Must doctors be able to receive e-invoice even when they are not required to issue it?
Short answer
Yes. Healthcare services are generally exempt from VAT, so a doctor will usually not be required to issue e-invoice for those services. As a taxable person receiving medical supplies, energy or other services from suppliers that are required to issue e-invoice, however, the doctor must be able to receive the structured XML through an arranged delivery service and process it in suitable software.
Free health services
As a rule, a doctor is not a payer VAT for this activity.
As a taxable person
Valid for purchases from payers VAT (material, energy, services).
Adapted to income
He doesn't need to know e-invoice exhibit, just process received.
Easy application is sufficient
On the reception side, a basic web or mobile application is sufficient.
Detailed explanation
This asymmetry — the obligation to receive e-invoices without the obligation to issue them — is typical for entities that provide tax-exempt supplies but, at the same time, routinely purchase goods and services from VAT payers as part of their business operations (e.g. a mobile clinic or doctor’s surgery). A doctor, therefore, just like other non-VAT payers, can make do with a simple web-based or mobile ‘e-invoicing delivery-service provider’ app designed for receiving invoices, without the need for a complex invoicing system to issue e-invoices, which the law does not require in their case.
As set out in the Act
The obligation to issue electronic invoices, pursuant to Section 85o(2) of Act No. 222/2004 Coll. on VAT, applies to taxable persons under Sections 4, 4b or 4c. The obligation for legal entities and taxable persons to be able to receive e-invoices stems from the general provisions of Section 71 of the VAT Act.
Practical examples
- A medical practice purchases medical supplies from a VAT payer, who must send it an e-invoice — the medical practice must be able to receive it.
- The doctor continues to issue invoices to patients for their medical services outside the e-invoice system.
- The doctor chooses a simple digital mail application for receiving invoices only, without the need for an invoicing module to issue them.
Most common mistakes
- “Doctors are completely exempt from obligations relating to e-invoices.” As taxable persons, doctors are also obliged to accept e-invoices from VAT-registered suppliers.
- “If a doctor does not need to issue e-invoices, they do not need any software or a digital mail service.” To receive them, they need software capable of processing XML and a contracted e-invoicing delivery-service provider.
- “The obligation to accept e-invoices applies only to VAT payers.” It applies to taxable persons in general, including non-VAT payers such as doctors providing exempt services.
Conclusion
Doctors will generally not issue e-invoice for exempt healthcare services but must be technically able to receive it where their suppliers are required to send it.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 71 a Section 85o(2) (as amended by Act No. 385/2025 Coll.)
Related questions
- Must a self-employed person accept e-invoices?
- Must a civic association have an e-invoicing delivery-service provider?
- Do I need an e-invoicing delivery-service provider?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., Act No. 215/2019 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoice, EN 16931 and Peppol BIS Billing 3.0. Verified on 7 July 2026.