ViDA Pillar 1, Intra-community EU Digital Reporting Requirement & e-invoicing
Work progresses for July 2030 launch and domestic harmonisation to EU standards by Jan 2035
As part of the EU ViDA reforms, EU Finance Ministers gave political agreement to Pillar 1, Digital Reporting on 5th November 2024. Work has already begun on Pillar 1’s implementation:
- Revision of the EU standard for e-invoicing to adapt it from B2G to B2C. It is expected that a draft version will be made available in June 2025
- Start of the IT project phase of the central VIES (see below) for accepting digital reporting intra-community transactions from July 2030
- Implementing act to establish the central VIES to contain details, formats, access rights and controls. Roles and responsibilities.
- Fiscalis project group and workshops to determine critical issues for the successful launch of the pillar. The next workshop was in Greece on 31 October. The focus is on:
- Implementing Act – Definition of the common electronic message for suppliers/acquirers to provide the data from the e-invoice to their Member State
- Supporting explanatory notes
- Phasing out legacy VIES system July 2032
July 2030 Pillar 1: Digital Reporting Requirements and e-invoicing
Digital Reporting includes July 2030 plans to introduce near-real time digital reporting and e-invoicing on intra-community goods and services supplies. Member states will then have to harmonise any domestic e-invoicing or digital transaction reporting with the new regime by 2035.
Digital Reporting of intra-community transactions to tax authorities
- Introduction of Digital Reporting Requirements (DRR) for suppliers and their customers of header-level data of (Article 262):
- intra-community: supplies; acquisitions; B2B services;
- reverse charge when the supplier is not established;
- supplies of energy to a taxable dealer; and
- triangulation.
- Each member state will be free to develop their own reporting protocols and technical specifications.
- There have been a number of compromises to this proposal to reflect practical burdens:
- The reporting deadline has been extended to ’10 days’ from ‘2 working days’ from issuance of the e-invoice.
- Member states may exempt customers of goods or services from also reporting the transaction if they can obtain assurances by other means (Article 262).
- In addition to the existing information required of recapitulative statement, additional information will be required including bank details to enable tax authorities to track payments. But there is no longer a requirement to note the payment date which was included in the original proposal.
- Withdrawal of ESL recapitulative reporting since is now supplanted by the new DRR regime, above.
- Domestic transaction reporting schemes will remain an option. Existing schemes, such as SAF-T on domestic reporting, may remain in place.
- Central VIES – EC operated transaction database
- A new ‘Central VIES’ central database will be overseen and maintained by the EC, and will include DDR transactions and ID info of taxpayers, including their VAT identification number. It will also have some integration into the Customs Surveillance system and the upcoming Central Electronic System of Payment CESOP information
- It will also give transparency for customers to see what intra-EU transactions are being reported against their VAT numbers. This will help prevent them potentially being caught-up in VAT frauds unaware. This may be enabled by a common EC endpoint.
- The EC will report back to the Council by March 2033 an evaluation of the functioning of the DRR (including e-invoicing, below) regime.
Mandatory structured e-invoicing for DRR transactions
- Structured e-invoices based on Directive 2014/55/EU (Electronic invoicing in public procurement) will become mandatory for any DRR transaction (see list above). Other formats, including paper, may continue for other transactions e.g. domestic supplies. Hybrid formats such as Germany’s ZUGFeRD will be valid if they include the required data structure (Article 218).
- This will include a new definition of the EN16931 e-invoice standard (draft due July 2025) (Article 216).
- There is now inclusion of basic validation or technical requirements of e-invoices, termed ‘accreditation schemes’, where the tax authorities may check data structures via a platform.
- Such e-invoices must be issued by at least the 10th day after the chargeable event (2 days in the original proposal; today the deadline is 15 days after the reporting period end) (Article 222). There must be no requirement for acceptance by the customer (Article 232). In the case of payment on account, and e-invoice must be issued within 10 days of receipt of the payment. Self-billing has a deadline of 5 days after the supply. These requirement does not apply to any member states’ reporting regimes on domestic supplies.
- In a change to the original proposals, holding an e-invoice for eligible transactions will become a substantive condition to VAT deduction or reclaims.
- In a compromise proposed by France, taxpayers may engage with third-party e-invoicing service providers
- E-invoices supplant paper invoices for legal purposes except in limited circumstances.
- The proposal to prohibit the use of summary invoices has been dropped under pressure from businesses. Instead, they may be used issued with the criteria (Article 223):
- that the VAT on the invoice is chargeable in the same month; and
- the summary invoice must be issued by the 10th of the following month;
- a fraud-sensitive supply and the member state has exercised its option to prohibit their use.
- Any member states which have launched a domestic real-time reporting regime after 1 January 2024 must harmonise to the EU ViDA standard.
July 2032
- Phasing out of legacy VIES
January 2035 Pillar 1: Harmonisation of domestic and intra-community transaction reporting
- The proposal to require existing domestic e-invoice reporting regimes to harmonise to the ViDA e-invoicing standard has been changed to January 2035 (originally 2027). This separation from the main e-invoicing launch date of July 2030 reflects member states (e.g. Italy) concerns that tax authorities and taxpayers had invested extensively in the already launch/planned domestic regimes.
- This applies to member state regimes introduced prior to 1 January 2024.
Tax Engine and VAT reporting with CTC
VAT Calc’s tax engine, ‘VAT Calculator’, has been developed with the EU’s VAT in the Digital Age reforms in full focus, including Continuous Transactions Controls agility to live calculate and report invoice data. And since VAT Calculator is built on the same single platform as our VAT Filer product, there is full reconciliation on VAT return reporting.
EU VAT in the Digital Age reforms
EU VAT in the Digital Age | |
3 pillars to improve efficiency of VAT for all and reduce fraud | |
1. Digital Reporting Requirements; e-invoicing | Jul 2030-35: Mandatory digital reporting of intra-community transactions; obligation to be able to issue and receive intra-community e-invoices; member states free to impose own e-invoicing or real-time reporting but most conform to EU e-invoice standard EN 16931 |
Read more about EU Digital Reporting Requirements (DRR) | |
Structured e-invoices mandated for intra-community supplies | |
EC Sales lists replaced by Digital Reporting Requirements | |
Withdrawal of EU permission requirements for e-invoicing | |
2 Platform economy | Jan 2030: Travel & accommodation sharing platforms to become deemed supplier / liable to users' VAT. New definitions of the roles of providers, users and platforms to avoid double and no-taxation (voluntary Jul 2028) |
Read more - Travel & accommodation platforms deemed suppliers for EU VAT | |
3 Single VAT Registration; extension of OSS | July 2028: Following the 1 July 2021 introduction of the One Stop-Shop (OSS), extended to cover movement of own stocks prior to cross-border B2C to reduce the foreign, non-resident VAT registrations & returns. Plus to movements of own stock with ending of 'call-off' stock burden |
More details on Single VAT Registration in the EU | |
Call-off stock VAT simplification ends | |
Harmonisation of B2B Reverse Charge rules |