The Law on Electronic Invoicing (hereinafter: “ZEF”) came into effect on May 7, 2021, but its implementation was postponed, and the rights and obligations for public sector entities and private sector entities were specifically regulated.
Regarding public sector entities, the implementation of ZEF is regulated as follows:
- The obligation to issue e-invoices to private sector entities starting from July 1, 2022;
- The obligation to receive and store e-invoices issued by another public sector entity starting from January 1, 2022;
- The obligation for electronic recording of value-added tax starting from January 1, 2022;
The implementation of ZEF for private sector entities is regulated as follows:
- The obligation to issue e-invoices to public sector entities starting from January 1, 2022;
- The obligation to receive and store e-invoices issued by public and private sector entities starting from July 1, 2022;
- The obligation to issue and store e-invoices in transactions between private sector entities starting from January 1, 2023;
- The obligation for electronic recording of value-added tax calculations, except when one of the transaction participants is a public sector entity, applies from January 1, 2023.
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A system for invoice management is also intended for public sector entities, which is independent of the e-invoice system and is intended for voluntary use if:
- the public sector entity does not have its own invoice management system;
- it has multiple levels of approval in its approval processes;
The electronic invoice system can be accessed directly and indirectly. Direct access offers the following two technical solutions:
- Access via the user interface allows an authorized person to access the system through an internet browser, where they can create and issue e-invoices and/or accept and reject e-invoices, and perform electronic recording of value-added tax calculations on behalf of the transaction entity within their authority;
- Access via an application programming interface (API) that enables connection with the transaction entity’s software system (ERP – Enterprise Resource Planning). For this purpose, the Ministry of Finance has published an internal technical manual that, among other things, explains the necessary steps for connecting the ERP with the electronic invoice system.
Indirect access involves engaging an information intermediary who:
- performs tasks related to issuing, sending, and receiving electronic invoices on behalf of the public sector entity;
- ChatGPT
- performs tasks related to issuing, sending, receiving, and storing electronic invoices on behalf of the private sector entity.
The implementation of the ZEF is further regulated by secondary legislation (3 decrees and 3 regulations), as well as an internal technical manual of the Ministry of Finance, which has been in effect since January 1, 2022. Violations of the regulations in the area of electronic invoicing are subject to penalties.
