Electronic invoice in Slovenia
Comprehensive guide to electronic invoicing in Slovenia – B2G mandate since 2015 via UJP eRačun with e-SLOG and Peppol support
Slovenia has had mandatory B2G e-invoicing since 2015, and now has a law for the rest. ZIERDED — the Act on the Exchange of Electronic Invoices and Other Electronic Documents (Zakon o izmenjavi elektronskih računov in drugih elektronskih dokumentov) — was adopted on 23 October 2025 and makes structured e-invoicing compulsory for domestic B2B from 1 January 2028.
Two things about it are widely misreported. It is not a clearance or reporting system — the earlier proposal to report invoice data to the tax authority within eight days was dropped, and the final law contains no per-invoice transmission to FURS. And it is not a Peppol mandate: Peppol is one of four permitted channels, of equal standing with the others. What the law does ban is ordinary email.
The 2028 date has moved several times. Earlier proposals pointed at April 2026, then July 2026, then January 2027. The adopted law settles on 2028 — and along the way lost its reporting obligation entirely.
Suppliers of goods and services to budget organisations must send electronic invoices through the infrastructure of the Public Payments Administration (Uprava Republike Slovenije za javna plačila, UJP).
A separate real-time system for cash invoices, connecting cash registers to FURS. It is not replaced by ZIERDED — see Cash fiscalisation.
ZOPSPU-1A, published on 26 July 2019, extended the European standard rules to contracting authorities under the public procurement legislation, including those that are not budget users. The relevant provisions applied three months after entry into force.
The National Assembly adopts the Act on the Exchange of Electronic Invoices and Other Electronic Documents; it was published on 6 November 2025.
The ZIERDED provisions on e-path providers (ponudniki e-poti) start to apply — the first operative date for anyone intending to run national infrastructure. See Requirements for providers.
UJP is to maintain the official register of registered e-path providers from this date, three months before the mandate itself.
Structured e-invoices must be sent and received between businesses covered by the Act. Paper and PDF-only invoices stop satisfying the mandate.
The EU obligations for the cross-border transactions in scope. See ViDA and 2030.
The secondary legislation is still outstanding. The implementing acts are due within twelve months of the law entering into force — approximately by 6 December 2026 — and the full set has not yet appeared. Final APIs, testing procedures and the details of the national register may therefore still be specified. Build with those layers configurable.
Two points that get lost. First, the boundary is drawn precisely: after 1 January 2028 paper invoices are no longer allowed between businesses, but they remain allowed with consumers and with foreign companies. Second, the mandate is two-sided — a Slovenian business must be able to receive structured invoices as well as issue them, so a company that sells only to consumers still needs receiving capability for its own suppliers.
UJP is the central gateway for public sector invoicing, and it has been for a decade. Three routes reach budget users:
UJP acts as a routing and delivery gateway, not as a tax clearance platform. It validates and forwards; it does not authorise the invoice for VAT purposes. Foreign suppliers can and do invoice Slovenian budget users through their own certified Peppol Access Point without any Slovenian registration.
From 2028 the law sets out four ways to exchange a domestic B2B e-invoice. They are alternatives, not a hierarchy — and understanding that Peppol is one option among four is the difference between a correct implementation plan and an expensive assumption.
Providers registered with UJP in the national register — the domestic exchange network, with its own accreditation and obligations.
The Peppol Network and its certified Access Points, listed in the Act as a channel in their own right.
Permitted only by agreement between the parties, and only where the requirements on security, integrity, identification, delivery notifications and delivery deadlines are met.
The state's free tool, intended for entities with a smaller volume of business, with transmission through UJP as the transport point. Format choice is restricted — see Formats and PDF.
All four routes run over secure electronic paths. Sending by email will not be permitted — except where the recipient is a consumer. That is the operational change most Slovenian SMEs will actually feel in 2028: not the XML, which their accounting software will produce, but the loss of "just email it over" in business-to-business trade.
The future Slovenian B2B system is decentralised and non-clearance. ZIERDED does not provide for transmitting each electronic invoice to the tax authority.
