Slovakia: The eFaktúra FAQ Is Reissued Again and the Peppol Provider Registers Reach 62 Certified Operators
Country Update — Slovakia | 25 August 2026 | Topic: E-Invoicing / Authority Guidance and Readiness
In the week of August 17, 2026 the Slovak Financial Administration issued two further readiness artifacts ahead of the mandatory e-invoicing regime that starts on January 1, 2027. On August 17, 2026 it reissued its official eFaktúra question-and-answer document, reference 9/DPH/2025/IM, now running to 48 pages. On August 25, 2026 it replaced the two registers of Peppol delivery-service providers, which now list 62 certified providers and a further 13 in accreditation.
Background
Slovakia's mandatory e-invoicing and e-reporting regime was enacted by Act 385/2025 Z.z., which amends the VAT Act (Act 222/2004 Z.z.). Domestic B2B and B2G invoicing becomes mandatory from January 1, 2027, with cross-border coverage — and the abolition of the control statement (kontrolný výkaz) and the EC sales list (súhrnný výkaz) — following on July 1, 2030. Slovakia has adopted a Peppol-based five-corner model, with the Financial Administration acting as the Peppol Authority of the Slovak Republic.
Rather than publishing a single consolidated guidance document, the Financial Administration is running a rolling FAQ. Reference 9/DPH/2025/IM has been reissued repeatedly through 2026 — 42 pages on May 25, 46 pages on June 12, 47 pages on July 7, and now 48 pages on August 17. Each reissue carries the same reference number, so the length and the date in the filename are the only external signals that the content has moved. That is an easy artifact to miss, and it is where several substantive official positions now live.
In parallel, the Financial Administration maintains two public registers of delivery-service providers: those certified to operate in the Slovak Peppol network, and those still in the accreditation process. Together with the regional conference programme opened on August 17, covered in our separate update, these registers are the principal readiness instruments Slovakia is putting in front of taxpayers before the 2027 start.
The Change
Neither item changes the law. Act 385/2025 Z.z. and the amended VAT Act remain as enacted, and no new deadline, threshold or penalty was introduced in August.
Both are nonetheless operative. The FAQ is the Financial Administration's own statement of how it reads the regime, and in a system where the taxpayer must map its data to EN 16931 and route it through an accredited provider, the authority's stated reading is the practical compliance standard. The provider registers are operative in a harder sense: only a provider that appears on the certified register can lawfully carry a Slovak e-invoice, so the register determines the feasible set of vendors.
Scope
The reissued FAQ is structured in two parts. Part I contains 74 numbered taxpayer scenarios. Part II, beginning at page 25, addresses ERP and accounting-software vendors and delivery-service providers — an unusual and welcome feature, since it puts the authority's expectations of the software supply chain in the same document as its expectations of taxpayers.
The core obligations restated in the document are: issue and send within 15 days; report the invoice data within 5 days of receipt by the Digitálny poštár; retain invoices for 10 years in XML; penalties of up to EUR 10,000, rising to up to EUR 100,000 for repeat breaches; a EUR 400 threshold for simplified invoices and eKasa receipts; and a EUR 100 threshold under section 74(3)(a) of the VAT Act.
The technical baseline restated is EN 16931, Peppol BIS Billing 3.0 in the November 2025 Release as amended by Hotfix 3.0.20 of February 23, 2026 — which is the release that permits PDF and image attachments — together with UBL 2.1, CII, AS4 transport, MDN and MLS acknowledgements, SMP and SML lookup, the participant identifier scheme 0245 based on the Slovak tax identification number (DIC), and the C1 to C5 corner model. The document also restates that ISO/IEC 27001 certification becomes mandatory for Peppol service providers from July 1, 2027.
Content clusters that are new or materially expanded relative to the earlier editions cover non-governmental organizations and entities holding only an ICO, municipalities and the G2G and B2G flows, self-billing (which carries its own technical code and a C4 to C3 to C2 routing), corrective invoices issued as a Credit Note carrying BT-25, and questions 71 to 74 on the registration of Slovak DIC identifiers in foreign SMPs.
The provider registers were refreshed twice in the same week. The versions published on August 21, 2026 listed 61 certified delivery-service providers and 14 in accreditation. Those files were then withdrawn and replaced on August 25, 2026 by a renamed pair listing 62 certified providers, with contiguous identifiers EFSK000001 to EFSK000062, and 13 in accreditation.
The single movement between the two versions is a graduation rather than a new entrant: TP SOFT, s.r.o. left the accreditation list and was certified as EFSK000062. The certified list includes SAP SE (EFSK000040), Comarch, Pagero, EDICOM, ecosio, Odoo and AWS EMEA; the accreditation pipeline includes NTT DATA Business Solutions, compacer, Montova and Unimaze SK. The Financial Administration notes on both files that the lists are updated continuously.
Timeline
- May 25, June 12 and July 7, 2026 — successive editions of FAQ 9/DPH/2025/IM at 42, 46 and 47 pages.
- August 17, 2026 — FAQ 9/DPH/2025/IM reissued at 48 pages.
- August 21, 2026 — certified and in-accreditation Peppol delivery-service provider registers updated (61 and 14); these files were subsequently withdrawn.
