Czech Kontrolní Hlášení: VAT Control Statement Guide for AP Teams

The Czech kontrolní hlášení (KH) is the Czech Republic's mandatory VAT Control Statement. Every Czech VAT-registered taxpayer must file it electronically, reporting individual invoices that exceed CZK 10,000 with granular detail: the supplier's DIC (tax identification number), the invoice number, and the exact tax amounts charged. The Czech tax authority uses this data to cross-check what buyers report against what sellers report, matching transactions on both sides to detect VAT fraud and reporting discrepancies.

This guide walks through everything AP teams, accountants, and financial controllers need to handle KH compliance with confidence:

• Who must file and when: filing obligations, frequencies, and deadlines for different entity types
• The CZK 10,000 reporting threshold: how this cutoff determines whether a transaction is reported individually or as an aggregate, and what it means for your invoice processing workflows
• Required invoice data fields: which specific data points from each invoice feed directly into the KH, and why getting them wrong creates compliance exposure
• The escalating penalty structure: fines that reach up to CZK 500,000 for non-compliance, with automatic penalties that apply even without fault
• The 2025 Section 74b unpaid invoice rule: a 2025 provision requiring VAT deduction reversals on invoices left unpaid for six months

What makes the kontrolní hlášení significant for AP operations is that it turns invoice data accuracy into a legal compliance requirement. The Czech tax authority (Finanční správa) actively cross-checks your reported invoice data against your suppliers' filings. When the numbers do not match, the result is a formal discrepancy investigation, and potentially financial penalties. Every invoice field you capture, from the DIC to the tax base amount, becomes auditable data that the government verifies independently.

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What Is the Kontrolní Hlášení and Why It Exists

The kontrolní hlášení, or VAT Control Statement, has been a mandatory filing requirement in the Czech Republic since January 2016. It functions as a transaction-level invoice data cross-check operated by the Czech Financial Administration (Finanční správa), and it fundamentally changes what invoice data accuracy means for every business registered for Czech VAT.

The mechanism works like this: both the buyer and the seller independently report detailed invoice data for the same transaction to the tax authority. The Finanční správa then matches these two submissions against each other. When the data reported by one party does not align with the data reported by the counterparty, the system flags a discrepancy and the authority can initiate an investigation into the transaction.

The primary objective behind the KH is fraud prevention. Before its introduction, carousel fraud and missing trader fraud schemes were draining the Czech VAT system of billions of CZK each year. These schemes exploited the gap between aggregate VAT reporting and the lack of granular transaction visibility. The kontrolní hlášení closes that gap by giving the Czech tax authority a line-by-line view of every qualifying transaction, making it far harder for fraudulent chains to operate undetected.

The KH and the standard Czech VAT return serve different purposes, and AP professionals encounter both. The VAT return reports aggregate totals grouped by VAT rate. The kontrolní hlášení, by contrast, reports individual invoice-level detail for every transaction above the reporting threshold. These are separate filings submitted on different schedules, but they must be fully consistent with each other. Any discrepancy between your KH data and your VAT return totals will itself raise questions.

The operational implication is significant. Because both sides of every transaction report the same invoice data independently, a data extraction error or manual entry mistake on your side can trigger a mismatch with your supplier's filing. The supplier may have reported everything correctly, but if your reported figures diverge, the Finanční správa flags the transaction regardless of which party made the error. This is what makes invoice data accuracy a direct compliance obligation in the Czech Republic, not merely an internal efficiency concern. And the Czech Republic is not alone in this approach. Other EU member states have introduced their own granular invoice-level reporting requirements, such as Poland's mandatory split payment mechanism, each tying invoice data quality directly to regulatory compliance.

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Who Must File the Kontrolní Hlášení and When

Every Czech VAT-registered taxpayer is required to file the kontrolní hlášení. This obligation applies to Czech-domiciled companies and to foreign entities that hold a Czech VAT registration. If you are registered for Czech VAT, there are no exemptions from KH filing.

Filing frequency depends on the type of entity:

• Legal entities (companies) must file monthly, without exception. Even if your company files its VAT return on a quarterly basis, the KH is always due every month.
• Individual entrepreneurs (sole traders) file on the same schedule as their VAT return. If your VAT return period is monthly, so is your KH. If quarterly, you file the KH quarterly.

A common and costly misconception is that periods with no relevant transactions require no filing. They do. A nil kontrolní hlášení must be submitted for any period where no reportable transactions occurred. Failing to submit a nil return triggers the same penalties as missing a populated one.

The filing deadline is the 25th of the month following the end of the reporting period. There is no grace period. If the 25th falls on a weekend or public holiday, standard Czech tax calendar rules apply, but building your process around the 25th as a hard cutoff is the safest approach.

