Why do some accounting teams request a PDF in addition to the archived XML?

Detailed explanation

In practice, this most often involves three aspects: firstly, many internal approval processes (who approves which invoice for payment, who verifies its accuracy) have historically been based on the assumption that a person simply views the document as an image or PDF, and not every company already has a convenient tool built into its software to view XML directly. Secondly, it is a matter of inertia and mistrust of the new format, which will likely fade over time as tools for viewing XML become a standard feature of accounting software. Thirdly, your observation from abroad — where XML is sent via post and the PDF separately by email — is a valid concern: if these two channels are not synchronised, there is a risk that someone will work with an out-of-date or incorrectly assigned PDF, whilst only the XML remains legally binding. The correct solution is not to abandon PDFs altogether, but to have a single secure tool capable of displaying the XML in a readable format at any time upon request, without the need to maintain a parallel, separately delivered file.

As set out in the Act

The obligation to retain an electronic invoice for ten years in its original XML format is laid down in Section 85o(15) of Act No. 222/2004 Coll. on VAT. The requirement for the invoice to be legible and for this to be met by displaying it on request rather than permanently storing it in a legible form is confirmed by the interpretation of Section 71(3) of the VAT Act, according to which it is not necessary to have the invoice permanently available in a legible form (for example, as a PDF file stored alongside the XML) — a mechanism that generates a legible output from the XML on request is sufficient.

Practical examples

• The company will integrate an XML viewer into its accounting software, and the approval process will be just as convenient as it was previously with PDFs.
• A foreign partner sends the XML via Peppol and the PDF separately by email, which causes confusion as to which document is the current one.
• Once a reliable tool for viewing XML has been introduced, the company will no longer require PDFs to be retained alongside the XML.

Most common mistakes

• “The law requires the permanent concurrent storage of both XML and PDF.” The law requires the archiving of XML and readability on request, not the permanent duplication of PDFs.
• “Insisting on PDFs is always justified by a legal requirement.” In most cases, this is a matter of organisational habit or the incomplete digitisation of approval processes.
• “The solution to the confusion between XML and PDF is to stop using PDF altogether.” The solution is a reliable XML viewer that generates a readable output on demand, not a rejection of the readable format as such.

Conclusion

Retain the XML and ensure that it can be displayed in human-readable form; keeping a parallel PDF is generally an internal practice, not a statutory duty.

Legal basis

• Act No. 222/2004 Coll. on VAT, Section 85o(15)
• Act No. 222/2004 Coll. on VAT, Section 71(3)

Related questions

• Is a PDF an e-invoice?
• In what format should I submit e-invoices during an audit?
• May PDF be attached to e-invoice?

This does not constitute legal advice. Sources: Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoice. Verified on 7 July 2026.