- August 25, 2026 — both registers replaced under new filenames, listing 62 certified providers and 13 in accreditation.
- Through 2026 — transitional period; the FAQ describes it as running from January 1, 2026 to December 31, 2026 in one answer and “to January 1, 2027” in another, an internal inconsistency taxpayers should not rely on either way.
- Q3 2026 — planned go-live of C2 to C5 reporting, per the FAQ.
- Autumn 2026 — assignment of DIC numbers to entities that currently hold only an ICO.
- January 1, 2027 — mandatory domestic B2B and B2G e-invoicing and reporting.
- July 1, 2027 — ISO/IEC 27001 certification mandatory for Peppol service providers.
- July 1, 2030 — cross-border coverage; control statement and EC sales list abolished.
Businesses Affected
All VAT-registered businesses making domestic supplies in Slovakia are in scope from January 1, 2027, including foreign-established businesses with a Slovak VAT registration. The August reissue is particularly relevant to three groups that the earlier editions addressed thinly: non-governmental organizations and other entities that hold an ICO but no DIC and will therefore be assigned one; municipalities and public bodies dealing with G2G and B2G flows; and any business using self-billing, where the technical treatment differs from ordinary invoicing.
Software vendors and shared-service centers are addressed directly by Part II and should read it as a specification of what the Financial Administration expects their products to do.
Required Actions
- Replace any earlier copy of FAQ 9/DPH/2025/IM in your compliance file with the August 17, 2026, 48-page edition, and diff it against the July 7 edition rather than assuming continuity. The shared reference number makes silent supersession the normal case here.
- Confirm that your chosen delivery-service provider appears on the current certified register of August 25, 2026 and note its EFSK identifier. Do not rely on a saved copy of the August 21 files; they were withdrawn and replaced under different filenames within four days. If it appears only on the accreditation list, obtain its expected certification date and plan a fallback.
- Where you use self-billing, model the C4 to C3 to C2 routing and the separate technical code explicitly — it is not a variant of the standard outbound flow.
- Confirm your correction process issues a Credit Note carrying BT-25 rather than any locally conventional credit-memo form.
- Validate your build against Peppol BIS Billing 3.November 0, 2025 Release Hotfix 3.0.20 of February 23, 2026, not against an earlier hotfix, and confirm your provider's ISO/IEC 27001 roadmap against the July 1, 2027 date.
- Confirm the 10-year retention is satisfied in XML. Retaining a PDF rendering is not compliance with this requirement.
- If your Slovak entity holds only an ICO today, track the DIC assignment expected during autumn 2026 — the participant identifier scheme is 0245 based on the DIC, so the identifier is a prerequisite for network registration.
Practical Implications
The most consequential feature of the Slovak approach is that the authority is legislating once and clarifying continuously. A 48-page rolling FAQ under a fixed reference number is a genuinely useful document, but it is a poor fit for corporate change control: there is no version number, no change log, and no notification. Groups should treat each reissue as a controlled document event, capture the dated PDF, and record the diff.
The internal inconsistency on the transitional period — one answer ending it on December 31, 2026, another referring to January 1, 2027 — is trivial in substance and instructive in kind. It illustrates why a rolling FAQ should inform a design decision but should not be the sole authority for one; where a date matters, the amended VAT Act text is what governs.
On the provider side, 62 certified operators fifteen months before the mandate is a healthy market, and the presence of SAP SE on the certified register simplifies the architecture question for SAP-based groups considerably. The 13 providers still in accreditation are worth monitoring: a group that has already signed with one of them has a real, dated dependency. The registers also show why they must be cited by filename date rather than by saved copy: neither PDF dates itself internally, and the August 21 pair was removed from the portal within four days.
Finally, the emphasis in Part II on ERP vendors signals where the Financial Administration expects failures to originate. The Slovak model asks the taxpayer for accurate EN 16931 semantic mapping, not merely for a valid file. Mapping errors that survive schema validation — wrong tax categories, wrong document-type codes, missing BT-25 on corrections — are the defects that will surface as rejections after January 1, 2027.
Expected Next Steps
Further reissues of FAQ 9/DPH/2025/IM should be expected roughly monthly through 2026, and the provider registers are updated continuously. The next substantive milestones are the C2 to C5 reporting go-live planned for the third quarter of 2026, the DIC assignment exercise during the autumn, and the regional conference programme running from September 7 to 30, 2026.
How Can KGT Support You?
KGT is a specialist indirect tax technology firm working exclusively inside the SAP landscape. We deliver SAP-integrated e-invoicing add-ons for countries where a local mandate outpaces the standard SAP roadmap, and we implement and run SAP Document and Reporting Compliance (SAP DRC) where the standard solution is the right answer. Because we build and operate both, our advice on which route to take for a given country is not a sales position.
For the development described above, KGT typically helps clients in four ways: assessing the impact on the existing SAP configuration and interface build; carrying out the mapping and regression work against the current official specification version; managing the platform, provider or registration dependency; and running the resulting flows as a managed service, so that each release, schema version and validation change is absorbed for you rather than by you. To discuss what this means for your SAP landscape, contact KGT at
This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.
