Must advance-payment invoices also be sent through an e-invoicing delivery-service provider?
Short answer
Yes. An invoice issued for a payment received before goods or services are supplied is a regular invoice under § 72 ods. 1 of the VAT Act, not a separate document with a lower legal status. From 1 January 2027 it is therefore subject to the same electronic-invoicing regime as a normal final invoice: it must be issued in the required structured format and sent through a certified delivery service like any other e-invoice.
Advance invoice = regular invoice
Accepted payment in advance establishes the obligation to draw up an invoice in the same way as for delivery.
From 1/1/2027
An advance invoice is subject to the same structured format and delivery service as a regular invoice.
Differentiation of documents
A request for payment without invoice details is not sent through the e-invoice system.
The same as for a regular invoice
It also applies to the invoice for the received payment in advance.
Conclusion
An advance invoice issued for a payment actually received is a regular invoice and, starting in 2027, it must be sent via a e-invoicing delivery-service provider in the same way as a regular billing e-invoice.
Sources
- Law no. 222/2004 Z. z. Coll. on VAT, § 72 ods. 1
- Law no. 222/2004 Z. z. Coll. on VAT, § 85o (as amended by Act No. 385/2025 Z. z. Coll.)
Not legal advice.