EET se vrací, ale v jiné podobě a s novými dopady

The Electronic Sales Registration (EET) is returning to the legislative process after several years. The government’s draft law is planned to take effect from the beginning of 2027 and does not aim to simply restore the original system. A fundamental change is the abandonment of the distinction between cash and cashless payments, replaced by the concept of so-called contact payments.

What matters is not how the customer pays, but whether the payment occurs in personal contact with the entrepreneur or at their place of business, or in another comparable context. Problematic situations may arise especially when multiple entities are involved in a single transaction, such as partner locations, franchise networks, marketplace models, platforms, or logistics service providers, where the customer pays upon receipt of goods or services, but the money is collected by an intermediary.

The draft law emphasizes who receives the decisive income and the role of the individual entities involved. This may require a review of existing contractual documentation. Legal responsibility for recording the sales will rest with the entity to whom the law assigns this obligation, not necessarily the entity that technically collects or processes the payment.

Some entities or activities will not be subject to registration at all, usually due to strong regulation of the relevant sector.

The return of EET is therefore not just a technological issue but a shift in how the state views income registration in an increasingly complex business environment. Proper assessment of the decisive facts and appropriate contractual arrangements will be key to ensuring compliance with electronic sales registration under the legal framework. We are ready to assist you with this assessment.

We are preparing an article on this topic for our upcoming Tax and Legal Reports.

Authors:

Ivana Krylová
Dušan Kmoch
Jonáš Kozák
Matěj Šimpach