Czech Republic: EET 2.0 Becomes Law (Act 180/2026 Coll.) and the Real-Time Sales Reporting Regime Starts on 1 January 2027

KGT Country Update  |  Czech Republic  |  30 October 2026

The Czech Collection of Laws published Act No. 180/2026 Coll., on the recording of sales (the "EET 2.0" Act), in the week of 5 to 11 October 2026; the Collection entry is dated 7 October and the Financial Administration reported the publication on 15 October. The Act was passed by the Chamber of Deputies on 9 September 2026, when it overrode the Senate's proposed amendments, and was signed by the President on 17 September 2026.

It restores a real-time sales reporting regime for Czech income taxpayers receiving payments in personal contact with customers, with general entry into force on 1 January 2027. The Financial Administration (Finanční správa) has already published the technical interface, a test environment and methodological material, so the work for point-of-sale and ERP vendors is under way now.

Background

The original Czech electronic sales recording (EET) was introduced in 2016, suspended in 2020 and later abolished. The new bill entered first reading in the Chamber of Deputies on 2 June 2026, was approved in third reading on 15 July 2026 and was finally adopted on 9 September 2026. In parallel, the Financial Administration launched the official eet.gov.cz portal and an information line on 2 September 2026, published technical documentation for point-of-sale developers on 5 June 2026, and opened a Playground test environment on 1 July 2026.

Between 26 July and 26 August 2026 the Playground processed 170,389 test transactions with a 94.6% success rate, according to the Financial Administration (3 September 2026).

This is a sales-transaction reporting regime rather than a VAT return or e-invoicing mandate. It matters to VAT and indirect tax teams because it is a new real-time data flow to the tax authority from point of sale, and retail, hospitality, travel and services groups with Czech outlets will have to integrate their cash registers and POS estates with it.

The Legislative Change

Act No. 180/2026 Coll. (zákon o evidenci tržeb a o změně některých dalších zákonů) is dated 9 September 2026. Under § 36 it enters into force on 1 January 2027, subject to specific provisions that apply earlier. Under the transitional rule in § 29, the certificate-related provisions (§§ 14, 15 and 18) apply from 1 November 2026 at the earliest, which is why taxpayers can prepare their registrations and certificates before the regime starts. The key provisions, as read in the published text, are:

• Who: income taxpayers, both individuals and legal entities, must record sales made in the Czech Republic (§ 2).
• What: a recorded sale is a payment that meets the formal requirements and creates taxable business income (§§ 4 to 5). The regime is built around "contact payments", meaning payments received in personal contact with the payer or at the taxpayer's premises or vehicle in connection with supplying goods or services (§ 6). Fully remote payments without personal contact are outside the regime according to the Ministry of Finance.
• Data: each sale triggers an authenticated XML data message containing the taxpayer's identifier, the identifier of the evidence unit and cash register, a sequential number, the date and time of the sale, the total amount in CZK and a message identifier; additional amounts apply to prepayments, deferred settlements and sales through an agent (§ 17). Individual items and VAT are not reported in the data message.
• Timing: sales must be reported when they occur. The cash register response-time limit is set by the taxpayer and must be at least two seconds; if it is exceeded or the connection fails, the data must be sent without delay once the cause ends and in any case within 48 hours of the sale (§§ 16, 19 and 20).
• Certificates and registration: before the first recorded sale the taxpayer must report its evidence units and obtain the required certificates through its tax data mailbox (§§ 14 and 15). Taxpayers must protect certificates against misuse and report actual or threatened misuse without undue delay.
• Exemptions: the Act exempts, among others, the State and public bodies, banks and other financial institutions, certain disabled taxpayers, vending machines and certain self-service devices, and a list of subject-matter exemptions (§§ 11 to 13). A voluntary "EET OFF" route is available to the smallest flat-rate taxpayers in the first band (annual income up to CZK 1 million) who pay an increased monthly flat-rate amount, as set out in the Ministry of Finance brochure of 9 September 2026.
• Penalties: the Act provides fines of up to CZK 500,000 for seriously hindering the recording of sales and for failing to send the data message (§§ 23 and 24). The Financial Administration has said that the first phase focuses on support, methodology and a pilot rather than sanctions; the exact length of any penalty-free period should be confirmed against the Financial Administration's guidance.

