"also invoice" switch

How should invoicing software distinguish mandatory e-invoice from a consumer invoice?

Short answer

The software may expose a switch or processing flag that determines whether a document is validated and submitted as e-invoice through a delivery-service provider or issued through the ordinary consumer workflow, for example as a PDF. That flag must be driven by the actual status of the parties and the supply, not selected merely for convenience; the issuer remains responsible for verifying the classification.

Switch when displaying

"also invoice"

Most samples of certified solutions include this flag.

The position of the customer is decisive

VAT number or VAT number

The software identifies whether it is a taxable or non-taxable person.

It goes through the postman

The document is validated and sent as an e-invoice.

Off

The usual way

The invoice is delivered as before, e.g. PDF by e-mail.

Detailed explanation

The decision as to whether a specific invoice should be designated as electronic is made by the issuer based on the recipient of the invoice: if the recipient is a taxable person liable for tax under Section 4, Section 4b or Section 4c, the invoice must be electronic; if the customer is a natural person (consumer) without an assigned VAT registration number or company registration number, the obligation to issue electronic invoices does not apply to them. In practice, the software identifies the customer based on the identification details provided (in particular the VAT registration number or company registration number) and, accordingly, either automatically suggests or allows the user to manually designate whether it is an e-invoice. When issuing an invoice, the issuer should always verify that this flag corresponds to the recipient’s actual status, as incorrect flagging may result either in an unnecessary burden on the delivery system or, conversely, in a failure to comply with a legal obligation.

As set out in the Act

The obligation to issue electronic invoices only to taxable persons as defined in Section 4, Section 4b and Section 4c of Act No. 222/2004 Coll. on VAT, and the exemption for end consumers without a VAT registration number and tax identification number is set out in Section 85o as amended by Act No. 385/2025 Coll.

Practical examples

The issuer enters the customer’s VAT registration number on the invoice — the software automatically suggests the designation ‘e-invoice’ and dispatch via the digital post office.
If the issuer invoices a natural person without a tax identification number, the ‘also invoice’ flag remains disabled and the document is sent as before.
When checking the issued documents, the accountant verifies that the “also invoice” flag is set correctly according to the customer’s actual status.

Most common mistakes

“The distinction between an e-invoice and a standard invoice is always fully automatic, and the issuer does not need to concern themselves with it.” Although the software may suggest the flag based on the data entered, the issuer should check that the designation is correct.
“If I issue an invoice as an e-invoice by mistake, even where it is not required, this constitutes an error.” Marking an invoice as electronic even where the law does not require it is not in itself a breach — the problem arises only in the opposite scenario, i.e. if a mandatory e-invoice is not marked as such.

Conclusion

A software flag can control the route, but it must reflect the customer’s status and the actual supply; the issuer must verify the result.

Legal basis

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