What should be checked in a bulk e-invoice export for a tax audit?
Short answer
Check that the export is complete, that it contains the original unchanged XML corresponding to the invoices actually sent or received, and that the documents can be displayed in a readable form for the auditor. The export should also preserve the links and identifiers needed to trace each document.
No spaces
Even when changing software or provider during the period.
Conformity with the original document
The export must not contain additional edited files.
For faster orientation
PDF or print alongside original XML facilitate the work of the controller.
Section 71(3) a Section 85o(15)
Content integrity and ten-year archiving period.
Detailed explanation
The completeness of the export is particularly important if a company has changed its accounting software or e-invoicing delivery-service provider during the period in question — in such cases, it is necessary to verify that the archive covers the entire required period, regardless of which system or provider was in use at the time. The integrity of XML files is crucial because it is the original, unaltered document that constitutes a legally binding document under Section 71(3) of the VAT Act; any subsequent modification to the exported file could call into question its evidential value.
As set out in the Act
The requirement for the authenticity of the origin and the integrity of the invoice’s content throughout the entire retention period stems from Section 71(3) of Act No. 222/2004 Coll. on VAT. The ten-year retention period for electronic invoices in their original XML format is laid down in Section 85o(15) of the VAT Act.
Practical examples
- Prior to the audit, the company will verify that the archive contains e-invoices from the period when it was still using its previous digital mail service provider.
- In addition to the XML files, a readable PDF preview of each invoice is prepared for the auditor.
- The export is generated directly from the archived original files, not from a manually edited copy.
Most common mistakes
- “All you need to do is export the invoices from your current accounting system or provider.” The export must cover the entire period under audit, even across any changes in software or provider.
- “For the audit, it is sufficient to export only the readable PDF previews without the original XML files.” The original XML file remains the legally binding document and must be included in the export.
- “A minor adjustment to the exported file before handing it over to the auditor is not a problem.” Any change could call into question the integrity of the content under Section 71(3) of the VAT Act.
Conclusion
A defensible audit export is complete, preserves the original XML and enables every document to be traced and displayed in human-readable form.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 71(3)
- Act No. 222/2004 Coll. on VAT, Section 85o(15)
Related questions
- In what format should I submit e-invoices during an audit?
- What happens to the archive when the postal service provider changes?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, Act No. 431/2002 Coll. on Accounting, official methodological and information materials from the Slovak Financial Administration on e-invoicing, the Peppol (OpenPeppol) network operating rules and the Peppol Authority Specific Requirements for the Slovak Republic. Verified on 7 July 2026.