e-invoices from 2027: do hosts on the flat-rate tax need to send them?
From 1 January 2027, businesses outside the VAT system must also issue e-invoices. For most private hosts on the flat-rate tax this changes nothing, but there are exceptions worth checking in time.
From 1 January 2027, the obligation to issue and fiscalise e-invoices (eRačun) extends to taxpayers who are not in the VAT system. So the same question is going round among hosts again these weeks: do I have to send e-invoices or fiscalise invoices to guests from January?
For most private hosts who pay the flat-rate tax (paušal), the answer, according to the text of the law and the Tax Administration's guidance, is no. But there are a few situations where your obligations do change, and it's better to clear them up now than in March.
the law looks at the type of taxpayer, not the type of business
The Fiscalisation Act (Zakon o fiskalizaciji, NN 89/2025) ties obligations to tax status. A taxpayer subject to fiscalisation of invoices is a taxpayer of income tax on self-employment income or of corporate profit tax. From 1 January 2027, the same group, if not in the VAT system, must also issue and fiscalise e-invoices to other business entities. Those entered in the VAT taxpayer register have been doing this since 1 January 2026.
A host in a household on the flat-rate tax earns income from property, not from self-employment. In its guide for hosts, the Tax Administration explicitly states that taxpayers on the annual flat-rate income tax for renting do not have to fiscalise the invoices they issue.
What stays the same: an invoice to a guest is still issued in at least two copies, with the prescribed basic elements, and every issued invoice is entered in the Record of Turnover (Evidencija o prometu, form EP).
when your obligations do change
| Your situation | What applies |
|---|---|
| Flat-rate host, not in the VAT taxpayer register | No fiscalisation of invoices and no obligation to issue e-invoices; invoices and EP as before |
| Entered in the VAT taxpayer register | Issuing and receiving e-invoices already from 1 January 2026 |
| You rent out through a sole trader business (obrt) or a company | Fiscalisation of invoices; if you are not in VAT, issuing e-invoices to businesses from 1 January 2027 |
| You determine rental income under the rules for self-employment (you keep business books) | Not clear-cut; check with your accountant or the Tax Administration |
A common mix-up: the VAT identification number that many hosts have because they pay VAT on Booking's or Airbnb's commission is not the same as being entered in the VAT taxpayer register. A VAT ID number alone does not put you in the group that issues e-invoices from 2026.
what to do
- Check your status. Do you have a flat-rate decision, a sole trader business or a company, and are you entered in the VAT taxpayer register or do you just have a VAT ID number?
- If you are on the flat rate and outside the VAT register, keep issuing invoices and keeping the EP as before. You don't need to buy e-invoicing software because of 2027.
- If you operate through a sole trader business or company outside VAT, decide before 1 January 2027 how you will issue e-invoices. For smaller taxpayers, the Tax Administration is announcing a free app called MIKROeRAČUN.
- If you are in the VAT register or keep business books, ask your accountant or the Tax Administration for an answer for your specific case, preferably in writing.