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What happens to the e-invoice archive when changing delivery-service provider?

⚠ Machine-translated answer, not yet manually reviewed. For the exact wording, see the Slovak original.

Short answer

A delivery-service provider has no statutory obligation to retain transmitted electronic invoices on behalf of the VAT payer. Under § 85o ods. 15 of Act No. 222/2004 Z. z. on VAT, the payer remains responsible for retaining the original XML for ten years after the end of the relevant calendar year. Before ending the old provider’s contract, export and store the existing archive rather than assuming that access will remain available.

Quick checklist

3 matters before the contract is terminated

1

Check the archive range with the provider

The terms of the contract vary, some offer long-term archiving, others store documents only for a short operating period.

2

Export the entire archive

Original XML, attachments and status/audit data — see what exactly constitutes the evidence package.

3

Do it before, not after

After deregistrationcii access to the history of the original provider may be restricted or tolled.

Who is responsible for the archive

The responsibility lies with you, not the postman

The delivery-service provider (e-invoicing delivery-service provider) technically delivers the document, but is not legally obliged to store it long-term on your behalf. If you rely on access to your invoice history being retained after the contract ends, you risk losing easy access to older documents — either following formal deregistration or after the expiry of the contractually agreed retention period within the postman’s app.

A digital mail service is not automatically an archive. You should therefore check the scope and duration of retention for a specific provider directly in the contract or terms and conditions — do not simply assume it. Some providers offer long-term archiving as part of the service or as a paid add-on, whilst others only provide the short operational period necessary for delivery and any potential complaints.

What exactly to export

Not just XML, the entire evidence package

For the export to have genuine evidential value, it is not enough to simply download the invoices themselves. Following the same logic as for standard e-invoice archiving , an export when changing email providers should contain:

Original XML

Not only PDF preview

The technical source of the document is never replaced by the PDF XML.

Delivery metadata

Message ID, dates, statuses

Without these, it is difficult to prove what happened to the document in the event of a dispute over delivery.

Annexes

Linked documents

If an invoice had a delivery note or other document attached, it should be included in the export along with the invoice.

Audit trail

Processing history

Who approved, amended or exported the document — if the provider records this.

Legal basis

Section 85o(15) of the VAT Act

The obligation to retain an electronic invoice for ten years from the end of the calendar year to which it relates, in the original XML format, stems from Section 85o(15) of Act No. 222/2004 Coll. on VAT (transitional provision in force from 1 January 2027 to 30 June 2030). The fact that this obligation rests with the taxpayer, not the delivery-service provider, is also confirmed by the Slovak Financial Administration’s methodological interpretation of e-invoicing (official methodological and information materials of the Slovak Financial Administration). This ten-year period applies regardless of how many times you change providers during that period.

Common myths

What people wrongly believe

Myth

“The e-invoicing delivery-service provider is obliged to maintain an archive of e-invoices.”

Reality

The delivery-service provider has no legal obligation to retain the XML files sent — this responsibility lies with the taxpayer.

Myth

“Access to the history is automatically retained after changing providers.”

Reality

Without exporting the data themselves, a company may lose easy access to older documents once the contract ends.

Myth

“The archive export should only be carried out immediately prior to an audit.”

Reality

It is recommended to carry out regular backups or exports at the latest before the contract with the original provider ends, not once access has already been closed.

Conclusion

The archiving of e-invoices is always the responsibility of the taxpayer, not the provider. Before changing your e-invoice provider, therefore, ensure you export the entire set of supporting documents — XML, metadata, attachments, audit trail — whilst access to the original provider is still available.

Sources

Verified sources

Act No. 222/2004 Coll. on VAT, Section 85o(15); official methodological and information materials from the Slovak Financial Administration on e-invoices; Act No. 431/2002 Coll. on Accounting. Verified on 10 July 2026.

This is not legal advice.