The free miniBlagajna application does not change this. It is a tool for creating and exchanging invoices, transmitted through UJP as the transport point — the law does not provide that the invoice data collected there is used for mandatory transaction reporting. The government states the position plainly: the Act does not provide for reporting exchanged e-invoices to FURS, and it does not interfere with the Cash Register Validation Act. What changes is the form of the invoice, from paper to electronic — not the tax process around it.
Worth stating explicitly because earlier commentary said otherwise: the proposal circulated in 2025 included reporting invoice data to FURS within eight days. That obligation was removed from the adopted Act. Any planning document still budgeting for a Slovenian e-reporting build is working from a superseded draft.
ZIERDED does not require the exchange of other electronic documents. What it does is set the standards and the method of exchange if businesses choose to use them — covering the e-order, e-delivery note, e-reminder and e-IOP (statement of open items). Useful to know when a client asks whether the 2028 project has to cover the whole document set: it does not.
Slovenia already has a CTC-like system, and it has nothing to do with ZIERDED. Since 2 January 2016, cash registers connect to a central FURS system which confirms and stores invoice data in real time at the moment of issue.
Three regimes therefore coexist and should never be conflated: cash fiscalisation (real-time confirmation of cash invoices by FURS, in force), B2B e-invoicing from 2028 (structured exchange with no tax clearance), and ViDA from 2030 (near-real-time reporting of cross-border intra-EU transactions). ZIERDED replaces neither of the other two.
ZIERDED permits three categories of format, which makes Slovenia unusually flexible for a mandate country.
The free application will only handle e-SLOG or syntaxes from the official EN 16931 list. An arbitrary international format agreed between the parties is not available on that channel — so the format freedom the Act grants does not extend to the free option.
A PDF is not an electronic invoice within the meaning of ZIERDED. The mandatory domestic B2B invoice must be a structured, machine-readable document capable of automatic processing.
A PDF remains useful as the visualisation of the XML invoice, as an attachment, as the readable version for a consumer, and in dealings with foreign companies outside the domestic mandate where the general VAT rules and the parties' agreement allow it. Where a structured e-invoice is sent to a consumer, a visualised version is mandatory.
For consumers the Act changes nothing by default: businesses continue to issue paper invoices unless the consumer agrees to receive them electronically. An electronic invoice may be sent to a consumer only on the basis of prior explicit consent, and a consumer may withdraw that consent at any time and require the business to revert to paper.
Where a structured e-invoice does go to a consumer, a visualisation is mandatory — and notably it is mandatory only for consumers. Email delivery also remains permitted in this direction, which is the single exception to the ban on email.
These are enforceable duties with their own penalty scale — lower than the B2B one, but real. A retailer that switches everyone to electronic invoices by default, without consent and without a readable version, is committing a distinct offence from anything on the B2B side. The right to withdraw consent means the paper path has to stay operational, not just documented.
The national Peppol electronic address scheme is 9949 — Slovenia VAT number (SI:VAT), used in EndpointID/@schemeID. The UJP participant identifier, for example, takes the form 9949:si10641424.
There is no separate Slovenian EAS for the business register number in the current Peppol code list — unlike Estonia, Latvia or Lithuania, where the registry code is available alongside the VAT number. General international schemes such as GLN 0088 can be used where the parties agree, but 9949 is the Slovenia-specific one, and a participant without a VAT number is correspondingly harder to address.
Peppol is legally not the sole or compulsory channel, either for B2G today or for B2B from 2028. It matters practically because every Slovenian budget user is reachable through the UJP Access Point — but the system cannot be described as Peppol-based.
OpenPeppol lists the Slovenian Ministry of Finance and UJP as an AP Provider and an SMP Provider — but not as a Peppol Authority, and UJP sits within the OpenPeppol governance zone. So UJP is simultaneously the state B2G gateway, a certified Access Point and an SMP provider, while OpenPeppol performs the contracting authority function for Slovenian Access Points.
