Slovakia: eFaktura FAQ Reissued with VAT Category Code Mapping, and the Certified Provider Register Reaches 74

KGT Country Update  |  21 September 2026  |  VAT, e-invoicing and SAF-T monitor

In the week of 15 to 18 September 2026 the Financial Administration of the Slovak Republic reissued its eFaktura questions and answers document, reference 9/DPH/2025/IM, and refreshed three related registration artifacts ahead of the mandatory electronic invoicing regime that takes effect on 1 January 2027.

The reissued FAQ, dated 15 September 2026, runs to 59 pages and adds a new Part III on VAT category codes and VATEX exemption reason codes mapped to Slovak conditions. The register of certified delivery service providers, refreshed on 18 September 2026, now lists 74 accredited providers.

New application forms for access to the Service Metadata Publisher and for registration in the list of intermediaries were issued on 17 September 2026.

Background

Slovakia's mandatory electronic invoicing regime rests on Act No. 385/2025 Coll., which amends Act No. 222/2004 Coll. on value added tax. Section 76a of the amended VAT Act requires the European delivery standard, and the Financial Administration has confirmed that the standard meeting this requirement is the OpenPeppol AISBL standard.

The legislation took legal effect on 1 January 2026 and becomes operative on 1 January 2027. Methodical guidance 7/DPH/2025/I of 29 December 2025 covers the provisions effective from 1 January 2026, and methodical guidance 1/DPH/2026/I of 14 January 2026 covers those effective from 1 January 2027 and 1 July 2030.

The obligation to receive electronic invoices applies to all legal persons and entrepreneurs that are taxable persons under Slovak law, including sole traders, the liberal professions, self-employed farmers and landlords. Receiving invoices requires a contract with a certified delivery service provider.

KGT has reported this program repeatedly through 2026: the Peppol model and its EU recognition on 6 July, the draft VAT amendment on 9 July, the ex officio allocation of tax numbers on 11 August, the regional conference program on 17 August, the FAQ reissue and the Peppol registers at 62 certified operators on 25 August, and the step-by-step manual on 4 September.

This update concerns the September artifacts, which change the FAQ's content and the register's composition rather than restating them.

The Legislative Change

There is no legislative change. Everything reported here operates within the framework already enacted by Act No. 385/2025 Coll. and within the Peppol accreditation scheme of the Slovak Peppol Authority. It is set out here because in a network-based mandate the binding constraints are frequently not statutory.

A certified delivery service provider not on the register cannot deliver. An invoice that fails the transposed Peppol BIS validation rules is rejected at the network layer, not penalised after the event. An incorrect VAT category code produces a rejection or misstated tax treatment, regardless of what the VAT Act says.

The FAQ, the register and the transposition workbook are therefore operationally binding in a way that a guidance document in a post-audit jurisdiction is not, and the practical consequence of ignoring them is that invoices do not arrive.

The most substantive September change is inside the FAQ. The 15 September 2026 issue of 9/DPH/2025/IM introduces a new Part III, Rules for the VAT category code and VATEX basic mapping for Slovak conditions, starting on page 57, alongside the existing Part II addressed to software and ERP vendors and delivery service providers, starting on page 33.

Part III addresses the single field that causes more Peppol rejections than any other. The VAT category code and the VATEX exemption reason code determine how a line is treated for VAT, and their correct selection for Slovak domestic and cross-border scenarios is a mapping exercise that has to be performed in the sending system, not in the network. Publishing an authority-endorsed mapping removes a material source of ambiguity for ERP configuration.

The FAQ has grown steadily as the mandate approaches: 48 pages on 17 August 2026, 51 to 53 pages on 26 August, 57 pages on 11 September and 59 pages with more than 81 numbered worked examples on 15 September.

The document carries no printed issue date; the date is established by the Financial Administration's own file path and by the link live on the eFaktura page.

Scope

The FAQ addresses all Slovak taxable persons, and Parts II and III address software vendors, ERP providers and certified delivery service providers specifically.

The certified provider register and the accreditation list address businesses selecting a provider, and the providers themselves. The Service Metadata Publisher access form and the intermediary registration form address providers and intermediaries, not end users.

The Peppol BIS transposition workbook addresses anyone building or configuring an invoice-generating system for Slovakia.

Timeline

• 8 September 2026 user guide for selecting a delivery service provider, version 05, published.
• 10 September 2026 Peppol BIS transposition workbook for Slovak conditions updated to version 1.11, published 11 September 2026.
• 15 September 2026 eFaktura FAQ 9/DPH/2025/IM reissued, 59 pages, adding Part III on VAT category codes and VATEX.
• 17 September 2026 new versions of the application for access to the Service Metadata Publisher and the application for registration of an entity in the list of delivery service intermediaries, issued in Slovak and English.
• 18 September 2026: register of certified delivery service providers refreshed, listing 74 providers with identifiers EFSK000001 to EFSK000074; the list of providers in the accreditation process refreshed on the same date.
• 1 January 2027 the electronic invoicing legislation becomes operative.

