Invoice for non-VAT registered businesses: what it should look like + template

Most sole traders in the Czech Republic start their business without VAT registration. With annual turnover below 2 million CZK, they are not required to register for value added tax, so they issue invoices without VAT. However, even such an invoice must meet exact legal requirements. An incorrectly issued invoice can cause problems not only for you, but also for your client — they may have an expense rejected in their tax return, or there may be confusion about the payment amount.

In this article, we'll show you in detail what details a non-VAT registered invoice must contain, what should never appear on it, what the most common mistakes are, and what it should look like in practice. We'll also include a sample invoice description you can use immediately as a template.

Who is a non-VAT registered business and when do they invoice without VAT

A non-VAT registered business is a sole trader (OSVČ) or company that:

• Has not exceeded the statutory turnover threshold — from 2025, the threshold for mandatory VAT registration is set at 2,000,000 CZK per calendar year (previously it was 1,000,000 CZK over 12 months).
• Has not opted for voluntary VAT registration.
• Does not carry out transactions that would require mandatory registration regardless of turnover (e.g. acquisition of goods from the EU above a set threshold).

If you fall into this category, you issue invoices without VAT. This means you do not show any VAT rate, tax base, or VAT amount on the invoice. The total amount on the invoice is the final price.

Required details on a non-VAT registered invoice

A non-VAT registered invoice must contain all the details required by the Civil Code for commercial documents, plus additional details necessary to substantiate the business transaction.

Why you should state that you are not VAT registered

Although the law does not explicitly require it, including the statement "I am not a VAT payer" or "The supplier is not a VAT payer pursuant to § 6 of Act No. 235/2004 Coll. on VAT" on the invoice is very important in practice:

• For your client — if the client is VAT registered, they immediately know they cannot claim a VAT deduction from this invoice.
• For clarity — it eliminates any confusion about whether the price includes VAT or not.
• In the event of an inspection — the tax authority can easily verify during an audit that you did not include VAT without entitlement.

What does NOT belong on a non-VAT registered invoice

Knowing what to leave off an invoice is just as important as knowing what to include. A non-VAT registered business must not show the following on an invoice:

What happens if a non-VAT registered person shows VAT on an invoice

This is one of the most serious mistakes a non-VAT registered person can make. Under § 108(4) of the VAT Act, if a person who is not a VAT payer shows tax on a document, they are obliged to declare and remit that tax. In other words — if you issue an invoice showing VAT while not being VAT registered, you will have to pay that VAT to the tax authority, with no entitlement to deduct any input VAT whatsoever.

Sample invoice for a non-VAT registered business

Below is a description of a sample invoice you can use as a template. All details are fictitious and are provided for illustrative purposes only.

Breaking down the sample invoice

Let's look at the key elements of the template:

1. Invoice number 2026015 — unique, contains the year and a sequential number within the series.
2. Supplier details — name, address, IČO, Trade Register entry.
3. Statement "I am not a VAT payer" — clearly informs the client.
4. Client details — including DIČ if the client is VAT registered (this is the client's detail, not the supplier's).
5. Dates — both date of issue and payment due date.
6. Payment details — account number and variable symbol for easy payment identification.
7. Description of services — sufficiently specific, with quantities and unit prices.
8. Total amount — one final sum with no breakdown into tax base and VAT.

The most common mistakes on non-VAT registered invoices

Based on practical experience, we have identified the most frequent mistakes that non-VAT registered businesses make when invoicing.

1. Showing VAT on the invoice

As explained above, this is the most serious mistake. A non-VAT registered person must not show VAT on an invoice. If they do, they become obliged to remit that tax.

2. Showing a DIČ

A non-VAT registered person has not been assigned a DIČ. Some business owners confuse IČO with DIČ, or "create" their own DIČ by adding the prefix CZ to their IČO. This is fundamentally wrong — you only obtain a DIČ upon VAT registration.

3. Missing statement about non-VAT status

While the absence of a statement that you are not VAT registered does not lead to a direct penalty, it can cause problems for a client who is VAT registered. They may incorrectly assume the price includes VAT and attempt to claim a deduction — which the tax authority will reject during an inspection.

4. Missing register entry information

Under § 435 of the Civil Code, a business person must state their registration in the relevant register on commercial documents (including invoices). For OSVČ this is typically the Trade Register; for legal entities it is the Commercial Register. A missing entry can result in a fine.

5. Incorrect or incomplete invoice numbering

Invoices must be numbered in an unbroken sequence. Skipping numbers, duplicate numbers, or the absence of a numbering system can raise doubts during a tax audit.

6. Insufficient description of the transaction

A general description such as "services" or "work" is not sufficient. The invoice should contain a specific description of what was delivered — for example, "Logo and business card design" rather than just "Graphic services".

7. Missing payment due date

Although the law does not require a non-VAT registered invoice to state a payment due date, its absence can lead to uncertainty about when payment is expected. Always include it.

Non-VAT registered invoice vs. VAT registered invoice

If you are considering voluntary VAT registration, it is useful to understand the main differences between the two types of invoices.

