Cyrille Sautereau – President FNFE-MPE & CEO Admarel Conseil 

Ahead of the Tax Compliance Summit Sovos Always On: Paris on 19th November, we asked Cyrille Sautereau, Chair of the AFNOR “Electronic Invoice” Commission and President of the National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE), to discuss the evolving landscape of e-invoicing reform in France, the challenges of interoperability, and the country’s role in shaping European standards.

 

The National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE) plays a key role in coordinating discussions around the reform. Could you remind us of the Forum’s mission and how it serves as a bridge between the administration and businesses?

The National Forum for Electronic Invoicing was created in 2012 following the establishment of the European Multi-Stakeholder Forum on Electronic Invoicing (EMSFEI), which led several Member States, including France and Germany, to create their own mirror forums. From the outset, its mission has been to support the development of e-invoicing in France, across both public and private sectors, in alignment with EU initiatives. We became an association in 2016 and now have more than 280 members divided into three colleges: users, service providers, and independent experts and consultants.

Our role is both normative and educational. Normative, because we actively contribute to the development of European and national e-invoicing standards, in close collaboration with the AFNOR “Electronic Invoice” Commission, which I also chair; and educational, because we provide best practices and help the ecosystem understand the regulations, enabling companies to transition smoothly to e-invoicing.

Finally, we fully play our role as a bridge between public authorities and the market. The FNFE is regularly consulted by the tax administration and lawmakers, particularly on regulatory developments related to the reform. We bring field expertise — our knowledge of invoicing practices, tools, and the operational constraints businesses face. This ongoing dialogue helps fine-tune regulations and ensures a harmonized, effective implementation of the reform.

 

The FNFE-MPE brings together public institutions, businesses, software providers, and technical experts. How do you manage to unite these actors, whose interests sometimes differ, around common standards?

The FNFE-MPE brings together a wide range of stakeholders: businesses, vendors, service providers, accountants, professional federations, and even representatives of the public administration. Our mission is to facilitate dialogue among these groups, which don’t always share the same priorities. The key is transparency and co-construction: everyone can take part in our working groups and contribute to developing the standards.

We hold several plenary sessions each year, along with about ten thematic working groups covering topics such as e-invoicing reform, interoperability, standards and norms, communication, best practices, invoicing and payment, B2G invoicing, and factoring. These forums allow members to share feedback, identify practical challenges, and bring them to standardization bodies.

This collaborative approach has fostered a genuine common language between public and private actors. That’s the strength of the FNFE — its ability to unite the entire ecosystem around a shared vision, ensuring that both technical and regulatory choices remain realistic, effective, and business-oriented.

 

One of the major challenges of the reform lies in ensuring interoperability between private platforms and public systems. In your view, what are the main hurdles to overcome to ensure a smooth and coherent ecosystem?

Interoperability is indeed one of the most sensitive aspects of the reform. Contrary to what people might think, the main challenge doesn’t lie in connecting private platforms to the Public Invoicing Portal — that interface is precisely defined by the DGFiP’s specifications — but rather in ensuring smooth communication among private players themselves.

The first challenge concerns certified platforms (formerly PDPs), which must be able to exchange data without multiplying bilateral integrations. That’s why we supported the rollout of the Peppol network in France — a model where one connection makes you interoperable with all other network participants. The second pillar is a shared addressing system based on the SIREN number and managed within a public directory. This ensures that every business is reachable through a stable e-invoicing address — one that remains unchanged when switching platforms.

Finally, there’s the “last mile”: connecting companies’ internal systems (so-called “compatible solutions”) to their certified platforms. Given the variety of software tools on the market, proprietary integrations must be avoided. That’s the goal of the AFNOR initiative to design a standardized API — a universal connector that ensures seamless transitions between platforms. Portability is essential for an open, sustainable ecosystem.

 

The French e-invoicing mandate — the progressive obligation for all companies to issue and receive invoices through certified platforms starting in 2026 — is part of a broader European movement driven by the ViDA (VAT in the Digital Age) initiative. How does France position itself in this EU-wide transformation?

The French reform is closely aligned with the European ViDA project, which aims to harmonize e-invoicing and reporting practices across the EU. ViDA calls on Member States to establish systems for e-reporting and e-invoicing based on structured data and standardized formats — exactly what France has already implemented.

Our national model, based on the exchange of structured electronic invoices between French taxpayers and the automatic transmission of data to the tax administration, already mirrors ViDA’s intended architecture. The key difference is that France chose from the outset to combine mandatory e-invoicing with e-reporting to the tax authorities — whereas other countries limited their first phase to B2B e-invoicing, postponing e-reporting to a later stage. We also introduced two unique features: invoice status tracking — ensuring lifecycle traceability and giving suppliers the visibility and value they’re entitled to — and B2C e-reporting, which isn’t covered by the European scope. In short, France won’t need to adapt its system to ViDA; it already embodies it. 

 

Some believe that France could become a reference model in Europe, provided it successfully deploys the reform. Do you share that view? What lessons could other Member States draw from the French approach?

France can indeed become a European benchmark, provided the operational rollout succeeds. What sets us apart is the decision to tackle the issue holistically, integrating technical, regulatory, and business aspects from the beginning. While other countries proceeded step by step — first e-invoicing, then reporting — we decided to merge both dimensions right away.

Requiring VAT data to be transmitted to the tax administration from each invoice inherently assumes that, within each invoice, the seller is responsible for VAT collection and the buyer for deduction. This creates additional complexity in many cases where intermediaries — such as aggregators handling invoice consolidation or grouped payments — play a role without being the actual taxpayer.

Our approach builds on significant collaborative work within the AFNOR “Electronic Invoice” Commission, which I also chair. Over six months, more than 250 experts from all sectors took part in over sixty meetings. This work revealed the real complexity of use cases, often underestimated — for example, scenarios where several service providers appear on a single invoice for one buyer, such as in the water, leasing, insurance, or travel sectors. These configurations turned out to be far more common than expected. The AFNOR work also helped align French practices with the European semantic standard EN 16931 — ViDA’s foundation — while identifying its limitations and addressing them through data extensions or management rule updates.

Finally, this process confirmed the need for flexibility — allowing human-readable formats, like hybrid Factur-X invoices, which include operationally useful data that may not fit within the semantic standard or technical capabilities of some small businesses.

