PDF, XML and other sending method

What if my supplier sends only a PDF invoice by email?

Short answer

Under § 85o ods. 4, a PDF sent by email is not by itself a structured electronic invoice. If the transaction is subject to mandatory e-invoicing, request the XML e-invoice. The parties may use another delivery channel with the recipient’s consent, but that does not turn a PDF into the required structured format. The right to deduct VAT is assessed separately under § 49 to 51 and according to the particular circumstances.

PDF

It is not an e-invoice

PDF can be a readable preview, but it does not replace a structured document according to Section 85o(4).

XML

The structure is decisive

The document must enable automated processing and be in the permitted EN 16931 syntax.

Another channel

Requires consent

E-mail or EDI can be used as a method of sending a structured e-invoice only with the consent of the recipient.

VAT

Do not make an automatic verdict

The right to deduct tax is not judged solely on whether the email attachment was a PDF.

What exactly does the law say?

Under Section 85o(4) of the VAT Act, an electronic invoice is a document that contains the particulars specified in Section 74(1), enables automated and electronic processing, and uses a data structure in accordance with the European standard and the list of syntaxes. The Financial Administration interprets this requirement as structured UBL or CII XML. A standard PDF does not meet this definition.

Section 85o(2) also permits the sending of an electronic invoice by means other than a delivery service, provided the recipient consents to this. The key distinction lies between the format of the document and the method of sending it: email may be an agreed channel, but the attachment must still be a structured e-invoice, not merely a PDF.

Recommended procedure for the recipient

Check whether the transaction is covered by Section 85o.
Check whether the email also contains a UBL or CII XML file.
If only a PDF has been received, ask the supplier for the document in the correct structured format.
Keep the PDF as an accompanying or readable document, not as a substitute for the XML.
If you are dealing with a VAT deduction from a disputed document, do not assess it solely on the basis of the attachment format; the conditions for deduction under Sections 49 to 51 must be assessed separately.

What we do not yet claim

In the Financial Administration’s currently published materials, we have not found a general position stating that the mere acceptance of a PDF in place of a mandatory e-invoice would automatically invalidate or automatically preserve the right to deduct VAT in all situations. Such a conclusion therefore cannot be safely generalised.

Conclusion

Where mandatory e-invoicing applies, obtain the structured XML; an agreed alternative delivery channel does not make a PDF an e-invoice.

Legal and technical basis

Section 85o(2) and (4) of Act No. 222/2004 Coll., as amended by Act No. 385/2025 Coll.
Financial Administration FAQs, examples Nos. 1, 3, 44 and 61
Sections 49 to 51 of the VAT Act for the separate assessment of tax deduction