Electronic-Only Submission

The kontrolní hlášení must be filed exclusively through electronic channels. Paper submissions are not accepted under any circumstances. Two authorized submission methods exist:

• Datová schránka (Data Box): A government-mandated secure electronic mailbox automatically assigned to all Czech-registered companies. Messages sent and received through a datová schránka carry the same legal weight as registered post, with legally binding timestamps for every communication. Tax authority responses, summons, and penalty notices are also delivered through this channel, making active monitoring of your Data Box essential for Czech VAT compliance.
• Moje Daně (MY TAX portal): The Czech tax authority's online filing portal, available as an alternative to the datová schránka for KH submission.

Consistency with the VAT Return

Your KH filing must be consistent with the VAT return (přiznání k DPH) submitted for the same period. The Czech tax authority automatically cross-references both filings, and discrepancies between the KH and the VAT return trigger additional scrutiny or formal requests for explanation. This level of automated cross-checking reflects a broader European trend toward digital tax compliance infrastructure, similar to Germany's GoBD digital record-keeping requirements. Beyond the VAT return, KH data must also be consistent with your EC Sales List (souhrnné hlášení) for intra-EU B2B supplies and with Intrastat declarations for physical goods above the reporting threshold.

The next section explains the CZK 10,000 threshold, which determines how much invoice-level detail you are required to report in the kontrolní hlášení.

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The CZK 10,000 Reporting Threshold

The kontrolní hlášení uses a single invoice value threshold to determine how transactions are reported: CZK 10,000 including VAT. This figure is the dividing line between invoices that require full individual reporting and those that can be grouped into aggregate totals.

Invoices with a total value exceeding CZK 10,000 (VAT included) must be reported as separate line items in the KH. Each individually reported invoice requires a complete set of data fields: the supplier or customer's DIC (tax identification number), the invoice number, the date of taxable supply (DUZP), the tax base broken down by applicable VAT rate, the corresponding VAT amount per rate, and the relevant supply type code. The next section covers each of these required fields in detail.

Invoices at or below the CZK 10,000 threshold follow a simpler reporting path. These transactions are reported as cumulative totals grouped by VAT rate. No individual invoice identification is needed, so there is no requirement to capture supplier DIC, invoice numbers, or dates of taxable supply for these smaller transactions.

This CZK 10,000 invoice reporting threshold is the operational decision point that dictates data capture requirements. At roughly EUR 400, the threshold sits well below the value of most B2B commercial transactions between Czech-registered businesses. In practice, the majority of supplier invoices your team processes will exceed this amount and require full individual reporting in the KH. High-volume invoice processing environments face this reality at scale: nearly every commercial invoice demands precise, field-level data capture to satisfy Czech VAT control statement requirements.

One detail that catches teams off guard is that the threshold applies to the total invoice value including VAT, not the net (pre-tax) amount. An invoice with a net value of CZK 9,200 at the standard 21% VAT rate carries a total of CZK 11,132, placing it above the threshold and into individual reporting territory. Always evaluate invoices against the CZK 10,000 line using the VAT-inclusive figure.

With most B2B invoices falling above this threshold, the accuracy requirements for individually reported invoices become the default standard for your AP workflow.

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Required Invoice Data Fields for the Kontrolní Hlášení

Every invoice above the CZK 10,000 threshold that you report individually in the kontrolní hlášení must include a specific set of data fields. The Czech Financial Administration cross-checks each of these fields between the buyer's and the seller's filings, so accuracy across every single data point is a compliance requirement, not a preference. Here is what the KH demands:

• DIC (daňové identifikační číslo): The Czech tax identification number of your counterparty. It follows the format "CZ" followed by 8 to 10 digits. Both the buyer and the seller report this number, and the Financial Administration matches them directly. Even a single incorrect digit will trigger a mismatch between filings.

• Evidenční číslo daňového dokladu (invoice number): The unique identifier printed on the invoice. Both parties report this number, and it must be identical in both KH filings. Differences that seem trivial, such as leading zeros, extra spaces, or inconsistent formatting conventions between your system and the supplier's, are enough to cause a discrepancy.

• DUZP (datum uskutečnění zdanitelného plnění): The date of taxable supply, meaning the date when goods were delivered or the service was performed. This is one of the most common sources of KH errors because the DUZP is frequently different from the invoice issue date. Reporting the wrong date, particularly entering the invoice date instead of the actual supply date, will create a timing mismatch with your counterparty's filing.

