The EU VAT e-commerce package changed VAT rules for cross-border trade.
While the package makes life simpler and fairer for all, the details can be complex. This guide helps you to:
Make the right decisions for your business
Say goodbye to buzzwords, jargon and painful accounting
Ease trade and unlock business growth
Don’t have time for reading? Ask our experts instead, no question is too difficult for them on the EU VAT e-commerce package.
How to trade within and outside the EU
Knowing how to trade within the EU or as a business outside the market is more challenging than ever. Numerous rules to follow. Penalties to avoid. Even finding accurate, up-to-date information is difficult.
Our guide explains how to handle EU E-Commerce VAT compliance, from the moment you advertise a product to when and how you pay your VAT bill. Our guide is ideal reading if you are:
A business affected by Brexit
An ambitious e-commerce company that’s expanding internationally
A tax professional facing EU VAT headaches
An accounting team struggling with new compliance requirements
A curious retailer intrigued by online marketplaces
A finance person tasked with understanding the rules
This guide to the EU VAT e‑commerce package contains:
Information. Lots of helpful information.
We go right back to basics, explaining what EU VAT is, what you need to know as a business, and the goal of the EU VAT e-commerce package.
We cover key facts too, so you can get a solid grasp of what the package is. Don’t forget a timetable with all the important dates you need to know. Then we cover the schemes enabling simpler trade for all.
The idea behind the EU VAT e-commerce package is to level the playing field by simplifying distance selling. The package also means B2C businesses selling into the EU can use the appropriate VAT registrations across the EU according to their requirements instead of registering in each Member State.
The EU VAT e-commerce package consists of three schemes – the Import One Stop Shop (IOSS), One Stop Shop (OSS) and Non-Union One Stop Shop (Non-Union OSS, which used to be the Mini One Stop Shop (MOSS)). Depending on where your business is based and where it operates, you could need to use just one or all three schemes.
All of these are explained later in our guide.
The most important thing to remember is that although these schemes simplify trade, they require businesses to prepare and thoroughly understand the additional requirements involved.
This means:
Life becomes harder for anyone responsible for VAT within a non-EU business
Companies must change how they process and report transaction data
Compliance becomes more complex
The chance of human error increases, as does the risk of penalties
Help is available to make your life easier
The EU VAT e-commerce package affects many parties, from VAT experts and tax managers to e-commerce sellers, entrepreneurs, marketplace store owners, accountants and audit firms.
An introduction to EU VAT: What you need to know
Like other regions across the globe, EU Member States charge VAT on purchases.
Member States is an official term for countries within the European Union, and Value Added Tax (VAT) is a tax collected by businesses on behalf of their government. Generally, the burden for VAT lies with the consumer, who pays VAT that applicable companies then collect through their supply chain.
There is no single standard rate of VATin the EU. The VAT rate varies from country to country. Some tax authorities charge 19%, while others charge 25% or higher rates. The minimum EU standard rate can be no less than 15%.
Businesses must charge the correct applicable VAT rate, as mistakes can cause customer issues or, worse, result in financial penalties.
Explaining how to follow all the rules correctly is covered in our guide that introduces EU VAT as a general concept.
Key facts about the EU VAT e-commerce package
Everyone loves a fact, and we have plenty to share on the EU VAT e-commerce package.
Did you know…
Import One Stop Shop (IOSS) is for low value goods delivered from outside the EU
Union One Stop Shop (Union OSS) is for intra-EU B2C deliveries of goods and for intra-EU services provided B2C by EU established suppliers
Non-Union One Stop Shop (non-Union OSS) is for non-EU to EU services and replaces and extends the previous Mini One Stop Shop (MOSS)
Businesses using any OSS simplification must apply it to all qualifying transactions
Additional record keeping is required for OSS
Declarations for Union OSS and Non-Union OSS are quarterly, declaration for IOSS is monthly
Non-EU businesses might need to appoint an intermediary
Non-EU retailers may need to report under all three schemes
All this talk about different rates, dates and thresholds can be confusing – simplify your life by reading our EU VAT buster on rates, number formats and thresholds.
Timetable of the EU VAT e-commerce package
Businesses need to know where they’ve been to know where they’re heading. This is why we’ve summarised the package’s major milestones since the moment it was first announced.
2016 – European Commission publishes ‘Action Plan on VAT’, introducing a One Stop Shop mechanism for cross-border e-commerce
15 July 2020 – European Commission adopts new Tax Action Plan, a four-year plan to make tax fair and simple
30 September 2020 – European Commission publishes ‘Explanatory Notes on VAT E-Commerce Rules’
1 July 2021 – The EU VAT E-Commerce Package is introduced
8 December 2022 – European Commission proposes changes in relation to VAT in the Digital Age initiative
Keeping track of dates is often time-consuming, especially with so much information spread across many online sources.
OSS stands for One Stop Shop, the umbrella term for all three schemes. Union OSS is a scheme to help EU established suppliers with providing B2C intra-EU services and for B2C deliveries of goods within the EU.
EU established businesses need to register for OSS in the Member State they are established in.
Don’t fear OSS. Our free guide covers everything you need to expand your knowledge.
Want to skip straight to the benefits? Talk to an expert about leveraging the OSS scheme for your business
How to trade outside the EU
IOSS is short for Import One Stop Shop. This scheme simplifies the registration obligations for taxpayers who carry out distance sales of goods imported from third countries to private individuals in the EU. IOSS applies to low value goods, defined as up to €150.
What is meant by distance selling?
This term covers the sale of goods, services or digital content where there is no face to face contact with the consumer. It includes online, postal, and phone sales.
What is meant by a third country?
This basically refers to any country that is not a member of the EU.
Non-Union OSS applies to all services sold B2C by suppliers not established in the EU.
Want to learn more about IOSS? We’ve got an easy to understand ebook about IOSS to help you get to grips with the scheme.
What non-EU countries need to know about IOSS and OSS
Does it pay to be in the EU club? Judging by the fact EU VAT becomes trickier when your business isn’t located within the region, perhaps the answer’s yes. These are the key facts you need to know. If you want more information about what non-EU countries need to know, read more here.
What’s the difference between IOSS and OSS?
IOSS accounts for B2C of goods imported from third countries, whereby the eligible supplies are restricted to a single consignment value of up to €150.
OSS accounts for B2C intra community distance sales of goods irrespective of the consignment value.
The main difference is that with IOSS the goods are located in a third country (outside the EU customs territory) at the time of the sale, whereas with OSS the goods are located within the EU’s territory.
Related content on the EU VAT e-commerce package
Our helpful guide doesn’t stop here. Our experienced VAT experts have produced guides, blogs and webinars to explore everything related to the EU VAT e-commerce package.
This of course depends on what goods or services you are supplying, but unless an exemption or zero rate applies VAT will be due on e-commerce sales into or within the EU.
How does VAT work for e-commerce?
This depends on whether you are selling goods or services as the rules vary, but generally VAT looks to tax the point of consumption, whether that be an individual streaming music in their country of residence or an individual receiving goods purchased online.
Should I be charged VAT from an EU supplier?
Most EU suppliers will need to charge VAT. There are some exceptions, such as the €10,000 threshold for small businesses and depending on the type of product a zero rate or exemption may apply.
Do you charge VAT on digital services to the EU?
Yes, for business to consumer sales, VAT is due in the country of the customers establishment / residence. The OSS simplifications are particularly useful for meeting reporting obligations.
Who is affected by the EU VAT e-commerce package?
The EU VAT e-commerce package applies to VAT for intra-EU B2C supplies of goods and imports of low value goods as well as services. It affects cross-border B2C trade and e-commerce, including businesses who sell on online marketplaces. The schemes that make up the EU VAT e-commerce package (IOSS, OSS and non-Union OSS) are currently optional.
TheEU VAT E-Commerce package has been in place since 1 July 2021. This applies to intra-EU B2C supplies of goods and imports of low value goods. Three schemes make up the package. These are based on the value of goods and the location of the sale of goods.
All OSS schemes are currently optional. The schemes mean taxpayers can register in a single EU Member State and account for the VAT due in other Member States.
For companies outside of the EU, the package schemes that apply are:
Non-Union One Stop Shop (Non-Union OSS) – non-EU businesses can account for VAT on all supplies of B2C services where EU VAT is due.
Union One Stop Shop (Non-Union OSS) – non-EU businesses can account for VAT on all Intra-EU supplies of B2C goods that are located in the EU.
Import One Stop Shop (IOSS) – for low value goods delivered from outside the EU, where the intrinsic value of the goods is no more than €150.
Want to understand how OSS and IOSS work? Keep reading!
Exporting products to the EU is challenging. Couriers often have a bewildering number of services. Prices differ from service to service.
There’s no easy way to find fast, cost-effective shipping services, but here are tips to help:
Look for couriers that have information about IOSS and OSS on their websites already
Familiarise yourself with customs forms for the country of import
Ask your courier how they support the schemes and can support your business
Confirm if your carrier can act as an indirect customs representative if you do not have an EU establishment
Does my company need a VAT number?
Businesses with a certain turnover must register for VAT. This varies from country to country. For example, the UK’s VAT threshold is £85,000 for established businesses. If you are interested in a business solution, please get in touch with our sales team.
How do I get a VAT number?
Registering for VAT takes time. Each Member State has its own process for obtaining a VAT number. VAT compliance differs from Member State to Member State.
For non-EU companies, appointing a Fiscal Representative might be necessary. A Fiscal Representative acts on behalf of companies in a local VAT jurisdiction, managing VAT reporting and other requirements. For IOSS, most non-EU businesses will need an IOSS intermediary.
We know registering for VAT is difficult and involves understanding place of supply rules, fiscal representation and many other elements.
The EU VAT E-Commerce package enables taxpayers to register in one Member State to account for VAT in all Member States.
Benefits of applying for a VAT number as a non-EU business
In most cases, a VAT number will be mandatory because of your business’ activity; in some cases, it will be voluntary. There are many benefits to applying for a VAT number.
These include preventing financial penalties and receiving EU VAT refunds. EU VAT refunds depend on certain circumstances, such as on VAT exempt items.
How to register for OSS
The OSS scheme is currently optional. Before registering businesses should consider the benefits and impact on their supply chain.
When a supplier obtains either an the Member State that grants the VAT number becomes known as the Member State of Identification.
Registering for OSS in the UK
As the UK is no longer part of the EU, registering for OSS as a UK business means using the Non-Union OSS, Union OSS or IOSS schemes. There is no need to have a normal VAT registration in the EU to apply for IOSS or a non-Union OSS VAT registration, however, a local EU registration is required before obtaining the OSS registration.
The first step is to understand if an needs appointing. The intermediary, usually an agent or broker, submits the IOSS returns on behalf of the company.
The UK business will need to choose the Member State it wants to register with for the non-Union OSS scheme.
If the UK business has warehouses in the EU, then the company will still need local in each Member State with a warehouse, but they can choose one Member State for OSS registration.
The Northern Ireland Protocol adds even more complexity to cross-border trade. Stop browsing the internet for unhelpful answers; contact our experts for advice instead.
Our team of experts can help you understand OSS and IOSS further. Don’t hesitate to get in touch today, especially about the Northern Ireland Protocol’s effect on trade.
FAQ for non-EU countries
What is VAT number called in USA?
The USA doesn’t have VAT. The equivalent is Sales Tax, with its own permit and tax ID.
DO US companies have a VAT number?
If a US company wants to sell goods into Europe it can register for a VAT number with the relevant Member State tax authority. The business’ supply chain will determine if / where a VAT registration is required.
Do US companies have to pay UK VAT?
This depends on the product or service and whether the US company has activity in the UK that requires it to become VAT registered such as selling low value goods or importing in its own name into the UK.
How much is international shipping to Europe?
The cost of international shipping to Europe varies, depending on where you send goods from and how quick delivery is.
How much does it cost to ship from USA to Europe?
