EET 2.0 without a trade licence

I have an IČO but no trade licence. Does EET reach me?

Yes — and it is the most common misunderstanding about the new act. The recording act does not know the word trade licence. It asks whether your income is income from business, and whether the customer pays you in person. A doctor, a lawyer, a vet, a tax adviser, a physiotherapist and a chartered architect are all in business under special statutes, and the act treats that as business like any other.

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Where the act says so

Under § 2, recording binds an income-tax payer, not the holder of a trade authorisation. Under § 7(1)(a), decisive income is “income from self-employment that is business”. Business includes other business under special statutes — precisely the frame the liberal professions work in. The words trade licence do not appear in the act once.

They record (for contact payments)

Doctors and dentists in private practice
Lawyers, notaries and court enforcement officers
Veterinary surgeons
Tax advisers and auditors
Physiotherapists, psychologists and other health professionals
Chartered architects and chartered engineers
Patent attorneys, expert witnesses and interpreters

They probably do not record

Income from an independent profession and from copyright fees under § 7(2) of the income tax act is not business, and so creates no decisive income under § 7(1)(a). That typically covers visual artists, musicians, writers and athletes without a trade licence; fees taxed at source are excluded expressly. Anyone who holds a trade licence for the same work, or runs it as a business, records like everybody else.

Even when you record, you do not record everything

A recorded sale is only a contact payment under § 5 and § 6: cash, a card or another payment taken in person, on your premises or in your vehicle. An invoice the client settles by transfer from home or from an office is not a contact payment — and neither is a health insurer paying against a statement.

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An exemption most liberal professions cannot reach

Anyone in the first band of the flat-tax regime whose income last year stayed under CZK 1,000,000 may register for the surcharge that releases them from recording; the surcharge is CZK 1,400 a month. For a great many surgeries and offices the million is out of reach. Whoever does record and files a tax return may claim a tax credit of up to CZK 5,000 for their first year of recording.

What to put in the diary

The certificate and the notification of recording units are dealt with under § 14 and § 15 from 1 November 2026 at the earliest — and always before the first recorded sale. The act takes effect on 1 January 2027, January is a ramp-up month and full operation starts on 1 February 2027. That holds for someone who takes cash twice a year too.

Deadlines

What people ask

With no trade licence, am I outside the recording duty?

No. The recording act never mentions a trade licence. § 7(1)(a) decides — income from self-employment that is business. Business under special statutes is business.

I am an artist with an IČO. Do I have to record?

If the income is from an independent profession or from copyright under § 7(2) of the income tax act, it is not business and creates no decisive income. But if you hold a trade licence for the work, or run it as a business, you record like anyone else. The line is not sharp — take it to a tax adviser.

I take cash only rarely. Can I register afterwards?

No. Under § 14 the recording certificate must exist before the first recorded sale, and the recording units are notified before that. One cash payment a year therefore means the same preparation as a hundred.

Get ready without the rush

Eetuj is sales recording on the phone you already carry. The first five sales are free, with no card and no registration.

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