This ability to identify specific cases and address them within a shared normative framework is, in my view, France’s main strength. It helps anticipate complex situations, deliver standardized solutions (“the same problems, the same answers”), and maintain coherence between regulatory requirements and business realities. Many Member States will likely draw inspiration from this integrated approach when implementing ViDA.

 

Beyond compliance, the reform will generate an unprecedented volume of standardized economic data. Do you think this infrastructure could ultimately become a driver of competitiveness and innovation for French companies?

Beyond compliance, the reform will fundamentally change how companies manage their operations. By generalizing e-invoicing, we’re introducing structured, reliable, and continuously available data — replacing the paper and PDF-based exchanges that still dominate today. This is transformative: data becomes instantly usable by management systems, without re-entry or manual processing.

In practical terms, this will allow all companies — including SMEs — to reach levels of automation and visibility previously reserved for large groups. Cash-flow reporting or monthly closings will no longer take days of reconciliation: invoices will be integrated in real time, and discrepancies will appear immediately. This responsiveness will enhance business leaders’ ability to manage performance, detect weak signals, and anticipate payment delays — in short, to shift toward predictive management.

In the long run, value-added services could emerge from aggregated, anonymized data analysis. For example, a platform could offer buyers average market price benchmarks based on peer transactions, helping them better position themselves competitively. These uses will need to be regulated to preserve confidentiality, but they open promising perspectives. Competitiveness will thus depend not only on compliance, but on data quality and intelligent exploitation.

 

You’ll be speaking at Sovos’ Always-On event on November 19, which will bring together public authorities, businesses, and solution providers around e-invoicing and tax compliance. What do you expect from such a gathering at this pivotal stage of the reform?

We regularly take part in events like Always-On because they play an essential role in collective education around the reform. The more opportunities for dialogue, the better. For the FNFE-MPE, it’s a concrete way to fulfill our mission of supporting businesses. These meetings help clarify what the reform truly entails, demystify its implementation, and provide a neutral perspective that complements that of service providers.

That’s important, because many companies still have a fragmented understanding of the reform: some overestimate its complexity, while others haven’t yet grasped its full impact. In this context, direct exchanges among public authorities, experts, vendors, and users are key to building a shared culture and reliable reference points. Such events help reinforce a crucial message: the success of e-invoicing depends on adopting shared standards, ensuring consistency of practices, and rejecting unnecessary complexity.

For too long, everyone built their own processes, portals, and formats — often with limited success. One of the reform’s main goals, and one of the benefits of events like Always-On, is to move beyond this “each to their own” mindset and build a truly interoperable ecosystem.

 

Among the many topics that will be discussed during the event, artificial intelligence stands out as particularly important. AI is now increasingly present in both compliance and tax controls. How can we ensure that this technological evolution strengthens — rather than undermines — the relationship of trust between taxpayers and authorities?

The importance of AI will grow as data volumes increase. AI can first help companies better understand what the administration “sees” about them by comparing their internal data with prefilled information. This “mirror visibility” can help identify and explain discrepancies even before an audit is initiated.

That said, we must remain clear-eyed about technology’s limits. AI is an analytical support tool, not an arbiter of truth. Its effectiveness will always depend on the algorithms behind it and the quality of the data it processes. Used rigorously and transparently, AI can strengthen trust between companies and tax authorities by making processes more objective and efficient. Conversely, if poorly managed, it risks creating new areas of opacity or misunderstanding.

The challenge in the years ahead will be to strike the right balance: leveraging AI’s power to make compliance more reliable and streamlined while preserving human interpretation and dialogue. Only under these conditions can technology truly serve trust, rather than weaken it.

VAT in the Digital Age (ViDA) is one of the most significant regulation changes to EU VAT in recent years. Changes to requirements became effective on 12 March 2025 with the official adoption of the package, with further rules coming into effect in 2030.

This blog discusses the changes impacting businesses, including Digital Reporting Requirements, and when they take effect.

Changes effective as of ViDA’s approval on 12 March 2025

Removal of EU approval for domestic e-invoicing

Under the previous VAT Directive, EU approval was required for Member States to introduce domestic mandatory B2B e-invoicing. Countries such as Italy, Poland, Germany, France, Belgium and Romania applied for derogations to mandate e-invoicing. With ViDA, Member States may impose domestic e-invoicing without needing EU approval, provided it applies only to established taxpayers.

Buyer e-invoice acceptance eliminated

The previous EU VAT Directive stated the use of e-invoices was subject to buyer acceptance. Under ViDA, Member States that have introduced mandatory domestic e-invoicing will no longer require buyer consent.

ViDA changes effective from 1 July 2030

Redefinition of electronic invoicing

ViDA redefines electronic invoices. Under the proposal, electronic invoices are those issued, transmitted and received in a structured electronic format that allows its automated processing. This means that non-structured formats, such as pure PDFs or JPEG images, will no longer qualify as an e-invoice. Hybrid formats, such as ZUGFeRD and Factur-X, can remain due to their structured portion.

In principle, electronic invoices must comply with the European standard and the list of its syntaxes pursuant to Directive 2014/55/EU (the “EN” format). However, ViDA allows Member States to use other standards for domestic transactions upon meeting certain conditions.

From 2030, B2B e-invoices compliant with the European standard will be the default and no longer requiring buyer acceptance. However, if a Member State opts for a different mandatory domestic standard, they may either waive or require buyer acceptance for e-invoices using the European standard.

ViDA Digital Reporting Requirements (DRRs) for cross-border transactions

One of the most impactful updates in ViDA is the requirement for near-real-time digital reporting of cross-border transaction data.

Starting in 2030, taxpayers engaging in cross-border transactions within the EU must report invoice data electronically following the EN format. Such DRR will be a condition for taxpayers to exempt VAT in a cross-border transaction or claim input VAT. Each Member State will provide electronic mechanisms for submitting this data.

With ViDA, cross-border e-invoices within the EU must be issued in up to 10 days after the chargeable event. In these cases, DRR must happen at the same time the e-invoice is issued or should have been issued.

Invoices issued by the recipient on behalf of the seller (known as self-billing) and the invoices related to intra-community acquisitions must be reported no later than five days after the invoice is issued or should have been issued or received, respectively.