Costs for shipping from the USA to Europe vary, depending on if they are express or standard shipping times. Different couriers charge different prices too.
What is the cheapest way to ship a package from USA to Europe?
This depends on package size, insurance and delivery speed.
How long is shipping from EU to US?
Shipping from the EU to the US can take anywhere from four days to four weeks, depending on customs and import requirements.
You want to sell and trade within the EU with ease?
Tax has always been challenging and ever-changing VAT regulations across Europe add to the complexity, requiring technology adoption to support compliance- related activities.
It’s time for businesses to evaluate how efficiently they’re handling their VAT compliance obligations.
We created this checklist to help you assess whether you already have an effective, scalable solutions that’s optimized for the diverse range of compliance requirements and future-proofed to adapt to coming changes.
If you can tick all the boxes, you’re on the right path to mitigate risk and meet the demands of VAT digitization.
Checklist
How does your current VAT compliance solution measure up?
Compliance coverage across Asia, EMEA, LATAM
Continuous regulatory monitoring by tax experts
Maintained in alignment with regulatory changes
Flexible integration, whatever your systems
Supported by multilingual experts
Built to the latest Information Security requirements
Delivering valuable insights from your data
Scalable, future-proof platform
Functional compliance covering:
VAT Determination
E-invoicing & secure access to digital evidence
Real-time reporting
Periodic reporting (including SAF-T)
Can’t check all the boxes? Don’t worry, Sovos helps ease the increased demands of tax digitization so you can prioritise your core business . We take a future-facing approach to always-on tax compliance with intelligent tools that provide data insights for a competitive advantage.
Global solutions and services provider appoints executives to lead new era of growth
LONDON – January 11, 2022 – Global tax compliance provider Sovos today announced that Wendy Walker, solution principal, and Charles Maniace, vice president of regulatory analysis and design, were recognised in Accounting Today’s Top 100 Most Influential People in Accounting. Accounting Today’s list acknowledges the industry’s authoritative thought leaders, change makers, regulatory and other leaders who are shaping the profession. Additionally, Christiaan van der Valk, vice president of strategy and regulatory, was named a winner of Business Intelligence Group’s 2023 BIG Innovation Award. The BIG Innovation Awards recognise organisations and people who bring new ideas to the table and change the way we experience the world.
As the federal government moved toward reducing the threshold to trigger 1099-K reporting, Walker has been monumental in ensuring that third-party payment processing and gig economy platform organisations prepare for the upcoming changes. In addition to her responsibilities at Sovos, Walker also serves as chair of the Information Reporting Subgroup of the Internal Revenue Service Advisory Council (IRSAC), advising the IRS on a variety of withholding and information reporting issues impacting the industry.
“When the American Rescue Plan Act was signed into law in March 2021, we knew that compliance was going to be a heavy undertaking for organisations of all sizes,” said Walker. “I’ve been vocal about what these changes mean for companies, and I thank Accounting Today for recognising my efforts to empower business to stay ahead of these changes.”
Maniace leads a team of 40+ attorneys and tax professionals to ensure that Sovos’ suite of sales tax compliance solutions remains continually up to date as sales tax rules and requirements change at an increasingly frenetic pace. This is the fourth year that Maniace has been recognised by Accounting Today.
“Since SCOTUS made its historic ruling in 2018 enabling states to require tax compliance from remote sellers, legislators and regulators should be striving to simplify and streamline their requirements so that sales tax never represents an undue burden. In some places, we have seen the opposite, with complex new laws and regulations creating traps for the unprepared.” said Maniace. “My goal is to advocate for sales tax simplicity and modernisation while ensuring that our customers are always ready for whatever may come.”
As vice president for strategy and regulatory at Sovos, Christiaan Van Der Valk leads research into trends in the market and tax legislation. His insight and expertise are instrumental in determining business strategy and when to buy, build or partner to create solutions that meet emerging trends. Van der Valk holds long-standing leadership roles at the International Chamber of Commerce (ICC) and the European E-invoicing Service Providers Association (EESPA).
“The large-scale aggressive use of real-time integration technologies by governments seeking to fill tax gaps is changing the way businesses think about tax compliance and information systems” said van der Valk. “To minimise friction from this new paradigm, my long involvement with key international organisations has helped me spearhead initiatives to broker new ways in which complex government and business ecosystems can collaborate more effectively. Among other deliverables, this has led to the ICC Principles for Continuous Transaction Controls (CTCs).”
New global leaders to drive business growth
In addition to our experts’ industry recognition, Sovos has expanded its global leadership team to drive continued growth and enhanced solutions and services.
“Solving the world’s most challenging compliance issues takes strong leadership and a sustained commitment to excellence at both the technical and partnership levels,” said Andy Hovancik, CEO, Sovos. “I am confident this is the right team to bring Sovos to the next level of growth and solution delivery, anywhere our customers do business.”
Kevin Cunningham, Chief Financial Officer: Cunningham oversees the finance and accounting organisation, including tax, treasury, corporate development, accounting operations and financial planning and analysis. He held a senior divisional chief financial officer role at Honeywell and was also CFO at Sparta Systems prior to joining Sovos.
Jonathan Eisner, Chief Channel Officer: Eisner leads partner strategy, programs and sales. In his role he works across regions, product teams and functional areas to ensure close alignment on best practices and go-to-market execution. He was VP, worldwide partner sales and alliances at Deltek prior to joining Sovos.
Leah Rasori, Chief Marketing Officer: Rasori leads the strategy and execution of the company’s brand marketing, client communications and demand generation to increase awareness for the global tax compliance provider’s solutions and services. She served as vice president of performance marketing at Fiserv prior to joining Sovos.
Christopher Sowa, Chief Commercial Officer: Sowa leads growth strategy development, alignment and orchestration across the company’s U.S.-based lines of business, including Sales and Use Tax and Tax, Regulatory Reporting and Sovos ShipCompliant. He was the global vice president of strategy and innovation for Schneider Electric prior to joining Sovos.
To learn why Sovos is trusted by half of Fortune 500 companies, visit www.sovos.com.
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About Sovos
Sovos was built to solve the complexities of the digital transformation of tax, with complete, connected offerings for tax determination, continuous transaction controls, tax reporting and more. Sovos customers include half the Fortune 500, as well as businesses of every size operating in more than 70 countries. The company’s SaaS products and proprietary Sovos S1 Platform integrate with a wide variety of business applications and government compliance processes. Sovos has employees throughout the Americas and Europe, and is owned by Hg and TA Associates. For more information visit www.sovos.com and follow us on LinkedIn and Twitter.
Nearly every major economy has a form of VAT. That’s 165 countries, each with its own compliance and reporting rules. The main exception is the United States. VAT is by far the most significant indirect tax for nearly all the world’s countries. Globally VAT contributes more than 30% of all government revenue.
Levying VAT is a term used to describe when a company collects VAT on behalf of a tax authority. This happens at each stage in a supply chain when a taxable event occurs. A country’s tax rules define what a taxable event is.
In a nutshell, VAT essentially turns private companies into tax collectors.
How VAT works
VAT is due on nearly all goods and services. This is up to, and including, the final sale to a consumer – that’s you and me.
Applied correctly, VAT should be cost neutral for most businesses. Companies collect VAT from their suppliers, then pay this money to the government. In the UK, this is normally every three months.
As a business this means:
You charge VAT on your invoices or what you sell
This is accounted for in your company’s accounting books
You send a VAT return with all your VAT collections to the tax authority
You then pay the VAT collected
Companies can reclaim the VAT on some of their purchases. When applicable, this means your business pays less VAT when its VAT return is due.
Essentially, this encourages businesses to spend and help an economy grow.
Another thing a company can do is postpone its VAT accounting. There are different reasons why this is allowed, for example, in relation to import VAT.
A VAT return is a document listing all the VAT you have collected and what you are reclaiming VAT on along with various other information on sales and purchases in the period.
Submitting VAT returns is a legal requirement in most countries. The format and frequency vary around the EU, so it’s essential to keep
In addition to VAT returns, businesses might have to submit other declarations. This depends on the company’s trading activity and the requirements in the Member State of registration. This could include or . These can be quite complicated, as we explain here.
Understanding your VAT obligations also requires mapping a supply chain for the country of registration.
The following information applies to larger businesses or businesses selling into the EU.
VAT returns and other declarations – for reporting a business’s liabilities to the tax authority. This is the money owed to the government. The format of a VAT return and its frequency varies across the EU.
Invoicing – The VAT Directive provides the legislation across the EU, but Member States can choose how to apply this to their local laws.
Applying exemptions – a supplier needs to provide evidence that VAT exemptions have been applied correctly. Failure to do so can lead to an exemption being denied. This can result in financial penalties and interest charges.
Recovery of VAT – Member States interpret the requirements for VAT recovery differently.
Intrastat – Intrastat declarations provide trade information, and when required, declarations must be accurate – as with VAT returns, the process in each Member State varies.
Continuous transaction controls – Continuous transaction controls (CTCs) mandates vary. Some requirements only apply to resident businesses and certain thresholds.
So, what is the difference between Sales Tax and VAT?
VAT is a broad-based consumption tax and a form of indirect taxation. It is imposed on goods and services at each stage of the supply chain, with each party paying the government the tax and passing the final cost onto the ultimate consumer.
The idea is that each party effectively only pays VAT on the value added to the product or service. This is because the party can recover the VAT on associated costs (of course, there are exceptions). One of the disadvantages is that it requires accurate accounting.
On the other hand, sales taxes are generally taxes placed on the sale or lease of goods and services.
Usually, the seller collects the tax from the purchaser at the point of sale. Sales tax is calculated by multiplying the purchase price by the applicable tax rate. The seller at a later stage transfers the tax to the responsible government agency.
How does VAT work between EU countries?
The EU VAT Directive 2006/112/EC establishes the rules for where VAT is due in the EU. Member States must implement these rules in a uniform way to avoid the possibility of double or no taxation. This blog goes into details how VAT between European countries works.
How EU countries apply VAT
VAT in the EU happens when:
There’s a supply of goods – Where goods are not transported, the place of taxation is where the goods are made available to the customer. Where the goods are transported, the place of supply is where the transport starts (unless an exemption applies).
There’s a supply of services – For B2B transactions the place of taxation is generally where the customer has established their business. This applies to “intangible” services where the place of consumption cannot be determined easily.
There are certain where the place of consumption can be determined. These are:
Services connected with immovable property (i.e. real estate) – this is taxed where the immovable property is located.
Passenger transport is taxed where the journey takes place.
Activities relating to culture, sport, education and entertainment restaurant services are taxed where the event happens.
Catering services are taxed where the food and drink is provided to customers.
Short-term transport hire is taxed where the transport is used.
Increasingly, digital services to consumers – such as software downloads or content streaming – are taxed in the country of consumption.
A thing called intra-community acquisition of goods occurs – The place of taxation is the place where the transport ends (i.e., the EU country where the goods are finally located after transport from another EU country).
At the point goods are imported – The place of taxation is where goods imported from non-EU countries are generally taxed (i.e., in the EU country where they are cleared for free circulation).
Why EU countries use VAT
There are many reasons why an EU country uses VAT.
VAT can be adjusted up and down depending on how a country’s economy is performing quickly. This means a country can raise taxes quickly or support a certain sector by reducing VAT.
Once collected, the money can be spent on public services, infrastructure, healthcare and other important growth initiatives.
But wait, what about those pesky questions like “should I charge VAT to EU customers?” or “do I pay VAT if buying from Europe?”. We hear these all the time from customers who struggle with VAT rates across different EU countries.
Standard rates, reduced dates, special rates. What’s the difference?
And then you have super reduced rates and zero rates? Let’s not forget intermediary rates.
If your business is expected to charge VAT to EU customers, or you yourself are faced with paying VAT on a purchase when buying from Europe, it’s important you feel confident applying the right VAT rate each and every time.
