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Slovenia

Policy module: src/events/compliance/policies/si.py (SloveniaPolicy, using FiscalizedInvoicingMixin, plus one organizer notice).

Issue: #1062

Status

Restricted: attendee invoicing blocked for organizers established in Slovenia and for physical events held there.

The Fiscal Verification of Invoices Act (ZDavPR) requires every invoice paid "in cash" to be verified with FURS in real time. For ZDavPR, "cash" includes card payments. The FURS detailed description (Podrobnejši opis) lists Stripe in §3.2.4, with the outcome depending on the provider's payment-service status, and §3.3 treats online payments paid out to the seller in batches as cash. FURS has no Stripe-specific opinion. Revel's attendee invoices are not verified with FURS.

What Revel does

  • Attendee invoicing cannot be enabled. Switching to HYBRID or AUTO is refused (HTTP 422) for organizations whose resolved country is Slovenia, with a translated explanation, naming Slovenia, that invoices must go through FURS invoice verification.
  • Generation is skipped (invoice generation, issuing an existing draft, including drafts created before the gate, and credit notes) for sales by organizers established in Slovenia, and for physical events held in Slovenia by foreign organizers, because the law there reaches sellers of supplies made in Slovenia. Virtual events held by foreign organizers are not affected. A foreign organizer can still enable attendee invoicing; only the sales Slovenia reaches are skipped.
  • Existing settings: organizations in Slovenia that had HYBRID or AUTO were switched to NONE by the data migration 0128_disable_blocked_attendee_invoicing. Existing invoices were not touched. No notification was sent automatically, so affected organizers should be informed out of band.
  • Organizer notice (non-blocking), for organizers established in Slovenia and physical events held there (the same sales the block reaches), shown next to the attendee-invoicing setting (key si_furs, topic attendee_invoicing): "Revel can't issue attendee invoices where Slovenian rules apply: invoices paid by card or online must be verified with FURS in real time. FURS treats card payments, and online payments paid out to you in batches (as Stripe usually does), as cash payments. If you must issue invoices, issue a FURS-verified invoice for every paid sale from your own software, even with attendee invoicing turned off." The Stripe point rests on the batching rule (FURS description, 4th ed., August 2026, §3.3), not on a FURS ruling about Stripe: §3.2.4 lists Stripe but makes the outcome depend on the provider's payment-service status, and FURS hasn't confirmed it for Stripe specifically (open questions below). It also covers paid sales while invoicing is NONE, where Revel issues nothing and the organizer's own verified invoice is the only one. "If you must issue invoices" leaves room for those not liable (ZDavPR Art. 3 and the FURS conditions) and the Art. 81.a association exemption.
  • Online and offline payments are not restricted.
  • The common ticket content applies.

Open questions

  • Whether Revel could verify with its own certificate, or must use the organizer's.
  • Whether verification must happen at payment or at the latest when the event takes place.
  • Whether foreign organizers holding events in Slovenia "keep business books" in the ZDavP-2 sense.
  • The 2015 FURS Q&A said PSP card payments need no verification; the 2026 guidance narrows this. Not confirmed by FURS for Stripe specifically.
  • Counter-argument from §3.4 of the FURS description (the Payoneer example): payments through an e-money institution notified to Banka Slovenije count as non-cash. Stripe's regulated EEA entity is Stripe Technology Europe Ltd, an e-money institution authorized by the Central Bank of Ireland (C187865); whether that puts Stripe payouts on the non-cash side is unconfirmed.
  • Free tickets and zero-amount orders are presumably out of scope; not explicitly confirmed.

Later layers

  • Fuller organizer guidance for Slovenia (FURS certificate, internal act, premises type, the association exemption) and possibly a self-declared exemption flag. The in-app notice above shipped in #1092.
  • Optional native FURS verification: per-organization certificate and premises configuration, Slovenian numbering, a verification client computing ZOI and storing EOR, verified credit notes, and fiscal data with QR code on the PDF.

See #1062.