As expected, DRRs may be carried out by the taxpayers themselves or outsourced to a third party on their behalf.

ViDA Digital Reporting Requirements for domestic transactions

ViDA grants Member States the option to mandate digital reporting for domestic B2B/B2C sales, purchase data, and self-supplies for VAT-registered taxpayers within their jurisdiction. Domestic reporting requirements must align with ViDA’s cross-border DRR standards, and Member States must permit submissions in the European standard format, although other interoperable formats may be allowed.

For Member States with domestic real-time reporting systems in place as of 1 January 2024, compliance with ViDA’s standards will be required by 2035. On the other hand, the package clarifies that other reporting obligations, such as SAF-T, can still exist. This alignment will ensure consistency across the EU in preparation for full ViDA implementation.

Member States have until 30 June 2030 to integrate ViDA’s e-invoicing and DRR provisions into their national legislation, making the Directive effective across the EU by 1 July 2030.

ViDA’s impact on businesses

ViDA represents a significant shift for businesses operating within the EU, promising both opportunities and challenges. By introducing DRRs, ViDA aims to replace obsolete requirements, reduce administrative burdens, improve accuracy, and combat VAT fraud.

The move towards structured e-invoicing and near-real-time digital reporting will require businesses to update their invoicing and reporting systems, driving digital transformation across sectors. While the transition may entail initial adjustments, it is expected to increase efficiency, create a level playing field, and facilitate smoother interoperability between companies using different systems.

Find out more by reading our dedicated VAT in the Digital Age guide.

With the pilot phase of France’s e-invoicing reform fast approaching, we’re prepared to support businesses every step of the way. As a global provider of tax compliance solutions and a trusted technology partner, we’re ready to help companies navigate the upcoming transition with confidence.

Preparing for a Milestone Year

The French B2B e-invoicing reform is set to begin its pilot phase in February 2026, and we’re fully prepared to support companies during this critical stage.

With less than a year to go before the phased implementation of the mandate, we’re anticipating the needs of both French and international businesses operating in France. Our solution is complete, interoperable, and aligned with the latest specifications published by the French tax authority (DGFiP) and the AFNOR Commission.

A Pilot Phase Starting in February 2026

According to Article 91 of the 2024 Finance Law, the obligation to receive electronic invoices will apply to all VAT-registered businesses from 1 September 2026. The issuance of e-invoices and e-reporting data will be introduced progressively between 2026 and 2027.

To help companies prepare, the French tax authority has announced a pilot phase starting in February 2026. Participation will be voluntary and will involve testing all end-to-end flows, formats, and business scenarios set out in the reform. Companies and their Partner Dematerialisation Platforms (PDPs) will play a central role in ensuring everything is operational before the full mandate kicks in.

We’re Operational and Ready to Cover 100% of the Use Cases

We’re committed and ready to support our clients and partners in this next crucial step. Our solution enables participation in the pilot while covering all 36 use cases identified by the DGFiP, including:

Our platform is fully compliant with the latest technical specifications issued by the DGFiP, and we plan to support our first voluntary clients from the very beginning of the pilot in early 2026.

As of August 2024, we’re officially registered as a Partner Dematerialisation Platform (PDP no. 0004). Thanks to our deep regulatory expertise, strong local presence, and robust global infrastructure, we’re uniquely positioned to support clients not only during the pilot, but all the way through full implementation.

Guiding You Through the Transition with Confidence

This combination of technology, expertise, and trusted partnership makes Sovos a strategic ally in the transition to e-invoicing. We’re here to guide businesses of all sizes with confidence, ensuring full compliance with the evolving requirements in France, across Europe, and around the world.

The digital business landscape is forever changing, yet one thing is certain: electronic archiving is more than a convenience – it’s a matter of compliance.

As governments worldwide invest in digital tax transformation initiatives like e-invoicing and e-reporting, a complex web of e-archiving requirements that vary across borders is also developing.

Understanding your e-archiving requirements is essential for maintaining proper tax evidence, surviving audits, and preventing potential business disruptions.

Understanding e-invoicing and e-archiving fundamentals

E-invoicing refers to the issuance and exchange of digital invoice documents, often in structured formats, replacing traditional paper processes. As countries implement mandatory e-invoicing and other types of Continuous Transaction Controls (CTCs) to close tax gaps and reduce fraud, these electronic documents must adhere to increasingly complex country-specific requirements.

While e-invoicing addresses the transaction process, e-archiving focuses on the long-term storage and preservation of these electronic documents in their original format to allow subsequent audits. This means proving that an archived invoice is precisely the same as when it was originally issued or received, with no unauthorised alterations.

According to research conducted between 2024 and 2025 by the Digital Innovation Observatories, “document archiving and management is the most commonly adopted service as a consequence of the introduction of e-invoicing mandates.”

This trend reflects a broader shift: regulatory compliance is no longer just about issuing invoices correctly, but also about how those documents are managed and retained throughout their lifecycle. As such, understanding the fundamentals of both e-invoicing and e-archiving is critical for organisations aiming to remain compliant, efficient and prepared in an increasingly digital and regulated environment.

Why e-archiving deserves your attention

E-archiving requirements are frequently underestimated but are critical to tax compliance globally.

While CTC systems provide real time granular data to the authorities, the possibility to conduct audits persists after the e-invoicing process, i.e. during the storage period, when the authorities will access e-archives to verify compliance. This makes a robust e-archiving system essential for businesses operating across multiple jurisdictions, each with unique regulatory requirements.

Importantly, businesses must maintain their own e-archiving strategy even when tax authorities offer centralised archiving services as part of CTC frameworks. In the event of an audit or legal dispute, it is ultimately the taxpayer’s responsibility to disprove or challenge the data held by the authorities. Relying solely on tax authority systems – or worse, on a counterparty’s archive – could leave businesses vulnerable, with limited control over the integrity or availability of critical documentation.

Moreover, businesses should view e-archiving not merely as a compliance obligation but as an opportunity to improve document management, streamline operations and strengthen audit defence. Without proper archiving, companies risk substantial penalties during audits and may face difficulties demonstrating compliance with local tax laws.

Key e-archiving requirements

While there are several varying requirements from country to country, the following represent some of the essential general elements businesses must keep in mind when implementing a compliant e-archiving system:

Country-specific e-archiving complexities

As mentioned before, businesses often overlook the fact that e-archiving regulations can be as diverse and specific as e-invoicing mandates themselves, with each jurisdiction imposing its own distinct set of requirements.

