B 1 Jan 2028	Peppol-based

The strategic takeaway: Slovakia, Belgium, Latvia, and the ViDA 2030 endgame all converge on Peppol + EN 16931/UBL. Building invoice generation around clean EN 16931 UBL semantics is the one investment that pays off in every one of these markets; Poland's KSeF is the notable divergent (its own XML schema and central API).

9. Compliance checklist — what must exist for Slovak users to be 100% compliant on 1 Jan 2027

Outbound: generate EN 16931-valid UBL 2.1 (Peppol BIS 3.0) XML for every domestic B2B/B2G invoice, credit note, and corrective invoice, within 15 days of supply.
Transmission: deliver it through an accredited Digital Postman — via their API from the backend. The Financial Administration publishes and updates the list of accredited providers (first entries expected during 2026); ideally support more than one, since customers may have provider preferences and the outage-defense rules make failover valuable.
Inbound: every customer entity (VAT payer or not) must be registered/addressable by DIČ (scheme 0245) and able to receive e-invoices — the system needs to ingest incoming UBL from the provider, not just send.
Buyer-side reporting: confirmation/reporting of received-invoice data within 5 days (watch LP/2026/282 — may move to 2030).
Validation: enforce EN 16931 + Peppol business rules before handing off, because a rejected invoice past day 15 is the user's fine.
Archiving: 10/20-year retention of the structured XML with integrity guarantees.
Transition: use 2026 as the testing year — the voluntary phase and Peppol Testbed exist precisely so ERPs can certify their flows before the deadline.
To be the pipe: apply for Slovak accreditation as a service provider — EU registered office, clean criminal record for the company and representatives, passed Peppol Testbed conformance, reliable sender/recipient identification, and capability to generate and submit TDDs to corner 5. That makes you a Peppol Access Point + Slovak Digital Postman, and then the backend genuinely pushes XML "directly" into the network. It's the only legal route to eliminating the third-party middleman.

Watch items between now and 2027: enactment status of LP/2026/282 (grace period + buyer-reporting deferral), the final corner-5/TDD technical specification (system projected live Q3 2026), and the growing accredited provider list — all published by the Financial Administration (financnasprava.sk, eFaktúra section).

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