Have a question about the many different types of VAT rates in the EU? Our tax experts are yet to receive a question that stumps them, and they will happily help unload you from this burden.
Sometimes companies don’t have to pay VAT. This happens when the goods or products they sell fall into an exempt category.
Some examples of exceptions include education and training, charity fundraising and insurance. Insurers instead pay a tax called (IPT).
A VAT exempt business cannot register for VAT, nor can it reclaim VAT. This is slightly different to zero-rated goods or services. In that case, VAT is charged, but at 0%. Some companies can be partly exempt too.
VAT exemptions differ country to country so it’s important to check a tax authority’s website to see whether your business needs to pay VAT. ? We love setting our clients free from their tax compliance burdens so they can focus on growing their business.
Yes. A person or company buying a service or product pays the tax when the item is chargeable.
Do sellers pay VAT?
Sellers pay VAT on any items they purchase for their own business. The VAT they collect from their own customers is paid to HRMC. In some cases, sellers also need to self-account for the VAT due from their customers.
Who pays VAT, the buyer or seller in the UK?
VAT is 20% in the UK. A buyer pays this to the seller when they purchase an item, product or service. There are also some cases where the seller pays the VAT by way of a self-accounting mechanism.
What is the difference between sales tax and VAT?
Sales tax is found in the United States and is a tax applied at state government level on the purchase of goods or services. VAT is a consumption tax and is collected by all sellers in a supply chain, not just charged to the final consumer.
Our large advisory team can help you navigate the complexities of modern VAT compliance. Don’t hesitate to get in touch today.
Changes are coming to Portugal’s Billing SAF-T reporting requirements for non-resident taxpayers that trade in the country.
The process may be stringent but that doesn’t mean it has to be difficult for your company. Here are four things you need to be aware of about Portugal’s billing SAF-T obligations.
1: Non-resident taxpayers must file the first billing SAF-T report by 8 February 2023
Billing SAF-T is already compulsory for resident Portuguese companies but from January 2023, non-resident VAT registered companies are also obligated to submit a monthly billing SAF-T. The first report is due on 8 February 2023 and has particular requirements, which we discuss below.
The monthly deadline for submitting the Billing SAF-T is the eight day of the month following the reporting period.
2: You must use a certified billing software to generate the monthly report
A unique requirement to Portugal is that the Billing SAF-T file must be generated by ‘certified billing systems’ as designated by the tax authorities. Failure to comply with this requirement is subject to a fine.
Non-resident taxpayers need to ensure they are using a certified billing software to remain compliant.
Sovos’ SAF-T cloud solution is recognised as a certified billing software by Portugal’s tax authority. This makes staying on top of Portugal’s SAF-T Billing report obligations simple, with customised options available for customers needing to take a tailored approach.
3: You must submit SAF-T Billing in the correct format
Portugal’s SAF-T requirements include specific formatting for generation and submission. Based on the original OCED 1.0 schema, this includes a specified header, master files, and source documents.
Master files can include: customer and/or supplier tables, product tables, and tax tables.
Source documents can include: sales and purchase invoices, documentation on movements of goods, and payment information, as applicable.
For the most part, information in the schema is conditionally required, meaning most fields only need to be submitted if the relevant data exists in a taxpayer’s source system.
Taxpayers must be able to generate the required fields in their system and understand which data is required for submission.
4: Portugal’s SAF-T requirements continue to change
Portugal’s tax authority has continued to introduce new requirements and extend the scope of SAF-T in the country. Changes include stricter integrity and authenticity requirements and reducing the time window for invoice reporting obligations.
The tax authority’s changing requirements and increased visibility put additional strain on taxpayers to submit compliantly and on time.
Sovos’ Managed Service can help ease tax compliance burden for companies operating in Portugal and beyond. Our team of tax experts combined with our tax technologies help companies with filing and reporting obligations. Speak to our team to learn more about how Sovos can help solve tax for good.
Serbia is on the final straight to implementing its mandatory e-invoicing, which will come into effect from 1 January 2023. Legislative changes are still being proposed before that deadline to allow for a complete introduction of mandatory e-invoicing to the whole B2B sector.
On 12 December 2022, the Ministry of Finance published the following Laws on Amendments in the “Official Gazette of the RS” No. 138 among others:
1. Amendments to Serbia’s Electronic Invoicing Law
One of the changes regarding the scope of the Law on Electronic Invoicing involves natural persons who are not liable for income tax for self-employment, in the sense of the law governing personal income tax, who will be excluded from the provisions of the Law on E-Invoicing.
Regarding the type of transactions that will not be in the scope of e-invoicing, there will be no obligation to issue an electronic invoice for the sale of goods and services free of charge. Lastly, the legal entities and entrepreneurs who are not VAT payers, nor voluntary users of SEF, will not be obliged to record VAT calculation in SEF if they are tax debtors.
In case of a temporary interruption in the operation of the electronic invoice system, the system will consider an e-invoice as delivered at the time operation resumes. The act of the Ministry of Finance that regulates such procedures will be adopted on 1 April 2023 – three months from the date of entry into force of this law.
Also, the following paragraph will be added to Article 6 stating: “An electronic invoice that has been rejected can be subsequently accepted”. This provision will apply from 1 June 2023 for electronic invoices recorded in the central register of invoices, in accordance with the law regulating the deadlines for settling monetary obligations in commercial transactions.
The law will enter into force on 1 January 2023.
2. Amendments to Serbia’s VAT Law
The changes introduced to the law on VAT that impacts electronic invoicing processes stipulate that an invoice is an electronic invoice accepted by the buyer, as required by the Law on E-Invoicing.
The law ensures that the taxpayer accepting the electronic invoice within the deadline to submit the tax return may exercise the right to deduct the preliminary tax at the earliest date for the tax period where liability occurred. The taxpayer will also need to notify the tax authority about a change of data relevant to the calculation and payment of VAT contained in the registration form. The notification will be exclusively electronic and excludes notice in writing.
The law will enter into force on 1 January 2023, coinciding with the Serbian e-invoicing mandate go live date.
3. Amendments to Serbia’s Fiscalisation Law
The Law on Fiscalisation regulates, among other things, the subject of fiscalisation and the procedure conducted through an electronic fiscal device. The supply of goods and services, conducted by a fiscalization obligor to a legal entity or taxpayer of income from self-employment, outside the retail store, is not considered a retail supply. Therefore, such supply will not be subjected to fiscalization requirements and will not need to be recorded through an electronic fiscal device.
Moreover, the amendments specify that the fiscal receipt does not need to contain the value of the transaction per tax rate as a mandatory element. By scanning the QR code for verification, which has all the parts of an electronic signature when printing a fiscal invoice or a hyperlink for verification when a fiscal e-invoice is issued, it will be possible to receive additional information about the fiscal receipt.
The amendments to the Law on Fiscalisation that impact the future e-invoicing mandate cover changes related to the fiscal invoices issued to legal entities and taxpayers on income from self-employment. Transferring these fiscal invoices to the System of Electronic Invoices (SEF) will happen upon fulfilment of technical requirements. The Minister of Finance will further regulate the method and procedure of data transfer in the future.
Based on Article 7, a separate regulation will control the manner and procedure of data transfer to the SEF platform, that will be adopted within 180 days from the day when this Law enters into force. This means adoption will be in June 2023 at the earliest.
The Law on Amendments and Supplements to the Fiscalisation Act will be enforced on the 8th day following its publication, which took place on 12 December 2022.
Integration of the Fiscalisation system with SEF
The above amendments relate to the plans introduced by the MoF to integrate the Fiscalisation system with the E-Invoicing system (SEF), which will most likely start at the earliest in January 2024. As the Minister of Finance Vuk Delibašić announced on 1 December 2022: “The plan is to integrate the E-Invoicing system with the Customs Administration, e-fiscalization, as well as the creation of a semi-automatic VAT declaration, and an electronic excise tax is also being prepared.”
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The European Commission’s VAT in the Digital Age initiative brings significant modifications to the VAT treatment of the platform economy related to the operators in the short-term accommodation and passenger transport services. Short-term is defined as a maximum of 30 days – however, to adapt to different national specificities of the sector, EU Member States should have the possibility to make short-term accommodation rental services subject to certain criteria, conditions and limitations in accordance with their national laws.
VAT treatment of the platform economy
It is worth mentioning that the ‘VAT treatment of the platform economy’ only relates to the supply of certain services via a platform. There are also a set of e-commerce rules related to the supply of goods via platforms.
The rise of the platform economy business model has triggered new challenges for the VAT system. As per the view of the EU Commission, one of these problems is VAT inequality that can be experienced if we look at:
The accommodation platform model that the EU Commission sees as competing directly with the hotel sector direct distribution model or
The transportation platform model that the EU Commission sees as competing directly with private taxi firms
We can better understand the EU view of the distortion of the competition if we look at the European Commission’s Impact Assessment report. The report outlines the growing importance of the platform economy in VAT collection and explains the studies conducted to ascertain where the EU Commission needs to take action.
In terms of numbers, the value of VAT revenue from the digital platform ecosystem is estimated at about EUR 25.7 billion per year for the Member States, i.e. 2.6 percent of total VAT revenue.
Scale of platform economy operation, by sectors (EU27, EUR billion, 2019)
The total value of VAT revenue includes EUR 3.7 billion related to accommodation services and EUR 3.1 billion related to transportation services.
In these two sectors, private individuals and small businesses (i.e. underlying suppliers) can provide their VAT-free services (i.e. they do not account for any VAT) via a platform. With the economies of scale and network effect, these businesses can be in direct competition with traditional VAT-registered suppliers.
Taking into account the supporting study, the number of underlying suppliers who are not registered for VAT, can be up to 70%, depending on the type of platform.
For example, in the accommodation sector, over 50% of users of a particular accommodation platform specifically access the platform’s offering over a traditional hotel. In Europe, the cost of accommodation offered via the accommodation platform can be, on average, some 8% to 17% cheaper than a regional hotel’s average daily rate.
In the view of the European Commission this means a distortion of competition between the same services offered via different channels.
The VAT treatment of the facilitation service
Clarifying the nature of services provided by the platform was the most supported intervention across different stakeholders.
In some Member States the treatment of the facilitation service charged by the platform is regarded as an electronically supplied service, whilst in others it is regarded as an intermediary service.
This is relevant because it can lead to different places of supply, which can lead to double or non-taxation. Therefore, clarification of these rules is necessary.
According to the proposal, the facilitation service (where the term “facilitation” extends to include short-term accommodation and passenger transport services) provided by a platform should be regarded as an intermediary service (Article 46a amending Directive 2006/112/EC). This allows for a uniform application of the place of supply rules for the facilitation service.
While this has no impact on the existing rules when the supply is carried out on a B2B basis, the same cannot be said about B2C supplies. Under this scenario, the place of supply will be where the underlying transactions takes place.
How will the VAT in the Digital Age proposal change the status quo?
According to the European Commission, the main issue with the platform economy is the inadequacy of the current VAT legal framework to ensure a level playing field with traditional businesses, specifically in the transport and accommodation sectors.
Supplies made by small underlying suppliers via a platform are not taxed and the facilitation services made by platforms are taxed differently in different Member States. This leads to difficulties for the platforms, suppliers, and Member States.
Introducing a deemed supplier model will solve these issues, by which platforms will account for the VAT on the underlying supply where no VAT is charged by the supplier. This model ensures equal treatment between the digital and offline sectors of short-term accommodation rental and passenger transport.
The deemed supplier obligation will not apply if the underlying supplier provides their VAT number and declares responsibility for collecting and remitting the VAT due to the digital platform. Moreover, if the underlying supplier is below the VAT registration-threshold in the EU Member State where the VAT is due, that EU Member State may choose to not make the digital platform the deemed supplier.