While general requirements are present in almost every country, there are also unique complexities. As requirements differ from country to country, companies will find that certain jurisdictions have more complex and stringent e-archiving rules

Some country-specific e-archiving complexities examples are listed below:

Developing a robust e-archiving strategy

Developing and implementing an effective e-archiving strategy presents significant challenges for businesses operating across multiple jurisdictions. With varying retention periods, technical requirements and constantly evolving regulations, organisations often struggle to establish compliant archiving processes that scale efficiently while minimising risk. A well-designed e-archiving approach ensures compliance, optimises operational efficiency and supports business continuity.

To develop an effective e-archiving approach, businesses should:

  1. Implement centralised archiving governance to maintain consistent compliance across all business entities
  2. Select a solution that supports the relevant geographic scope
  3. Ensure proper documentation of archiving systems and processes
  4. Verify that archived invoices maintain their legal validity with proper signatures and timestamps
  5. Involve regulatory and legal teams in the strategy development process to ensure all jurisdictional requirements are properly addressed
  6. Enable appropriate access controls for auditors while maintaining security

Tax audits can occur unexpectedly, requiring immediate access to archived invoices. Businesses should regularly test the retrieval and readability of archived documents and ensure staff understand how to access and present them during audits.

Benefits beyond compliance

Beyond meeting regulatory requirements, a well-designed e-archiving system delivers significant business advantages:

Building your compliance foundation

Implementing a globally compliant e-archiving solution requires careful planning across technical, legal and operational dimensions. Rather than treating e-archiving as an afterthought to e-invoicing, it should be part of the foundation of your compliance strategy.

Sovos eArchiving offers compliant storage across over 60 countries from a single platform, ensuring country-specific compliance and continuous regulatory updates. This approach allows businesses to maintain compliance with constantly evolving requirements via one universal compliant e-invoice archive, regardless of the number of service providers and e-invoicing software solutions a company uses.

As tax authorities worldwide continue embedding compliance into business transactions, a robust e-archiving system isn’t just good practice—it’s essential for business continuity and audit readiness in our increasingly digital tax environment.

Last month, a cross-functional group of Sovos unclaimed property experts—including folks from product development, product marketing, managed services, our general counsel’s office, and the consulting team—traveled to Tucson, Arizona to the Unclaimed Property Professional Organization’s annual conference. We spent the week diving deep into all things unclaimed property.

There was one topic that kept coming up: digital assets.

Whether it was NFTs, crypto wallets, sports betting accounts, or the rewards creators earn from social media platforms, digital property raised big questions. How should it be categorized? When is it considered abandoned? Who owns it? Who has access to it? And, maybe most important to holders – what are states doing about it?

Spoiler alert: They’re starting to act. The inclusion of digital assets in unclaimed property laws is becoming more common, and it’s changing the game for holders and owners alike.

Let’s break down what’s happening and what it means for all of us trying to stay ahead of the curve.

Reminder, unclaimed property = consumer protection

Unclaimed property laws are all about consumer protection. If a company is holding onto money or property that belongs to someone—but hasn’t had contact with that person in a certain number of years—it’s required to report and remit that property to the state. The goal is to reunite the owner with their property.

Traditionally, this applied to tangible items like uncashed checks, forgotten savings accounts, and unused rebates, etc. But as more of our lives—and our money—shift online, regulators are starting to rethink what “property” means in the modern era. 

Enter digital assets: From crypto to creator rewards

Digital assets are a broad category. We’re talking about:

These assets don’t live in a safe deposit box or a bank account. They exist entirely in cyberspace, and they’re often managed by tech platforms or stored behind cryptographic keys that only the owner controls. So, what happens when these assets sit idle? When an account goes untouched for years, or a wallet gets locked away forever?

States are starting to say: That’s unclaimed property and it’s escheatable.

What states are actually doing

Two states leading the charge are Delaware and Illinois. Both have updated their unclaimed property laws to formally include digital assets—but have limited their scope to virtual currencies.

Delaware’s take

In 2021, Delaware passed legislation that defines virtual currency as property and requires holders to liquidate it if it becomes abandoned. After five years of inactivity, companies must:

Importantly, the law makes clear that any increase in the value of the virtual currency after liquidation would not impact the value of the property that was remitted to the state as unclaimed.  The risk associated with potential loss of value associated with liquidated accounts and the potential for related lawsuits is reason for Holders to be proactive about managing the digital portfolios held in their care.

Illinois follows suit

Illinois did something very similar. Their updated law uses the same five-year dormancy period and defines virtual currency in a nearly identical way. Holders must liquidate and remit the proceeds within 30 days prior to filing their unclaimed property reports.

So, if you’re a business holding customer crypto (think exchanges, fintech apps, digital wallets), your compliance obligations may have just expanded.

Why this matters for holders (like financial platforms, exchanges, betting apps):

Organizations are going to need to start tracking digital assets more closely. That means:

That’s no small feat, especially with the volatility of crypto markets and the added security concerns that come with handling digital wallets.

What’s Next? More States, More Complexity

The general consensus at the Tucson conference was this: We’re just getting started.

Digital assets aren’t going away. In fact, as more people embrace Web3 and decentralized finance, the volume of digital property will only grow.

That means more states are likely to follow Delaware and Illinois. We expect to see:

What we heard again and again in Tucson is that digital assets are challenging, but they’re not exempt.

At Sovos, our team is staying on top of these changes to help businesses navigate the risks and stay compliant. The digital economy doesn’t fit neatly into old frameworks—but that doesn’t mean it’s out of scope.

Need help navigating the evolving landscape of digital assets? Subscribe to the Sovos newsletter today to get the latest insights, news and compliance updates delivered straight to your inbox.

We recently partnered with StudioID on a global survey of 150 finance leaders to reveal significant insights into how companies are navigating the increasingly complex world of indirect tax compliance. The research, which included CFOs, EVPs/SVPs/VPs of Finance, and Finance Directors from companies with revenues ranging from $500 million to over $5 billion, provides a comprehensive look at the strategies finance leaders are implementing to stay ahead of changing regulations.