Two statuses exist in Slovenia and they are not the same thing: a national e-path provider (ponudnik e-poti) registered with UJP, and a certified Peppol Access Point operating over the Peppol Network.
Working through the national infrastructure requires entry in the UJP register, which is a genuine national accreditation — functionally similar to admitting a national e-delivery provider. The conditions include:
On the literal wording of Article 9 — no, not where the provider serves clients through Peppol. The Act lists registered e-path providers, the Peppol Network, certified Peppol Access Points and direct systems separately, which indicates that a Peppol Access Point is an independent lawful channel and need not also obtain national provider status merely to deliver over Peppol. Registration is needed if the same provider wants to connect to the national UJP register and exchange invoices outside Peppol as a ponudnik e-poti.
A certified Access Point from another EU country can serve Slovenian clients. For B2G this is already confirmed in practice — Slovenian and foreign legal entities may invoice budget users through their own certified Peppol Access Point. For the 2028 B2B regime the Act does not restrict the Peppol route to Slovenian Access Points either.
The obligations on a registered e-path provider are more detailed than most national regimes, and worth reading before deciding you want that status:
Retention splits three ways, which is unusual and easy to implement wrongly. Transport metadata: two years. Return messages: five years. The invoice itself: kept by sender and recipient under the VAT and accounting rules — and as a general rule the provider deletes the transmitted document after successful delivery unless the parties have separately agreed archiving.
From 2028, sanctions apply to failing to issue or receive a mandatory domestic B2B e-invoice, using an impermissible transport channel, providing national e-path services without registration, and breaching the requirements on retaining transport data and messages.
For sending an e-invoice without the consumer's consent, failing to provide a visualisation, or refusing to issue a paper invoice:
Until 1 January 2028 — no. The Slovenian VAT Act (ZDDV-1) permits paper and electronic invoices. To deduct input VAT the taxpayer needs an invoice complying with Articles 80a–84a of ZDDV-1 and must meet the other substantive and formal conditions.
From 1 January 2028, the structured electronic form becomes the mandatory lawful form of exchange for domestic B2B, so a paper or PDF-only invoice will breach ZIERDED and create a serious compliance risk.
But the two questions stay separate. ZIERDED imposes administrative fines; it contains no provision that the absence of an e-invoice automatically and unconditionally cancels the buyer's right to deduct VAT, and it does not replace the substantive conditions under ZDDV-1.
Invoices are generally retained for ten years, rising to twenty years where the invoice relates to real estate. Electronic invoices are kept in their original, unaltered digital form.
That second point deserves emphasis. Slovenia is one of the few countries to say explicitly in law that the intermediary discards the document — so a business that assumes its provider is quietly keeping a copy for ten years will find nothing there in year three.
From 1 July 2030, ViDA introduces mandatory e-invoicing and transaction-level digital reporting for the covered cross-border B2B transactions inside the EU. The reporting will be based on e-invoice data and will replace the existing system of aggregated recapitulative statements.
Slovenia has not yet published a national technical architecture for ViDA reporting. Whether it runs through a Peppol five-corner arrangement, a separate FURS interface or another mechanism is undecided — which means the 2028 domestic build and the 2030 reporting build should be kept deliberately loosely coupled.
Slovenia does not require a licence to serve clients over Peppol — but it does require getting the channel question right:
9949, with the endpoint verified rather than assumed from the VAT numberSlovenia now has a full B2B mandate with a firm date and an unusually liberal design. From 1 January 2028 structured e-invoices must be sent and received between covered domestic businesses — through any of four channels, in any of three format categories, with no clearance and no reporting to the tax authority.
The corrections that matter against older material: the eight-day FURS reporting obligation was dropped, the date is 2028 rather than 2026 or 2027, and Peppol is not mandatory — it is one lawful channel among four, and a certified foreign Access Point can use it without Slovenian registration.
Two practical things to carry away. Ordinary email stops being an option for domestic B2B — that is the change most small businesses will feel. And the provider deletes the document after delivery, so the ten-year archive has to be yours.