Forgotten invoice

Can I issue a forgotten e-invoice later using a backdated issue date?

Short answer

A forgotten invoice must be issued and sent without further delay, but the document must not show a false issue date. The supply date can be earlier than the issue date because they are separate invoice particulars. Issuing the invoice later does not remedy a possible breach of the 15-day deadline under § 85o ods. 6. For an invoice sent through a delivery service, the supplier’s five-day period under § 85o ods. 9 runs from the date the invoice is issued, not from a later sending date.

Technically possible

No date check

The system does not block an invoice with a delivery back date.

It shall be accepted by the beneficiary

No specific obstacle

Acceptance and processing do not depend on how old the delivery date is.

Two different deadlines

15 days vs. 5 days

Invoices and data reporting are separate obligations with different counting.

Open question

Penalties for delayed exposure

Accurate sanctioning effect outside Section 85o we recommend checking the fines individually.

Detailed explanation

A distinction must be made between the deadline for issuing an e-invoice and the notification deadline. For a supplier who sends an e-invoice via a delivery service, Section 85o(9) requires the details to be notified at the time of issue or, at the latest, within five days of the date of issue. For a received e-invoice, the recipient has five days from the date of receipt, in accordance with paragraph 10. Section 85o(11) deems the notification obligation to have been fulfilled upon handing over the e-invoice to the delivery service. Late issuance cannot be ‘rectified’ by backdating the date of issuance.

As set out in the Act

The 15-day period is governed by Section 85o(6). Notification by suppliers is governed by Section 85o(9), notification by recipients by paragraph 10, and fulfilment of the obligation via a delivery service by paragraph 11.

Practical examples

If a company discovers a missed delivery a month later, it must state both the correct date of delivery and the actual date of issue, and dispatch the document without delay.
The supplier’s five-day deadline is calculated from the actual date of issue; a further five days are not added on from the later date of dispatch.
Dispatch and reporting do not alter the fact that the original 15-day deadline for preparation may have been breached.

Most common mistakes

“The backdated delivery date and the backdated issue date are the same.” No. These are different details on the invoice, and both must correspond to the facts.
“I always have five days from dispatch to submit my report.” No. Under paragraph 9, the deadline for the supplier runs from the date of issue; under paragraph 10, for the recipient, it runs from the date of receipt.
“Compliance with the reporting requirement removes the delay in issuing the invoice.” It does not; these are two separate obligations.

Conclusion

Additional exposure forgotten e-invoice the back date is technically possible and accepted by the recipient, but it is a breach of the 15-day period for issuing the invoice; We recommend that the exact sanctioning effect of this particular infringement (outside the notification penalty) be verified individually.

Legal basis

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