Transitional period

Does e-invoice apply to invoices for supplies made in December 2026?

Short answer

No. The transitional obligation under § 85o ods. 2 of the VAT Act applies where the VAT payer makes the relevant domestic supply, or receives payment before that supply, from 1 January 2027. The decisive point is the date of the supply of goods or services, not the later date on which the related invoice is physically issued.

Decision date

Delivery of goods or services

Not the invoice date.

December 2026

Outside mandatory e-invoice

Delivery before 1.1.2027 is not controlled by a mandatory mode.

January 2027 and later

Mandatory e-invoice

It shall apply to deliveries made from that date onwards.

Invoice exposed later

No decision on the regime

Also, the invoice issued in January 2027 for December delivery remains outside the mandatory e-invoice.

Detailed explanation

This means that an invoice for goods or services supplied in December 2026 does not fall under the mandatory e-invoicing regime, even if this invoice is not issued until January 2027 (for example, within the standard 15-day period for issuing an invoice following delivery). Such an invoice will be issued in accordance with the rules in force prior to the introduction of the mandatory e-invoicing scheme. Conversely, if the taxable person supplied goods or services on 1 January 2027 or later, the invoice for that supply is subject to the mandatory e-invoicing regime, even if it were physically issued, for example, at the beginning of January shortly after the supply.

As set out in the Act

Section 85o(2) of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll. imposes an obligation to issue an electronic invoice on a taxable person who, ‘with effect from 1 January 2027’, has supplied goods with a place of supply within the country pursuant to Section 13, or a service with a place of supply within the country pursuant to Section 15 or Section 16, or has received payment prior to such a supply.

Practical examples

Goods supplied on 28 December 2026 are invoiced on 8 January 2027 in accordance with the existing rules, not as a mandatory e-invoice.
Goods supplied on 2 January 2027 are already subject to the mandatory e-invoice regime, regardless of the fact that this is only a few days after the New Year.
When the year changes, the company primarily takes into account the date of delivery, not the date on which it physically processed the invoice.

Most common mistakes

“The e-invoicing system applies to all invoices issued after 1 January 2027, regardless of the delivery date.” The decisive factor is the date of delivery of the goods or services, not the date the invoice was issued.
“An invoice for a transaction in December 2026 must be sent via the digital post office if it is not issued until January 2027.” As the supply took place before 1 January 2027, this invoice is not subject to the mandatory e-invoice scheme, regardless of the date of issue.
“The transitional period is calculated from the calendar year in which the invoice is issued.” The transitional provision in Section 85o(2) is expressly linked to the date of supply, not to the calendar year in which the invoice was issued.

Conclusion

Mandatory e-invoice applies to the specified supplies made from 1 January 2027; an invoice for a December 2026 supply remains outside that regime even if issued later.

Legal basis

Act No. 222/2004 Coll. on VAT, Section 85o(2) (as amended by Act No. 385/2025 Coll.)