Businesses Affected

Every Slovak taxable person is within scope of the receiving obligation from 1 January 2027, which includes group entities that have no Slovak sales but do have Slovak purchases. Multinationals frequently discover this population late, because a dormant or purchasing-only entity does not appear in a sales-side scoping exercise.

Groups that have already selected a provider should note that the register has grown from 62 certified operators in late August to 74 on 18 September. The additions include providers of the kind a large SAP estate would consider  the register lists, among others, SAP SE at EFSK000040, together with Odoo, Comarch, Pagero, EDICOM, ecosio, Unimaze, Avalara, the large accounting networks and AWS EMEA. A group that concluded in July or August that no suitable provider was accredited should revisit that conclusion.

ERP and software teams are the audience for the new FAQ Part III and for the transposition workbook version 1.11.

Required Actions

• Re-read the FAQ rather than assuming the August issue is current. The document has gained eleven pages and a new part in three weeks, and the new part addresses field-level configuration.
• Map the VAT category code and VATEX codes for every Slovak billing scenario against Part III of the FAQ, and validate the mapping against transposition workbook version 1.11 before the first test transmission. This is the single highest-yield piece of preparation available today.
• Confirm the provider selection against the 18 September register. Where a provider was chosen in the summer, verify that it still appears, that it appears in the certified register rather than the accreditation list, and that its identifier is recorded.
• Check that any intermediary arrangement uses the 17 September versions of the Service Metadata Publisher access form and the intermediary registration form. Superseded forms are a common cause of avoidable delay in accreditation processes.
• Complete the receiving-side scoping. Identify every Slovak-registered group entity, including purchasing-only and dormant entities, and confirm that each has a route to receive from 1 January 2027.
• Use the remaining months of 2026 for testing. The Slovak testbed suites for billing and self-billing are published and available, and the window between now and January is the only period in which failures are free.

Practical Implications

The pattern in Slovakia this month is characteristic of a mandate approaching go-live: the legislation stopped moving in January and the operational artifacts started moving weekly. Four separate documents changed in four days. A business monitoring Slovakia at the level of legislative change would have seen nothing in September; a business monitoring the Financial Administration's eFaktura page would have seen a new FAQ, a new register, new forms, and a new transposition workbook.

The addition of Part III on VAT category codes has the most direct effect on an SAP implementation. In a Peppol mandate the VAT category code is where accounting reality meets network validation, and it is derived in the sending system from tax codes, tax procedures and item-level determination.

Getting it wrong does not produce a late filing; it produces a rejected document and, in the worst case, an invoice the customer never receives and a receivable that ages without anyone understanding why. An authority-endorsed mapping published three and a half months before go-live is exactly the artifact an ERP team needs, and it should be treated as a configuration input rather than as reading material.

The register's growth from 62 to 74 providers in three weeks is also worth reading carefully. It indicates that accreditation is proceeding at pace and that the market will be adequately served by January, which was a legitimate concern earlier in the year. It also means that contracting decisions made on a thin field should be revisited.

The wider point for multinationals is that Slovakia has chosen the Peppol network model rather than a central clearance platform. That has two consequences. Failures are silent from the tax authority's point of view: nothing is rejected by the state, so nothing generates a state notification and the controlling relationship is contractual, with a provider, rather than administrative, with the authority.

Governance of that provider relationship, including what happens on outage and who holds the delivery logs, belongs in the implementation scope and not in the procurement footnotes. Certified providers are required to retain delivery and receipt logs for a minimum of six months.

Expected Next Steps

On the cadence observed since August, a further reissue of the FAQ can be expected in October, and the certified provider register will continue to be refreshed as accreditations complete. The transposition workbook is the artifact to monitor for validation rule changes; version 1.11 is current.

The Financial Administration has also been running a conference and webinar programme through the autumn. Recordings and presentations are published on its eFaktura pages and on its training portal.

KGT will report subsequent FAQ issues where they change a position of substance, and will report validation rule changes in the transposition workbook as they occur.

How Can KGT Support You?

KGT delivers SAP-integrated electronic invoicing and statutory reporting. For Slovakia the work is the mapping and the network integration: deriving a correct Peppol BIS document, including the VAT category code and VATEX codes, from SAP billing data, connecting to a certified delivery service provider, and reconciling the delivery acknowledgement back to the SAP document so that the compliance record and the accounting record cannot drift apart.

Our SAP add-on handles the document generation and the provider interface, and extends standard SAP determination where the condition technique cannot express a required rule. For clients running SAP Document and Reporting Compliance we support scoping, configuration, country activation and provider governance, and we advise even-handedly on whether an add-on or a DRC country version is the better fit for a given landscape and release calendar. We also run receiving-side scoping exercises, which in Slovakia is where multinationals most often find entities they had not counted.

This country update is provided for general information only and does not constitute tax, legal or professional advice.