Is an e-invoicing delivery-service provider used only for delivery, while invoices may be issued in other software?
Short answer
Yes. A certified delivery-service provider under § 76a of the VAT Act handles transmission, formal validation and the required notifications. The invoice itself may be created in different accounting or invoicing software, provided that software produces valid XML under Peppol BIS Billing 3.0 before the invoice is handed over for delivery.
Transmission and notification only
It provides delivery, time stamp and financial report.
Document creation
Creates valid XML by Peppol BIS Billing 3.0.
Different systems possible
It doesn't have to be one common software.
Interface between systems
The completed document shall only be sent to the postman for dispatch.
Detailed explanation
In practice, this means that your invoicing or ERP system will prepare a complete, valid XML document (possibly with a readable attachment), which is then handed over to the e-invoicing delivery-service provider solely for dispatch and to fulfil the relevant legal obligations regarding delivery. These two functions — document creation and delivery — are separable and, in practice, are often handled by different systems: one for issuing and processing invoices, the other (a certified delivery-service provider) solely for their secure transmission via the Peppol network. Some software providers offer both in a single package, but the law does not require this model to be the only one possible.
As set out in the Act
The definition of a certified delivery service and its obligations (verification of formal requirements, identification of parties, time stamp, reporting of data) is set out in Section 76a of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. The requirements and format of the electronic invoice itself are governed by Sections 74 and 85o of the same Act, without stipulating that the issuance and transmission of the document must be carried out by one and the same entity or software.
Practical examples
- A company issues invoices in its existing ERP system and transfers the completed XML file to a separate certified provider for dispatch.
- Another company uses a single software package that handles both — issuing and delivery — in one package.
- A small business owner uses a simple invoicing application and a separate digital postbox to send them.
Most common mistakes
- “e-Invoices must always be issued in the same system as they are delivered.” These are two separate functions that can be handled by different, interconnected systems.
- “The digital post office also checks the factual accuracy of the invoice’s content, such as prices or quantities.” The post office verifies formal requirements and technical validity, not the commercial or factual accuracy of the data.
- “It is not possible to issue an e-invoice without software from the same provider as the postman.” Any system capable of generating a valid XML file in accordance with Peppol BIS Billing 3.0 can submit the document to any certified postman.
Conclusion
The invoice may be created in separate software; the delivery-service provider handles its validation, transmission and notification after receiving valid XML.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 76a, Section 74 a Section 85o (as amended by Act No. 385/2025 Coll.)
Related questions
- Do I have to choose the same service provider as my software?
- What is a time stamp?
- How to choose a e-invoicing delivery-service provider?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoices, Peppol Authority Specific Requirements for the Slovak Republic. Verified on 7 July 2026.