EU ViDA Digital Reporting Requirements e-invoicing July 2030 latest

Third draft Explanatory Notes to be finalised early 2027

Member States and stakeholders remain divided on a wide range of definitional and operational issues that must be settled before the DRR draft Explanatory Notes can be finalised by the start of 2027:

• Issuance, transmission and acceptance definitions – When exactly an invoice is deemed issued, how transmission acknowledgements work, and what constitutes customer acceptance or refusal.
• Transition measures
• Timing rules – Clarification needed on whether DRR “days” mean working or natural days, and what transitional arrangements apply during the EU-wide rollout.
• Corrections and late invoices – Harmonised rules for corrective and rejected e-invoices, including cash-accounting adjustments and cross-border error handling.
• E-invoice content, formats and standards – Scope of allowable formats; treatment of non-structured documents; status of EDIFACT; and integration of hybrid standards such as ZUGFeRD and Factur-X.
• EN16931 fields, such as document type identifiers, may be mandatory for the standard even though they are not explicitly required by the VAT Directive itself.
• Conformant vs compliant – Need to differentiate between technically conformant invoices and those legally compliant with EN 16931 under the revised VAT Directive.
• Attachments and supporting documents – How to link invoices to contracts, delivery notes or supporting files; and whether PDFs can accompany structured XML.
• Data-field uncertainties – When IBAN numbers may be excluded; how to report VAT data not present on the invoice; and new DRR requirements to report nature-of-goods fields for sensitive goods.
• Omitted triangulation code – Delegations noted that the updated CEN schema still lacks a code for triangular transactions.
• Cross-border treatment – Which Member State’s rules govern e-invoicing (supplier vs buyer), especially for services, VAT groups, chain transactions and reverse-charge supplies.
• Non-EU counterparties – clearer guidance needed on mixed transactions involving non-EU suppliers or customers, particularly where an EU VAT registration exists.
• Validation and transmission across borders – How to manage cross-border acceptance/refusal messages, platform interoperability and competent authority responsibilities.
• Self-billing and numbering – Rules for self-billing flows, invoice sequencing, cash vs credit disclosures and cash-accounting specificities.
• No VAT ID – scenarios where the customer has not yet communicated its VAT identification number when the invoice must be issued.
• Foreign currencies and translations – Consistent treatment of FX conversions, rounding and multilingual invoice content.
• Transaction definition for DRR – Whether reporting should attach to the invoice, the taxable event or another trigger; implications for customer-side reporting when no invoice exists.
• Hybrid invoices – the circumstances in which EN16931 extensions may continue to be used for domestic and intra-EU transactions, and whether these require agreement between the trading parties.
• Post 2030 reporting regimes that Member States may maintain beyond 2030, which is also generating a controversial debate.

Digital Reporting Requirements next steps

• Member states no longer require domestic e-invoicing derogation permission from VAT Directive, and can require customers to receive structured e-invoices.
• Feb 2026: EN16931 modernisation for B2B e-invoicing adopted
• Spring 2026: European Commission to adopt EU e-invoice common messaging proposal
• Autumn 2026: Explanatory Notes to DRR finalised
• 2027:
  • ongoing ViDA Peppol pilot with tax authorities, service providers and taxpayers
  • Start of the IT project phase of the central VIES (see below) for accepting digital reporting intra-community transactions
  • Autumn 2027: Implementing Act
• 2029: starts of new Central VIES testing
• July 2030: Launch
• July 2032: 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 e-Reporting of intra-community transactions to tax authorities

• Introduction of 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.
• Countries with existing domestic transaction-based reporting before 1 January 2024 may retain them beyond July 2030. Regimes introduced since then must converge to the ViDA requirements by 1 July 2030.
• Each member state will be free to develop their own reporting protocols and technical specifications. This is an important point for businesses to consider operating across multiple jurisdictions since schema’s and connectivity protocols will differ.
• 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). If they do not, reporting by acquirers of their purchase invoices must be done within 5 days of e-invoice receipt.
  • 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 DRR transactions and ID info of taxpayers, including their VAT identification number.
  • Another practical question concerns which Member State should receive the digital report in more complex cross-border scenarios. This will be addressed alongside the development of the Central VIES architecture.
  • 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 between businesses 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 ten days 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.
• Businesses are also seeking confirmation that customers should not automatically lose their right to deduct input VAT solely because a supplier has failed to comply with the new e-invoicing obligations.
• 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 – new articles 218 and 232 of the VAT Directive. 
• 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.

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EU VAT in the Digital Age reforms