Provisional: We read the Act text through a copy of the Collection of Laws entry and could not open the official e-Sbírka text. The section numbers and the penalty amounts above should be confirmed against e-Sbírka before this item is relied on for compliance decisions. Public commentary is not fully consistent on the treatment of vouchers, cheques and virtual assets and on whether sales on payment cards are recorded; confirm the scope for each of your payment methods against the Act and the Financial Administration's methodology.

Scope

The regime covers in-person (contact) sales by Czech income taxpayers, not remote sales via e-shops, payment gateways or bank transfers made without personal contact. It applies to legal entities as well as individuals. Foreign groups that sell in the Czech Republic through a branch, permanent establishment or locally registered subsidiary with shops, restaurants, service points or mobile sales fall within scope for those sales. Sales already recorded under a foreign law of a state with which the Czech Republic has an information-exchange treaty are excluded (§ 28).

Timeline

Technical Specification (Operates within the Legal Framework)

The technical material is not itself legislation; it implements the Act and operates within it. It is nonetheless binding in practice, because a cash register that cannot authenticate and submit a message in the prescribed format is rejected by the production service. The Financial Administration has published the following:

• Implemented interface version 4.1 (SOAP, EETServiceSOAP/v4). The Playground access and operating document is version 1.1 dated 30 June 2026 and the production document is version 1.1 dated 10 July 2026.
• Production access is via DNS name only; systems must respect the DNS TTL and re-resolve when opening new connections. HTTPS with TLS 1.2 or higher is mandatory, and the production endpoint uses an extended-validation TLS certificate from DigiCert. The specific certificate may change, so clients should validate the trusted CA, EV type and domain rather than pin a certificate.
• Cash register certificates are issued by EET CA 2 (RSA 2048, 366-day validity) under a sub-CA with four-year validity. Because of the 366-day validity, certificate renewal needs to be built into POS operations.
• The maintenance window is usually Thursday from 20:00 to 06:00; production targets 24x7 operation. On 15 October 2026 the Financial Administration published a methodological document explaining the data message items with filled-in examples.

Businesses Affected

Retail, hospitality, leisure, fuel and convenience, travel, health and beauty and other consumer-facing businesses with Czech points of sale; POS, ERP and cash register vendors; payment service providers and acquirers that supply integrated terminals; and franchisors that need uniform compliance across franchisees.

Required Actions

• Confirm whether each Czech legal entity and sales channel is a contact-payment sale in scope or falls under an exemption, and document the conclusion.
• Ask POS and cash register vendors for their EET 2.0 roadmap against interface version 4.1 and test in the Playground environment well before 1 January 2027.
• Prepare registration of evidence units and certificate issuance through the tax data mailbox, assign ownership for certificate renewal, and set up monitoring for the 48-hour fallback rule.
• Reconcile the new transaction flow with the sales data feeding Czech VAT reporting in SAP, so that EET messages, receipts and ledger postings tell the same story.

Practical Implications

Because every contact sale is reported when it occurs, differences between till data, the general ledger and VAT reporting become visible to the authority almost immediately. Offline operation and the 48-hour fallback are operational controls, not legal safe harbors for chronic delay. Multi-site groups should expect that rollout is a project spanning vendors, store operations and finance, not a tax-department filing change.

Expected Next Steps

• Further Financial Administration methodology, the free web application for the smallest businesses and the roadshow of information seminars are expected before the start date.
• Clarification of the penalty-free or pilot period, which the Financial Administration describes as a support-focused first phase.
• Possible further revisions to the technical documents and interface versions as vendors complete testing.

How Can KGT Support You?

KGT supports multinationals with SAP-integrated e-invoicing add-ons and SAP Document and Reporting Compliance (DRC) services. We can assess how Czech EET 2.0 interacts with your SAP billing, point-of-sale and VAT reporting landscape, define the integration and testing approach, and coordinate with your POS vendors and local advisers. Contact KGT to discuss your readiness for 1 January 2027.

This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.