In addition, clarifications will be given on the treatment of the facilitation service to allow for a uniform application of the place of supply rules, and steps will be taken to harmonise the transmission of information from the platform to the Member States.
It’s been confirmed that, in order to avoid situations in which platforms are included in the special scheme for travel agents in respect of transactions for which they are considered to be the deemed supplier, those transactions are outside the scope of that special scheme (i.e. TOMS). Similarly, travel agents are not included in the deemed-supplier rule.
In terms of timing, EU Member States will have until 1 January 2030 to implement the deemed supplier provision (with optional implementation from 1 July 2028).
Furthermore, by 1 July 2033, the EU Commission will submit a report to the Council evaluating the operation of these measures and the application of the VAT rules on facilitation services, including the impact on the functioning of the internal market and the effectiveness of VAT collection.
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Acquisition holds immediate benefit for customers with complex supply chains and footprints across Europe; furthers Sovos’ long-term global tax engine strategy
BOSTON – December 6, 2021 – Global tax software provider Sovos today announced it has acquired Germany-based TLI Consulting GmBH. The move significantly advances Sovos’ value-added tax (VAT) determination capabilities, with immediate benefits for businesses running SAP. VAT determination is one of three pillars of modern tax compliance, and often the first that multinational companies tackle before addressing digital reporting and complex continuous tax controls (CTCs), like e-invoicing. Sovos will leverage TLI Consulting’s software, consulting services and team to help customers Solve Tax for Good® with complete, continuous and connected solutions for every facet of the digital transformation of compliance.
Sovos is on a years’ long journey to build end-to-end offerings that help businesses infuse trust in every transaction. That journey has included the acquisition and development of global CTC, VAT reporting and SAF-T solutions, and a Sovos Connect Once API for a seamless customer experience across systems that need to comply with a wave of real-time and e-audit VAT mandates. TLI Consulting, Sovos’ ninth acquisition in the past 12 months, continues that journey with enhanced VAT determination for businesses with complex supply chains covering a broad jurisdictional landscape across Europe and beyond.
“Sovos has built the most complete suite of technology and services for frictionless compliance in digitizing economies, with advanced solutions for CTC, SAF-T, VAT reporting and other global requirements,” said Andy Hovancik, CEO, Sovos. “The acquisition of TLI Consulting continues that leadership with heightened capabilities for VAT determination, which is often the first piece of an increasingly complex puzzle companies must solve.”
TLI Consulting has served businesses whose transaction and tax determination needs are too complex or costly to configure and maintain via native SAP and in-house tax experts. The company’s software solution extends native SAP VAT determination functionality, and its consultants have the integration and implementation expertise to ensure that SAP ECC or SAP S/4 HANA enterprise resource planning systems can seamlessly determine the right VAT decisions and tax codes for any outbound or inbound transaction.
“Today’s announcement represents a key building block toward a Sovos tax determination portfolio that now helps customers meet modern indirect tax compliance challenges globally, including in Europe, the United States, Brazil and elsewhere,” said Steve Sprague, general manager, global value-added tax, Sovos. “Together, we’re creating the technology solutions that speed simpler tax determination for every transaction, in every jurisdiction, for every tax regime.”
Sovos’ acquisition of TLI Consulting has immediate potential for positive impact on customers in Germany and throughout Europe. In addition to the SAP software extensions upon which it has built its business, TLI Consulting’s expertise and experience will contribute to Sovos’ global tax engine strategy, which is to ensure any customer system can benefit from indirect tax determination, CTC and SAF-T support through a single integration.
“As we join Sovos, the TLI Consulting team gains the opportunity to help create the one-stop VAT solutions companies crave, while expanding our reach as part of a global technology leader. We look forward to this next phase and the positive impact it will have on our customers and future customers,” said Martin Grote, Sovos vice president of European VAT determination and former TLI Consulting director.
John Gledhill, vice president of corporate development for Sovos, said, “As a global organization with more than 2,300 employees, Sovos will scale TLI Consulting’s software and services business in support of the largest multinational companies with complex business transactions in Europe. With this acquisition, Sovos also establishes operations in Germany and now has employees in 14 countries.”
The terms of the deal were not disclosed. Sovos is owned by Hg, the London-based specialist private equity investor focused on software and service businesses, and TA Associates. EY served as financial advisor to Sovos, and Burness Paull and Luther provided legal counsel. Rödl & Partner advised TLI Consulting.
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About Sovos
Sovos was built to solve the complexities of the digital transformation of tax, with complete, connected offerings for tax determination, continuous transaction controls, tax reporting and more. Sovos customers include half the Fortune 500, as well as businesses of every size operating in more than 70 countries. The company’s SaaS products and proprietary Sovos S1 Platform integrate with a wide variety of business applications and government compliance processes. Sovos has employees throughout the Americas and Europe, and is owned by Hg and TA Associates. For more information visit www.sovos.com/en-gb/ and follow us on LinkedIn and Twitter.
About TLI Consulting
TLI Consulting offers VAT determination software and associated consulting to support clients in entering VAT processes into their SAP (and other ERP) systems through developing and implementing customized, practical and compliant solutions for accounts receivable and accounts payable processes. Further, TLI Consulting offers SAP solutions for VAT ID validations and VAT reconciliations and analysis.
Sovos Partner Network drives digital transformation of tax compliance for customers while offering significant profit potential and borderless growth to partners
BOSTON – October 6, 2022 – Global tax software provider Sovos today announced the launch of its new Sovos Partner Network designed to guide partners in addressing the critical needs of their customers as they navigate the complexity of digital compliance and changing tax regulations around the world. With access to Sovos’ complete portfolio of compliance solutions, along with its unmatched regulatory and tax expertise, this new program enables partners to bolster their tax compliance offerings and expand their business opportunities.
“Government authorities have gone increasingly digital with the calculation, reporting and compliance of taxes and Sovos continues to invest heavily in tax technology solutions. Collaborating with Sovos allows KPMG to bring both its leading technology and tax and implementation experience to clients,” said Niren Saldanha, Partner, Tax, KPMG LLP.
The Sovos Partner Network was built to align to our partners’ business models, whether they resell, co-sell, implement or embed Sovos solutions. Competitive incentives and other business-related program benefits were designed to assist partners in expanding their businesses in ways that best fit their go-to-market strategies. The modern program includes a rich array of consistent and accessible tools, training and a self-service partner portal. Industry leaders such as Oracle, NetSuite, SAP and KPMG have already partnered with Sovos to increase customer support, in addition to hundreds of other partners across the globe, both large and small. Collectively, these partners share Sovos’ core mission to Solve Tax for Good®.
Sovos’ global commitment to partners extends to Latin America. “EY Brazil brings tax transformation and automation to its clients by leveraging process and tax automation software in the market, such as Sovos Taxrules,” says Giovanni Schiavone, Tax Transformation Partner at EY Brazil. “We conduct ‘Tax Transformation Projects’ that evaluate our clients’ GAPs and then suggest automations using the most advanced features of solutions like Sovos to help create a high-performance tax area, aligned with current and future Brazilian compliance needs.”
Why partner with Sovos?
The Sovos Partner Network offers many ways to create mutually beneficial opportunities, including:
Driving new revenue streams: Business partners can expand their product portfolio and market coverage by offering solutions that solve their customers’ needs for compliance.
Offering the most comprehensive suite of solutions and services: Leveraging Sovos’ Cloud, SaaS and API development, partners can offer robust solutions to customers such as SAGE, Sun Chemical and Nationwide that address real-world challenges.
Building upon 40 years of experience and research: Through our team of subject matter experts, Sovos supports tens of thousands of customers around the globe, including half of the Fortune 500, and is deployed in more than 70 countries.
Collaborating with trusted names in the industry: Partners can provide their customers with up-to-date tax compliance solutions amid global regulatory changes with one of the most trusted brands in the market.
Access to growth-focused tools and resources: Sovos offers a wide range of actionable benefits that are designed to drive success, including sales and marketing, business development, technical and enablement tools and other resources that help partners grow their business.
“Strong partner relationships are a key component of our strategic business approach. This new global program represents the next step in our ability to support the evolving needs of customers in today’s global tax and compliance marketplace,” said Jonathan Eisner, vice president, global alliances and chief channel officer, Sovos. “Investing in a stronger ecosystem that better supports and rewards our partners is a critical part in solving these dynamic challenges.”
To learn more about the Sovos Partner Network or apply to become a partner, click here.
About Sovos
Sovos was built to solve the complexities of the digital transformation of tax, with complete, connected offerings for tax determination, continuous transaction controls, tax reporting and more. Sovos customers include half the Fortune 500, as well as businesses of every size operating in more than 70 countries. The company’s SaaS products and proprietary Sovos S1 Platform integrate with a wide variety of business applications and government compliance processes. Sovos has employees throughout the Americas and Europe and is owned by Hg and TA Associates. For more information visit www.sovos.com and follow us on LinkedIn and Twitter.
Electronic invoicing in Poland via KSeF has undergone a long journey. Providing new expectations for B2B and B2G transactions alike, it is vital for taxpayers to understand what’s to come – though that can be tough when rules and regulations change frequently.
This blog provides a comprehensive timeline of Poland’s advancement towards its e-invoicing mandate, detailing the adjustments your organization should be aware of. The cost of non-compliance reaches beyond financial penalties, so knowledge is vital.
Ministry of Finance Publishes KSeF 2.0 Implementation Manuals and FAQs
The Polish Ministry of Finance (MoF) has expanded the available KSeF resources by publishing comprehensive new information on their website. This latest release includes detailed FAQs and four implementation manuals to support businesses preparing for the mandatory e-invoicing system scheduled to launch on 1 February 2026.
KSeF 2.0 Manuals
The Ministry has published four complementary manuals to help businesses prepare for the mandatory e-invoicing implementation:
“KSeF 2.0 Manual Part I: Getting Started with KSeF” covers initial setup procedures, system registration, authentication methods, and user rights management.
“KSeF 2.0 Manual Part II: Issuing and Receiving Invoices in KSeF” focuses on the implementation of the FA(3) invoice structure, technical aspects of invoice submission, and the verification process.
“KSeF 2.0 Manual Part III: Additional KSeF Functionalities” explains invoices with attachments, OFFLINE mode functionality, VAT RR invoicing procedures, and self-billing processes.
“KSeF 2.0 Manual Part IV: KSeF in Public Sector and Other Authorization Models” addresses invoice issuance and receipt in local government units and government institutions, along with invoicing for enforcement procedures and public procurement.
KSeF 2.0 FAQs
The Ministry has also released extensive FAQs developed in collaboration with businesses, integrators, and stakeholders. The FAQs address fundamental questions about system functionality, technical implementation, authentication methods, and regulatory compliance.
KSeF 2.0 Roadmap
A detailed implementation roadmap is now available on the official KSeF portal. The timeline outlines key preparation stages for the mandatory e-invoicing implementation:
2025:
1 September 2025: KSeF 1.0 test environment shutdown
24 September 2025: Free KSeF training sessions begin
30 September 2025: KSeF 2.0 API made available in the test environment
15 October 2025: KSeF 2.0 API made available in pre-production environment
1 November 2025: Certificate and Authorization Module (MCU) launch
3 November 2025: KSeF 2.0 Taxpayer Application made available in the test environment
15 November 2025: KSeF 2.0 Taxpayer Application made available in pre-production environment
2026:
1 January 2026: Launch of notification module for invoices with attachments in e-US (electronic tax office platform)
26-31 January 2026: Technical maintenance break of KSeF 1.0 production environment
1 February 2026: KSeF 2.0 goes live for large businesses and invoice recipients
1 April 2026: KSeF 2.0 becomes mandatory for all remaining businesses
2027:
1 January 2027: KSeF 2.0 becomes mandatory for previously exempt businesses (up to PLN 10,000 monthly)
With the fast-approaching KSeF mandatory deadlines in 2026, businesses should review these materials as they prepare for the mandate and ensure their invoicing processes meet the new compliance requirements.