Real-Time Reporting Becomes Essential

The survey found that an overwhelming 95% of finance executives believe ensuring accurate real-time data reporting is important or extremely important for improving tax and compliance operations. This shift reflects a fundamental change in how tax authorities operate globally.

Previously in indirect tax, the way that the government could enforce the law was always through periodic reporting, but it was an unsophisticated instrument. Now, continuous transaction controls have become very popular since it’s about sending data in real time to the government.

This transition means businesses are no longer simply reporting their subjective view of a period’s aggregate sales and purchasing numbers —tax authorities are increasingly gathering authenticated data in real-time and informing companies of their liability instead. The stakes are higher than ever, with non-compliance potentially halting business operations entirely rather than just resulting in penalties.

Navigating Complex Jurisdictions

The complexity of global tax compliance is staggering. Approximately 30% of both US-based and international companies surveyed sell products and services across 2,000 to 5,000 different tax jurisdictions. Each jurisdiction has its own rules, rates, and reporting requirements. Requirements are also increasingly dynamic, with laws and technical specifications evolving to reflect tax administrations’ fine-tuning operations at an ever-increasing rate.

With initiatives like VAT in the Digital Age (ViDA) and e-invoicing mandates rolling out across Europe and beyond, companies must stay ahead of regulatory changes. Encouragingly, 87% of finance executives report having systems and processes in place to anticipate these upcoming mandates.

Top Challenges in Implementation

When it comes to successfully implementing current and upcoming e-invoicing mandates, finance leaders identified two primary challenges:

  1. Staying informed about domestic and international compliance requirements (38%)
  2. Choosing the right platform that can seamlessly integrate with existing systems (49%)

Additionally, 56% of respondents mention difficulty in making business decisions due to limitations around tax and compliance data accessibility and accuracy.

Strategic Responses to Tax Complexity

Finance leaders are implementing several key strategies to improve their indirect tax and compliance operations:

These investments are paying off—76% of finance executives report seeing a positive return on investment from their tax compliance software. However, cost remains a significant concern, with 91% identifying “lowering or maintaining compliance costs” as a top priority.

The Problem of Point Solutions

One notable finding is that 73% of respondents believe their companies use too many point systems to meet tax obligations across different geographical locations. The median number of systems currently in use is 40, with most wanting to reduce this number significantly.

There seems to be a lot of confusion in the market, whereby a lot of businesses think they need to replace their business software with regulatory-driven software. This simply isn’t true as there are multiple ways that leaders can make existing business software compliant.

Looking Ahead

As tax authorities worldwide continue advancing their technology, making compliance more complex and demanding, finance leaders must balance compliance requirements with business objectives. The most successful approach integrates tax considerations into core business processes rather than treating them as separate functions.

The message is clear: while tax compliance is becoming more complex, the right strategies and technologies can transform this challenge into an opportunity for greater efficiency and intelligence about your business. Whatever you set as your business objectives, make sure that your compliance software works in such a way that the tax is never a burden.

By staying ahead of regulatory changes and investing in the right solutions, finance leaders can ensure their organizations not only remain compliant but thrive in an increasingly complex global tax landscape.

 

Want to learn more about how finance leaders are adapting to the changing indirect tax landscape? Download the full research report, “The Future of Indirect Tax: How Finance Leaders Are Staying Ahead of Changing Regulations” for comprehensive insights and strategic recommendations. Download Now

VAT in the Digital Age (ViDA) aims to modernise and simplify the European VAT system.

ViDA was officially adopted by the EU on 11 March 2025. The package took 27 months to be approved and adopted, with the initiative initially being proposed by the European Commission in 2022.

The path to adoption included many versions and consultations, which this blog outlines in a timeline.

Want to understand more about ViDA and how it will impact your business? Read our ViDA guide.

 

2025

25 March 2025 – ‘VAT in the Digital Age’ Published in the EU Official Journal

On 25 March 2025, the VAT in the Digital Age (ViDA) package was officially published in the Official Journal of the European Union amending the following legal instruments:

These amending acts will enter into force on 14 April 2025, with different changes taking effect from that date through to 2035.

This means that in 20 days, the first changes will take effect regarding electronic invoicing rules. Under the new framework, EU Member States will have the flexibility to introduce domestic e-invoicing mandates without needing prior approval from the EU.

11 March 2025 – EU Officially Adopts ‘VAT in the Digital Age’

The VAT in the Digital Age Package (ViDA) has been adopted by the EU on 11 March 2025, 27 months after it was initially proposed by the Commission in late 2022.

The package includes a directive, regulation, and implementing regulation, focusing on three key areas: digitalizing VAT reporting by 2030, requiring online platforms to collect VAT on short-term accommodation and passenger transport services, and expanding the online VAT one-stop-shop to simplify cross-border VAT registration.

The new rules will take effect on the 20th day after publication in the Official Journal of the EU, with Member States required to transpose the directive into national law.

While many rules will come into effect only a few years from now, some will be effective immediately, such as Member States’ right to introduce mandatory domestic electronic invoicing without needing prior authorization from the EU.

12 February 2025 – European Parliament approves ViDA Proposal 

The European Parliament has approved the VAT in the Digital Age (ViDA) proposal, bringing it one step closer to official adoption. The proposal will now head to the Council of the EU for final approval, marking a key step in the effort to modernize VAT systems throughout the European Union. 

 

2024

5 November 2024Member States agree to adopt ViDA package

The European Parliament has approved the VAT in the Digital Age (ViDA) proposal, bringing it one step closer to official adoption. The proposal will now head to the Council of the EU for final approval, marking a key step in the effort to modernize VAT systems throughout the European Union.

The long-awaited VAT in the Digital Age (ViDA) proposal has been approved by Member States’ Economic and Finance Ministers. On 5 November 2024, during the Economic and Financial Affairs Council (ECOFIN) meeting, Member States unanimously agreed on adopting the ViDA package. This decision marks a major milestone in modernizing the VAT Directive, setting the stage for a more efficient and digital VAT system across the European Union.

Certain changes will take effect immediately once the package comes into force, while others will roll out in stages over the coming years.

The text will proceed to formal approval by the Parliament, after which it will be ready for official adoption.

1 November 2025 – New ViDA Proposal Set for ECOFIN Approval

The Council of the European Union has released a new proposal regarding the VAT in the Digital Age (ViDA) reform.

