Does e-invoice also apply to B2C consumer invoices?
Short answer
An ordinary sale to an individual acting as a final consumer is not the main target of mandatory B2B/B2G e-invoicing. Where an individual buys from an e-shop privately and outside a business activity, the supplier will generally not send a mandatory Peppol e-invoice. If the same person or a company buys as a business, provides business identification details and the supply meets the conditions in § 85o, the mandatory e-invoice rules must be assessed.
Private purchase
As a rule, a citizen outside of business is not a recipient of a Peppol e-invoice.
Business purchase
The VAT number, status and specific delivery are decided.
Customer resolution
The form should correctly capture whether it is a company or a citizen.
Readable form
The consumer must be provided with a document that can be used by a person.
Detailed explanation
An online shop must be able to distinguish between different customer statuses. Different rules apply to a private individual’s purchase than to a purchase made by a sole trader, a limited liability company (s.r.o.) or another legal entity. The decisive factor is not merely that the order was placed via the website, but who the customer is and in what capacity they are making the purchase. In practical terms, this means that the order form must process the tax identification number (DIČ), VAT registration number (IČ DPH), billing address and business status so that the customer’s status is determined before the invoice is issued.
As set out in the law and technical rules
Section 85o of the VAT Act defines the obligation to issue e-invoices for supplies specified by law. Section 71(5) addresses the recipient’s obligation to accept an e-invoice if the supplier is required to issue one. A consumer, as a private individual, does not typically act as a business recipient under the mandatory B2B regime.
Practical examples
- A member of the public buys clothing for personal use. This does not constitute a mandatory B2B e-invoice.
- A sole trader buys a laptop for business purposes and provides their VAT number. The supplier applies Section 85o.
- A company orders goods via an online shop as a limited liability company (s.r.o.). Provided the conditions are met, the invoice is treated as an e-invoice.
Common misconceptions
- “Every online shop must send XML invoices to citizens from 2027.” No. Standard B2C sales are not subject to the main mandatory regime.
- “A natural person is never included in an e-invoice.” They can be, if they are purchasing as a business.
- “The ‘business/non-business’ field without a VAT number is sufficient.” In the B2B regime, correct identification of the customer is required.
Conclusion
In the e-shop, he decides whether the customer buys as a citizen or as an entrepreneur; the mandatory e-invoice is assessed according to the specific transaction, not according to the fact that the sale took place online.
Legal and technical basis
- Act No. 222/2004 Coll. on VAT, Section 71(5)
- Act No. 222/2004 Coll. on VAT, Section 74
- Act No. 222/2004 Coll. on VAT, Section 85o
Related questions
This does not constitute legal advice. Sources: Act No. 222/2004 Coll. on VAT, Act No. 385/2025 Coll., official guidance and information materials from the Slovak Financial Administration on e-invoice, EN 16931, Peppol BIS Billing 3.0 and OpenPeppol eDelivery documentation. Verified on 13 July 2026.
Official cases from the Slovak Financial Administration’s FAQs
The following questions and answers are taken from the current July FAQ from the Financial Administration and have been assigned to this topic. Grouping the cases prevents the creation of duplicate pages, whilst retaining the full answer and the exact wording of the question.
Example No. 4: Does e-invoice also apply to consumer invoices (B2C)?
No. At present, e-invoice applies only to invoicing between businesses (B2B) and between businesses and public administration (B2G).
Primary source: Financial Administration of the Slovak Republic, FAQ 9/VAT/2025/IM k e-invoice, July 2026 update. Processed and checked on 13 July 2026.
Review of questions from an earlier presentation
The presentation by the Slovak Accountants’ Centre was used solely to identify practical issues. The following conclusion has been updated in line with a subsequent FAQ from the Financial Administration and the applicable legislation; we do not treat the author’s suggestions, recommendations or incorrectly merged fragments as legal rules.
- slide/page 41: How will, for example, a mobile phone operator or energy supplier know that I am a private individual, a non-taxable person, and that they should not send me an electronic invoice but, as before, an invoice in a readable format?
- slide/page 41: They will continue to send them as before. If I run an online shop and my customers are private individuals, do I have a duty to issue them with electronic invoices?
Current conclusion: The mandatory domestic regime does not apply to standard B2C sales to citizens. However, the supplier must reliably distinguish whether the customer is purchasing as a consumer or as a taxable person or a legal entity.
Primary sources: FAQ Financial Administration of the Slovak Republic k e-invoice, July 2026; Act No. 222/2004 Coll. on VAT Effective from 1. 1. 2027. Revised 13 July 2026.