Update 5 September 2025 by Kelly Muniz
KSeF 2.0 Updated Draft Regulation on the Use of KSeF
The Polish Ministry of Finance has published an updated version of the draft regulation on the use of the National e-Invoicing System (KSeF). The regulation addresses authentication methods, granting and withdrawing rights in KSeF, KSeF certificate use, invoice marking requirements (QR codes), use of attachments and other technical aspects of the system.
This updated draft primarily clarifies the provisions of the draft published in June this year, rather than introducing significant changes. The new revision mainly offers enhanced descriptions of existing mechanisms, more precise definitions, and clearer explanations, while maintaining the same fundamental approach to KSeF operations and timelines.
Key Clarifications:
KSeF Certificate Validity – Certificates will be valid for up to 2 years from the date of creation or from a starting date specified by the taxpayer, and can be renewed during the validity period.
KSeF Certificate Purposes – More distinct explanation of certificate functions: a) for authentication in the KSeF system and b) for confirmation of issuer identity when issuing invoices in special modes.
Invoice Marking Requirements – Further detailed specifications for marking invoices in different scenarios, requiring different QR code implementations depending on when the invoice is shared with the buyer in relation to KSeF submission. Accordingly, invoices shared outside KSeF before submission will require both an access QR code and a “certificate” QR code to ensure authenticity, while those shared after submission require only the access QR code.
Attachments Notification Process – Refined procedures for submitting and processing notifications regarding the intention to issue and send invoices with attachments to the KSeF system.
The draft regulation continues to undergo the approval process in the Ministry of Finance and has not yet been officially finalized.
Update 1 September 2025 by Kelly Muniz
H2: KSeF 1.0 Test Environment Shut Down
On Friday, August 29, the Polish Ministry of Finance published important news regarding the KSeF (National e-Invoice System).
As of 1 September 2025, the KSeF 1.0 Test environment has been officially shut down. Therefore, from now on no further testing can be conducted in KSeF 1.0. In practice, this means that to become a new KSeF user, taxpayers must wait for the new KSeF 2.0 Test environment once this new environment opens. Users of the current Production environment of KSeF 1.0, can still use it until the maintenance break, which will occur between 26-31 January 2026.
This impacts any taxpayers currently issuing e-invoices in the KSeF 1.0 Testing environment.
Update 28 August 2025 by Kelly Muniz
KSEF 2.0 Act Signed by President and Go-live Timeline Confirmed
Following the parliamentary approval of the KSeF 2.0 Act, Polish President Karol Nawrocki has signed the legislation on 27 August 2025. With this critical approval, which establishes the implementation timeline for Poland’s mandatory e-invoicing system – KSeF, the law now awaits publication in the Polish Journal of Laws (Dziennik Ustaw) to formally enter into force.
Key Implementation Dates Confirmed
The signed legislation maintains the phased approach previously outlined:
1 February 2026: Mandatory e-invoicing begins for large businesses with annual turnover exceeding 200 million PLN in 2024
1 April 2026: Requirement extends to all other businesses
Special provisions:until 31 December 2026 businesses with monthly sales under 10,000 PLN are exempt from KSeF compliance
The law will take effect the day after its publication in the Polish Journal of Laws, with certain provisions becoming effective on 1 February 2026, the mandatory KSeF go-live date.
Businesses should now accelerate their implementation plans, as this final approval confirms the mandatory timeline. Additional updates will follow as implementing regulations are published.
Update 6 August 2025 by Kelly Muniz
KSEF 2.0 Act Approved by Parliament
After months of anticipation, the Polish Parliament has approved the KSeF 2.0 Act, which now awaits the President’s signature and official publication in the Polish Journal of Laws. This milestone legislation revises the National e-Invoicing System (Krajowy System e-Faktur, or KSeF), scheduled to become mandatory from February 2026 for the first group of affected taxpayers. The Act addresses key concerns raised by businesses during the consultation period, introducing significant changes to the implementation framework including extended compliance deadlines and new technical requirements.
Key Changes
The KSeF 2.0 legislation introduces important modifications to Poland’s e-invoicing requirements. After a postponement in 2024, the implementation will follow a phased approach based on taxpayer size: large businesses with annual turnover exceeding PLN 200 million (approximately €46 million) in 2024 must comply starting 1 February 2026, all other businesses by 1 April 2026, and businesses with monthly sales under PLN 10,000 (approximately €2,300) have until 1 January 2027.
Most notably, the Act establishes a permanent offline24 mode allowing businesses to issue e-invoices and submit them to KSeF by the next business day. Technical changes include the requirement for potentially placing two QR codes on invoices, the ability to include attachments in the e-invoice schema and the use of internal KSeF certificates. Importantly, certain penalties under the VAT Act and the requirement to include KSeF numbers in payment transfers have been postponed until 2027, giving businesses additional time to adapt.
What’s Next?
Following the President’s signature, two additional regulations in draft form will complete the KSeF 2.0 framework:
KSeF Exemptions Regulation: This draft outlines categories of transactions that will be exempt from mandatory e-invoicing requirements, focusing on specific sectors and transaction types, including certain self-billing scenarios.
KSeF Usage Rules Regulation: This forthcoming regulation will establish the procedures for granting system access rights, authentication tools, QR code specifications, and rules for registering to issue e-invoices with attachments.
Businesses should be aware of the key implementation dates: API testing availability on 30 September 2025; KSeF certificate issuance beginning 1 November 2025; and KSeF 2.0 production environment go-live on 1 February 2026.
Update 30 June 2025 by Kelly Muniz
KSEF 2.0 Official API Documentation and FA(3) Logical Structure Published
The Polish Ministry of Finance has reached another milestone in the KSeF 2.0 implementation roadmap with the publication of the technical API documentation and FA(3) logical structure on 30 June 2025.
This publication enables businesses and software providers to begin preparations for implementing the KSeF 2.0 in the test environment, which aligns with the previously announced timeline towards mandatory e-invoicing.
Technical Documentation Details
The Ministry of Finance has released comprehensive technical documentation, including:
FA(3) schema logical structure
API technical specifications
Overview of critical changes between KSeF API 1.0 and 2.0
General explanations of the KSeF 2.0 features
The FA(3) logical structure represents the official version of the mandatory Polish e-invoice schema and was developed through extensive consultation with tax experts, accountants, auditors, software providers, and future users.
Starting 1 February 2026, KSeF 2.0 will become mandatory for all taxpayers subject to the first implementation phase. This date also marks a significant technical transition, as the newly published FA(3) logical structure will officially replace the current FA(2) schema that businesses use in today’s voluntary system.
Confirmed Implementation Timeline
The Ministry has reaffirmed the following implementation roadmap:
30 June 2025: API documentation and FA(3) schema published
30 September 2025: Test environment for KSeF 2.0 API will be available
November 2025: Test version of the KSeF Taxpayer Application browser interface
1 February 2026: Mandatory KSeF 2.0 implementation begins
As previously announced, the phased implementation will start with larger businesses on February 1, 2026, followed by other taxpayers in April 2026, with the smallest businesses having until January 2027.
What’s Next?
The legislative process for KSeF 2.0 continues to advance, with regulations expected to be finalized in July 2025. This publication marks an important step toward mandatory e-invoicing in Poland and follows the timeline presented in the Ministry’s implementation roadmap.
Update 14 April 2025 by Kelly Muniz
Updates on KSeF e-Invoicing and Revised Draft Law
The Polish Ministry of Finance (MoF) has published an announcement on the current status of legal, technical, and business preparations for the implementation of the mandatory Krajowy System e-Faktur, also known as KSeF e-invoicing system.
After analysing the comments from the November 2024 public consultations, the MoF considered all the key demands submitted by businesses and other stakeholders and published a revised version of the draft proposal of the KSeF simplifying regulations.
The key points of the proposal and of the MoF announcement are the following:
Mandatory KSeF Deadlines
The MoF confirmed that the obligation to issue structured electronic invoices through KSeF will be introduced in two stages, with the same dates as previously planned, and with certain changes:
1 February 2026:Mandatory for large taxpayers whose total turnover in 2024 (including VAT) exceeds PLN 200 million (approx. €46 million).
1 April 2026:Extended to all other taxpayers, except the smallest “digitally excluded” taxpayers whose monthly sales do not exceed PLN 10,000 (approx. €2,500) and single invoices stay below PLN 450 (approx. €100). These smallest entities will have a longer adaptation period and their go-live is scheduled for 1 January 2027.
The turnover threshold for Stage I of KSeF implementation will now be based on 2024 data instead of 2025, giving larger taxpayers earlier clarity on their inclusion in Stage I of KSeF.
VAT RR invoices, which document the purchase of agricultural products from flat-rate farmers, are exempt from the mandatory KSeF requirement, with their optional issuance postponed from 1 February to 1 April 2026.
Unified Postponement of Specific Obligations
Several obligations scheduled for mid-to-late 2026 are proposed to be uniformly postponed. This means that until 31 December 2026:
The option of issuing invoices from cash registers is maintained
No penalties for errors related to invoicing via KSeF will be applied
There will be no obligation to provide the KSeF number in payments for e-invoices (including those made using the split payment mechanism)
There will be no obligation to issue invoices in KSeF for transactions involving small amounts (up to PLN 450 (approx. €100) for a single invoice and up to a total sales value of PLN 10,000 (approx. €2,500) per month)
Access to Authentication Certificates
Starting 1 November 2025, taxpayers will be able to apply for invoice issuer certificates required for authentication in the KSeF system and when issuing e-invoices in system failure or “offline24” mode. The technical details will be provided in the API documentation published in June 2025.
Permanent “Offline24” Mode
To mitigate concerns over system outages or delayed responses at the end of accounting periods, the Ministry made improvements to the “Offline24” mode. The main change is that it will be possible to issue invoices in this mode for an indefinite period (the original proposal allowed it until the end of 2026, under certain situations). The Offline24 mode will allow:
Issuing invoices outside the KSeF system with a QR code when technical difficulties occur (for example, the quality of the transmission network) or when dealing with a foreign entity, a consumer or domestic buyer without a NIP (Polish Tax Identification Number).
Uploading these invoices to KSeF no later than the next working day.
Automatic classification of such documents in KSeF as “offline” if the issuance date (field P_1 in FA(3)) precedes the system submission date.
QR Code Standardization
The QR code for online mode and offline mode contain different elements. However, to ensure consistency and security, these QR code structures will be unified. QR codes will allow the confirmation that the invoice exists in the KSeF system.
KSeF for B2C Transactions
The plan to allow optional issuance of invoices to consumers (B2C) via KSeF remains in place. This simplifies operations for companies engaged in mass invoicing and ensures compatibility with retail practices.
E-invoice Attachments
The plan to allow attachments to e-invoices as part of the FA(3) structure remains in place.
Updated KSeF 2.0 Implementation Roadmap
The Roadmap initially published in November last year was updated to include the date of the FA(3) schema publication and postponement of the completion of the legislative process:
June 2025: Information on the new version of the system, the KSeF 2.0, will be published via the new API documentation and the new FA(3) schema.
July 2025: Completion of legislative process.
30 September 2025: Launch of open API testing environment – possibility to test the API of the KSeF 2.0 in an open manner by all integrators and large companies.
November 2025: Release of taxpayer authentication certificates and test version of KSeF 2.0 taxpayer application.
1 February 2026: KSeF Stage I – KSeF becomes mandatory for companies with turnover > 200 million PLN (based on 2024 data).
1 April 2026: KSeF Stage II – KSeF mandatory for all other businesses.
31 December 2026: End of the extended deadline for specific obligations (see point 2).
New Public Consultation
The revised version of the draft legislation is open for opinions and comments of the general public until 25 April 2025
Update 7 November 2024 by Kelly Muniz
H2: Draft Act and FA(3) Scheme Published
The Polish Ministry of Finance (MoF) has initiated the final consultation process for its National e-Invoicing System (KSeF).
