E-Invoices after 1 January 2028: New Rules for Business Entities

On 23 October 2025, the National Assembly of the Republic of Slovenia adopted the Act on the Exchange of Electronic Invoices and Other Electronic Documents (ZIERDED), which introduces mandatory exchange of e-invoices between business entities and also regulates rules regarding their issuance to consumers.

From 1 January 2028, business entities will be required to exchange exclusively e-invoices for mutual supplies of goods and services carried out in Slovenia. Business entities are considered to be entities registered in the Slovenian Business Register (e.g., limited liability companies (d.o.o.), joint-stock companies (d.d.), branches), as well as natural persons performing activities who are not sole traders under the Companies Act (ZGD-1) (e.g., lawyers, notaries, private medical practitioners).

The Act does not apply to foreign business entities not registered in the Slovenian Business Register and registered in Slovenia solely for VAT purposes. The same applies to permanent establishments for tax purposes.

a)    Exchange of e-invoices

E-invoices will be exchanged in the eSLOG standard, in syntaxes compliant with European standards for electronic invoicing, or in other internationally recognised standards, if previously agreed.

The exchange of e-invoices will take place either via e-route providers listed in the relevant register of providers, through PEPPOL network, or via proprietary systems for direct exchange of e-invoices. The Slovenian tax authority also provides a free application called miniBlagajna for e-invoice exchange, primarily intended for users with a smaller volume of business. Sending e-invoices by email between business entities is not permitted.

E-invoices and e-documents with state budget users will continue to be exchanged via the UJP system, which remains the single entry/exit point for state budget users.

b)    Mandatory data on e-invoices

An e-invoice must include the data defined as mandatory by the regulations governing compulsory invoice elements.

c)    Storage of e-invoices and data

Each issuer and recipient, except consumers, must ensure the storage of e-invoices in accordance with the requirements of VAT regulations and accounting and bookkeeping legislation.

E-route providers and business entities that exchange e-invoices directly must also retain traffic data on exchanged e-invoices for 2 years from receipt or sending. The minimum set of traffic data includes an identification number, date of sending and receipt, identification data of the issuer and recipient, and delivery data. Identification data of the issuer or recipient includes an email address, bank account number, or tax number.

UJP, e-route providers, and business entities that exchange e-invoices directly must also ensure storage of acknowledgement messages for 5 years from receipt or sending.

d)    Issuing e-invoices to consumers

Business entities may send e-invoices to consumers only if there is an explicit prior agreement between the parties. The burden of proof regarding the existence of such agreement lies with the business entity. The consumer may withdraw consent at any time and request that the business entity issues a paper invoice.

Consumers may receive e-invoices via e-invoice receipt service providers, through the business entity’s application, or via email.

When a business entity sends an e-invoice to a consumer, a visual representation of the invoice must also be attached in PDF, TIFF, or another standard format enabling easy viewing of the invoice content.

e)    Offences and fines

Offences include, in particular, breaches of the obligation to exchange e-invoices in the prescribed format, use of prohibited transmission methods, and failure to comply with storage requirements and provision of prescribed data. Fines range from EUR 500 to EUR 3,000, and for responsible persons from EUR 100 to EUR 500.

Given the scope of the changes, we recommend that business entities review the adequacy of their accounting and IT systems and their methods of exchanging e-invoices with business partners. In many cases, adjustments to existing solutions or integration into appropriate e-invoice exchange networks will be required.

Your KM Consulting team