RUFF

Must a sole trader using single-entry accounting have a delivery-service provider?

Short answer

Official materials state that every legal person or taxable entrepreneur, including a sole trader, that falls within the receiving obligation must be able to receive e-invoice through a delivery service. The accounting method is not decisive; the person’s status and the applicable invoicing rules are.

Taxable person

Deciding criterion

Not the accounting system, but the position under the Act VAT.

Simple accounting

No derogation

A self-employed person using single-entry bookkeeping also needs an e-invoicing delivery-service provider.

Small volume

A Simple Solution Enough

Application accountcii A postman is good enough.

Access for the accounting officer

Shared approach

SKZOP can give access to the application directly to its accountant.

Detailed explanation

A small sole trader using simple accounting who issues or receives only a few dozen invoices a year does not, according to the recommendation of the Slovak Financial Administration, need to procure an expensive automated system — for example, an account in a digital mail service application will suffice, from which they can download the invoices or make them directly available to their accountant. The obligation to have a contracted digital mail service provider applies regardless of whether the business is a VAT payer or simply a taxable person who does not pay VAT.

As set out in the Act

The obligation to receive electronic invoices via a delivery service arises from Sections 76a and 85o of Act No. 222/2004 Coll. on VAT. The VAT Act does not link this obligation to the method of keeping accounts under Act No. 431/2002 Coll. on Accounting.

Practical examples

A self-employed tradesperson using single-entry bookkeeping will engage a digital mail service provider and send the downloaded e-invoices to their accountant.
A self-employed person who is not a VAT payer must be able to receive an e-invoice from a VAT payer, even though they do not declare VAT themselves.
A small business grants its accountant direct access to the digital mail service application instead of forwarding files.

Most common mistakes

“Simple accounting is exempt from the obligation to accept e-invoices.” It is the taxable person’s status that matters, not the accounting system.
“Only VAT payers need the digital mailbox.” The obligation to receive e-invoices also applies to non-VAT payers who are taxable persons.
“A small sole trader needs a costly ERP system.” According to the recommendation of the Slovak Financial Administration, a simple account in the e-Postman application is sufficient.

Conclusion

Single-entry accounting does not create an exemption; the need for a delivery-service provider follows from the person’s status and obligation to receive e-invoice.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 76a a Section 85o
Official methodological and information materials Financial Administration of the Slovak Republic k e-invoice