Regulatory updates - Slovenia

On October 31, 2025, the President of Slovenia promulgated the Act on the Exchange of Electronic Invoices and Other Electronic Documents (ZIERDED).

The law transposes the EU VAT in the Digital Age (ViDA) Directive (2025/516/EU) and establishes a mandatory framework for electronic invoicing and document exchange between business entities in Slovenia.

Scope

This Act applies to:

1. All business entities registered in the Business Register of Slovenia.
2. Natural persons carrying out a business activity (unless exempted as sole proprietors under the law governing companies).
3. Budget users and contracting authorities.

This Act does not apply to mass-issued documents for financial services that are exempt from VAT (e.g., bills, payment instruments, statements, notifications) and are issued by business entities instead of invoices.

Technical standards and interoperability

E-invoices must be exchanged in:

• the national e-SLOG standard,
• syntaxes compliant with the European standard for e-invoicing, or
• other internationally established standards if contractually agreed.

If the issuer and recipient use different standards, the issuer’s e-route provider must convert the e-invoice or e-document to the recipient’s syntax.

Exchange methods and providers

E-invoices and e-documents between businesses must be exchanged via:

• Registered e-route providers,
• The PEPPOL network or certified PEPPOL access points,
• Direct system-to-system exchange.

E-mail is prohibited for e-invoice exchange between business entities.

The Public Payments Administration (UJP) acts as the single entry and exit point for budget users and for business entities using the tax authority’s free e-invoicing application. All e-invoices and e-documents exchanged must go through the UJP, which serves as the central hub for both sending and receiving these documents.

Storage and data retention

E-route providers, the UJP and the business entity that directly exchanges e-invoices and e-documents must store traffic data on exchanged e-invoices and e-documents for two years and return messages for five years.

Penalties

Non-compliance with the Act may result in fines of:

• €1,000–€3,000 for legal entities,
• €500–€1,500 for sole proprietors or individuals,
• €100–€500 for responsible persons.

Additional penalties apply for violations related to consumer invoicing.

Timeline and next steps

The implementation of the Act considers the following:

• November 30, 2025: The Act on the Exchange of Electronic Invoices and Other Electronic Documents enters into force
• Until November 30, 2026: The Minister of Finance will issue all necessary implementing regulations.
• April 1, 2027: Provisions under this Act about the registration of e-route providers apply.
• October 1, 2027: The official list of e-route providers will be established.
• January 1, 2028: The main provisions under this Act enter into force.

On October 23, 2025, Slovenia’s National Assembly adopted the Act on the Exchange of Electronic Invoices and Other Electronic Documents. The law introduces mandatory e-invoice exchange between business entities, aiming to simplify operations and reduce costs.

Scope

The obligation applies to all business entities registered in the Business Register of Slovenia and natural persons carrying out a business activity. As of January 1, 2028, paper invoices will no longer be accepted in business-to-business (B2B) transactions in Slovenia.

Consumer rules

The law does not change invoicing rules for consumers. Businesses may continue issuing paper invoices unless consumers agree to receive e-invoices.

Exchange methods

E-invoices must be structured XML documents enabling automation of business processes. PDF files do not qualify as e-invoices. The exchange of e-invoices will be decentralized and carried out through secure channels using one of the following methods:

• E-mail providers (only if the recipient is a consumer),
• Proprietary direct exchange systems,
• The international PEPPOL network,
• Free miniBlagajna applications for smaller businesses.

The law does not require reporting exchanged e-invoices to the Financial Administration. It also sets standards for exchanging other electronic documents such as e-orders (e-naročilnica), e-delivery notes (e-dobavnica), e-dunning notices (e-opomin) and e-IOP.

Next steps

The text of the law was sent to the National Council on October 24, 2025. The final step will be the President’s signature before the law is officially enacted.

On February 11, 2025, the Slovenian government announced an amended version of the draft law on electronic invoicing. The law is now being passed on to the National Assembly for further approval.

Changes to the technical infrastructure

In the new version of the draft law, significant changes are made to the proposed infrastructure, including:

• Removal of reporting obligation to FURS: The previous version of the draft law proposed a reporting requirement that invoices be reported to the tax authority within 8 days of issuance. In the new version, invoices will no longer be reported to the tax authority.
• The requirement to exchange via accredited service providers: Business entities will have to contract service providers accredited in Slovenia. Additionally, this will encompass Peppol-accredited service providers, as Peppol is now explicitly mentioned as one way to comply with the exchange requirements.

Businesses may further exchange the invoices between buyer and seller, but only provided there is consent between the issuer and recipient of the e-invoice that must comply with EN-16931 standards. E-mail may not be used for invoice exchange.

Interoperability as the default model

Therefore, the default will be an interoperability model, where e-invoices are exchanged through Peppol or accredited service providers without reporting to the tax authority.

Specified certification requirements

Several requirements for service providers have also been specified. Providers will need to obtain an ISO/IEC 27001 certification to ensure invoices are exchanged compliant with standards relating to integrity and confidentiality. In addition, providers must undergo external security audits to make sure data is handled according to security standards.

Postponed timeline

Businesses are furthermore given additional time to comply with the mandate as the obligation is postponed from June 1, 2026 to January 1, 2027.

Penalties

Fines ranging from 100 to 3000 EUR will apply to taxpayers who issue e-invoices without consumer consent or deliver e-invoicing, refuse to accept EN-compliant formats, fail to manage and retain transmitted data, and more (as mentioned in the penal provisions section of the draft law).