Are there exceptions to mandatory e-invoice?
Short answer
Yes. There are specific cases in which an electronic invoice is not issued even though the transaction might otherwise fall within the mandatory regime. The Financial Administration’s FAQ identifies, in particular, classified supplies and supplies for state security bodies such as the Slovak Information Service or Military Intelligence. In those cases, a paper invoice or another legally permitted method is used.
Not a normal exception
Exceptions shall apply to specific security or classified services.
Obligation Remains
If the law does not provide an exception, the payer VAT can not choose paper only from convenience.
Special schemes
The FAQ includes, for example, SIS and Military Intelligence.
Consider the specific delivery
It determines the nature of the performance, not the general type of company.
Detailed explanation
This exemption does not provide any practical relief for the average business owner who does not wish to use e-invoices. It applies to a narrow range of situations where standard electronic exchange via a delivery service could conflict with confidentiality requirements, security rules or the specific nature of the transaction. In the case of standard B2B transactions between Slovak businesses, therefore, it is not possible to argue that a company can simply opt for a paper format. First, there must be a specific legal reason why an e-invoice should not or must not be issued.
As set out in the law and the FAQs
Official guidance documents from the Slovak Financial Administration refer to classified transactions and supplies for state security agencies. The basic scope of the obligation to issue e-invoices is set out in Section 85o of the VAT Act; exceptions must be interpreted in conjunction with specific regulations and the nature of the particular supply.
Practical examples
- A supply relating to classified activities may fall outside the standard e-invoicing regime.
- A standard invoice for office services provided to a Slovak company does not constitute an exception simply because the customer prefers a PDF format.
- If a company is unsure whether a supply is classified or security-related, it should seek a legal or methodological assessment before issuing the document.
Common misconceptions
- “I can opt for the exemption if I don’t have the software ready.” No. A lack of technical readiness is not an exemption from the legal obligation.
- “It’s enough that the recipient doesn’t want an e-invoice.” No. Where e-invoicing is mandatory, the recipient’s consent to the issuance is not required.
- “Every supply to the state is an exemption.” No. The exemption applies to specific security or classified cases, not to all B2G transactions.
Conclusion
The exceptions are narrow and mainly concern classified or security-related supplies; ordinary businesses cannot use them as a general way to avoid e-invoice.
Legal basis
- Financial Administration of the Slovak Republic - official methodological and information materials k e-invoice
- Act No. 222/2004 Coll. on VAT, Section 85o
Related questions
- Who is required to issue e-invoices?
- Is the recipient’s consent required?
- From when do I have to issue e-invoices?
This does not constitute legal advice. Sources: Act No. 222/2004 Coll. on VAT, official methodological and information materials from the Slovak Financial Administration on e-invoicing, Peppol BIS Billing 3.0 as relevant. Verified on 13 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 8: Are there any exceptions where electronic invoices cannot be issued?
There are specific cases where electronic invoices must not be issued. This mainly concerns classified transactions or supplies to state security agencies (the Slovak Information Service, Military Intelligence). In these cases, traditional paper invoices or other forms are used.
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.