Must mandatory e-invoice be received only through Peppol?
Short answer
Where the statutory electronic-invoice regime applies, the recipient must be able to receive e-invoice through a delivery service. In the Slovak model this is implemented through Peppol and a certified delivery-service provider. Other communication channels may coexist, but an emailed PDF does not replace receipt of the mandatory structured invoice through the prescribed channel.
Adoption
The recipient must be able to accept e-invoice via delivery service.
Practical infrastructure
e-invoicing delivery-service provider ensure direction and delivery.
Additional channel
It can serve as communication, not as a substitute for compulsory e-invoice.
Specific delivery
The obligation shall be assessed by transaction and supplier.
Detailed explanation
The key factor is whether the invoice is one that must be issued and delivered electronically by law. If so, the recipient must have a means of receiving it via a delivery service. Email may remain a supplementary channel for communication, complaints, sending visualisations or attachments, but it does not replace the statutory channel for structured e-invoices. In voluntary or non-mandatory cases, the agreement between the parties and the specific legal obligation must be assessed.
As set out in the law and technical rules
Section 71(5) of the VAT Act requires a person to whom goods or services are supplied domestically – where the supplier is obliged to issue an electronic invoice – to ensure that the invoice can be received via a delivery service. Section 76a deals with delivery services and Section 85o with the scope of the obligation to issue e-invoices.
Practical examples
- A Slovak VAT payer issues a mandatory e-invoice to a business; the recipient must be able to receive the document via a courier.
- The supplier will also send a PDF preview by email, but the legally binding e-invoice is sent via the delivery service.
- For documents not subject to the mandatory regime, the parties may agree on a different method of exchange, provided the law permits it.
Common misconceptions
- “It’s enough that I receive invoices by email.” Not in the case of a mandatory e-invoice, which must be sent via a delivery service.
- “Peppol prohibits any other form of communication.” No. It is prohibited to replace the mandatory structured flow with an informal channel.
- “Only VAT payers are obliged to accept e-invoices.” No. Section 71(5) uses the broader term ‘any person’ provided the conditions are met.
Conclusion
For mandatory e-invoice, use the certified Peppol delivery route; email or PDF may supplement it but does not replace the structured delivery.
Legal and technical basis
- Act No. 222/2004 Coll. on VAT, Section 71(5)
- Act No. 222/2004 Coll. on VAT, Section 76a
- Act No. 222/2004 Coll. on VAT, Section 85o
Related questions
- Who is required to accept e-invoices?
- How do you choose a e-invoicing delivery-service provider?
- Is a PDF invoice e-invoice?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, official methodological and information materials from the Slovak Financial Administration on e-invoices, Peppol BIS Billing 3.0 and OpenPeppol eDelivery documentation. Verified on 13 July 2026.
Official cases from the Slovak Financial Administration’s FAQs
The following questions and answers are taken from the current July FAQ from the Financial Administration and have been assigned to this topic. Grouping the cases prevents the creation of duplicate pages, whilst retaining the full answer and the exact wording of the question.
Example No. 44: Is it mandatory to receive electronic invoices only via the Peppol network? Is it possible to receive them by other means?
For the purposes of sending and receiving electronic invoices from 1 January 2027, the Peppol network, via delivery service providers certified within the OpenPeppol network, will be the primary means of communication. For this reason, it is necessary to secure a delivery-service provider that enables the receipt of electronic invoices via the Peppol network. However, under Section 85o(2) of Act No. 222/2004 Coll. on Value Added Tax, it is permissible to send an electronic invoice by means other than a delivery service, provided the recipient of the invoice consents to this. Such consent may be agreed, for example, in a commercial contract or other contractual arrangement between business partners. Even in such cases, an electronic invoice delivered outside the Peppol network must still meet all the legal requirements for an electronic invoice, i.e. it must be drawn up in the standardised UBL 2.1 or UN/CEFACT CII format and comply with the European standard EN 16931. Companies may therefore continue to use existing EDI solutions or their own communication channels, provided they ensure the exchange of electronic invoices in the required standardised format and the recipient consents to this method of delivery. However, if an electronic invoice is delivered via the Peppol network, the recipient is obliged to ensure its receipt. How should the recipient’s consent be given? Is it sufficient, for example, to agree by email, or is a contract required? As Section 85o(2) of the VAT Act does not specify the form in which consent to the sending of an electronic invoice by means other than a delivery service must be expressed, the customer may give their consent in any manner, e.g. in writing, in a contract, by email, or even by the customer’s processing of the invoice or its payment. This means that so-called implied consent is also accepted, for example, if the customer accepts and pays the invoice.
Primary source: Financial Administration of the Slovak Republic, FAQ 9/VAT/2025/IM k e-invoice, July 2026 update. Processed and checked on 13 July 2026.