This involves collecting the public’s comments on the new KSeF Draft Act and the updated logical structures FA(3) and FA_RR(1) that have also been published.
The objective of the proposed legislation and updated schemas is to promote necessary changes and simplify certain KSeF obligations, especially considering the topics raised during the multiple consultations held earlier this year.
Main Regulatory amendments proposed by the Draft Act:
Introduction of mandatory issuance of e-invoices for all taxpayers: the Draft reaffirms the mandatory e-invoicing deadlines previously announced:
From 1 February 2026: taxpayers whose sales (including tax) exceeded PLN 200 million (approx. EUR 46 million) in 2025
From 1 April 2026: all other entrepreneurs
Voluntary Issuance of B2C e-invoices:issuing e-invoices to final consumers (B2C) becomes optional. This is currently not allowed in KSeF.
Alignment of the KSeF Environments:the aim of this alignment is to transition from the current optional KSeF setup to its mandatory version. This involves introducing the technical aspects of mandatory KSeF, before the go-live date, allowing taxpayers to undergo testing in advance. The replacement of the Production environment is planned for Q4 of 2025.
KSeF Grace period: maintenance of the postponement until 31 July 2026 of application of penalties for non-compliance with KSeF obligations.
Offline mode:extension of the offline mode until 31 December 2026 so that taxpayers experiencing difficulties in submitting invoices to KSeF may issue outside of KSeF and submit e-invoices to the system within a day of issuance.
Invoice issuance via cash registers: postponement of this measure, which means maintaining until 31 July 2026 the option to issue invoices via cash registers.
Inclusion of KSeF number in e–invoice payments: postponement until 31 July 2026 of the requirement to include the KSeF number in all e-invoice payments, including split payment transactions.
Grace Period for small taxpayers:between 1 April 2026 to 30 September 2026, taxpayers may issue electronic or paper invoices provided that they only issue invoices up to PLN 450 (approx. EUR 100) and that the total value of their monthly sales documented by the invoices is of up to PLN 10,000 (approx. EUR 2300).
Main Technical amendments proposed:
Possibility of submitting e-invoices with attachments, which will form an integral part of the e-invoice. This will be optional and taxpayers will need to send a notification via API to the authority so that this option can be linked to their NIP (tax identification number).
Modification of the e-invoice’s logical structure to include the rules for indicating the payment deadline.
New obligation to ensure access to invoices for entities subordinate to local government units (JST) by including the mark “JST”.
Introduction of a new “employee” role in the Entity3 node.
General improvements and other minor modifications to the structure following the earlier consultations.
The MoF has also shared the following KSeF Roadmap:
Q1 2025: Legislation completion
Jan 2025: Launch of the KSeF Infoline
Jun 2025: API documentation release
Jun-Aug 2025: Limited API testing
Sep-Dec 2025: Open testing
Nov 2025: Environment alignment – KSeF Production Environment 2.0
Feb 2026: Mandatory KSeF
Public Consultation
All changes described above, both in the Draft Act and in the new logical structures, are subject to public consultation and other official formalities before being finally adopted.
Update 26 April 2024 by Marta Sowinska
New E-invoicing Mandate Dates Announced
The Polish Ministry of Finance announced the new official implementation date for mandatory e-invoicing via KSeF during a press conference. The new timeline is as follows:
1 February 2026 – for taxpayers whose turnover exceeds PLN 200 million (approx. EUR 46 million) in the preceding year
1 April 2026 – for all other taxpayers
The Ministry of Finance emphasised that an earlier implementation date for the mandatory KSeF would not be feasible due to findings from an external technical audit. Consequently, the KSeF system will require a comprehensive architectural rebuild.
Further information concerning technical specifications and necessary legal amendments will be published in the coming months.
Update 23 January 2024 by Marta Sowinska
Electronic invoicing in Poland via KSeF has undergone a long journey. Providing new expectations for B2B and B2G transactions alike, it is vital for taxpayers to understand what’s to come – though that can be tough when rules and regulations change frequently.
This blog provides a comprehensive timeline of Poland’s advancement towards its e-invoicing mandate, detailing the adjustments your organisation should be aware of. The cost of non-compliance reaches beyond financial penalties, so knowledge is vital.
If you’re looking for the current KSeF requirements, visit our overview of e-invoicing in Poland. If you want to see the journey the regulation has been on, and any upcoming changes that could affect your business, keep reading.
Electronic invoicing in Poland via KSeF has undergone a long journey. Providing new expectations for B2B and B2G transactions alike, it is vital for taxpayers to understand what’s to come – though that can be tough when rules and regulations change frequently.
This blog provides a comprehensive timeline of Poland’s advancement towards its e-invoicing mandate, detailing the adjustments your organisation should be aware of. The cost of non-compliance reaches beyond financial penalties, so knowledge is vital.
If you’re looking for the current KSeF requirements, visit our overview of e-invoicing in Poland. If you want to see the journey the regulation has been on, and any upcoming changes that could affect your business, keep reading.
Update 19 January 2024 by Marta Sowinska
Poland Postpones E-invoicing Mandate Rollout
Poland’s Ministry of Finance announced today the postponement of its e-invoicing mandate. Originally scheduled for July 2024, the initiative has been postponed indefinitely due to major errors identified in the KSeF system.
The Minister of Finance emphasised that the current technical status of the KSeF system poses substantial challenges, preventing its secure implementation in Poland. Critical errors were identified in the code, affecting overall system functionality and performance of KSeF, prompting the Ministry to take decisive action.
To address these issues, the Ministry of Finance will initiate an external audit to assess the functioning of the KSeF system and evaluate the preparedness for its implementation. The final date for the introduction of mandatory e-invoicing will be contingent upon the results of these audits. In addition, the Ministry will intensify consultations with businesses regarding KSeF.
While expressing full support for the implementation of the KSeF system, the Ministry of Finance reiterated that their priority is to ensure the proper functionality of the system. This commitment stems from the need to secure the economic turnover in the country and avoid situations where taxpayers might be unable to issue e-invoices due to KSeF errors.
Update 5 January 2024 by Marta Sowinska
Poland Publishes Amendment to JPK_VAT Requirements
The regulation amending the scope of data included in the JPK_VAT with a declaration (VAT return) in Poland, has been published in the Official Journal on 4th January.
The final version of the regulation from 29 December 2023 has been further changed compared to the initial draft, and its final form does not include previously stated obligations to:
include the special mark “OFF” in the VAT return in respect to invoices issued during KSeF system failure or offline mode, when the technical difficulty to connect with KSeF was on the taxpayer’s side.
include the special mark “BFK” in the VAT return with respect to invoices issued outside of KSeF.
However, it still includes the obligation to include the unique ID number (numer KSeF) in the VAT return, in case the number has been assigned on the invoice, from:
1 July 2024 in the sales and purchase records voluntarily.
1 January 2025 in the sales records mandatorily.
The regulation is planned to enter into force from 1 July 2024.
Update: 19 December 2023 by Marta Sowińska
KSeF Technical Specifications Released
The Ministry of Finance has released technical specifications for the KSeF interface in the test environment. This documentation outlines details about QR codes and their associated verification links, it also clarifies information derived from the draft regulation on the use of KSeF that was published in November.
The QR codes serve as visual representations of the verification links and must adhere to the ISO/IEC 18004:2015 standard. Their size and precise placement on printouts are flexible and can be tailored to specific requirements.
Update: 28 November 2023 by Marta Sowińska
Mandatory E-invoicing Draft Acts Published in Poland
On 26 November, the Ministry of Finance published two long-awaited draft acts regarding mandatory e-invoicing via KSeF.
Verification codes (i.e. QR codes): included on the invoices sent to the buyer outside of KSeF and in the event of system or taxpayer failure to connect with KSeF (offline modes)
Offline modes: the scope of data allowing access to invoices in KSeF that were issued in offline mode
New authorisations and authentication methods to connect to KSeF, also for VAT RR and VAT RR KOR invoices
Invoices issued by VAT-exempt taxpayers must include the NIP numbers of both buyer and supplier to align with issuing invoices via KSeF from January 1, 2025
The draft acts are planned to enter into force on 1 July 2024, except for the obligation covering VAT-exempt taxpayers.
In the coming days, the tax authorities will publish the interface technical specifications and description of the technical requirements for the verification codes (i.e. QR codes).
On 4 August 2023, the Polish President signed an Act amending the VAT Act and certain other laws which introduces mandatory e-invoicing via KSeF. This means that the e-invoicing mandate will enter into force on 1 July 2024, with no further postponements.
Following the enactment of the law, the Ministry of Finance published a draft regulation amending the regulation on the use of KSeF from 27 December 2021.
Update: 28 July 2023 by Marta Sowińska
Poland’s Draft E-invoicing Law To Move Forward
The Sejm has voted against the Senate’s veto which blocked the draft legislation introducing the national e-invoicing system, KSeF, on the grounds of it being unconstitutional.
Following its adoption by Sejm and pursuant to the draft legislation, the e-invoicing obligation will come into force, as planned, on 1 July 2024, with some exceptions.
As a next step, the draft law will be adopted and enacted in the country after it has been signed by the President.
On 9 May, the government in Poland adopted a draft law introducing mandatory e-invoicing via KSeF, which will take effect from 1 July 2024. Now the draft law must be approved by Parliament, and the next session is planned for the end of May.
The adoption of this piece of legislation is an essential step, showing that the government is moving forward with the digitalization of the public sector by introducing mandatory e-invoicing via KSeF.
Poland has published the second draft law amending the VAT Act and certain other laws on the Government Legislation Centre on 15 March 2023.
The amendments mainly confirm previously announced changes, though some additions are worth noting. The essential clarifications include:
1. Scope of the KSeF mandate
Postponement of the KSeF mandate from 1 January 2024 to 1 July 2024, with some exceptions
VAT-exempt taxpayers will be in scope from 1 January 2025
From 1 January 2025,it will not be possible to issue invoices using cash registers and simplified invoices in the current form
The mandatory scope of the KSeF system will exclude invoices for B2C transactions, and invoices issued and settled for OSS and IOSS will not be included in the mandate.
Foreign taxpayers with a fixed establishment in Poland performing activities required to be invoiced according to Polish VAT law will be obliged to issue invoices via KSeF, to the extent that this permanent place of business relates to the supply of goods or services which are invoiced
2. Corrective notes excluded from KSeF
The draft law entirely withdraws the possibility for buyers to issue corrective notes. Buyers cannot propose corrections to the original invoices through or outside KSeF, which the previous draft law presented. Accordingly, changes in the issued invoice can be made only by issuing a corrective invoice.
3. Issuing invoices outside KSeF in case of failure
In line with the previous draft proposal, the current draft law specifies the possibility of issuing e-invoices in offline mode – outside of KSeF in a structured format and delivering to KSeF on the next business day – in case of a failure on the taxpayer side.
The Ministry of Finance will communicate relevant information to the public regarding any maintenance work conducted in KSeF or any system failure. During this time, taxpayers can issue invoices outside of KSeF and deliver them to the buyers in the agreed format.
Such invoices must follow the structured format, be assigned with a QR code and, after the failure ends, be delivered to KSeF within seven days. The date of issuance will be the date stated in the P_1 field, while the buyer’s receipt date will be the date when KSeF assigned the unique ID.
4. QR code
The government has added a new requirement for including a QR code on the invoices issued during a failure of the KSeF system. As previously announced, the QR code must also be included on the invoice visualizations issued outside of KSeF, for example, to foreign buyers and on the VAT RR invoices and corrections to them.
5. Self-billing process under KSeF
The Ministry of Finance responded to feedback about the lack of a self-billing process for cross-border transactions. Therefore, a method of authentication in KSeF for foreign buyers will be included in KSeF, allowing foreign buyers to issue structured invoices on behalf of the suppliers.