The proposal aims to modernise and streamline VAT systems across the EU, notably e-invoicing and Continuous Transaction Controls (CTC). Members States will review it on 5 November at the upcoming ECOFIN meeting. The main change in the new ViDA proposal concerns the dates when measures become effective. Deadlines have been postponed as a result of the setbacks ViDA has faced since its initial draft.

If approved, a series of changes will take place over time – some of which will take effect as soon as the Directive enters into force.

25 June 2024ViDA Rejected again

During the latest ECOFIN meeting on 21 June, Member States met to discuss if they could come to an agreement to implement the VAT in the Digital Age (ViDA) proposals. At the ECOFIN meeting in May, Estonia objected to the platform rules being proposed, instead requesting to make the new deemed supplier rules optional (an opt-in), allowing Member States to choose whether to implement them in their national VAT legislation or not.

In the meeting a new compromise text was proposed. The compromise text meant that there would be an opt in for the new deemed supplier rules but for SME businesses. Whilst 26 Member States and the commission came to an agreement on this, Estonia could not support the new compromise due to the fact there was no substantial changes since the last meeting and their objections remained. It will now be up to the Hungarian presidency to seek agreement on the proposals, during the second semester of 2024.

 

2023 

November 2023 – Committee on Economic and Monetary Affairs proposes postponement of ViDA

The Committee on Economic and Monetary Affairs from the European Parliament has proposed to postpone most aspects of ViDA for at least one year. The committee cites ongoing delays in the legislative process as a reason for the postponement. The recommendation was decided on a nearly unanimous vote; no members voted against the measure.

If the Committee’s proposal is adopted as written, the revised launch dates for ViDA will be as follows:

E-Invoicing and Digital Reporting Requirements: Member States must implement administrative provisions for digital reporting requirements by January 1, 2029. The requirement for Member States to allow electronic invoicing, subject to common standards and without prior authorization from the tax authority, would take effect January 1, 2025. 

Deemed Supplier Rules for Platforms: Member States must implement provisions to harmonize treatment of services facilitated by electronic platforms, and to impose deemed supplier rules for goods facilitated by electronic platforms, by January 1, 2026. 

Single VAT Registration: Existing rules for VAT treatment of call-off stock would cease to apply as of December 31, 2025 [no change from original proposal]. Changes to Article 194 of the VAT Directive would take effect by January 1, 2026. Member States must implement provisions to expand the scope of non-Union and Union One-Stop Shop schemes by January 1, 2026. 

 

2022

8 December 2022Commission adopts ViDA proposal and issues a follow-up feedback period

May 2022Feedback period ends

January 2022EU Commission proposes VAT in the Digital Age plan

As governments worldwide continue to shift to Continuous Transaction Controls (CTC) systems, such as e-invoicing and real-time e-reporting, another trend organically unfolds as part of this move towards tax digitisation: pre-filled returns.

With access to real-time transactional level data – and other types of data, such as payroll, inventory and other accounting data transmitted at less regular intervals – tax authorities can facilitate other tax obligations with measures like prepopulating returns. This move ensures that the data submitted via CTC systems become the taxpayer’s single source of truth and highlights the importance of data quality.

Countries such as Chile – the cradle of e-invoicing – along with Indonesia, Spain and Portugal, have now been using pre-filled returns for several years. Many other countries have followed suit, with Greece being one of them.

Pre-filled VAT Returns in Greece: Overview

Greece made this significant step in 2022, introducing a new framework for pre-filled VAT returns based on data submitted through the myDATA platform. The measure aims to increase accuracy, transparency, and administrative efficiency for both businesses and tax authorities.

Greece has also made the pre-filing of income tax returns, namely the Statement of Financial Data from Business Activity (Form E3) based on myDATA, available.

As this framework evolved, Greece made another move. The country’s tax authorities set limits to the adjustments taxpayers could make to pre-filled returns, essentially locking the declarations to a certain extent. Since 2025, a zero-deviation limit has been reached for pre-filled VAT returns, while a more flexible cap is currently in place for Form E3. However, this is also expected to be gradually reduced over time.

What Are Pre-Filled VAT Returns?

Pre-filled VAT returns are VAT declarations that are automatically populated using data transmitted to the digital bookkeeping platform, myDATA. Rather than manually entering figures into the VAT return, taxpayers see their returns pre-filled with data based on their invoices and expense records submitted through CTC regimes.

Under this model, the VAT return becomes effectively “locked”. Taxpayers can no longer freely adjust revenue and expense fields. If discrepancies are identified, businesses must correct the data directly within myDATA to ensure the return reflects accurate information.

Key Regulatory Provisions

Ministerial Decision 1020/2024 is the regulation that outlines the rules governing how submitted myDATA data impacts pre-filled VAT returns, sets the limits on allowable deviations and the procedures for handling correlation difficulties.

The regulation introduced two core compliance rules:

Tolerable Deviation Thresholds

The regulation sets temporary thresholds for deviation between declared amounts and those submitted via myDATA to provide transitional relief from the revenue and expense rules. These are called tolerable deviation limits.

The initial rule allowed taxpayers to adjust their income and expenses by up to 30%. However, over time, the limits were gradually reduced. Since January 2025, the threshold has dropped to 0%, which means that there is no possibility of deviating from the amounts locked in the pre-filled return by myDATA under the revenue and expense rules.

Deadline for Corrections

One of the most important compliance aspects is the deadline for updating data in myDATA. Corrections must be made before the submission deadline of the VAT return for the relevant period. After that, the return is locked, and any subsequent changes would require the filing of an amended VAT return.

Pre-Filled Income Tax Returns

Since the 2023 tax year, Form E3 has been pre-filled based on data submitted to myDATA by taxpayers. However, from the 2024 tax year onwards, taxpayers may only modify these pre-filled amounts within certain limits.

According to new rules introduced in March 2025, a 30% deviation limit is established for revenue and expense data reported in Form E3, per tax year, in relation to the corresponding myDATA-reported values.

In addition to deviation limits, the new rules regulate aspects such as the classification of income and expenses, the mandatory reconciliation of reported data with myDATA records and the procedures for handling discrepancies in pre-filled amounts.

However, following the trend seen with VAT returns, deviation limits for Form E3 are expected to be gradually reduced until it is no longer possible to change the pre-filled amounts under the revenue and expense rules.

