Approval and audit

How can a client approve an invoice prepared on its behalf by an accounting firm?

Short answer

Approval before dispatch is an internal process for which the law does not prescribe a single workflow. It may be handled through restricted client access in the invoicing software or through an approval process outside that system. In either case, retain an auditable record of the client’s approval.

Model 1

Access to software

The client approves the invoice directly in your system.

Model 2

Approval outside the system

For example, by e-mail, with a separate consent record.

It is not a legal obligation

Internal process

The VAT Act does not regulate the approval process between the client and the company.

Recommendation

Keep proof of consent

Regardless of which model you choose.

Detailed explanation

In the first model (software access), the client has a direct overview and approval takes place in the same environment where you prepare the invoice — the advantage is a single record in the system; the disadvantage may be that it is more complicated to set up access rights for specific invoices only. In the second model (sending for approval outside the system), the technical setup is simpler, but you must keep the approval record (for example, an email confirmation stating ‘I agree, you may send it’) separately from the e-invoice itself, for instance attached to the internal documentation for that invoice in your archive. In both cases, you, as the issuer, are responsible for ensuring that the e-invoice is based on genuine and approved client documentation — which is precisely why it is advisable to have proof of this approval to hand, regardless of whether it is directly required by the VAT Act.

As set out in the Act

The technical and formal requirements for e-invoices are set out in Sections 74 and 85o of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll.; however, these relate to the final document, not the internal approval process between the client and the accountancy firm. The general requirement for the verifiability of an accounting transaction stems from Section 6 of Act No. 431/2002 Coll. on Accounting, which justifies the need to retain a record of the approval of supporting documents.

Practical examples

An accountancy firm prepares an invoice in its software and sends the client a preview by email, requesting confirmation before dispatch.
Another firm grants the client limited access to its system, where the client approves the invoice themselves before it is sent.
The firm stores the email confirmation of approval alongside the other documentation relating to the invoice in question.

Most common mistakes

“The e-Invoice Act prescribes the exact procedure for clients to approve invoices.” This is an internal process which the company sets up itself according to its own needs.
“There is no need to keep a record of the client’s approval anywhere.” Given the general requirement for verifiability, it is advisable to have proof of the client’s consent to hand.
“The only correct solution is always to give the client direct access to the software.” Sending documents for approval outside the system is an equally valid approach, albeit with a different method of record-keeping.

Conclusion

Choose an internal approval workflow appropriate to the parties and retain evidence of the client’s approval before the invoice is sent.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 74 a Section 85o (as amended by Act No. 385/2025 Coll.)
Act No. 431/2002 Coll. accounting, Section 6