For all deliveries to their employees, employers will have to issue a fiscalized invoice

According to the regulations currently in force, invoices that are paid in cash and by credit cards are subject to the obligation of fiscalization, but not invoices paid in other ways. From January 1, 2026, the obligation of fiscalization will be introduced for every issued invoice for sales intended for final consumption, regardless of the payment method. Business entities subject to the fiscalization obligation 1.0 will have to fiscalize every invoice issued for final consumption from January 1, 2026, whether they are paid in cash, by credit cards, by bank transfer, by postal order, by offsetting, or by salary deduction. This obligation also applies to deliveries from employers to their employees, regardless of how they are charged for them.

Every single invoice

In the practice of business entities, deliveries of goods and services to employees occur for their personal and family consumption. Employers sell mobile phones, computers, the right to use sports and recreation services that the employer has purchased or contracted, etc. Sometimes the motivation for such actions is the price that the supplier allows for the sale of larger quantities, thus accommodating their employees.

Employers sell old devices and machines, used furniture, surplus raw materials and materials, etc. Also, in certain situations, inventory shortages of goods are invoiced to the employee who is charged for the resulting shortage. Regardless of how the employee will pay for the goods or services purchased from the employer – in cash at the employer’s cash register, by payment to a bank transaction account, or by salary deduction, employers who are subject to fiscalization 1.0 must fiscalize the outgoing invoices issued to employees from January 1, 2026. The obligation does not depend on whether VAT is charged on the outgoing invoice or if it is a delivery exempt from VAT; every invoice for final consumption is fiscalized.

Regardless of the VAT obligation

Taxpayers of fiscalization 1.0 are legal and natural persons who are subject to corporate income tax and natural persons who are subject to income tax from self-employment, whether or not they are VAT taxpayers. Employers organized as institutions, non-profit associations, and other organizations are not subject to fiscalization 1.0, but only on the condition that they are not corporate income tax payers. If they are corporate income tax payers, then they are automatically subject to fiscalization 1.0 by the regulations.

For example, commercial companies are corporate income tax payers, so a commercial company that sells a mobile phone to an employee from January 1, 2026, will have to fiscalize that invoice, regardless of how the employee will pay for it. The obligation of fiscalization also includes invoices that the employer charges based on the previously obtained consent of the employee by deducting from the employee’s salary. In contrast, an institution or another legal entity that is not a corporate income tax payer does not have the obligation to fiscalize the issued invoice when selling goods and services for final consumption to its employees.

How to prepare

Entrepreneurs who are already subject to the fiscalization of cash invoices under the existing regulations will only expand the data about the business premises and the device from which they issue invoices for deliveries to employees, if such a need arises. Business entities that are corporate income tax payers and self-employment income tax payers who have not been subject to the obligation of fiscalization of cash invoices until the end of 2025 because they operate exclusively in the B2B system, and intend to make deliveries to employees from January 1, 2026, must timely carry out preparatory actions to establish a B2C invoice fiscalization system.

They must ensure an internet connection and a software solution that allows for the issuance of invoices while conducting the fiscalization process in the Tax Administration’s computer system, immediately before handing over the invoice to the end consumer. The invoice issued to the employee must contain the prescribed elements, including, among others, the data about the issuer of the invoice, the operator’s designation, the payment method designation, a unique invoice identifier, the issuer’s protection code, and a QR code.

Issued invoices must be numbered according to the prescribed rule so that each invoice has a three-part number indicating the numerical invoice number, the designation of the business premises, and the number of the device from which the invoice is issued. Invoices must be numbered in an uninterrupted sequence, without gaps or skips. All of this must be arranged by the employer through their acts, and the Tax Administration must be electronically provided with data about the business premises where they will issue invoices for final consumption to their employees. This can be the same business premises and/or the same device from which they issue invoices to other end consumers, or it can be a separate space and a separate device.