Must advance-payment invoices also be sent through an e-invoicing delivery-service provider?
Short answer
Yes. An invoice issued for a payment received before goods or services are supplied is a regular invoice under § 72 ods. 1 of the VAT Act, not a separate document with a lower legal status. From 1 January 2027 it is therefore subject to the same electronic-invoicing regime as a normal final invoice: it must be issued in the required structured format and sent through a certified delivery service like any other e-invoice.
Advance invoice = regular invoice
Accepted payment in advance establishes the obligation to draw up an invoice in the same way as for delivery.
From 1/1/2027
An advance invoice is subject to the same structured format and delivery service as a regular invoice.
Differentiation of documents
A request for payment without invoice details is not sent through the e-invoice system.
The same as for a regular invoice
It also applies to the invoice for the received payment in advance.
Detailed explanation
It is important to distinguish between a genuine advance invoice issued against an actual payment received and a standard ‘pro forma’ or payment request, which does not meet the requirements for an invoice under the VAT Act and does not give rise to a tax liability upon issue — such a document is not an invoice within the meaning of the VAT Act and is not subject to submission via the e-invoicing system. However, as soon as payment is received prior to supply and the payer is therefore obliged to issue an invoice in accordance with Section 72(1) of the VAT Act, this invoice is then considered a valid tax document and, from 2027, the same 15-day deadline for issuing it and sending it via a delivery service will apply as for a standard invoice.
As set out in the Act
Section 72(1) of Act No. 222/2004 Coll. on VAT stipulates the obligation to issue an invoice, amongst other things, upon receipt of payment prior to the supply of goods or services. Special provisions governing domestic electronic invoicing from 1 January 2027, including advance payments, are set out in Section 85o of the VAT Act, as amended by Act No. 385/2025 Coll.
Practical examples
- A company receives an advance payment for a future supply of goods and issues an e-invoice for it, sent via the digital post office in the same way as for a standard billing invoice.
- An internal payment request without the mandatory invoice details is not sent via the e-invoicing system, as it does not constitute an invoice under the VAT Act.
- Upon receipt of payment, there is an obligation to issue an invoice within 15 days, just as with a standard supply of goods.
Most common mistakes
- “Advance payment invoices are a specific type of document to which the e-invoice requirement does not apply.” An invoice for a payment received is a valid invoice under Section 72(1) of the VAT Act and, from 2027, will be subject to the same e-invoicing regime.
- “Every advance invoice or pro forma invoice must be sent via the digital post office.” Only a genuine invoice issued in respect of an actual payment received in accordance with Section 72(1); a standard pro forma invoice lacking the requisite elements of an invoice is not sent via the e-invoice system.
- “A different, longer deadline for issuing an advance invoice applies than for a standard invoice.” The same 15-day deadline applies as for a standard invoice for the supply of goods or services.
Conclusion
The advance invoice issued for the actually received payment is a regular invoice and from 2027 it must be sent via e-invoicing delivery-service provider in the same way as a regular billing e-invoice.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 72(1)
- Act No. 222/2004 Coll. on VAT, Section 85o (as amended by Act No. 385/2025 Coll.)
Related questions
- How should an advance-payment document be handled in e-invoice?
- What to check before shipping e-invoice?
This does not constitute legal advice. Sources: Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoice. Verified on 7 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. 38: Obligation to issue an e-invoice for an advance payment: Is an e-invoice required for advance payments?
From 1 January 2027, the obligation to issue an electronic invoice is specifically regulated in the transitional provision of Section 85o(2) of the VAT Act, pursuant to which a domestic taxable person (Section 4, 4b or 4c) is obliged to issue an electronic invoice if they have supplied goods with a place of supply within the country pursuant to Section 13 of the VAT Act, or a service with a place of supply within the country pursuant to Section 15 or Section 16 of the VAT Act, or have received payment prior to such supply of goods or services, and the recipient of the supply is also a domestic taxable person (including a legal person) or a domestic non-taxable legal person. This means that if, after 1 January 2027, a domestic taxable person receives payment prior to the supply of goods or services within the country from a domestic taxable person or a domestic non-taxable legal person, they are obliged to issue an electronic invoice for the payment received. An electronic invoice for a payment received prior to the supply of goods or services within the country may also be issued, without the consent of the recipient, by a domestic taxable person who, pursuant to Section 85o( 22 of the VAT Act, from 1 January 2026 to 31 December 2026, sends electronic invoices via a delivery service and the recipient has ensured that they are able to receive electronic invoices via a delivery service.
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 42: Am I obliged to issue an electronic invoice for an advance payment as well?
Current conclusion: If a payment received prior to supply gives rise to an obligation to issue an invoice under the VAT Act, from 2027 onwards, under the mandatory domestic regime, it must be issued as an e-invoice. The deadline is determined in accordance with Section 73; it cannot be described in general terms without assessing the date of receipt of the payment and the end of the month.
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.