§ 7 a § 7a

Must a person registered under § 7 or § 7a issue e-invoices?

Short answer

No. The obligation to issue electronic invoices and report their data to the Financial Administration applies exclusively to VAT payers registered under § 4, § 4b or § 4c of the VAT Act. A person registered for tax under § 7, for example because of an acquisition of goods from another Member State, or under § 7a in connection with specified services, does not have this issuing obligation.

Section 4, Section 4b, Section 4c

Compulsory display

Only these payers have to display e-invoice.

Section 7 a Section 7a

Without obligation to display

Registration for specific cross-border transactions, not full status of payer.

Admission

May continue to apply

As a taxable person, he may have an obligation e-invoice receive.

Source of resolution

Section 85o(2) Act on VAT

The transitional provision clearly defines the scope of exhibitors.

Detailed explanation

Registration under Section 7 or Section 7a gives rise to specific obligations only in relation to defined cross-border transactions (for example, the acquisition of goods from the EU above a specified limit or the receipt of services from a foreign entity), not the full status of a taxable person. As the obligation to issue an electronic invoice is linked specifically to the status of a taxable person under Section 4, Section 4b or Section 4c, persons registered solely under Section 7 or Section 7a are exempt from this obligation — although, as taxable persons, they may still be required to accept e-invoices.

As set out in the Act

The distinction between the categories of persons subject to this obligation is set out in Act No. 385/2025 Coll., amending Act No. 222/2004 Coll. on VAT, specifically in the transitional provision of Section 85o(2), which links the obligation to issue an electronic invoice to taxable persons under Section 4, Section 4b or Section 4c. Registration under Sections 7 and 7a is governed separately by the VAT Act for specific cross-border situations.

Practical examples

A business registered solely under Section 7a for the receipt of foreign services is not required to issue domestic e-invoices.
An entity registered under Section 7 remains exempt from the obligation to issue an e-invoice when acquiring goods from the EU.
However, as a taxable person, that same entity must be prepared to receive e-invoices from other taxable persons.

Most common mistakes

“Any VAT registration gives rise to an obligation to issue e-invoices.” Only taxable persons under Section 4, Section 4b or Section 4c are subject to this obligation; persons registered under Section 7 or Section 7a are not.
“A person registered under Section 7a is completely outside the e-invoice system.” As a taxable person, they may still be obliged to accept e-invoices, even if they do not issue them.
“Registration under Sections 7 and 7a automatically converts over time to registration under Section 4.” These are different legal grounds for registration, which do not change in themselves.

Conclusion

Persons registered under Section 7 or Section 7a Act on VAT they have no obligation to issue e-invoices, which only belongs to payers by Section 4, Section 4b or Section 4c.

Legal basis

Act No. 385/2025 Coll.amending Act No. 222/2004 Coll. on VAT, Section 85o(2)