Does mandatory e-invoice apply to an eKasa payment of up to EUR 400?

Simplified invoices up to €400: It follows from the transitional provision in Section 85o(1) of Act No. 222/2004 Coll. on Value Added Tax, effective from 1 January 2027 (hereinafter referred to as the ‘VAT Act’), it follows that a taxable person is not obliged to issue an electronic invoice if, upon the supply of goods or services, they have issued a simplified invoice in accordance with Section 74(3)(a) or (b) of the VAT Act. Under Section 74(3)(b) of the VAT Act, a simplified invoice is a document issued by an eKasa cash register where the price of the goods or services, including tax, does not exceed 400 euros, and a document issued by a self-service fuel dispenser, provided that the price of the goods, including tax, paid by electronic means of payment does not exceed 400 euros. A document from the eKasa system need not contain details of the customer or the unit price. It follows from the above that if a taxable person issues a simplified invoice via an eKasa cash register (up to €400), they are not obliged to issue an electronic invoice. Invoices over €400: From 1 January 2027, pursuant to the transitional provision in Section 85o(1) of the VAT Act, a domestic taxable person is obliged to issue an electronic invoice for the following supplies of goods and services, including where payment is received prior to such supply: - the supply of goods where the place of supply, in accordance with Section 13 of the VAT Act, is within the country; - the provision of services where the place of supply, in accordance with Section 15 or Section 16 of the VAT Act, is within the country, if the goods or services were supplied to a taxable person who has their registered office, place of business, establishment, residence or usually resides in the country, or to a non-taxable legal person which has its registered office or a place in the country characterised by a sufficient degree of permanence and an appropriate structure, in terms of the human and technical resources necessary for the performance of its activities. As stated in the answer to the first question (simplified invoices up to €400), the taxable person is not obliged to issue an electronic invoice if, in connection with the supply of goods or services, they have issued a simplified invoice in the form of a document from eKasa, provided the price is €400 or less (inclusive). If the price of the goods or services exceeds 400 euros, in the case of a domestic supply of goods or services to a domestic taxable person or a domestic non-taxable person, the taxpayer is obliged to issue an electronic invoice in accordance with the definition set out in Section 85o(4) of the VAT Act. For the purposes of mandatory domestic electronic invoicing during the transitional period, an electronic invoice is any document or notification which contains the particulars specified in Section 74(1) of the VAT Act and is issued, sent and received a) in the format of an electronic document that allows for its automated and electronic processing, and b) in a data structure compliant with the technical standard for electronic invoicing and with the list of its syntaxes as set out in a separate regulation, namely Commission Implementing Decision (EU) 2017/1870 of 16 October 2017 on the publication of a reference to the European standard for electronic invoicing and a list of syntaxes pursuant to Directive 2014/55/EU of the European Parliament and of the Council. In this case, the seller should issue a receipt for the payment of the invoice via the eKasa till in accordance with Section 8(2) of Act No. 384/2025 Coll. on the recording of sales and amending certain acts, as amended by Act No. 30/2026 Coll. According to the description of the eKasa system’s integration interface, such a receipt is identified by the code ‘UF’ in the ‘ReceiptType’ element; see page 24, Chapter 3.3.6 of the Working_Description_of_the_Integration_Interface_v2.7_20220311. As the issue of an electronic invoice is not subject to the consent of the recipient of the supply, for the purposes of sending electronic invoices, the VAT Act imposes an obligation on the supplier who is required to issue an electronic invoice and on the customer for whom an electronic invoice must be issued the obligation to ensure that they are able to issue/receive an electronic invoice via a delivery service. Sending an electronic invoice by any means other than a delivery service is subject to the consent of the recipient of the supply. The obligation to report data to the tax authorities applies, during the transitional period from 1 January 2027 to 30 June 2030, to supplies of goods or services where the electronic invoice is delivered via a delivery service. If the supplier sends the electronic invoice, with the consent of the recipient, by a method other than a delivery service, neither the supplier nor the recipient is obliged to report the data to the tax authorities.