Must property landlords have an e-invoicing delivery-service provider?
Short answer
Not every landlord is automatically required to issue e-invoices. If the landlord is not a VAT payer registered under § 4, § 4b or § 4c, the current wording of § 85o generally does not create an issuing obligation merely because the person rents out property. The landlord may nevertheless have to be able to receive e-invoices when acting as a business or taxable person and receiving supplies from suppliers that are required to issue them.
As a rule, it is not compulsory to
The rental itself without status according to Section 4, Section 4b or Section 4c It's not enough.
Assess Section 85o
In the case of legal supplies it may issue e-invoice.
Separate obligation
A service supplier may send a mandatory e-invoice.
Owner's identity
It is necessary to determine who is the invoicing entity and who has the tax identification number.
Detailed explanation
Rental is a sensitive area in that it can be carried out by individuals, sole traders, limited liability companies (s.r.o.), and both VAT-registered and non-VAT-registered entities. For each landlord, it is first necessary to ascertain whether the activity is a business or a taxable activity, whether they are registered as a VAT payer, and whether they issue invoices within the scope covered by Section 85o. The receipt of invoices for utilities, property management, repairs, accounting or legal services must be dealt with separately.
As set out in the law and technical rules
The obligation to issue e-invoices is assessed in accordance with Section 85o of the VAT Act. The obligation to accept e-invoices arises from Section 71(5) and is not limited solely to VAT payers. Delivery via a delivery service is governed by Section 76a.
Practical examples
- A natural person lets out a flat and is not a VAT payer. This does not automatically give rise to an obligation to issue e-invoices.
- A limited liability company (S.r.o.) that is a VAT payer lets out offices to businesses. Provided the conditions of Section 85o are met, it may issue e-invoices.
- A landlord who is not a VAT payer receives an invoice for building management from a VAT payer. They may need a method for receiving e-invoices.
Common misconceptions
- “A landlord never needs a postman.” No. A postman may be required when receiving e-invoices.
- “Every tenancy from 2027 onwards will be processed via e-invoices.” No. It depends on the entity’s status and the specific supply.
- “It is sufficient to assess only the rental invoices issued.” No. Invoices received from suppliers are also important.
Conclusion
The lessor should first determine his position by VAT; an obligation to issue may not arise but an obligation to accept e-invoice can occur independently.
Legal and technical basis
- Act No. 222/2004 Coll. on VAT, Section 4
- Act No. 222/2004 Coll. on VAT, Section 4b
- Act No. 222/2004 Coll. on VAT, Section 4c
- Act No. 222/2004 Coll. on VAT, Section 71(5)
- Act No. 222/2004 Coll. on VAT, Section 76a
- Act No. 222/2004 Coll. on VAT, Section 85o
Related questions
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, Act No. 431/2002 Coll. on Accounting, Act No. 385/2025 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoicing, EN 16931, Peppol BIS Billing 3.0 and OpenPeppol eDelivery documentation. Verified on 13 July 2026.
Official cases from the Slovak Financial Administration’s FAQs
The following questions and answers are taken from the current July FAQ from the Financial Administration and have been assigned to this topic. Grouping the cases prevents the creation of duplicate pages, whilst retaining the full answer and the exact wording of the question.
Example No. 54: Will a landlord – who is not a VAT payer – be subject to the e-invoicing obligation?
The obligation to issue invoices in electronic format does not apply to taxable persons (e.g. landlords) who do not have the status of VAT payers (registered under Sections 4, 4b and 4c of the VAT Act). However, on the other hand, these taxable persons must be able to receive such invoices if a VAT-registered person is obliged to issue an electronic invoice to them for the supply of goods or services within the country.
Primary source: Financial Administration of the Slovak Republic, FAQ 9/VAT/2025/IM k e-invoice, July 2026 update. Processed and checked on 13 July 2026.