Does e-invoice apply to invoices for supplies made in December 2026?
Short answer
No. The transitional obligation under § 85o ods. 2 of the VAT Act applies where the VAT payer makes the relevant domestic supply, or receives payment before that supply, from 1 January 2027. The decisive point is the date of the supply of goods or services, not the later date on which the related invoice is physically issued.
Delivery of goods or services
Not the invoice date.
Outside mandatory e-invoice
Delivery before 1.1.2027 is not controlled by a mandatory mode.
Mandatory e-invoice
It shall apply to deliveries made from that date onwards.
No decision on the regime
Also, the invoice issued in January 2027 for December delivery remains outside the mandatory e-invoice.
Conclusion
Mandatory e-invoice applies to the specified supplies made from 1 January 2027; an invoice for a December 2026 supply remains outside that regime even if issued later.
Sources
- Law No. 222/2004 Z. z. o VAT, § 85o ods. 2 (as amended by Law No. 385/2025 Z. z.)
zákon č. 385/2025 Z. z., prechodné ustanovenie § 85o ods. 2
Not legal advice.