Electronic sales registration is returning to the legislative process after several years, but in a fundamentally different form from what businesses knew in the past. The government bill, planned to take effect from the beginning of 2027, does not reinstate the original technical EET model but reflects a significant shift in how the state approaches the recording of income in the commercial environment.
A key change is the abandonment of the distinction between cash and cashless payments. Instead, the concept of a so-called “contact payment” becomes central. What matters is no longer the payment method used, but whether the payment takes place in personal contact with the business, at its premises or in a comparable physical context. Contact payments may therefore include cash, card payments, or even on-site QR payments. This new definition significantly affects more complex business structures. The bill emphasizes who ultimately receives the relevant income for income tax purposes and in what legal capacity the individual parties act, rather than who technically processes the payment.
Legal responsibility for recording the transaction will lie with the entity to which the law assigns this obligation, even if collection or payment infrastructure is handled by a third party. In practice, this may require revisiting existing contractual relationships and clearly defining the roles of all involved parties.
At the same time, the proposal includes a number of exemptions, particularly for highly regulated sectors where income is already monitored through other legal mechanisms. Small businesses are also offered an alternative option to opt out of the reporting obligation in exchange for a higher flat-rate payment.
The return of EET should therefore not be seen merely as a technical or administrative change. It represents a conceptual shift towards assessing the economic substance of transactions, placing greater demands on the proper legal and tax evaluation of business models. Early and expert adjustment of processes and contractual arrangements will be crucial. The final version of the law may still change, particularly regarding the definition of obligated entities and exemptions. We will keep you informed of further developments.
