Slovakia's Financial Directorate, part of the Financial Administration of the Slovak Republic, updated its eFaktúra FAQ in August 2026 with practical clarifications for businesses and service providers. The update also introduces a new section clarifying Peppol VAT Category Codes and VAT Exemption Reason Codes (VATEX) applicable in Slovakia ahead of the domestic e-invoicing mandate effective January 1, 2027. Key updates include:
Invoice timing and the date an e-invoice is considered issued
For an e-invoice to be considered issued on time, it must be sent to or made available to the customer within the statutory 15-day period, not simply created in the accounting system. For Peppol delivery, the invoice is considered issued when it is submitted to the service provider. For other delivery methods, it is considered issued when the invoice is sent or made available to the recipient.
Recipient not registered in Peppol and VAT deduction
If the supplier submits the e-invoice to its Accredited Service Provider within the statutory deadline but the recipient is not registered in Peppol to receive it, the supplier has fulfilled its issuance obligation. Where delivery via Peppol was not possible, the same invoice may subsequently be sent by email. The FAQ takes the view that this constitutes further disclosure rather than a new issuance, noting that the law does not expressly address this scenario.
Consent is required for e-invoice exchange outside the Peppol network through alternative means. The recipient may still claim input VAT deduction if it holds a valid e-invoice compliant with Article 85o of the VAT Act and all other VAT deduction conditions are met.
Factoring
If factoring is known at the time of issuance, the invoice may include factor and payment details as well as assignment information, using either invoice type code 380 or factoring invoice type code 393. Type 393 is optional, not mandatory. If assignment occurs after issuance, no replacement or corrective e-invoice is required solely for that reason. The customer should instead be notified separately.
VAT group internal transactions
Supplies between members of the same VAT group are treated as internal supplies within a single taxable person for VAT purposes. They are not considered a supply of goods or services subject to VAT, and no invoice obligation under the VAT Act arises. Accordingly, there is no obligation to exchange such documents via Peppol, though doing so voluntarily is permitted. Each member's unique tax identification number (DIČ) should be used as the EndpointID/Participant ID for routing. VAT category O (Not subject to VAT) applies. Under Peppol rule BR-O-02, seller and buyer VAT IDs must not appear on an invoice using category O. The VAT-law consent rule for sending mandatory e-invoices outside Peppol does not apply to these internal documents.
Self-billing reporting deadline and clarification
Under the latest version of the draft law, customers will continue to be permitted to issue self-billed invoices, provided the existing written agreement conditions are met. The FAQ also clarifies that the five-day deadline for reporting e-invoice data applies specifically to self-billed invoices and runs from the invoice issue date or, where applicable, from the expiry of the invoice-issuance deadline. This accounts for the fact that the supplier may not immediately be aware that the customer has issued the invoice.
New VAT category code and VATEX mapping section
A new Slovakia-specific mapping guide for Peppol VAT categories and VATEX exemption and special-regime codes has been introduced. The guidance clarifies that VAT treatment must be selected based on the applicable legal VAT regime, not simply on whether the VAT amount is zero. The categories are as follows:
- Standard rate (S): Taxable domestic supplies, including invoices subject to the 23%, 19%, or 5% VAT rates;
- Exempt from tax (E): Domestic VAT-exempt supplies, including postal, health, social welfare, education, membership, sports, cultural, insurance, financial, and certain real-estate supplies;
- Intra-community supply (K): VAT-exempt supplies of goods from Slovakia to another EU member state;
- Export outside the EU (G): VAT-exempt exports of goods to destinations outside the EU;
- Reverse charge (AE): Transactions subject to the reverse-charge mechanism, where the customer accounts for the VAT;
- Not subject to VAT (O): Transactions that fall outside the scope of VAT, including certain internal transactions between members of the same Slovak VAT group; and
- Zero-rated goods (Z): Use only where Slovak legislation provides for a genuine 0% VAT rate. A VAT amount of zero EUR is not, on its own, sufficient to determine that category Z applies.
The FAQ recommends using the applicable VATEX code in business term BT-121 and, where necessary, adding explanatory text in BT-120 of the structured e-invoice. It also provides examples of Slovakia-specific mappings, showing the relevant VAT category and VATEX codes.
