Transition of the old document to the new mode

How should an invoice originally issued on paper or as a PDF before 2027 be corrected after 2027?

Short answer

Where § 85o ods. 5 expressly requires it, the correction follows the format and delivery regime of the original invoice. An old paper or PDF invoice must not retrospectively be represented as though the original had been an e-invoice.

Original e-invoice

Same delivery service

If the original went through the delivery service, the repair goes the same way.

Old PDF/paper

It is not an original according to Section 85o(4)

Special sentence Section 85o(5) is not bound by its text.

Always

An unambiguous link

The correction must identify the original document and the changed data.

Boundary

Do not invent a methodology

The special FS procedure must be applied only after its official publication.

First, determine the status of the original

Section 85o(5) governs a document that amends the original electronic invoice in accordance with paragraph 4. If the original e-invoice was sent via a delivery service, the corrective document must also comply with the same conditions and use the same channel.

Old PDF or paper

An invoice issued prior to the mandatory regime solely as a PDF or on paper is not an original e-invoice under Section 85o(4). It cannot therefore be automatically assumed that the specific obligation to use the Peppol channel arises merely because the correction is made after 1 January 2027. However, the general rules on invoicing and accounting will continue to apply to the correction.

Safe practice

keep the original document in its original form,
in the correction, state the original document number and the amended details,
do not present the correction as a copy of the original XML, which did not exist,
for bulk transitional corrections, follow the current methodology of the Financial Administration.

Conclusion

Apply the original invoice regime where Section 85o(5) requires it; do not retrospectively treat an old paper or PDF invoice as an original e-invoice.

Legal and technical basis

Section 71(2) and Section 74 of the VAT Act
Section 85o(4) and (5) of the VAT Act
Act No. 385/2025 Coll.