Shipping outside the postman

If I send e-invoice by email outside a delivery service, is its data automatically reported to the Financial Administration?

Short answer

No. Merely issuing an invoice in your own system does not automatically make its data available to the Financial Administration. Automated reporting occurs only when e-invoice is sent or received through a certified delivery service. If, with the recipient’s consent, the invoice is instead sent by email outside that service, the automated reporting route does not apply.

Reporting condition

Passing through the delivery service

Not the actual creation of the invoice in the system.

Mail with consent

It remains possible

According to Section 71(4) and Section 85o(2) of the VAT Act.

No automatic report

When sent outside the postman

This notification route does not apply.

Other duties continue

For example, the factual accuracy of the invoice

The choice of channel does not waive other legal requirements.

Detailed explanation

During the transitional period (2027 to 30 June 2030), the Act expressly links the obligation to notify to the fact that the invoice is sent or received via a delivery service — not to the mere issuance of the invoice in a structured format. When sending an e-invoice by email (an option which remains available with the recipient’s consent under Section 71(4) and Section 85o(2) of the VAT Act), the element that would trigger the automated transmission of data is therefore missing — as this step is carried out by the delivery-service provider through whom the invoice actually passes. Therefore, if you choose to communicate outside the delivery service, you must bear in mind that this does not relieve you of other obligations (such as ensuring the factual accuracy of the invoice), but an automated report to the tax authorities will not be generated in this way.

As set out in the Act

The fact that the reporting obligation arises only when an invoice is sent or received via a delivery service during the transitional period follows from the interpretation of Section 85o of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. The option to send an electronic invoice by means other than a delivery service, with the recipient’s consent, is governed by Section 71(4) and Section 85o(2) of the VAT Act.

Practical examples

A company generates an e-invoice in its own system but sends it by email with the customer’s consent — the details are not automatically reported to the tax authorities.
The same invoice sent via a certified digital mail service would trigger an automated notification.
The company considers which channel to use, specifically depending on whether it wishes to have the automated report triggered or not.

Most common mistakes

“Generating an e-invoice in the system automatically means that the tax authorities are aware of it.” The notification is only triggered when the invoice passes through a certified delivery service, not when it is issued.
“Sending invoices by email outside the delivery service will be prohibited from 2027.” It remains possible with the recipient’s consent in accordance with Section 71(4) and Section 85o(2) of the VAT Act.
“When sending an invoice by email, the company automatically fulfils all its other legal obligations.” Choosing a channel other than a delivery service does not exempt the company from other requirements regarding the content and accuracy of the invoice.

Conclusion

Automated notification of data to the financial administration occurs only when an e-invoice is sent or received via a certified delivery service; when sending by e-mail outside this service, this automatic route does not apply.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 71(4) and Section 85o(2) (as amended by Act No. 385/2025 Coll.)