Do I need an e-invoicing delivery-service provider?
Short answer
Not everyone does. A private individual acting as a final consumer does not need one. From 1 January 2027, a domestic VAT payer issuing mandatory e-invoice and any legal or taxable person required to receive it must arrange access to a certified delivery service. This need not be a separate standalone product: access may be provided through accounting or invoicing software, an ERP system, a web inbox or the certified provider’s mobile application. What matters is that the recipient is genuinely reachable through the delivery service.
Who is affected and why
No.
If you shop as a normal citizen outside of your business, mandatory e-invoice doesn't concern you. The supplier is not obliged to send you e-invoice through Peppol Just because you're a customer.
Yes, for domestic deliveries
If you are a domestic payer VAT and you deliver goods or services in the mode where required e-invoice, you need a solution to its exposure, sending and receiving via delivery service.
Yes, at least for income
Although she does not have to expose herself e-invoice, must be able to accept e-invoice from the supplier obliged to issue it. So he practically needs access to the delivery service.
Yes, if you are a taxable person
Non-payer VAT does not automatically display e-invoice but as a businessman or other taxable person must be able to accept e-invoice from the payer VAT.
What does having a postman
A e-invoicing delivery-service provider is a practical term for a certified delivery-service provider. Their role is not to ‘create a nice PDF’, but to ensure the delivery of a structured e-invoice, the identification of the parties, technical processing and the necessary status or supporting data.
For a small business, this may look like a simple web-based inbox: you log in, view received e-invoices, download the XML file or grant access to your accountant. For a larger company, it may involve an API connection to an ERP system. For a client of an accountancy firm, it may be a solution provided by their accounting or invoicing software.
It is essential to distinguish between two things: the contractual and commercial relationship with the provider and technical accessibility for receipt. When receiving e-invoices, it is not enough to say ‘the accountant will sort it out somehow’. The entity must be clear about where the e-invoices will be delivered, who has access to them and how they will be transferred to the accounts.
What does this does not follow
“Every citizen must have a e-invoicing delivery-service provider.”
No. End consumers, i.e. private individuals not engaged in business, are exempt from the mandatory B2B/B2G regime.
“Non-VAT payers are not affected.”
A non-VAT payer is not obliged to issue e-invoices, but as a legal entity or business owner, they must be able to receive an e-invoice from a VAT payer.
“It’s enough for me to receive a PDF by email.”
For mandatory e-invoices, what matters is the structured electronic document and the delivery service. A PDF can only be a readable preview or an attachment.
“My accountant will sort it out for me.”
An accountant can help with selection or processing, but the business needs its own clear approach, responsibilities and method for submitting documents.
What to set up
Define your role
Are you a VAT payer, a legal entity, a non-VAT-registered business owner or a private individual? This determines whether you need to deal with issuing, receiving or neither.
Choose your approach
Web portal, mobile app, accounting software, invoicing system or ERP integration. You don’t need the most complex solution, but it must suit your volume of documents.
Arrange an accountant
If an accountant processes the documents, agree whether they will have access to the inbox, XML export, API connection or regular handover of document batches.
Test document receipt
Before going live, check that e-invoices actually arrive in the correct place and can be viewed, exported and archived.
Conclusion
If you are a private individual, you do not need a digital mail service provider. If you are a VAT payer, you need to arrange both sending and receiving. If you are a legal entity or a sole trader, even if you are not a VAT payer, you must at least arrange for the receipt of e-invoices. A separate contract with a delivery-service provider may not be the only option, but a delivery service must be effectively in place.
Verified sources
Official methodological and information materials from the Slovak Financial Administration on e-invoicing; Act No. 222/2004 Coll. on VAT, Section 71(5), Section 76a and Section 85o, as amended by Act No. 385/2025 Coll.; VPDS of the Financial Administration of the Slovak Republic. Verified on 10 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. 18: Archiving: Will archiving continue to be the responsibility of the accounting entity (taxpayer), or will this obligation (in whole or in part) be transferred to the entity responsible for delivering/transmitting invoices within the system, i.e. the e-invoicing delivery-service provider? If methodological guidance on this subject has already been issued, or if there is a reference to relevant documentation, please also send this to us.
The retention of invoices is governed by Section 76 of Act No. 222/2004 Coll. on VAT: https://www.slov-lex.sk/ezbierky-fe/pravne-predpisy/SK/ZZ/2004/222/?ucinnost=01.01.2027#paragraf-76.nadpis This section remains unchanged after 1 January 2027, so the provisions continue to apply as before. The archiving of electronic invoices for the period from 1 January 2027 to 30 June 2030 is also regulated by Section 85o(15) of the VAT Act, effective from 1 January 2027. The delivery-service provider has no legal obligation to retain the XML files (invoices) sent.
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.
Review of questions from an earlier presentation
The presentation by the Slovak Accountants’ Centre was used solely to identify practical issues. The following conclusion has been updated in line with a subsequent FAQ from the Financial Administration and the applicable legislation; we do not treat the author’s suggestions, recommendations or incorrectly merged fragments as legal rules.
- slide/page 37: Do I need to have a e-invoicing delivery-service provider even though I am a civic association that only has income from donations and the 2% tax allocation, and whose expenditure consists of donation agreements with natural persons?
Current conclusion: A legal entity must be able to accept mandatory e-invoices even if it expects to receive few such documents. However, changing providers, readability, foreign invoices and incorrect documents are separate issues and must not be lumped together into a single general answer.
Primary sources: FAQ Financial Administration of the Slovak Republic k e-invoice, July 2026; Act No. 222/2004 Coll. on VAT Effective from 1. 1. 2027. Revised 13 July 2026.