I have a VAT number under § 7a. Do I have to issue e-invoices from 2027?
No. Registration under § 7a does not make you a VAT payer, so you do not have to issue e-invoices. However, from 1. 1. 2027, you must be able to receive them. We explain why and what you need to prepare.
It is being written everywhere that from 1. 1. 2027, VAT payers must issue e-invoices. Anyone with a VAT number under § 7a therefore often asks whether this also applies to them. They are also referred to as a “partial payer”. The short answer is:
You do not have to issue e-invoices. You must be able to receive them.
Why the obligation to issue does not apply to you
“Partial payer” is not a term used in the law. The VAT Act distinguishes between:
- a taxable person, that is, a person registered under § 4, § 4b or § 4c (for example, after exceeding the turnover threshold of 50 000 €),
- a person registered for tax under § 7 or § 7a, who receives a VAT number only because of transactions in goods or services within the EU.
The obligation to prepare an electronic invoice (§ 85o of the VAT Act as amended by Act No. 385/2025 Coll.) applies to a taxable person. In its responses, the Financial Administration explicitly states that this concerns a domestic supply “supplied by a domestic taxable person registered under § 4, 4b, 4c”. It further states that the obligation does not apply to a taxable person who is not a VAT payer.
A person registered under § 7a is not a VAT payer. Even an assigned VAT number does not change that.
So what do you have to do
From 1. 1. 2027, every business must be able to receive an e-invoice if their supplier – a VAT payer – is required to send it. This also applies to you. In practice:
- Choose a digital postman (a certified delivery service provider) from the list on the Financial Administration portal.
- Register through them in the Peppol network. Your address will be derived from your tax identification number (0245:DIČ).
- Invoices from Slovak suppliers who are VAT payers (materials, telephone, software, accounting, etc.) will be delivered to you this way from January.
How this looks for individual transactions
| Situation | Is an e-invoice mandatory? |
|---|---|
| You invoice a Slovak company (without VAT, as a non-payer) | no, you send the invoice as before (e.g. PDF) |
| You invoice a service to an EU company (reverse charge) | no, the first phase only concerns domestic supplies |
| You receive an invoice from Google, Meta, etc. from abroad | no, this is not a domestic supply |
| You receive an invoice from a Slovak VAT payer | yes, you must be able to receive it |
Cross-border supplies are to be included only in the second phase, which is planned from 1. 7. 2030. Its exact rules have not yet been published.
You can issue them voluntarily
A non-payer may also join voluntarily. This does not create an obligation to send all invoices this way. If you do, under the Peppol rules (BR-O-02), the supplier’s and customer’s VAT number is not stated on an invoice from a non-payer, only the tax identification number. In addition, the Financial Administration states that the system reports invoice data depending on whether a VAT number is shown on it. DSDATA handles this automatically for non-payers.
When this will change
You would only have the obligation to issue e-invoices once you become a genuine VAT payer. For example, after exceeding the turnover threshold of 50 000 € (VAT payer from 1 January of the following year) or 62 500 € (VAT payer immediately). More in the article When you become a VAT payer.
Summary for § 7a
- Issuing e-invoices: no (you may do so voluntarily).
- Receiving e-invoices: yes, from 1. 1. 2027.
- Digital postman: yes, for receiving.
- Your other obligations under § 7a (tax return for months in which a service from the EU was received, recapitulative statement) remain the same. See Registration under § 7a.
Sources
- Financial Administration of the Slovak Republic – Frequently asked questions and answers on eInvoice, questions Nos. 7, 54, 57, 63 and the answer to § 85o para. 2 (version of 11. 9. 2026)
- Financial Administration of the Slovak Republic – VAT registration obligation (§ 4, § 7, § 7a)
- Peppol BIS Billing 3.0 – rule BR-O-02
This article is for information purposes only and is based on the regulations and sources listed in the text as valid on the verification date. It does not replace tax advice – for a specific situation, please contact a tax adviser or the Financial Administration.
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