We are a non-VAT-paying company operating several B2C e-shops. Must we issue e-invoices?

Detailed explanation

This situation is, in fact, a combination of two separate rules, which are worth distinguishing. Firstly, as your company is not a VAT payer, it is not subject to any obligation to issue electronic invoices at all — it therefore does not matter whether you sell via one or several online shops, nor whether any of them are directed abroad. Secondly, even if you were a VAT-registered business, there is a separate exemption for invoices issued to end consumers (natural persons without a VAT number or company registration number) — meaning that even a VAT-registered business operating an online shop for consumers would not be required to issue these specific documents as e-invoices. In your case, however, this second exemption does not apply either, as there is no need to invoke it at all — the first rule alone (you are not a VAT payer) completely exempts you from the obligation to issue e-invoices. Nevertheless, as a legal entity, from 1 January 2027 you must ensure that you are able to receive electronic invoices from your suppliers (for example, the operator of an e-shop platform, hosting provider or other service providers) who are VAT payers — for this, you need a contracted e-invoicing delivery-service provider acting at least as a recipient.

As set out in the Act

The obligation to issue electronic invoices only to taxable persons under Sections 4, 4b or 4c, and the obligation for legal entities to be able to receive e-invoices, arise from Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. (Sections 71 and 85o). The exemption for invoices issued to end consumers without a tax identification number (DIČ) or VAT registration number (IČ DPH) stems from the same provision, Section 85o.

Practical examples

• A company with two domestic and two foreign e-shops, which is not a VAT payer, does not need to deal with e-invoices for any of its customers.
• Nevertheless, the same company will contract a digital mail service provider so that it can receive e-invoices from its VAT-registered suppliers.
• If the company were to become a VAT payer in the future, its invoices to end consumers of the e-shop would still be subject to a separate exemption based on the customer’s tax identification number and VAT registration number.

Most common mistakes

• “A company with multiple e-shops has stricter electronic invoicing obligations than a company with a single e-shop.” The number of online shops has no bearing on electronic invoicing obligations; only the VAT status of the company and its customers is decisive.
• “Foreign online shops automatically require electronic invoicing more often than domestic ones.” It is the VAT status and type of customer that matter, not the country where the online shop is based.

Conclusion

As a non-payer VAT you don't have to expose e-invoice any of your e-shops, regardless of their number or country of destination, but you must ensure the ability to receive e-invoice from their payment service providers.

Legal basis

• Act No. 222/2004 Coll. on VAT, Section 71 a Section 85o (as amended by Act No. 385/2025 Coll.)

Related questions

• Who is required to issue e-invoices?
• Who is affected by the obligation to accept e-invoices?

This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. Verified on 7 July 2026.