6. Exchange rate
The exchange rate used for converting foreign currencies into PLN currency can be maintained from the day preceding the date indicated in the P_1 (date of invoice issuance).
The exchange rate will be calculated based on the date when an e-invoice was issued (stated in the P_1 field), provided that an e-invoice is sent to KSeF no later than the day after the date indicated in the P_1 field.
7. Penalties
Sanctions will apply from 1 January 2025 (previously 1 July 2024) up to 100% of the amount of VAT indicated on the invoice or up to 18.7% of the total amount due shown on the invoice. However, no minimum penalty amount will apply – previously, it was 1000 PLN – approx. 200 EUR.
Next steps for Poland’s KSEF e-invoicing mandate
The draft law is expected to be published in Q3 of 2023, with most provisions applying from 1 July 2024.
Accordingly, the associated final schema FA (2) and FA (RR) are also planned to be published at the end of June or the beginning of July, as announced by the Ministry of Finance during a conference on 16 February 2023. Therefore, we are still waiting for the legislative process to be completed for the e-invoicing mandate to take effect.
Speak with our team if you need more information on the upcoming e-invoicing changes in Poland.
Update: 3 February 2023 by Marta Sowińska
Poland: E-invoicing Mandate Postponement to 1 July 2024
According to an official announcement published by the Ministry of Finance on 2 February 2023, the go-live date of Poland’s mandatory e-invoicing system is now 1 July 2024 – delayed six months from the previous date.
More than a year after the roll-out of the voluntary phase and following extensive testing of the KSeF system by taxpayers, the Ministry of Finance responded to the feedback submitted in the public consultation by delaying the mandate and relaxing certain requirements.
The expected changes are:
The e-invoicing mandate will be postponed from 1 January 2024 to 1 July 2024
VAT-exempted taxpayers must comply with the e-invoicing requirements and issue invoices via KSeF from 1 January 2025
The KSeF system will exclude B2C transactions
Invoices issued through cash registers and simplified invoices can be issued in their current form until 31 December 2024, meaning such invoices will be in the scope of KSeF from 1 January 2025
In the case of a technical failure on behalf of the taxpayer, they will be able to issue invoices outside of KSeF and transmit them to the system the next day
Penalties will be postponed until 1 January 2025and imposed on taxpayers on a case-by-case basis
Taxpayers should not treat the postponement of the e-invoicing mandate as a reason to pause the implementation process. Instead, treat the delay as an incentive to implement complex legislative and technical requirements before the go-live date and adapt their accounting and invoicing processes considering any errors that may appear.
The European Commission has announced its long-awaited proposal for legislative changes in relation to the VAT in the Digital Age (ViDA) initiative. This is one of the most important developments in the history of European VAT, and affects not only European businesses, but also non-EU companies whose businesses trade with the EU.
The proposal requires amending the VAT Directive 2006/112, its Implementing Regulation 282/2011, and Regulation 904/2010 on Administrative Cooperation on the combat of fraud in the field of VAT. They cover three distinct areas:
This regulatory change proposal will still need formal adoption by the Council of the European Union and the European Parliament under ordinary legislative procedures before it can come into force. In tax matters such as these, the process requires unanimity among all Member States.
This blog focuses on VAT digital reporting obligations and e-invoicing, whereas future updates from Sovos will address the other two areas.
VAT digital reporting obligations and e-invoicing – an overview
Intra-EU B2B transaction data will need reporting to a central database:
Digital Reporting Requirements (DRR) will be introduced for intra-EU (B2B) transactions: All suppliers and customers (no thresholds or exemptions) in an intra-Community B2B transaction will need to submit data to their local tax administration no later than two working days after the issuance of the invoice. Each Member State’s tax authority will channel the data to a central database
The EU Standard for Electronic Invoicing (EN16931) will be used for the data elements and reporting format; only a sub-set of the invoice will be reported
The DRR will be coupled with mandatory e-invoicing for B2B intra-EU transactions
The reporting requirement will replace the current intra-Community listings (known also as recapitulative statements or EC Sales Lists)
Digital reporting requirements for domestic transactions will remain optional:
Implementing digital reporting requirements for domestic transactions will remain optional for Member States. This has been the competence area of the Member States until now, and following the principles of subsidiarity and proportionality, the Commission strives to align and harmonise without forcing Member States to introduce this requirement
If digital reporting requirements for domestic transactions are introduced in a Member State, e-invoicing will be mandatory for the transactions in scope
A local system will need to ensure interoperability with the intra-EU system on a data level; domestic e-reporting must use (a subset of) the European Norm EN16931; for newly introduced systems, this requirement will apply immediately while existing domestic systems must converge in the medium term
There is no requirement on Member States to provide pre-filled VAT returns
Changes will be made to facilitate and align e-invoicing:
Electronic invoicing will be the default system for the issuance of invoices
The need for derogation to introduce mandatory e-invoicing in a Member State will be removed
The need for customer acceptance of supplier e-invoicing will be removed
The definition of e-invoicing will be amended to align with Directive 2014/55 and will include only structured electronic files. Therefore, non-structured formats like PDF will not be deemed to represent electronic invoices from a VAT perspective
Payment data will be introduced as a new content requirement for invoices
“Transmission” will not be regulated:
The European Commission has, at this stage, chosen not to propose regulation regarding the transmission channel of the reported data to the tax authorities. This is currently left to Member States to decide on.
The reason for this decision is likely because it’s a technical issue, and that the discussion would have slowed down the process of publishing this proposal. The European Commission also appears ambiguous about whether it would want to regulate this in the future.
What does the future of VAT in the Digital Age look like?
Many countries primed to introduce continuous transaction controls (CTCs) have been waiting for EU regulators to provide an answer to what rules the individual Member State will need to abide by. It remains to be seen whether this proposal will embolden these Member States to move ahead with plans, despite the non-final status of the proposal. It’s noteworthy that Germany filed for a derogation from the current VAT Directive to be able to mandate e-invoicing just a few days before the original date that the Commission had planned to publish this proposal – 16 November 2022.
A Quick Guide to E-invoicing and Real-Time Reporting
Tax regulations in Eastern European countries are complex but that shouldn’t be a reason not to do business there. If you’re responsible for VAT compliance, this ebook provides key details of the varying VAT digitisation mandates and business requirements across the region:
Understand how to comply with the e-invoicing and reporting in Eastern Europe
Deep dives into Hungary, Poland, Romania, Serbia and Slovakia
Must-read for tax professionals and consultants
A Quick Guide to E-invoicing and Real-Time Reporting
Tax regulations in Eastern European countries are complex but that shouldn’t be a reason not to do business there. If you’re responsible for VAT compliance, this ebook provides key details of the varying VAT digitisation mandates and business requirements across the region:
Understand how to comply with the e-invoicing and reporting in Eastern Europe
Deep dives into Hungary, Poland, Romania, Serbia and Slovakia
Must-read for tax professionals and consultants
Get the ebook
Who should read this ebook?
Tax professional
Need to be up to date with Eastern European regulations
Understand system requirements for real-time reporting and e-invoicing
Prepare and future-proof for upcoming tax digitization
Consultancy
Ensure best practices for clients
Keep up to date with latest regulations and developments
Confidently navigate the tax landscape to help clients with planning
Written by tax experts and regulatory specialists
Tax administrations continue to insert themselves into the invoicing process or demand detailed records within a matter of hours or days of transactions. Many have introduced continuous transaction controls (CTCs)and are seeing the benefits of closing their country’s VAT gap and gaining granular, real-time or near real-time insight. Eastern Europe is part of this trend, moving forward rapidly with real-time reporting and e-invoicing initiatives.
The challenge of VAT digitization in Eastern Europe
Each Eastern European country has a different approach to CTCs. These differences could extend further as mandates evolve and businesses have to deal with new filing formats like SAF-T and real-time reporting to stay tax compliant. Understanding the varying demands of VAT compliance is key for any business operating in or looking to expand into the region. With this guide you’ll gain a greater understanding of the requirements across the region. Our deep dive into key countries will help you comply with VAT regulations now and prepare for upcoming mandates.
What this guide to Eastern Europe e-invoicing and reporting compliance covers
Get our guide for a comprehensive picture of CTCs in Eastern Europe and the many requirements that vary country to country. This includes invoice format, connectivity, data requirements, how to submit, archiving, legacy systems, technologies and business processes-all of which need to be reconsidered and rewired to be compliant. We also conduct extensive reviews of key Eastern European economies as well as uncover what’s on the horizon in one of the most important countries in the region, Slovakia:
The CTC landscape in Eastern Europe is constantly evolving, with countries at different stages of their journeys.
The Czech Republic, Austria, Croatia and Montenegro all currently allow post-audit invoicing.
Countries that have already implemented CTC regimes (either e-reporting or e-invoicing) where paper invoicing is still possible include Hungary, Albania and Greece.
In some cases, such as in Slovenia and Bulgaria, there are CTC schemes planned but details have yet to be specified.
Others have outlined their specifications and implemented voluntary schemes. Our guide covers some of these countries, providing details about the scope, document flows, key requirements and timelines of their regimes.
Romania – A sneak peak
There are three requirements for taxpayers in Romania:
Mandatory e-invoicing for B2G transactions
Mandatory e-invoicing for high-risk products
Electronic transport mandate
Taxpayers are required to use the Romania e-transport system to issue an e-transport document regarding the transport of high fiscal risk products before transportation of goods begins. This includes data regarding the sender, recipient, goods, places of loading and unloading and details of the means of transport and carrier.
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Government-mandated e-invoicing laws are making their way across nearly every region of the globe, bringing more stringent mandates and expectations on businesses. Inserted into every aspect of your operation, governments are now an omni-present influence in your data stack reviewing every transaction in real time as it traverses your network. Real-time monitoring has also brought about real-time enforcement that can range in severity from significant fines to shutting your business down completely. All of this has created a new reality for IT leaders who need a strategy to deal with these global changes. We asked our vice president of strategy and regulatory, Christiaan Van Der Valk to offer his guidance on how this will affect IT departments and how they can best prepare.
Q: With government authorities now in companies’ data and demanding real or near real-time reporting, what impact will this have on IT departments?
Christiaan Van Der Valk: The digitization of VAT and other taxes considerably expands the scope of the finance and transactional systems that need to meet specific – and ever-changing – government requirements. This phenomenon of broadening and decentralizing tax compliance in a company’s system and process landscape happens at the same time that more of these applications (for accounts payable automation, EDI, procurement, supply chain automation, travel and expense management, order-to-cash, customer communications management etc.) are used on a SaaS basis in multitenant mode.
This requires you to take stock of the applications that may come within the scope of VAT requirements in all relevant jurisdictions, and to review vendor contracts to ensure clarity as to responsibility for compliance. Procurement practices to license such external applications may also need to be reviewed to ensure proper contracting around tax compliance from the start.
Q: To meet government mandates and ensure operations continue uninterrupted, what should IT prioritize? What approach would you recommend?
Christiaan Van Der Valk: A key success factor is the degree to which IT and tax can team up to affect change in the organization. The default response to indirect tax changes will be to view these as evolutionary and best resolved by local subsidiaries. The introduction of CTCs, however, is a paradigm shift and one of the consequences is that solving these challenges in a decentralized manner can be harmful to a company’s digital transformation potential. IT and tax need to work closely together to raise awareness among all corporate and country stakeholders on the importance of a coordinated, strategic response to this profound change. The role of tax technologists who specialize in these interdisciplinary challenges cannot be underestimated.
A lot has changed in the world of government mandated e-invoicing. Continued investment in technology by government authorities has put regulators in the position to demand greater transparency along with more detailed and real-time reporting. To meet these demands, companies are looking to their IT organizations. The good news is you don’t need to go it alone. Sovos has the expertise to guide you through this global evolution based on our experience working with many of the world’s leading brands.
