Common misunderstanding

Does a ten-day invoicing deadline apply to domestic water supplies?

Short answer

No. The general 15-day invoicing period applies to domestic supplies, including water, electricity, gas and heat. The ten-day period under the ViDA rules is intended for cross-border supplies of goods or services within the EU from 1 July 2030, not for ordinary domestic water invoicing.

15 days, no 10

Domestic

The ten-day period does not concern normal domestic water invoicing.

Section 19(3)

Specific delivery day

No later than the last day of the clearing period, not the day of collection.

Section 85o(7)

Limit 1 month

Summary e-invoice shall not cover a longer period than a calendar month.

Consequence for waterworks

Change in the invoicing cycle

Quarterly/half-year summary invoice for e-invoice It's not enough.

Detailed explanation

For water supply companies, there is something more important than the specific duration of the period. The supply of water distributed via the mains network is classified as a supply of goods made on a recurring or partial basis under Section 19(3), first sentence, of the VAT Act — the tax liability arises no later than the last day of the accounting period to which the payment for the supplied water relates, not at the physical moment of water consumption by the customer. From this date of supply, the standard 15-day period for issuing an invoice then begins. A truly significant change for water supply companies with monthly, quarterly or half-yearly invoicing is Section 85o(7) of the VAT Act, which, from 1 January 2027, allows a summary electronic invoice to be issued for multiple recurring supplies covering a maximum period of one calendar month. A quarterly or half-yearly summary invoice in a single document will therefore probably not be possible for e-invoice — it will be necessary to switch to monthly invoicing or to issue several separate documents covering a longer billing period.

As set out in the Act

The first sentence of Section 19(3) of Act No. 222/2004 Coll. on VAT regulates the date of supply for goods supplied in instalments or on a recurring basis, including electricity, water, heat and gas. Section 85o(7) of the VAT Act (as amended by Act No. 385/2025 Coll.) limits the scope of a summary electronic invoice to a period of no more than one calendar month. The ten-day deadline for cross-border supplies from 1 July 2030 is based on Council Directive (EU) 2025/516 (ViDA).

Practical examples

The water company currently issues a single summary invoice on a quarterly basis; for e-invoices, it will have to issue invoices at most on a monthly basis.
The date of water supply for the March billing period is 31 March at the latest; the 15-day deadline for issuing the invoice begins on this date.
The company will swap the 10-day cross-border deadline from 2030 for the standard 15-day domestic deadline, which is already in force today.

Most common mistakes

“A 10-day deadline for issuing invoices applies to domestic water supplies.” The general 15-day period applies; the 10-day period will only apply to cross-border supplies within the EU from 1 July 2030.
“The date of supply of water is always the date of physical collection by the customer.” According to the first sentence of Section 19(3) of the VAT Act, this is no later than the last day of the accounting period.
“A quarterly or half-yearly summary invoice may also be issued as an e-invoice without any changes.” Section 85o(7) limits a summary e-invoice to a maximum of one calendar month.

Conclusion

Domestic water supplies use the 15-day rather than ten-day period; water suppliers must also account for the one-calendar-month limit on a summary e-invoice.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 19(3) First sentence
Act No. 222/2004 Coll. on VAT, Section 85o(7) (as amended by Act No. 385/2025 Coll.)
Council Directive (EU) 2025/516 of 11. 30 March 2025 (ViDA)