Specific situations when invoicing as a non-VAT registered business

Invoicing abroad

If you provide services abroad (within the EU or outside it) as a non-VAT registered person, the invoice looks similar to a domestic invoice without VAT. However, there are some specifics:

• Place of supply — for services provided to a taxable person (a business) in another EU member state, the place of supply is determined by the client's registered address (§ 9(1) of the VAT Act). This may mean you are required to register as an identified person for VAT purposes.
• Identified person — if you provide services to a business in the EU where the reverse charge mechanism applies, you must register as an identified person under § 6g of the VAT Act. This is not the same as being a full VAT payer.

Proforma invoices

A non-VAT registered person can issue proforma invoices (advance payment invoices). These are not tax or accounting documents and serve only as a request for payment. After delivering the goods or services, issue a proper invoice that accounts for the advance payment already received.

Invoicing in a foreign currency

As a non-VAT registered person, you can invoice in a foreign currency (typically EUR). Show the amount in the foreign currency on the invoice, and for tax records purposes convert it to CZK using the Czech National Bank exchange rate valid on the date the transaction took place (or the date the invoice was issued, if you keep a cash-basis tax record).

Credit notes

If you need to correct an invoice you have already issued, issue a credit note. This must contain:

• Reference to the original invoice (number and date)
• Reason for the correction
• The corrected amount (positive or negative)
• All other details required on a regular invoice

How long to keep invoices

The retention period for invoices depends on your record-keeping method:

Electronic invoicing for non-VAT registered businesses

In 2026, electronic invoicing is standard practice. As a non-VAT registered person you are not required to invoice electronically (unlike VAT payers, who must submit VAT control statements electronically), but electronic invoicing brings a number of benefits:

Benefits of electronic invoicing

1. Speed — the invoice reaches your client instantly.
2. Cost savings — no printing, envelopes, or postage.
3. Easy archiving — digital invoices are simple to store and retrieve.
4. Automation — integration with accounting software for automatic posting.
5. Environmental impact — you save paper and reduce your footprint.

Legal validity of electronic invoices

An electronic invoice has the same legal validity as a paper one, provided the following are ensured:

• Authenticity of origin — the recipient can verify the identity of the sender.
• Integrity of content — the content of the invoice has not been altered after issuance.
• Legibility — the invoice is legible from the moment of issuance throughout the entire retention period.

These conditions are met, for example, by sending a PDF invoice by email from your business email address.

Frequently asked questions about non-VAT registered invoices (FAQ)

Do I actually need to issue invoices as a non-VAT registered person?

The law does not explicitly require a non-VAT registered person to issue invoices in the sense of tax documents. However, if you keep cash-basis tax records, you need documents supporting your income and expenses. In practice, an invoice is the standard document in business-to-business transactions. If you provide services or deliver goods to another business, an invoice is a necessity.

Can I as a non-VAT registered person issue an invoice to a VAT-registered client?

Absolutely. You simply do not show any VAT on the invoice. The client — who is VAT registered — will post the full amount as an expense with no entitlement to deduct VAT. This is exactly why it is important to state your non-VAT status on the invoice, so the client does not expect a deduction.

How long should the payment terms be?

The law does not prescribe a mandatory payment period for non-VAT registered invoices. The common practice is 14 days. Between businesses, you can agree on any payment terms — most commonly 7, 14, or 30 days. If you do not state a due date and no other agreement is in place, the statutory 30-day period under § 1963 of the Civil Code applies.

Do I need to include a bank account number on the invoice?

If you require payment by bank transfer, then yes — including your account number is a practical necessity. While the law does not explicitly require it, without payment details your client cannot pay the invoice. We also recommend including a variable symbol for easy payment identification.

What if my client returns the invoice because of an error?

Do not issue a corrected invoice under the same number. The correct procedure is to issue a credit note referencing the original invoice, and then issue a new invoice with a new number. This preserves an unbroken numbering sequence and the integrity of your records.

Can I invoice in euros?

Yes, as a non-VAT registered person you can invoice in any currency. For cash-basis tax records or accounting purposes you must convert the amount to CZK using the Czech National Bank exchange rate. For cash-basis records, use the rate on the date payment is received; for accounting, use the rate on the date of the accounting transaction.

Is a proforma invoice a valid invoice?

No. A proforma invoice (advance payment invoice) is not an accounting or tax document. It serves only as a request for payment. After delivering the goods or services, you must issue a proper invoice that accounts for the advance payment received.

Practical tips for error-free invoicing

Issue invoices without the hassle with DokladBot

Filling in invoices by hand is time-consuming and error-prone. DokladBot is an AI assistant for Czech sole traders that helps you with invoicing and document management directly via WhatsApp.

Just tell it who you're invoicing and what for, and DokladBot will create an invoice with all the required details — correctly, quickly, and in full compliance with the law. No more wondering what belongs on an invoice and what doesn't.

Try DokladBot at dokladbot.cz — invoicing for non-VAT registered businesses doesn't have to be complicated.

Useful links to official sources

• Czech Financial Administration — VAT information — official information on VAT, registration and obligations
• MOJE daně Portal — electronic submissions to the tax authority
• ARES — Administrative Register of Economic Entities — verification of IČO, DIČ and other business entity details

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This article is for informational purposes only and does not replace professional tax advice. For specific situations, we recommend consulting a tax adviser. The information is current as of the date of publication (February 2026) and may change in line with legislative developments.