Electronic sales records (EET 2.0) are returning: an obligation aimed at income tax taxpayers – and, in certain cases, at non-residents too

What the package contains

The core of the bill is the records of sales themselves. The accompanying amendments touch the Income Tax Act, the VAT Act and the acts on the Financial and Customs Administration of the Czech Republic. The package therefore reaches beyond the records of sales into income tax and VAT. Those amendments will be discussed in future articles.

Who and what is recorded

Both personal and corporate income tax taxpayers are subject to the records, and the subject matter is sales carried out on the territory of the Czech Republic. What is recorded are primarily payments arising during personal contact with the customer or on business premises (so-called contact payments) – typically cash, card, QR payment, a virtual asset, a cheque or a bill of exchange – provided they give rise to decisive income, i.e. income from business activity. A sale must be recorded no later than when it is carried out, by sending a data message to the tax administrator authenticated by a certificate obtained through the tax information mailbox (DIS+). Unlike the original regime, the bill, according to the Ministry of Finance, does not introduce any obligation to issue and print receipts.

Exemptions

The bill provides for a number of exemptions – among others, sales of selected public-law entities and financial institutions, minor ancillary activities of public-benefit taxpayers, mass and air transport, postal services, gambling and vending machines are excluded. It also includes a special regime (so-called EET OFF) for entrepreneurs in the first band of the flat-rate tax with annual income up to CZK 1 million, who may choose not to record their sales (for the so-called surcharge).

Impact on tax non-residents

The obligation is tied to the status of an income tax taxpayer, not to tax residency. A tax non-resident who carries out business activity in the Czech Republic and earns income from sources on Czech territory – typically through a permanent establishment – may, in respect of that income, be a taxpayer for Czech income tax purposes. If they receive recorded contact payments in connection with that activity on Czech territory, the recording obligation may arise. The bill addresses cross-border situations: a payment is not a recorded sale where the taxpayer is obliged to record it in a comparable manner under the law of a state with which the Czech Republic has an agreement on the exchange of comparable information. Non-residents should therefore assess both whether the obligation arises and whether it can be excluded.

Penalties, effective date, work schedule and recommendations

Frustrating the records or failing to send the data message may attract a fine of up to CZK 500,000; the Financial Administration exercises competence, and the Customs Administration may also inspect and impose on-the-spot fines. However, unlike the original EET system, failure to comply with these obligations should not lead to the closure of business premises or the suspension of business activities. Under the bill, the act is to take effect on 1 January 2027, with January 2027 envisaged as a trial run. Regarding the implementation schedule, the technical documentation for developers of cash register systems is expected to be published in mid-June 2026, with the testing environment available from 1 July 2026. The EET 2.0 functionality within the DIS+ environment, including certificate generation, should be available from 1 November 2026, while the MY EET (MOJE EET) application is expected to be available from 1 December 2026.

Affected taxpayers should map their premises and cash register systems in good time and obtain certificates through DIS+; non-residents are advised to verify whether their income constitutes decisive income and whether the above exemption applies. As this is still a government bill under discussion in the