§ 7a Registration

Our company is registered for VAT only under § 7a. Must we still issue e-invoices?

Short answer

No. Under § 85o ods. 2 of the VAT Act, the obligation to issue electronic invoices and report their data to the Financial Administration applies exclusively to VAT payers registered under § 4, § 4b or § 4c. A company registered for VAT only under § 7a in connection with services supplied outside Slovakia is not one of those obligated persons and therefore does not have this issuing obligation.

Section 4, Section 4b, Section 4c

Mandatory exhibitors

Only these payers have to display e-invoice.

Section 7a

Specific cross-border registration

It does not create an obligation to display e-invoice.

Place of delivery in domestic

Additional condition

The transitional provision concerns only domestic supplies.

Admission

May continue to apply

Company may have an obligation e-invoice receive as a taxable person.

Detailed explanation

Registration under Section 7a serves specific purposes relating to the cross-border supply or receipt of selected services, not to establish full tax payer status in the country. Furthermore, as the transitional provision of Section 85o(2) of the VAT Act explicitly applies only to supplies with a place of supply within the country, your invoicing of services outside Slovakia is unlikely to fall within the scope to which the domestic e-invoice requirement applies. Nevertheless, as a taxable person, your company may be obliged to be able to receive e-invoices if a domestic taxable person is required to send them to you in respect of other domestic supplies — this obligation to receive e-invoices is, in fact, broader in scope than the obligation to issue them.

As set out in the Act

Section 85o(2) of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., imposes an obligation to issue an electronic invoice on a taxable person under Section 4, Section 4b or Section 4c in the case of a supply where the place of supply is within the country. Registration under Section 7a is governed separately by the VAT Act for specific cross-border situations relating to the supply or receipt of selected services.

Practical examples

A company registered under Section 7a invoices a client in another Member State without being obliged to issue an e-invoice.
The same company receives an invoice from a domestic taxpayer for a standard domestic purchase, which it is obliged to accept as an e-invoice.
The company verifies that its invoicing of services outside Slovakia does not fall within the scope of the domestic e-invoice obligation under Section 85o(2).

Most common mistakes

“Any VAT registration, including that under Section 7a, gives rise to an obligation to issue e-invoices.” Only taxpayers under Section 4, Section 4b or Section 4c are subject to this obligation.
“A company registered under Section 7a is completely outside the e-invoicing system, even as a recipient.” As a taxable person, it may still be obliged to accept e-invoices from domestic taxable persons.
“Invoicing for services outside Slovakia is subject to the domestic e-invoice requirement in the same way as domestic supplies.” The transitional provision in Section 85o(2) relates to supplies where the place of supply is within Slovakia, not to services outside Slovakia.

Conclusion

Registration by Section 7a does not impose an obligation to display e-invoice It belongs only to payers Section 4, Section 4b or Section 4c for domestic supplies; Obligation e-invoice However, firms may continue to be admitted as taxable persons.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 85o(2) (as amended by Act No. 385/2025 Coll.)