Non-payer registration

Must a non-VAT payer register a delivery-service provider with the Financial Administration when using it only to receive e-invoice?

Short answer

Yes. The provider-selection and registration process through the Slovak Financial Administration portal is the same whether the provider is used for both issuing and receiving or only for receiving. A non-VAT payer that is required to be able to receive e-invoice must therefore select and register its certified delivery-service provider through the portal.

Same portal

Regardless VAT Status

Registration of the provider takes place via the FS SR portal for all.

Reason

Heading in SMP

The system must know where to send e-invoice to tax identification number.

Non-payer VAT

Registration required

Although he only uses the mailman to receive.

Presumption of acceptance

Technical necessity

Without registration, the entity in the network is not addressable.

Detailed explanation

The reason is that the central metadata system (SMP), in which the entity registers, needs to know where to route e-invoices addressed to a given identifier (VAT number) within the Peppol network, regardless of whether the entity is a VAT payer obliged to issue invoices or a non-VAT payer obliged only to receive them. Registration is therefore a technical prerequisite for receipt as such, not something that applies only to those obliged to issue invoices.

As set out in the Act

The selection and registration of a certified delivery-service provider via the Slovak Financial Administration’s portal relates to Section 76a of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. The obligation for taxable persons (including non-VAT payers) to be able to receive e-invoices arises from Section 71 of the same Act.

Practical examples

A non-VAT payer with an assigned VAT number selects a provider via the Slovak Financial Administration portal exclusively for the purpose of receiving e-invoices.
Without this registration, a VAT-registered supplier would have nowhere to send an e-invoice to the non-VAT-registered party in question.
Registration for non-VAT payers follows the same process as for VAT payers, but with a different scope of service use.

Most common mistakes

“Only VAT payers obliged to issue e-invoices need to register a provider on the Slovak Financial Administration portal.” Registration is required for anyone who is to be addressable on the Peppol network for receiving e-invoices, including non-VAT payers.
“A non-VAT payer can receive e-invoices without any prior registration.” Without registration in the central SMP, their identifier cannot be found on the Peppol network.
“Registration for receiving e-invoices is simpler or different from registration for issuing them.” It involves the same process of selecting a provider via the FS SR portal; the only difference is the scope of subsequent use of the service.

Conclusion

A non-VAT payer using the provider only for receipt selects and registers that provider through the Financial Administration portal in the same way.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 71 a Section 76a (as amended by Act No. 385/2025 Coll.)