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Legislation

Act No. 2015/2019 on Guaranteed Electronic Invoicing and the Central Economic System is in force from 01 August 2019. The act specifies regulation for the requirements of eInvoicing for public administrations and their suppliers. They are obliged to use eInvoicing if the invoice amount issues by a public supplier is higher than EUR 5,000[1].

The use of eInvoicing in Slovakia, in the private sector, is allowed on a voluntary basis.

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].

In February 2021, the Ministry of Finance in Slovakia revealed a new draft law[3] 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 mandatory for all transactions (i.e. including B2B too) over time.

A public consultation on the above-mentioned measure was conducted until the end of March 2021. Preliminarily, the validity of the law is proposed at the beginning of 2022. Subsequently, there will be room for testing technical solutions. The latest date for the start of live operations can be expected in January 2023[4].

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 (A prototype of product is available on https://dev.einvoice.mfsr.sk/).

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)^[5].

The public procurement process for the delivery of an eInvoicing solution to ensure full transposition of eInvoicing Directive is planned by July 2022.

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 EN. The solution will provide also support for public finance management, as a side effect. The implementation will consist of the following three stages⁵:

1. Stage I – Mandatory receiving of eInvoices for contracting entities and voluntary sending of eInvoices for their suppliers (planned 10 months).
2. Stage II - Mandatory receiving of eInvoices for both, public contracting authorities and public contracting entities (planned 10 months) - after the completion of Stage II, full transposition of the eInvoicing Directive in public procurement will be ensured.
3. Stage III - Mandatory receiving and sending of eInvoices for all contracting authorities, contracting entities and for their suppliers (planned 10 months) - automatic processing and system to system communication will be available.

Entities involved in eInvoicing will receive their profiles in the online billing system. As abovementioned, 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[6].

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. It can therefore be assumed that the opening of the system could take place in the summer of 2021[3].

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. Therefore, it is forecasted to be fully introduced on July 2022 [3].

Monitoring eInvoicing implementation

Currently, there is neither a system nor an initiative in place to monitor eInvoicing implementation. It is not foreseen that the IS EFA, the central eInvoicing solution will monitor the eInvoicing uptake.

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) [5]

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.

[1] (Voxel, 2021), [2] (WTS, 2021), [3] (SKDP, 2021), [4] (Pagero, 2021), [5] (The Netherlands chamber of commerce in the slovak republic, 2021), [6] (Financial Administration Slovakia, 2021)

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