Can we agree after 1 January 2027 to send e-invoice by email outside a delivery service?
Short answer
Yes. § 85o ods. 2 permits e-invoice to be sent by a method other than a delivery service where the recipient consents. It must still be a structured, machine-processable e-invoice meeting § 85o ods. 4; a PDF alone is not sufficient. The Financial Administration’s current FAQ also states that during the 2027–2030 transitional period the reporting obligation is linked to e-invoice sent or received through a delivery service.
The beneficiary must agree
A channel other than a delivery service shall be permitted only with the consent of the recipient.
Must be XML
The alternative channel does not change the requirement for structured and machine processable e-invoice.
PDF alone is not enough
A readable preview may be attached but does not replace structured data.
Not automatically via mailman
FAQ FS binds reporting between 2027 and 2030 to use delivery service.
Conclusion
Email can be agreed channel for structured e-invoice. However, there is no exception to XML the format and during the transitional period does not create automatic reporting via delivery service.
Sources
- Law No. 222/2004 Z. z. o VAT, § 76a a § 85o ods. 2, 9 and 10
- FAQ Financial Administration k e-invoice, example No. 61
Words-Lex: Law No. 385/2025 Z. z. · FAQ Financial Administration k e-invoice
Not legal advice.