Is the recipient’s consent required for electronic invoicing?
Short answer
No, not where the supplier is required by law to issue e-invoice and it is delivered through a certified delivery service. The recipient’s consent is required where the parties use another delivery method, such as email, instead of the delivery service.
Consent not required
If copy e-invoice by legal obligation.
Consent required
Agreement between supplier and customer.
Just keep your mouth shut.
For example, by processing and paying an invoice without objections.
Simplification of the transition
Removal of the consent requirement should speed up implementation e-invoice.
Detailed explanation
This principle applies in both directions: the recipient cannot refuse to accept an e-invoice simply because they do not agree with the transition to electronic form, if its issuance is a legal obligation for the supplier. However, if the supplier and the recipient agree on a different channel (for example, continuing to send invoices by email alongside a delivery service), such an agreement requires the recipient’s consent — and, according to the official methodological and information materials of the Slovak Financial Administration, implied consent is also sufficient, for example if the recipient processes and pays the invoice without objection.
As set out in the law and the FAQs
This follows from the official methodological and information materials of the Slovak Financial Administration on e-invoices and from Section 85o of Act No. 222/2004 Coll. on VAT, which distinguishes between delivery via a certified delivery service (consent not required) and other methods of dispatch (consent required).
Practical examples
- A VAT payer sends a mandatory e-invoice via a digital mail service — the recipient cannot refuse delivery on the grounds of disagreeing with the format.
- The supplier and the customer agree that they will continue to send invoices by email — the customer’s consent is required for this.
- The recipient receives the e-invoice by email and pays it without comment — this constitutes implied consent.
Most common mistakes
- “The customer may refuse to accept an e-invoice because they do not agree with it.” No, if its issuance is a legal obligation and it is delivered via a certified service.
- “Consent must always be in writing.” No, implied consent is also sufficient, for example by paying the invoice.
- “Consent is required for every method of delivery.” No, it is not required at all for a delivery service.
Conclusion
Consent is not required for mandatory e-invoice delivered through a certified service; it is required for an agreed alternative delivery method such as email.
Legal basis
- Official methodological and information materials Financial Administration of the Slovak Republic k e-invoice
- Act No. 222/2004 Coll. on VAT, Section 85o
Related questions
- Do I need an e-invoicing delivery-service provider?
- What to do if the beneficiary disagrees e-invoice?
- Can we agree to send documents outside the FS SR system by email?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, official methodological and information materials from the Slovak Financial Administration on e-invoicing. Verified on 9 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 No. 12: Is the recipient’s consent to electronic invoicing required in Slovakia?
No, removing the requirement for the recipient’s consent simplifies the transition to electronic invoicing. Where the issue of an electronic invoice is mandatory, the recipient’s consent to its issue is not required.
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.