eInvoicing Documentation
eInvoicing in Slovakia
Legislation
Act No. 2015/2019 on Guaranteed Electronic Invoicing and the Central Economic System is in force from 01 August 2019. The Act specifies the requirements of eInvoicing for public administrations and their suppliers. This includes that central and sub-central authorities are obliged to accept eInvoices compliant with the European eInvoicing standard [1].
The law above covers the transposition as stated in article 11(1) of Directive 2014/55/EU, however, eInvoicing is not yet fully implemented. The obligations of the entities involved in eInvoicing will be introduced incrementally, according to the readiness of the eInvoicing platform called Information System for Electronic Invoicing (IS EFA)[2]. The IS EFA is expected to be rolled out by the end of 2024 [3].
The use of eInvoicing in Business-to-Business transactions is currently on a voluntary basis.
In February 2021, the Ministry of Finance in Slovakia revealed a new draft law on sending invoice data to the Financial Administration. According to the authorities’ preliminary statements, the aim is to introduce real-time invoice reporting that is supposed to be gradually mandatory for all commercial transactions (including B2B).
A public consultation on the above-mentioned measure was conducted until the end of March 2021. The proposal has been stalled and is expected to undergo a new public consultation. The new proposal is expected to take into account the EU VAT in the Digital Age legislative proposal.
eInvoicing platform and eInvoicing management solutions
Currently, there is still no eInvoicing platform for public procurement in Slovakia. The Ministry of Finance has prepared the final concept of a centralised eInvoicing solution.
The financing of the related national project from the European funding has been approved in December 2019. Entities involved in eInvoicing will receive their profiles in the online billing system. For the purpose of receiving guaranteed eInvoices, this system will be linked to the existing official e-mailbox system (slovensko.sk)[4].
The public procurement process for the delivery of an eInvoicing solution to ensure full transposition of eInvoicing Directive is planned by July 2022. The roll out of the IS EFA has been marked by delays and is currently foreseen to be implemented by the end of 2024.
Approach for receiving and processing eInvoices
The main goal of the centralised solution implementation is to ensure the mandatory receiving and sending of eInvoices and to enable automatic processing compliant with the European eInvoicing standard. The solution will provide also support for public finance management, as a side effect. The implementation will consist of the following three stages:
- Stage I – Mandatory receiving of eInvoices for contracting entities and voluntary sending of eInvoices for their suppliers.
- Stage II - Mandatory receiving of eInvoices for both, public contracting authorities and public contracting entities - after the completion of Stage II, full transposition of the eInvoicing Directive in public procurement will be ensured.
- Stage III - Mandatory receiving and sending of eInvoices for all contracting authorities, contracting entities and for their suppliers - automatic processing and system to system communication will be available.
Neither of the three stages have been implemented yet. To expedite the roll out, the government is considering simultaneous implementation of all three stages.
Entities involved in eInvoicing will receive their profiles in the online billing system. As mentioned above, the system will be linked to the existing official e-mailbox system (slovensko.sk).
The e-billing system will be similar to the existing system of “e-kasa”, i.e. the financial administration centralised system to which all stakeholders in Slovakia are connected[5].
eInvoicing implementation in sub-central level contracting authorities
A central billing system can be used upon agreement with the parts involved in the eInvoice transactions. The date, terms and conditions under which the system will be available to regular businesses will be determined by the Ministry of Finance. The ministry announced back in 2019 that the participation of voluntary participants in the billing system is not expected earlier than 2 years after the new Act came into effect. Nevertheless, due to delays the implementation of the system is yet to take place.
The centralised eInvoicing platform, Information System for Electronic Invoicing (IS EFA), will allow the implementation of eInvoicing according to the Directive 2014/55/EU in both central and sub-central level contracting authorities.
Status on the implementation of the European Standard on eInvoicing (EN)
The EN will be implemented by using the centralised eInvoicing solution (IS EFA) after finishing Stage II, as mentioned above. It is forecasted to be fully introduced in 2024.
Use of Core Invoicing Usage Specifications (CIUS) at national level
Today, there is no CIUS implemented at the national level yet. The implementation of CIUS will be analysed before the implementation of the eInvoicing solution.
The specifications followed by eInvoice content will be compliant with the European technical standard (OASIS UBL 2.1 or UN / CEFACT)[6].
Use of Core Invoicing Usage Specifications (CIUS) at national level
Today, there is no CIUS implemented at the national level yet. The implementation of CIUS will be analysed before the implementation of the eInvoicing solution.
The specifications followed by eInvoice content will be compliant with the European technical standard (OASIS UBL 2.1 or UN / CEFACT)[7].
Digital reporting requirements
Slovakia has introduced the obligation to submit electronically detailed transactional data (VAT Control Statement) jointly with the VAT return as of January 2014. Before its introduction, there was no other reporting requirement in place. The obligation to submit the VAT Control Statement applies to all taxable person registered in Slovakia for VAT, including non-resident businesses. The reporting frequency is monthly or quarterly (i.e. the frequency of the VAT return) [8].
The information must be reported on a transaction-by-transaction basis, with the exception of simplified invoices received, which must be reported in an aggregated form if the total amount of tax deductions from these invoices is below EUR 3 000 per reporting period. The data must be submitted using the XML format, either through the tax authority’s portal or using the downloadable form-filling program (eDane) distributed by the tax authority [9].
The aforementioned draft law from 2021 foresees real-time eInvoicing and digital reporting for all commercial transactions. To facilitate the transition towards real-time reporting, the government is planning to develop a software and mobile application called Virtual Invoice (Virtuálna faktúra) which will be free of charge. However, the draft law is yet to be adopted by the Parliament and no concreate measures in developing the Virtual Invoice have begun.
The scope of requirements in a VAT Control Statement are as follows:
- All transactions regardless of their value (i.e. there is no threshold). However, simplified invoices received with a total amount of tax deductions lower than EUR 3 000 must be reported in an aggregated form.
- B2B, B2G and B2C.
- Sales and purchases.
- Domestic and Intra-EU transactions.
The invoice information to be submitted in a VAT Control Statement include the following:
- Invoice date and Invoice number
- Type of transaction, tax rate, total amount, VAT amount payable and trading partner VAT number
Additional information
The eInvoicing solution IS EFA will provide support for the public finance and cash-flow management, budgeting and reporting, besides its core functionality.
The Ministry of Finance has been facilitating meetings, workshops and presentations on eInvoicing to encourage the uptake of eInvoicing at the central and the sub-central levels.
The Slovak Ministry of Finance (MoF) is continuing with the e-invoicing initiative, informačný systém elektronickej fakturácie. The proposed e-invoicing system would support both the issuance and receipt of e-invoices for domestic transactions and help foreign suppliers to create structured invoices which can be sent via an e-mail. The system would use UBL 2.1 along with an XML format and is aimed to reduce compliance burden and increase transparency.
The Ministry of Finance further launched a new website containing information regarding the e-invoicing initiative as well as a demo system which is open to all for testing and improvement before the live implementation.
[1](Electronic Invoicing Information System, 2024), [2] (Národný ystem: Informačný ystem elektronickej fakturácie (IS EFA)), [3] (Informácia o verejnom pripomienkovaní štúdie uskutočniteľnosti pre národný projekt Informačný systém elektronickej fakturácie), [4] (9 Things you need to know about new «guaranteed» e-invoicing), [5] (Financial Administration Slovak Republic), [6] (9 Things you need to know about new «guaranteed» e-invoicing), [7] (9 Things you need to know about new «guaranteed» e-invoicing), [8] (Financial Administration Slovak Republic), [9] (Financial Administration Slovak Republic)
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