This blog was last updated on November 1, 2024
The Council of the European Union has released a new proposal regarding the VAT in the Digital Age (ViDA) reform.
The proposal aims to modernise and streamline VAT systems across the EU, notably e-invoicing and Continuous Transaction Controls (CTC). Members States will review it on 5 November at the upcoming ECOFIN meeting.
If approved, a series of changes will take place over time – some of which will take effect as soon as the Directive enters into force. Here is an overview of the key updates, particularly on e-invoicing and CTC requirements.
What is new, and why the delay?
The new proposal does not substantially modify its previous version. The main change in the new ViDA proposal concerns the dates when measures become effective. Deadlines have been postponed as a result of the setbacks ViDA has faced since its initial draft.
The ViDA proposal has faced delays due to the complexity of its objectives, which are mainly to harmonise the varying VAT systems within the EU. In addition to the extensive consultations held during this process to balance different stakeholders’ interests, an approval of ViDA requires the alignment of Member States’ views and priorities.
This has proved a significant hurdle, as Member States have raised their concerns regarding different aspects of the proposal, such as implementation costs and alignment with EU data privacy rules, among others. ViDA must also go through the formal steps for approval by the European Parliament and the Council of the EU.
These factors combined have made ViDA adoption a lengthy process, but its implementation promises significant benefits in public and private sectors across the EU.
Recap: What is ViDA and what changes with its adoption?
Changes effective with the ViDA’s approval
Removal of EU approval for domestic e-invoicing: Under the current VAT Directive, EU approval is required for Member States to introduce domestic mandatory B2B e-invoicing. Countries such as Italy, Poland, Germany, France, Belgium and Romania have applied for derogations to mandate e-invoicing. With ViDA, Member States may impose domestic e-invoicing without needing EU approval, provided it applies only to established taxpayers.
Buyer e-invoice acceptance eliminated: The current EU VAT Directive states that the use of e-invoices is subject to buyer acceptance. Under ViDA, Member States that have introduced mandatory domestic e-invoicing will no longer require buyer consent.
ViDA changes effective from 1 July 2030
Redefinition of electronic invoicing
ViDA redefines electronic invoices. Under the proposal, electronic invoices are those issued, transmitted and received in a structured electronic format that allows its automated processing. This means that non-structured formats, such as pure PDFs or JPEG images, will no longer qualify as an e-invoice. Hybrid formats, such as ZUGFeRD and Factur-X, can remain due to their structured portion.
In principle, electronic invoices must comply with the European standard and the list of its syntaxes pursuant to Directive 2014/55/EU (the “EN” format). However, ViDA allows Member States to use other standards for domestic transactions upon meeting certain conditions.
From 2030, B2B e-invoices compliant with the European standard will be the default and no longer requiring buyer acceptance. However, if a Member State opts for a different mandatory domestic standard, they may either waive or require buyer acceptance for e-invoices using the European standard.
Digital Reporting Requirements (DRRs) for cross-border transactions
One of the most impactful updates in ViDA is the requirement for near-real-time digital reporting of cross-border transaction data.
Starting in 2030, taxpayers engaging in cross-border transactions within the EU must report invoice data electronically following the EN format. Such DRR will be a condition for taxpayers to exempt VAT in a cross-border transaction or claim input VAT. Each Member State will provide electronic mechanisms for submitting this data.
With ViDA, cross-border e-invoices within the EU must be issued in up to 10 days after the chargeable event. In these cases, DRR must happen at the same time the e-invoice is issued or should have been issued.
Invoices issued by the recipient on behalf of the seller (known as self-billing) and the invoices related to intra-community acquisitions must be reported no later than five days after the invoice is issued or should have been issued or received, respectively.
As expected, DRRs may be carried out by the taxpayers themselves or outsourced to a third party on their behalf.
Digital Reporting Requirements for domestic transactions
ViDA grants Member States the option to mandate digital reporting for domestic B2B/B2C sales, purchase data, and self-supplies for VAT-registered taxpayers within their jurisdiction. Domestic reporting requirements must align with ViDA’s cross-border DRR standards, and Member States must permit submissions in the European standard format, although other interoperable formats may be allowed.
For Member States with domestic real-time reporting systems in place as of 1 January 2024, compliance with ViDA’s standards will be required by 2035. On the other hand, the proposal clarifies that other reporting obligations, such as SAF-T, can still exist. This alignment will ensure consistency across the EU in preparation for full ViDA implementation.
Member States have until 30 June 2030 to integrate ViDA’s e-invoicing and DRR provisions into their national legislation, making the Directive effective across the EU by 1 July 2030.
ViDA’s impact on businesses
The ViDA proposal represents a significant shift for businesses operating within the EU, promising both opportunities and challenges. By introducing DRRs, ViDA aims to replace obsolete requirements, reduce administrative burdens, improve accuracy, and combat VAT fraud.
The move towards structured e-invoicing and near-real-time digital reporting will require businesses to update their invoicing and reporting systems, driving digital transformation across sectors. While the transition may entail initial adjustments, it is expected to increase efficiency, create a level playing field, and facilitate smoother interoperability between companies using different systems.
Find out more by reading our dedicated VAT in the Digital Age guide.