How to Ensure Compliance?

The move to pre-filled returns represents a broader shift toward real-time, data-driven compliance in Greece. While the framework introduces new responsibilities for taxpayers, it also simplifies the return process and reduces the risk of human error.

With tolerable margins eliminated for VAT returns – and further tightened for Form E3 – businesses should focus on proactive data management to fully benefit from the efficiencies of the new system.

To remain compliant and avoid discrepancies in their VAT returns, businesses operating in Greece should:

For businesses already familiar with digital reporting under myDATA, the transition should be smooth, but for others, now is the time to prepare.

Report

Tax Compliance 2025: Top Trends in Tax, Regulatory and Technology

Download the Report

Traditional approaches to tax compliance are becoming obsolete as governments harness the power of advanced technologies such as real-time data collection, AI-driven analytics, and digital platforms. The result? A global push for transparency, faster enforcement, and an unprecedented level of regulatory complexity.

The stakes have never been higher. Falling behind in compliance means risking hefty fines, operational bottlenecks, and even reputational damage. But staying ahead is where businesses find their competitive edge.

The 2025 Tax Compliance Trends report is for the innovators and the forward-thinkers. It’s for those who see compliance as a strategic advantage, not just a legal obligation. Featuring expert insights from our tax and regulatory leaders, this guide compiles decades of experience into one blueprint for navigating the future of tax compliance.

Explore the most significant tax trends for compliance in 2025 and beyond, including:

  • What governments are doing to close tax gaps with real-time reporting and enhanced enforcement.
  • How new rules for digital assets and indirect taxes will affect businesses.
  • Why the Internal Revenue Service’s accelerated deadlines are forcing companies to scale faster than ever.
  • Strategies and technologies to transform compliance into a growth enabler.

Get the eBook

“It doesn’t matter if you are a Fortune 500 conglomerate or a small business. You have a set of obligations to meet, and compliance has become far too big and important to get wrong.”

– Eric Lefebvre, CTO

The Top Tax Compliance Trends for 2025

The Tax Compliance 2025: Top Trends eBook features insights from industry leaders and tax professionals with decades of experience in compliance, technology, and regulatory analysis. Each chapter is curated by a subject matter expert, offering valuable perspectives into the challenges and opportunities ahead.

 

I. The convergence of regulatory and technology

Steve Sprague – Chief Product and Strategy Officer

II. AI and its impact on tax and compliance

Eric Lefebvre – Chief Technology Officer

III. Trends in indirect tax digitization

Christiaan Van Der Valk – GM, Indirect Tax

IV. Removing barriers for international expansion

Alex Pavel – Managing Director, APAC

V. How are governments replacing tax revenue

Charles Maniace – VP, Regulatory Analysis and Design

VI. Trends to watch in tax information reporting and withholding

Wendy Walker – VP, Regulatory Affairs

VII. Unclaimed property enters the spotlight: Three key trends

Freda Pepper – General Counsel, Unclaimed Property

VIII. The modernization of the beverage alcohol shipping marke

Alex Koral – Regulatory General Counsel, Sovos ShipCompliant

Plus, discover the global regulatory mandates and tax laws shaping the business landscape.

Don’t wait for regulatory changes to catch your business off guard. Download the eBook today.

If you want to stay on the right side of compliance, you need to stay ahead of changes in the Insurance Premium Tax (IPT) landscape. You’ll learn more on Italy – Statute of limitation period, EU submission requirements, UK Insights and 2024 updates and what to expect in 2025. Don’t miss out on this opportunity to gain valuable insights and ask your burning questions to our expert panel. Join us and empower your business with the knowledge to navigate IPT successfully!

Peppol E-invoicing explained: What it is and how it works

The global adoption of electronic invoicing is accelerating. Governments worldwide are pushing to adopt e-invoicing to digitally transform their national systems and, often, to close the VAT gap.

While many countries have introduced their own e-invoicing mandate to digitise fiscal controls, the requirements and systems implemented by each country often fail to align with one another. This makes it complex for multinational organisations to meet their electronic invoicing obligations.

To enhance interoperability, countries across Asia and Europe are embracing Peppol, a framework established to simplify interoperability for e-invoicing and other procurement documents. But what exactly is it? This blog has all the information you need.

What is Peppol?

Peppol began in 2008 as an effort to standardise public procurement in governments across the European Union. It is a framework made up of specifications that enable cross-border electronic procurement and a method of sending invoices to customers. Peppol integrates business processes by standardising the way information is structured and exchanged.

In recent years, Peppol has expanded its remit to include APAC. Singapore was the first Asian country to establish a Peppol authority. As well as being established in Europe, it also includes Australia, Japan, Malaysia and New Zealand.

What does it stand for?

Peppol is short for Pan-European Public Procurement On-Line, as it was initially a European initiative.

While receiving e-invoices has been mandated by law for all public sector entities in the EU since April 2020, being Peppol one of the options chosen by many countries to implement such obligation, and Peppol’s name derives from its European service, the standard is now being adopted outside of the union. Malaysia and Singapore are two non-European countries that have embraced Peppol in recent years, for example.

How does Peppol work?

While we have made it clear that Peppol is an EU-wide standard for exchanging electronic documents like e-invoices, that doesn’t explain how it actually works.

The European Union laid out standards for electronic invoices. These documents must meet the required specifications and, in most cases, be sent through its network. Most public sector entities in the EU are required to be able to receive such invoices, creating a uniform and universal method of invoicing B2G transactions across the region.

It’s worth noting that while the public sector is obligated to receive these invoices in some cases, they can also be sent to companies for B2B transactions. Peppol enables the efficient electronic exchange of e-invoices, purchase orders, and other business documents, whether you are a private business or a public organization.

Peppol invoices are sent to the recipient through a Peppol Access Point. This connects to the Peppol network and comes from an approved service provider, allowing businesses to electronically exchange documents with other organisations with an Access Point.

Peppol connects organisations through a network of Peppol-accredited Service Providers, removing barriers to electronic trading created by closed ‘three-corner’ networks.

What is a Peppol authority?

To ensure that the aforementioned Access Points follow the rules and regulations set out, it has official authorities. They are also in place to “set national requirements for the design and content of Peppol documents,” according to PEPPOL itself.

