Regardless of expectations

Must a non-VAT-paying sole trader using flat-rate expenses arrange e-invoice receipt even if no invoices are expected?

Short answer

Yes. The requirement is one of technical readiness to receive electronic invoices and is not conditional on the person currently expecting a particular invoice. A non-VAT-paying sole trader using flat-rate expenses must therefore prepare the receiving channel. The trader’s own invoices may still be sent as PDFs without using a certified delivery service because the trader is not subject to the mandatory issuing obligation.

Regardless of expectations

General readiness

The obligation to receive is also valid without a specific expected transaction.

Reason

The situation may change

New supplier-payer VAT can occur at any time.

Self-exposed documents

PDF without postman

As a non-payer VAT has no obligation to display e-invoice.

Two different obligations

Admission vs. display

The first is general, the second is tied to payers only Section 4, Section 4b, Section 4c.

Detailed explanation

The reason why one cannot rely on the notion that ‘I’m not expecting anything, so there’s no need to prepare’ is that the situation may change at any time — for example, if a self-employed person starts purchasing goods or services from a new supplier who is a VAT payer and obliged to issue e-invoices, that self-employed person must already be technically prepared to accept the document at that moment, rather than having to deal with registration retrospectively under pressure. The Act therefore makes no distinction between those who are expecting an invoice and those who are not currently expecting one — it requires all taxable persons to be generally prepared.

As set out in the Act

The obligation for taxable persons to be able to receive electronic invoices stems from the general provisions of Section 71 of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., and is not conditional upon the expectation of a specific transaction. The obligation to issue e-invoices, pursuant to Section 85o(2) of the same Act, applies only to taxable persons under Sections 4, 4b or 4c, a category which does not include VAT non-payers with flat-rate expenses.

Practical examples

A self-employed person with flat-rate expenses currently believes that they will not receive any e-invoices from anyone, yet they have nevertheless contracted a digital mail service provider in advance.
In a year’s time, this same self-employed person will start purchasing materials from a new supplier who is a VAT payer, who will send them an e-invoice — thanks to the email service set up in advance, they will be able to receive it without any problems.
This self-employed person continues to send their own invoices to customers as PDFs, as they are not obliged to issue e-invoices.

Most common mistakes

“If a business owner is not currently expecting to receive any invoices, they only need to register their e-invoice receiver when the need arises.” The obligation to be prepared applies in advance, not only when a specific incoming invoice appears.
“A non-VAT payer with flat-rate expenses is completely exempt from the obligation to receive e-invoices.” The obligation to receive e-invoices applies to taxable persons in general, not just VAT payers.
“As they are not obliged to issue e-invoices, they do not need to deal with receiving them either.” These are two separate obligations — issuing does not apply to them, but receiving does.

Conclusion

A sole trader must prepare for receipt even if no incoming invoice is currently expected; this does not turn the trader’s own PDF invoices into mandatory e-invoices.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 71 a Section 85o(2) (as amended by Act No. 385/2025 Coll.)