• Základ daně (tax base): The net amount broken down by each applicable VAT rate. If an invoice includes items at the 21% standard rate and items at the 12% reduced rate, you must report the tax base for each rate separately. Aggregating them into a single figure will not pass the cross-check.

• DPH (daň z přidané hodnoty): The VAT amount corresponding to each tax base at the correct rate. This figure must align precisely with the reported základ daně. A rounding discrepancy or an incorrect rate assignment will be flagged during the cross-check.

• Kód plnění (supply type code): A code that categorizes the nature of the transaction. Common categories include regular domestic supply, reverse charge, corrective documents, and intra-EU supply. Selecting the wrong code misclassifies the transaction in the Financial Administration's system.

Because the KH functions as a bilateral cross-check, the Financial Administration flags any discrepancy between what the buyer reports and what the seller reports for the same transaction. When a mismatch is detected, you receive a notification and typically have 5 calendar days to explain or correct the error. With six data fields per invoice and potentially hundreds of invoices per filing period, even a low per-invoice error rate compounds into a significant compliance risk.

The practical challenge is that these Czech invoice data requirements for KH compliance demand consistent, reliable capture from invoices that arrive in different formats, templates, and languages. Accurately extracting the DIC, invoice number, DUZP, tax base, and VAT amount from every document, and then verifying that each field matches the original, is repetitive and error-prone when handled manually at volume. For teams processing large batches of Czech supplier invoices, tools that automate Czech invoice data extraction reduce the risk of manual transcription errors across these fields. Invoice Data Extraction, for example, lets teams specify field-level extraction rules, such as standardizing all dates to YYYY-MM-DD for DUZP compliance or extracting DIC and invoice number into consistent columns, and its multi-language support handles Czech-language invoices without additional configuration.

Regardless of how your team captures this data, validating invoice data before submission is a critical step. Cross-referencing your extracted fields against the original invoices before you file helps catch the formatting inconsistencies and transcription errors that trigger KH discrepancies.

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Penalties for Late or Incorrect Kontrolní Hlášení Filing

The Czech VAT compliance penalties for kontrolní hlášení failures follow a strict escalation structure.

CZK 1,000 is the automatic fine for filing the kontrolní hlášení after the deadline. This penalty applies per filing period without any prior warning or formal communication from the tax authority. There is no discretion involved and no grace period. If the KH arrives late, the fine is assessed automatically.

CZK 10,000 applies when the tax authority issues a formal reminder, known as a výzva, and the filer then submits the KH in response. The reminder is delivered through the datová schránka and typically includes a short response deadline. Receiving a výzva signals that the tax authority is actively tracking the non-compliance.

CZK 30,000 is the penalty for failing to file the KH even after a formal summons from the tax authority. At this stage, the filer has ignored both the original deadline and the subsequent reminder, and the tax authority treats the case as a deliberate compliance failure.

Up to CZK 500,000 represents the maximum penalty reserved for serious or repeated non-compliance. This includes deliberate non-filing, obstruction of tax administration, or a pattern of systematic failure to cooperate with the tax authority's requests.

One partial relief provision exists: during the first calendar year in which a KH penalty arises, sole traders (OSVČ) and single-shareholder limited liability companies (jednočlenné s.r.o.) may receive a 50% reduction on the penalty amount. This first-violation discount does not apply in subsequent years or to other entity types.

The escalation dynamic deserves attention. A missed deadline that would cost CZK 1,000 if addressed immediately can reach CZK 500,000 through inaction, repeated failures, or refusal to cooperate. The penalty structure is specifically designed to compel prompt compliance, and each level of non-response triggers the next tier.

Beyond direct fines for late or missing filings, data mismatches create a separate compliance risk. When the data reported in your kontrolní hlášení does not match what the counterparty (your supplier or customer) has reported in theirs, the tax authority sends a discrepancy notification. You then have approximately 5 calendar days to respond with either a correction to your filing or a written explanation of the difference. Failing to respond within that window pushes the case into the higher penalty tiers, compounding the financial exposure from what may have started as a data entry error.

Filing deadlines and data accuracy are the two most visible compliance dimensions, but they are not the only ones. A rule introduced in January 2025 under Section 74b adds another layer by connecting invoice payment status directly to kontrolní hlášení reporting obligations.

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The 2025 Section 74b Unpaid Invoice Rule

Starting in January 2025, the Czech VAT Act introduced Section 74b, a rule that ties invoice payment tracking directly to VAT compliance. Under this provision, if a received invoice remains unpaid for six or more months past its due date, the buyer must reverse the VAT input deduction originally claimed on that invoice. The reversal then needs to be reported in the buyer's kontrolní hlášení for the period in which the correction occurs.