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Need help keeping up with global mandates? Get in touch with Sovos’ team of tax experts.
Problems encountered with Fire Brigade Tax rate increase in Slovenia
The rate increased from 5% to 9%. This came into effect on 1 October 2022. The first submission deadline followed on 15 November 2022.
Unfortunately, the transition has been plagued by problems. We discuss some issues and how Sovos is approaching them.
Slovenia’s new tax return
We had anticipated that the tax return would remain unchanged, with the premium reduction at 20% and the standard at 100% carrying over from the previous version. Instead, the Slovenian tax authorities overhauled the return entirely. This included:
The old rate at 5%
The new rate at 9%
Allowing for all combinations of rates to be selected
With the combinations, a return could include up to 30 different lines, but the return only includes four – one for each combination.
This layout suggests that the tax authority wishes to combine policies with the same rates, e.g., 100% and 9%.
This differs from previous returns.
Previously each class of business had a separate line. Sovos has contacted the tax authority about the most compliant way to complete this.
Telephone number information on tax return
Some aesthetic changes caused unexpected issues.
Telephone numbers now have a set number of boxes instead of an open line.
This change doesn’t accommodate longer phone numbers. For example, a UK phone number doesn’t fit.
This requires clarification from the tax authorities:
Should the number section be blank?
What about adding more boxes?
Will the authority issue a new tax return for international phone numbers?
Postcodes also have the same issue.
As frustrating as these issues are, there is a more significant frustration.
The amount of time between the new return’s publishing and the first submission deadline The new return was published online roughly three weeks before the deadline.
This was a very short turnaround to upload the returns to the systems and solve any problems that may have arisen, as well as informing clients about any new information that may be required here.
Fortunately, no new information was required. Short deadlines to comply with new tax return requirements are a frequent problem we encounter.
Conflicting information about Slovenia’s new Fire Brigade Tax return
Guidance from the tax authority has been inconsistent at best.
The new Fire Brigade Tax rate would apply to the cash received date. The 9% rate applies to any premiums generated after 1 October 2022.
However, guidance on the official Slovenian tax authority website stated that if the inception date for the policy was before 1 October, the 5% rate would still apply. This is regardless of when the premium was collected. This applies until the policy is renewed. At this point, the 9% rate is applied. This is a significant conflict. It’s potentially millions of euros difference in the amount due. Don’t forget the countless corrections required to balance the books.
As well as being issued late, multiple tax return versions were published online. Only one had the updated tax rate included. The return disappeared from the website and was replaced by the original return.
The English translation and other versions haven’t been updated – this is still the case even after the deadline.
Finally, the guidance on the tax authority’s website states it’s mandatory to submit the FBT returns online through the tax authority portal.
However, official communications from the tax authority directly informed us at Sovos that submissions were required by email only.
Again, this is a significant conflict. Submitting returns through the wrong channel would result in the tax authority declaring the submission late and levying fines.
Next steps with Slovenia’s new tax return
We have communicated all these issues to the Slovenian tax authority. We haven’t received a response yet, but we will update this blog as soon as we have more information.
Sovos has a wealth of experience that enables us to solve issues that arise and ensure our customers remain compliant with the latest tax requirements.
Need help with Fire Brigade Tax requirements in Slovenia?
Want to ensure compliance with the latest Fire Brigade Tax requirements? Speak to our experts.
This blog was last updated on 25 March, 2025 by Talent Gwaindepi
Little by little, we are witnessing how countries in Africa are starting to follow e-invoicing and continuous transaction control trends implemented by many other countries around the globe.
Each country in the continent is developing their own variation of a tax digitisation system. Currently there is no compliance standardisation, with requirements differing in each jurisdiction but local trends are emerging.
A common transaction reporting feature among African countries is the use of electronic or virtual fiscal devices. Electronic fiscal devices are essentially cash registers with software and direct communication to the tax authority. Virtual fiscal devices serve the same purpose but without the hardware component. Examples of countries using virtual fiscal devices are Kenya, Ghana and Uganda.
E-invoicing in Africa: Nigeria, Kenya, Egypt, Uganda and Tunisia
Another type of fiscal digitization process gaining popularity is e-invoicing mandates. This type of framework is on the legislative agenda for several national tax authorities, including Nigeria, Kenya, Egypt and Uganda. In this blog we explain the key features of these systems.
Nigeria e-invoicing: CTC invoice reporting under evolution and cross-border e-invoicing
Nigeria has a CTC e-reporting system. Taxpayers report invoice transactions electronically to the tax authority through the Automated Tax Administration System (ATAS), established for electronic VAT compliance purposes.
In addition to this e-reporting function, as of February 2022, all import and export operations need an authenticated e-invoice issued according to the format specified by the Central Bank of Nigeria (CBN).
The CBN has introduced the cross-border e-invoicing program, where suppliers and buyers operating in imports and exports register on a dedicated electronic platform. There are exemptions to obligatory e-invoices based on operations and taxpayers, such as the transaction value within the invoice.
In September 2024 the Federal Inland Revenue Service (FIRS) announced plans to implement a CTC clearance system introducing mandatory e-invoice through a new digital platform called FIRS Merchant Buyer Solution (FIRSMBS e-invoice). The new system is set to streamline invoice management in line with the Tax Administration and Enforcement Act of 2007. The initiative benefits B2B, B2C and B2G transaction by facilitating real-time transaction validation and e-invoice issuance, receipt and storage. E-invoices must be created in JSON or XML format, be digitally signed, and include specified data.
The national e-invoice system is designed in compliance with global best practices and utilises BIS Billing 3.0 UBL for seamless e-invoice exchange across platforms.
An e-invoicing pilot phase is planned to launch in the second half of 2025, starting with large taxpayers. Insights gained from the pilot phase will guide the broader implementation of the e-invoicing solution to other taxpayer groups. At this stage no further roll-out schedule has been published.
Kenya e-invoicing: cash register controls through TIMS/eTIMS
E-invoicing and e-reporting of invoice data to the Kenya Revenue Authority (KRA) became mandatory through the VAT (Electronic Tax Invoice) Regulations in 2020.
Initially, VAT-registered taxpayers were required to transmit individual invoice data in near real-time to the KRA using e-tax registers under the Tax Invoice Management System (TIMS). In 2023, KRA launched a new technology, the Electronic Tax Invoice Management System (eTIMS), to help with real-time electronic transfer of invoices to KRA. eTIMS can be accessed via electronic and digital devices, such as computers and mobile phone apps.
As of March 2024, both VAT-registered and unregistered persons need to be compliant with the eTIMS framework. Where a taxpayer already is TIMS compliant, there is no requirement to register for eTIMS, but they are required to ensure all sales invoices are TIMS/eTIMS compliant.
Businesses are prohibited from claiming all expenditures not supported by a TIMS/eTIMS-generated invoice and may receive a penalty of two times the tax due.
Uganda e-invoicing: Electronic Fiscal Receipting and Invoicing System
The Electronic Fiscal Receipting and Invoicing System (EFRIS) covers invoices and receipts of B2B, B2G and B2C transactions. Taxpayers must send e-invoices to EFRIS through electronic fiscal devices or via an API connection between the taxpayer and EFRIS. When initiating a transaction, transaction details are transmitted in real time to EFRIS to generate an e-receipt or e-invoice.
Egypt e-invoicing: CTC clearance
Egypt introduced a mandatory CTC clearance e-invoicing framework through a gradual roll-out plan that took place between November 2020 and 31 December 2022. Following completion of the roll-out phase, the CTC system now encompasses all businesses established in Egypt.
Sending e-invoices to the system on the same day of issuance is mandatory. B2G e-invoicing is mandatory regardless of company size. E-invoices must be created in JSON or XML format and contain the issuer’s electronic signature and a unified code for the goods or service.
Starting 1 July 2023, taxpayers who do not issue electronic tax invoices will be prevented from dealing with the Customs Authority and the customs system, whether in import or export.
The CTC regime was extended to also cover B2C transactions from 1 July 2022 and is being rolled out in phases. B2C receipts must be reported in real time. Phase 6 was rolled out in January 2025.
Foreign businesses conducting B2B sales into Egypt must validate their buyers’ Tax ID and Unique Identification Number (UIN) through a digital system. The compliance deadline, initially set for November 2024, was extended to 1 December 2024.
Tunisia e-invoicing: El-fatoura
Tunisia is a pioneer for e-invoicing with its system known as “el-fatoura”. Since 2016, the electronic issuing of invoices has been regulated in the Finance Law, and e-invoicing is mandatory for larger taxpayers.
The Tunisian e-invoicing regime operates under a CTC framework, which requires invoices to be registered through the Tunisie TradeNet (TTN) platform. E-invoices are issued using the XML format, and copies of validated and digitally signed e-invoices are sent to the Ministry of Finance.
Africa’s future e-invoicing landscape
We can expect more African countries to introduce similar e-invoicing systems in the near future given the growth in jurisdictions applying mandatory e-invoicing and e-reporting and the common agenda set by African Union that also refers to tax control and traceability.
Several African countries, including Angola, Botswana, Malawi, and Morocco have announced plans to implement e-invoicing systems, aiming to replace traditional electronic fiscal devices. However, in most of these cases, detailed information regarding the specific e-invoicing models to be adopted and their implementation timelines have yet to be published. The countries that follow will likely learn from the pioneers and early adopters, leading to a more uniform development of tax digitization in Africa.
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Part IV of V – Ryan Ostilly, vice president of product and GTM strategy EMEA & APAC, Sovos
Government-mandated e-invoicing laws are making their way across nearly every region of the globe, bringing more stringent mandates and expectations on businesses. Inserted into every aspect of your operation, governments are now an omni-present influence in your data stack reviewing every transaction in real time as it traverses your network. Real-time monitoring has also brought about real-time enforcement that can range in severity from significant fines to shutting your business down completely. All of this has created a new reality for IT leaders who need a strategy to deal with these global changes. We asked our vice president of product and GTM strategy, Ryan Ostilly to offer his guidance on how this will affect IT departments and how they can best prepare.
Q: With government authorities now in companies’ data and demanding real or near real-time reporting, what impact will this have on IT departments?
Ryan Ostilly: IT teams will have to work hard to ensure their core finance and transactional tax systems have the enhanced capability to extract, transform, remit and consume real-time data with all tax jurisdictions across their global footprint, in compliance with an ever-changing myriad of legal and procedural requirements. With the pace of disruption accelerating, governments are rewriting the rules on taxpayer control and engagement, forcing direct connection and intimacy with the data itself.
I fear that in a growing number of cases, the owners of the data may be functional departments. The IT department will need to evolve its role in this relationship, viewing the government as a critical business partner – one with whom they must always be connected, continuous and complete.
Q: To meet government mandates and ensure operations continue uninterrupted, what should IT prioritize? What approach would you recommend?
Ryan Ostilly: In this modern era of government-initiated tax transformation, the successful IT department will pursue a proactive strategy that prioritizes a connected, continuous and complete framework for government mandates and Continuous Transaction Controls (CTCs). These three principles are:
Connected – Architect a simplified integration and vendor strategy. Reduce exposure to multiple integrations and heavy projects when adopting new jurisdictions or implementing changes.
Continuous – Partner with regulatory and legal experts on a regular basis. Review upcoming mandates and assess the impact on your current and future business requirements.
Complete – Think beyond technical aspects and schemas. Partner with tax subject matter experts when translating and validating mandate requirements, as these outputs will define the financial and tax position of your company with the tax authorities in real time.
A lot has changed in the world of government mandated e-invoicing. Continued investment in technology by government authorities has put regulators in the position to demand greater transparency along with more detailed and real-time reporting. To meet these demands, companies are looking to their IT organizations. The good news is you don’t need to go it alone. Sovos has the expertise to guide you through this global evolution based on our experience working with many of the world’s leading brands.
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Need help keeping up with global mandates? Get in touch with Sovos’ team of tax experts.