Slovakia Refines Its 2027 E-Invoicing Mandate: Draft VAT Act Amendment Adds a Three-Month Grace Period and Eases Buyer-Side Obligations

On May 27, 2026, the Slovak Ministry of Finance submitted a draft amendment to the VAT Act to the interministerial comment procedure (legislative process LP/2026/282).

The draft fine-tunes the mandatory domestic e-invoicing and real-time digital reporting regime that takes effect on January 1, 2027, introducing a penalty-free tolerance period for the first three months of the mandate, easing selected buyer-side obligations, and clarifying the reporting of corrective invoices. The comment procedure has closed, and the submissions are currently being evaluated.

Background

Slovakia adopted one of the most ambitious e-invoicing reforms in the European Union. Under the VAT Act amendment approved by the government on September 24, 2025, and subsequently enacted (enacted as Law No. 385/2025 Coll.), VAT payers established in Slovakia must, from January 1, 2027, issue and receive structured electronic invoices for domestic supplies of goods and services, with invoice data transmitted automatically to the Financial Administration in near real time.

From July 1, 2030, the obligation extends to cross-border transactions in line with the EU VAT in the Digital Age (ViDA) package, and the domestic control statement and EC Sales List obligations will be abolished.

Slovakia has opted for a decentralized, Peppol-based delivery model (a five-corner model) in which certified delivery services (referred to locally as “digital postmen”) exchange e-invoices and report invoice data to the tax authority.

The Financial Administration has published and periodically updated the list of registered delivery services since January 2026 (with an update in March 2026), an important readiness milestone for businesses selecting their exchange channel. At the Peppol Conference Europe 2026 in Brussels, the Slovak model was noted for its high level of data reliability; this reflects favorable reception at an OpenPeppol event rather than a formal European Commission or OpenPeppol designation as a reference implementation.

The Legislative Change

Draft LP/2026/282 does not change the core architecture or the January 1, 2027 start date. Instead, it refines the rules based on experience from the ongoing technical implementation in Slovakia and other EU member states. With effect from January 1, 2027, the draft proposes:

• A tolerance (soft-landing) period covering the first three months of the mandate (January 1 to March 31, 2027), during which selected violations — such as late or incorrect issuance of an electronic invoice, or failure to report the required data in the prescribed scope or deadline — will not be sanctioned.
• Removal of the buyer’s obligation to report data from received electronic invoices transmitted through a delivery service. Because the exchange and reporting are fully automated, the data reported by the supplier is essentially identical to what the buyer would report.
• An exemption from the general obligation to be able to receive e-invoices via a delivery service for taxable persons that are not VAT payers, respecting invoices relating to VAT-exempt rental of real estate not included in business assets (the exemption does not apply if the person must be able to receive e-invoices for other supplies).
• Clarified rules for corrective invoices: the report must include all unchanged data from the original invoice together with the corrected data, as well as the sequential number of the original invoice.

With effect from July 1, 2030, the draft adds legislative-technical clarifications on when a simplified invoice cannot be issued, and provides that where a deadline for issuing an e-invoice or reporting invoice data falls on a Saturday, Sunday, or public holiday, the deadline moves to the next working day, in line with the Tax Procedure Code

Scope

The 2027 mandate covers VAT payers established in Slovakia for domestic supplies of goods and services. The obligation applies to supplies to other taxable persons and to non-taxable legal entities established in Slovakia — B2C supplies are excluded — and no turnover threshold applies, so all established VAT payers are covered regardless of size. The draft amendment primarily relieves buyers (whose separate reporting duty for e-invoices received through a delivery service is dropped) and non-VAT-payer taxable persons with limited exposure, such as landlords of exempt real estate held outside business assets. Suppliers remain fully responsible for issuing compliant structured e-invoices and for the automated reporting of invoice data.

Timeline

• May 27, 2026 – Draft amendment (LP/2026/282) submitted to the interministerial comment procedure; comments are now being evaluated.
• Second half of 2026 – Expected government approval and parliamentary passage.
• January 1, 2027 – Mandatory domestic e-invoicing and real-time data reporting take effect; proposed tolerance period runs through March 31, 2027.
• July 1, 2030 – Extension to cross-border transactions under ViDA; control statement and EC Sales List abolished.

Businesses Affected

All VAT payers established in Slovakia, including Slovak subsidiaries of multinational groups, are in scope from January 1, 2027. Foreign-established businesses with Slovak VAT registrations should monitor the legislative process closely, as the phasing for non-established VAT payers follows the ViDA framework. Accounting firms, shared service centers, and ERP teams supporting Slovak entities will need to reflect the revised buyer-side rules and corrective-invoice logic in their designs.

Required Actions

• Select and contract a registered delivery service (“digital postman”) from the Financial Administration’s published list, or verify that your ERP/e-invoicing provider offers a certified connection.
• Update implementation plans to reflect the proposed easing: buyers no longer need to build separate reporting flows for invoices received through a delivery service.
• Adjust corrective-invoice (credit/debit note) data mapping so that the full original invoice data, corrected fields, and the original invoice number can be reported.
• Do not treat the proposed three-month tolerance period as a postponement: e-invoice exchange must still function from January 1, 2027, since customers will expect compliant invoices.
• Track the outcome of the comment procedure and final adopted text before freezing system designs.

Practical Implications

The draft significantly reduces duplicate reporting and acknowledges the practical challenges of a large-scale ERP and process transformation. The tolerance period mirrors soft-landing approaches used in other member states (such as Poland’s KSeF penalty deferral) and gives businesses breathing room on sanctions without moving the go-live date. However, the mandate remains a fundamental change to order-to-cash and purchase-to-pay processes: invoice issuance becomes a controlled, real-time process, and master data or tax determination errors will surface immediately.

Expected Next Steps

The Ministry of Finance is evaluating the comments received. The amendment is expected to proceed to the government and parliament during 2026 so that the refined rules are in force before the January 1, 2027, start. Further technical documentation and testing guidance from the Financial Administration are expected in the second half of 2026.

How Can KGT Support You?

KGT specializes in SAP-integrated e-invoicing solutions for continuous transaction control regimes. KGT builds certified SAP add-ons where SAP Document and Reporting Compliance (SAP DRC) does not provide native coverage, and supports SAP DRC implementation, configuration, testing, and training end to end. If your organization needs to prepare SAP systems for Slovakia’s 2027 e-invoicing and real-time reporting mandate, we are happy to arrange a demonstration and answer your questions.

Official sources

• Slov-lex – Legislative process LP/2026/282 (draft VAT Act amendment) – View source
• Slovak Financial Administration – official portal (registered delivery services / eFaktúra) – View source

This publication is provided for general information purposes only and does not constitute tax, legal, or other professional advice.