The practical consequence is significant. The kontrolní hlášení obligation no longer ends when an invoice is accurately reported at the time of receipt. Each invoice now carries a six-month aging clock, and if payment is not completed within that window, the original KH filing effectively becomes incomplete without a follow-up correction.

The scale of the exposure is considerable. According to the Atradius Payment Practices Barometer for the Czech Republic, 61% of B2B invoices in the Czech Republic are paid past their due date, with bad debts accounting for around 10% of all B2B invoices. Under Section 74b, a large portion of those overdue invoices could trigger mandatory VAT reversals and corresponding KH corrections if they cross the six-month threshold.

This creates a three-way data dependency for every Czech supplier invoice your team processes. You need to maintain: the original invoice data as reported in the KH, the current payment status, and the elapsed time since the due date. An invoice that was correctly reported in a prior KH filing may require a correction entry in a future filing solely because payment was delayed. Tracking these connections manually across hundreds or thousands of invoices per month introduces real risk of missed reversals and the penalties that follow.

Section 74b transforms the kontrolní hlášení from a point-in-time reporting obligation into a continuous one. Your team must monitor the payment lifecycle of each invoice long after it has been received and initially reported. This ongoing record-keeping requirement parallels obligations in other European tax systems, where maintaining audit-ready invoice records with complete payment histories is standard practice, much like preparing invoice records for German tax audits.

The final section consolidates all of these KH requirements, including the Section 74b tracking obligation, into a practical preparation checklist for AP teams.

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KH Compliance Checklist for AP Teams

Kontrolní hlášení compliance rests on three operational pillars: accurate invoice data capture for every invoice exceeding CZK 10,000, timely electronic filing by the 25th of the following month, and ongoing invoice payment tracking under the 2025 Section 74b rule. The checklist below translates these requirements into steps your AP team can implement immediately.

Invoice threshold classification

• Check every Czech supplier invoice against the CZK 10,000 threshold (total amount including VAT). Invoices at or above this threshold require individual line-by-line reporting in the KH. Invoices below the threshold can be grouped into cumulative totals for the reporting period.

Data field accuracy for reportable invoices

• For each invoice above the threshold, capture all required KH fields with precision:
  • DIC (daňové identifikační číslo): Verify the supplier's tax ID follows the CZ + 8-to-10-digit format. A single transposed digit will trigger a mismatch when the tax authority cross-references the seller's KH filing against yours.
  • Invoice number (evidenční číslo daňového dokladu): Record the exact invoice number as printed on the supplier's document. The buyer's and seller's KH submissions must contain an identical string for cross-matching to succeed.
  • DUZP (datum uskutečnění zdanitelného plnění): Capture the date of taxable supply, which frequently differs from the invoice issue date. Using the wrong date shifts the transaction into the wrong reporting period.
  • Tax base and VAT amount per rate: Split amounts correctly across applicable VAT rates (21% standard, 12% reduced). Mixed-rate invoices require a separate line for each rate.
  • Supply type code: Assign the correct KH section code that classifies the nature of the transaction.

Pre-filing validation

• Validate every supplier DIC against the Czech VAT register (Registr plátců DPH) before submitting your KH. An unregistered or cancelled DIC means the deduction is ineligible and the filing will contain an error.
• Reconcile your KH data against the VAT return (přiznání k DPH) for the same period. The aggregate figures in both filings must align. Discrepancies between them are a common trigger for tax authority inquiries, and catching mismatches before submission prevents avoidable corrections.

Filing deadlines and submission

• File the kontrolní hlášení by the 25th of the month following the reporting period. For legal entities, this deadline applies monthly regardless of whether your VAT return is filed monthly or quarterly.
• Submit through your datová schránka (data mailbox) or the Moje Daně portal. Monitor your datová schránka actively for communications from the tax authority. A summons to correct (výzva) carries a five-day response window, and missing it escalates penalties from CZK 1,000 to CZK 10,000 or more.

Section 74b payment tracking

• Track invoice aging for the six-month unpaid invoice rule introduced under Section 74b. Flag any received invoices approaching the threshold where VAT was deducted but payment has not been made to the supplier.
• Prepare VAT deduction reversals in the reporting period when an invoice crosses the six-month boundary. Waiting until a later period creates a correction liability and potential penalties.

Looking ahead: The Czech Republic's transaction-level KH reporting is part of a broader shift across EU member states toward real-time digital tax reporting. The EU's ViDA (VAT in the Digital Age) initiative will extend similar invoice-level reporting obligations to cross-border transactions. AP teams that build accurate, automated invoice data capture into their Czech compliance workflows now will carry that operational foundation forward as these requirements expand across jurisdictions.