Upcoming E-Invoicing & E-Reporting mandates in the European Union (incl. ViDA)

Last update: April 21, 2023

Join the Linkedin groups on

• ”Global E-Invoicing/E-Reporting/SAF-T Developments”, click HERE

• ”VAT in the Digital Age”(VIDA), click HERE

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2023

During 2023: VAT in the Digital Age – Member states agreement

• Three-month public consultation by EC lasting until April 4, 2023
• March 3, 2023: EDPS Opinion on the package of legislative Proposals on VAT in the Digital Age
• EU Public Consultation on E-Invoicing Directive 2014/55/EC – the consultation is being held between 17 March and 14 April 2023.
• EU Member states are already opening their own public consultations to gather local views.
  • Italy – Due date April 10, 2023
  • Spain – Due date March 22, 2023
• March 2023 – European Parliament briefing: VAT in the digital age
• The EU Parliament and states will review, negotiate and approve at the European Council the proposed changes. It seems there is widespread backing for the reforms as they promise additional tax revenues balanced with flexibility to suit national priorities. Not all of the reforms will need to be adopted in 2023 since they do not come into effect for several years.
• 24 October 2023 for vote by member states at ECOFIN on proposals
• However, 2024 is EU Parliament elections year meaning limited political bandwidth for major reform debate. So the 2025 reforms (Single VAT Registration and Platform Economy pillars) will realistically have to be agreed by the Council by end of 2023 to meet the implementation target.

March 18, 2023

• Luxembourg – Mandatory B2G E-Invoicing – Phase 3 for Small and newly established companies

April 1, 2023

• Slovakia: Approved – Mandatory e-invoicing for B2G, G2G, and G2B transactions

May 1, 2023

• Belgium: Approved – B2G – Obligation for public contracts announced from 1 May 2023 whose estimated value is equal to or greater than 30,000 euros (excluding VAT)

November 1, 2023

• Belgium: Approved – B2G – All other public contracts will follow, with the exception of contracts below the threshold of 3,000 euros (excluding VAT) which are in principle exempt

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2024

January 1, 2024 

• ViDA – Still to be approved
  • Member states free to impose national e-invoicing without prior approval of the EC
  • Issuance of e-invoices will no longer be subject to the agreement of the customer, and therefore businesses must be prepared to accept e-invoices.
  • A revised definition of ‘structured e-invoices‘ is added to the VAT Directive. This will, for example, clarify that PDF’s do not qualify as e-invoices.
• France
  • Launch of a pilot
• Greece
  • B2G – suppliers to all central government agencies
• Italy
  • E-Invoicing mandatory for all remaining businesses
• Spain
  • Biscay province – implementation of BATUZ

January 3, 2024

• France – A pilot will run from January 3 to June 30, 2024 ahead of the mandate starting

July 1, 2024

• Belgium
  • Draft – Mandatory B2B E-Invoicing, gradual implementation, to be approved by EU Commission
  • May be delayed
• France – Phase 1
  • Approved in France, approved by the European Council
  • Gradual implementation as of July 1, 2024 of mandatory B2B, B2C E-Invoicing: 1 Jul 2024 for large companies (more 5,000 employees; and either of following: €1.5 billion turnover; or €2 billion balance sheet)
  • Approved – Obligation to receive invoices in electronic format will be started for all taxpayers
• Poland
  • Approved in Poland, approved by the European Council
  • Mandatory B2B and B2G E-Invoicing
• Spain – Phase 1
  • Approved in Spain, no approval yet from the European Council – Mandatory B2B E-Invoicing
  • For large taxpayers with an annual turnover of more than 8 million Euros, 1 year after the issuance of the implementing regulation.
  • Secondly, for rest of the taxpayers, 2 years after the issuance of the implementing regulation.

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2025

January 1, 2025

• Belgium
  • Taxpayers established in Belgium with an annual turnover, excluding VAT, during the calendar year 2023 of more than €700,000 but not more than €9,000,000 or more than €700,000, excluding VAT, during the calendar year 2024;
• Croatia
  • Not approved yet in Croatia, no approval yet from the European Council

  • New CTC Project – “Fiscalization 2.0.”

• France – Phase 2
  • Approved – Gradual implementation as of July 1, 2024 of mandatory B2B, B2C E-Invoicing: 1 Jan 2025 for medium sized companies
• Germany
  • Discussion Paper – Mandatory E-Invoicing for B2B domestic transactions between German businesses
• Latvia
  • Draft – Mandatory B2B and B2G E-Invoicing, no approval yet from the European Council
• Poland 
  • Approved – Cash register Tax invoices exceed PLN 450, ca EUR 97 and VAT-exempt businesses from Jan 2025 move to KSEF
• Romania
  • Approved in Romania
  • SAFT – Small taxpayers and non-resident taxpayers will start on 1 January 2025
• Slovakia
  • Mandatory B2B E-Invoicing
  • Real time invoicing may be postponed until 2025
  • No approval yet from the European Council

July 1, 2025

• Belgium
  • Small taxpayers under €700,000
• Spain – Phase 2
  • Approved in Spain, No EU approval yet – Mandatory B2B E-Invoicing
  • For rest of the taxpayers, 2 years after the issuance of the implementing regulation.

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2026

January 1, 2026

• France – Phase 3
  • Approved – Gradual implementation as of July 1, 2024 of mandatory B2B, B2C E-Invoicing
  • 1 Jan 2026 for small businesses

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2028

ViDA – Still to be approved

• Introduction of Digital Reporting Requirements for header-level data of intracommunity supplies within two days of the supply.
• DRR is to be issued by both the supplier and the customer.
• E-invoices supplant paper invoices for legal purposes except in limited circumstances. Member states have the option to impose e-invoices for domestic transactions but all national regimes must converge with the EU e-invoicing standard, EN 16931.
• No new pre-clearance e-invoice regimes may be introduced by member states. Those already in place, Italy SdI and Poland’s 2024 planned e-invoicing, may continue until January 2028.
• Ending of summary invoices
• Mandatory structured e-invoicing for intra-community supplies of goods based on EN 16931 standard. These will include new data fields (e.g. settlement details)
• Withdrawal of ESL reporting since supplanted by the new DRR regime, above.

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Unclear timing

• Bulgaria
  • Draft – A public consultation on mandatory B2B e-invoicing is planned, as well as proposals for introducing SAF-T reporting
• Denmark
  • Planned for 2024 and 2025 – Delayed – No further info available
  • Draft – Mandatory B2B E-Invoicing based on bookkeeping Act
• Germany

  • Germany will publish a discussion draft law for the introduction of mandatory B2B e-invoicing

• Hungary
  • Draft – Hungary plans to implement SAF-T reporting in late 2022/early 2023
• Romania
  • Draft – Mandatory B2B E-Invoicing, to be approved by EU Commission, implementation in 2024?
• Slovenia
  • Plan – Slovenia has announced plans to introduce B2B e-invoicing.
• Sweden
  • Draft – Swedish tax authority has started work on three different types of reporting(E-Invoicing, RTR, SAF-T)

  • Investigation on Mandatory B2B, G2B e-Invoicing