How should proof of e-invoice submission be archived?
Short answer
Archive the submission evidence with the specific invoice rather than separately in email. The evidence package should contain the submitted XML, its hash, the validation report, submission time, delivery and receipt statuses, technical acknowledgements, attachments, and any communication concerning an error or rejection.
Original sent
The exact file that was sent.
Content integrity
The hash will show if the XML has changed.
Timeline
Sent, delivered, received, error or rejected.
Validation and communication
Save partner or customer reports and messages.
Detailed explanation
A good archive must answer the following questions: what was sent, when, to whom, via whom, with what result, and whether the content was subsequently altered. Therefore, the evidence package must not be retroactively embedded in the XML, as this would alter the hash of the sent document. It must be linked to the XML separately.
As set out in the Act
Section 76a emphasises the authenticity of origin, the integrity of the content, legibility, and proof of the date and time of dispatch, delivery and receipt. This is why the archive requires more than just a saved PDF preview.
Practical examples
- During an audit, the company will provide the XML, hash, validation report and confirmation of delivery.
- In the event of a complaint, it can be demonstrated that the recipient received a specific version of the document.
- The ZIP file containing the evidence includes a manifest, XML, reports, statuses and attachments.
Most common mistakes
- “I’ll include the audit file in the XML.” This would change the XML hash; the evidence must be linked separately.
- “A PDF preview is sufficient.” A PDF does not prove the technical transfer or the integrity of the XML.
- “I’ll just leave the statuses with the partner.” The company must be able to export and retain the evidence.
Conclusion
Maintain a self-contained audit evidence package linked to the immutable submitted XML.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 76a
- Act No. 431/2002 Coll. on accounting
- Internal audit and archiving model
Related questions
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, Slovak Financial Administration e-invoicing FAQ, OpenPeppol BIS Billing 3.0 and the Slovak e-Invoicing Centre’s internal validation model. Verified on 7 July 2026.