Overview of the Draft Law on Electronic Invoicing

The draft law introduces a centralized electronic invoicing system managed by the Public Revenue Office for issuing, receiving, validating, accepting, rejecting, correcting, cancelling, storing, and evidencing e-invoices and related documents in structured electronic format. It aims to modernize invoicing, improve tax and accounting transparency, and enable automated processing.

  • System and validation: The system may be accessed through API integration, client, web, or mobile applications. A validated e-invoice receives a unique invoice identifier and electronic timestamp; validation confirms technical compliance, not the transaction’s legal, tax, or material accuracy.
  • Covered documents: The system covers invoices, credit/debit notes, advance invoices, VAT-related reports, invoice-delivery notes, construction statements, delivery and return notes, internal invoices, import reports, and other prescribed documents.
  • Required content: E-invoices must include invoice identifiers, dates, issuer and recipient data, transaction details, discounts, taxable amounts, VAT rate and amount, total amount, legal grounds for exemptions or special VAT treatment, and the authorized signer.
  • Legal validity: An e-invoice is valid when issued through the system in structured format, signed with a qualified electronic signature, and validated. Printed visual versions may have evidentiary value and can be checked by QR code.
  • Issue, receipt, and response: An invoice is issued and received when available in the system and notified electronically. Recipients may accept or reject it by the 10th day of the following month; silence means acceptance for tax and accounting purposes.
  • Corrections, storage, and outages: Only the issuer may correct or cancel an e-invoice through the system by issuing a new linked invoice. E-invoices must be stored under tax procedure rules and are downloadable for up to two years after the year of issue. If the system is unavailable for 24 continuous hours, invoices may be issued outside it but must be submitted within five working days after restoration.

Scope and transition

The obligation applies broadly to VAT-registered taxpayers, business entities not registered for VAT, certain individuals performing business activity, budget users, public and state-controlled entities, the National Bank, tax representatives, enforcement-related entities, self-billing recipients, and certain VAT debtors. Exemptions include some fiscal-receipt transactions, defence and security public procurement, specific VAT-exempt transactions, certain special VAT subjects, and final consumers.

Timeline: voluntary registration starts on 1 October 2026; mandatory use begins for VAT-registered taxpayers and specified public/state-owned entities on 1 April 2027, for non-VAT legal entities performing business activity on 1 July 2027, for budget users and state/municipality-financed institutions on 1 October 2027, and for all entities performing transactions on 1 January 2028.

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