Czechia has had electronic sales recording before. Act No. 112/2016 Sb. applied from December 2016 and was repealed with effect from 1 January 2023. The adopted Sales Recording Act, which has not yet been promulgated, is intended to restore it in a different form. Alongside the payment method, where and how the customer pays will be particularly important.
The current stage of the legislation
The Government submitted the bill on 11 May 2026 as Parliamentary Paper 189. The Chamber of Deputies passed it on 15 July 2026. The Senate returned it with amendments, and on 9 September 2026 the Chamber maintained its original text. The President signed the Act on 17 September 2026. On 1 October 2026 it was sent for promulgation in the Collection of Laws. As at 6 October 2026, the parliamentary record does not yet show a number for the promulgated Act. The explanation below describes the adopted text, rather than legislation currently in force.
Under the adopted text, the Act will take effect on 1 January 2027 (§ 36). The rules on certificates and notification of recording unit details are due to take effect on the day after promulgation, although they cannot be used before 1 November 2026 (§ 29).
Who will have to record sales
Under the adopted text, personal income tax and corporate income tax payers will be subject to the recording obligation. It will cover recordable sales made in the Czech Republic (§ 2). The adopted text does not make the business’s registered office decisive. According to the explanatory memorandum, tax non-residents will record sales constituting Czech-source income under the Income Taxes Act, and only sales made in Czechia. A Slovak company with a shop, business premises or delivery operation in Czechia should therefore expect to record sales unless an exemption applies.
Which payments will be recorded
A recordable sale will be a payment that meets the formal requirements and constitutes relevant income, essentially business income (§§ 4 and 7). The formal requirements will be met by a contact payment to the taxpayer made in any of the following ways (§ 5(1)):
- in cash,
- by a cashless transfer of funds,
- using a virtual asset,
- by cheque, bill of exchange or traveller’s cheque,
- using an instrument accepted only by a limited range of suppliers or for a limited range of goods and services, such as a voucher,
- by another similar method.
The decisive concept will be a contact payment, which the adopted text defines as follows.
Original statutory wording:
Kontaktní platbou se pro účely tohoto zákona rozumí platba, a) která je uskutečněna v rámci osobního kontaktu s poplatníkem nebo b) ke které dochází v provozovně nebo v dopravním prostředku poplatníka v souvislosti s dodáváním zboží nebo poskytováním služeb.
Unofficial translation: A contact payment means a payment made during personal contact with the taxpayer or at the taxpayer’s business premises or in the taxpayer’s means of transport in connection with supplying goods or providing services.
Cash and other tangible payment instruments will count as contact payments even away from the premises and without personal contact. The exception is a payment intermediated as a postal service by transfer to the taxpayer’s payment account (§ 6(2)).
For cashless payments, the place and circumstances will matter. The explanatory memorandum expressly states that cashless transfers include card and QR code payments. A card payment at a till on the business premises will therefore generally be a recordable sale.
According to the explanatory memorandum, an online shop without physical premises, where the customer pays remotely, will generally not receive a contact payment. However, where a restaurant guest orders and pays through a website on their own phone while sitting at the table, the same memorandum treats this as a contact payment. Cash payments on delivery must be considered separately in light of § 6(2).
Exemptions
The adopted text exempts, for example, sales by the state and municipalities, banks, insurers and other financial institutions (§ 11), payments on scheduled public passenger transport directly connected with the transport and sales from postal services (§ 12), and vending machine sales (§ 13(2)). For a legal person, sales made before allocation of a tax identification number and for ten days afterwards will also be excluded (§ 13(1)).
A sale that the taxpayer must record in a comparable way under another state’s law will not be recordable if Czechia has an international information exchange treaty with that state under which it can obtain comparable data (§ 28). The explanatory memorandum interprets this exemption narrowly. It applies only to comparable systems and sales for which Czechia can actually obtain all necessary information under the treaty. A Slovak company should not rely on it without assessing whether Slovak rules cover the particular Czech sale at all.
What businesses will have to send
Before making the first recordable sale, the taxpayer will have to obtain a certificate through the tax information mailbox (§ 14) and, before obtaining the certificate, notify the details of all its recording units through which it receives sales (§ 15). A recording unit will be business premises, a website or application providing access to goods or services, a means of transport, and finally the business itself for activities outside those units (§ 3). Changes to details must be notified before the first sale following the change and no later than within fifteen days (§ 15(3)).
The sale must be recorded by sending a data message to the tax authority no later than when it takes place (§ 16). This means receipt of the payment or, if earlier, the issuing of the instruction to make it. The message will contain the taxpayer’s recording identification number, the recording unit and till identifiers, the sale sequence number, date and time, total amount in Czech crowns and message identification (§ 17(1)). The recording identification number will generally be the tax identification number, or DIČ. For an individual who has not been allocated a DIČ, it will be created under the special rule in § 18. Individual purchase items and customer details will not be sent. According to the explanatory memorandum, the adopted text does not introduce a duty to give the customer a receipt.
If the system does not respond within the response time limit set by the business, which must be at least two seconds, the business must send the sale immediately after the cause is resolved and within 48 hours at the latest (§§ 19 and 20). Seriously obstructing or preventing recording, or failing to send data, will carry a fine of up to CZK 500,000 (§§ 23 and 24). According to the explanatory memorandum, supervisory authorities will not have the power to close business premises as an enforcement measure.
How to prepare
It is sensible to wait for promulgation of the Act and check compliance with the current technical requirements before buying new equipment. The Financial Administration has already published technical documentation for developers. However, the information needed for any technical solution can be prepared now:
- a list of every place where the company receives payments in Czechia, including deliveries, stalls and collection points,
- a breakdown for each sales channel between payments made during personal contact or at business premises and remote payments,
- confirmation that the till system supplier can send sales online and submit them retrospectively following an outage,
- designation of the person who will manage the certificate and protect it against misuse (§ 14(4)).
Once the Act is promulgated, check its final number and the tax authority’s current technical requirements under § 16(5).
How we can help
We will assess which sales made by your Czech operation will have to be recorded and whether an exemption applies. We can also help amend your contract with the till system supplier. If you are just entering the Czech market, we can arrange a Czech branch or incorporation of a Czech limited liability company. Our article on organisational units and branches explains the difference between these options. Online shops combining remote sales with a collection point can use our legal services for e-commerce.
Legislative status checked as at 6 October 2026. This article describes the adopted text and does not replace an assessment of a particular operation. Before introducing recording, check the promulgated wording and the tax authority’s current guidance.
This article provides general legal information as at 6 October 2026. It does not constitute legal services or advice on your specific matter. Laws change and the details of your situation may differ. Check the appropriate course of action or contact us before making a decision.