There are currently 17 Peppol Authorities in place, all of which are national bodies – bar one. OpenPeppol is the only authority which is not attached to a country as it serves as the official Peppol Authority in jurisdictions where no authority exists.

Why use it?

Its widespread implementation makes it an appealing option for many. Considering the variety of approaches to electronic invoicing across countries, the appeal to Peppol is the standardisation and interoperability of global electronic document exchange.

Having a collection of common standards for transferring electronic documents for every country an organisation conducts business in makes the process simpler – thus reducing the possibility of errors.

Standardising the way information is structured and exchanged makes it more secure. As well as invoices and purchase orders, Peppol has the potential to automate the exchange of any kind of business document, between any organisation, anywhere in the world.

Which countries use Peppol?

Peppol currently has 37 member countries, 29 of which of which are in Europe.

Outside of Europe, countries that have implemented Peppol standards include:

Peppol Corner Models

Corner models are frameworks for digital transactions. There are multiple approaches, though Peppol’s base framework is the 4-corner model

3-Corner model for e-invoicing

Now considered an old model, the 3-corner model for e-invoicing required senders and receivers to connect through a single service provider. Buyers would often decide on which service provider they use, meaning suppliers had to use multiple systems across their customers.

4-Corner model for e-invoicing

An upgrade to the previous approach, the 4-corner e-invoicing model connects four entities. The four corners are:

  1. Sender
  2. Sender’s Access Point
  3. Recipient’s Access Point
  4. Recipient

The introduction of Access Points secures transactions by ensuring that communication of documents is sent and received correctly, using document validation, Know Your Customer (KYC) procedures and more.

5-Corner model for CTC

As seen in Singapore, Peppol also has a 5-corner model. This approach adds another corner to the traditional model, being the Tax Authority/Government central platform. This framework is also known as Peppol CTC.

The 5-corner model allows tax authorities to receive almost real-time access to invoices, ensuring that tax information is transferred correctly.

At the discretion of the applicable government, the central platform can either validate documents before they are sent to the recipient or allow certified service providers to validate them instead, serving as a repository for the electronic invoices.

Peppol VIDA pilot project

This pilot project established by OpenPeppol demonstrates that the network and e-invoicing specifications can also be used to meet the digital reporting requirements of the EU’s VIDA proposal.

The project is open to EU Tax Authorities/Administrations, Service Providers and end users.

Sovos is participating in this pilot project. We are a respected member, serving as a provider in both Malaysia and Singapore.

Learn more about the adoption of electronic invoicing and its many rules and regulations in our E-invoicing Guide. For help complying with e-invoicing requirements and other tax considerations, consider our Compliance Cloud solution.

Stay informed with the latest updates from the European Commission’s VAT in the Digital Age (ViDA) on the three pillars:

* The real-time digital reporting system based on e-invoicing
* New VAT rules for the platform economy
* Single VAT registration for businesses selling to consumers across the EU

The webinar will also cover essential VAT recovery claims, highlighting the differences between EU VAT Refunds and 13th Directive claims, and guide you through the VAT recovery process.

In less than six months, Poland is going to introduce its long-awaited CTC clearance e-invoicing mandate – a tax reform that will impact a large amount of businesses.

It has been possible to issue and receive e-invoices voluntarily via Krajowy System E-Faktur (KSeF) since January 2022, but from 1 July 2024 it will become mandatory for suppliers and buyers that are in scope of mandatory e-invoicing to do this via KSeF.

A detailed understanding of the new regime, plus timely and proper preparation, is critical for compliance. Whilst there is a six-month grace period on financial penalties, non-compliance can negatively impact your business in many other, often unexpected, ways.

In this 45-minute deep-dive webinar, Marta Sowińska from our Regulatory Analysis and Design team will cover:

Join us on 8 February at 2pm GMT | 3pm CET for a thorough review of the Polish KSeF e-invoicing mandate and the opportunity to submit your questions.

Register today

Constandi to lead customer success and engagement to drive recuring revenue and customer retention

 

ATLANTA, JANUARY 9, 2024 – Global compliance technology solutions and services provider Sovos today announced the appointment of Dominic Constandi as its new Chief Customer Officer. In this role, he will initiate and drive customer programs that maximize customer value, ensure client success, and leverage the Sovos portfolio of best-in-class solutions and services to deliver true confidence to businesses navigating the complex regulatory environment. Constandi brings more than 20 years of global customer expertise to Sovos, with extensive experience leading cross-functional teams within the financial services and technology sectors. Known as a creative and analytical leader, he has a proven track record of building strong teams within successful organizations.

“Ensuring the success of our global customers is at the heart of everything we do, which is why our commitment to building the strongest possible customer partnerships is unwavering,” said Kevin Akeroyd, CEO, Sovos. “With his diverse and extensive experience leading customer success programs, I am confident that Dominic has both the drive and perspective to lead our global practice. I am thrilled to welcome him as part of our executive team.”

Constandi joins Sovos most recently from ZoomInfo where he served as chief customer officer. In this role, he grew the customer experience team from 60 to more than 500 employees, scaling it globally across all customer success functions. Prior to ZoomInfo, he held senior-level customer experience roles at Eze Software, where he oversaw a customer success organization responsible for more than $400 million in annual recurring revenue.

“My goal is always to create long-lasting customer relationships in which they view you as a strategic partner, not just a vendor, and I see that same commitment in everything that Sovos does,” said Constandi. “The critical nature of the solutions and services Sovos provides demands strong working relationships to get things right the first time, every time. I couldn’t be more excited to step into this role and lead this talented team to ensure the company’s continued excellence in meeting these customer needs.”

About Sovos  

Sovos is a global provider of tax, compliance and trust solutions and services that enable businesses to navigate an increasingly regulated world with true confidence. Purpose-built for always-on compliance capabilities, our scalable IT-driven solutions meet the demands of an evolving and complex global regulatory landscape. Sovos’ cloud-based software platform provides an unparalleled level of integration with business applications and government compliance processes.

More than 100,000 customers in 100+ countries – including half the Fortune 500 – trust Sovos for their compliance needs. Sovos annually processes more than three billion transactions across 19,000 global tax jurisdictions. Bolstered by a robust partner program more than 400 strong, Sovos brings to bear an unrivaled global network for companies across industries and geographies. Founded in 1979, Sovos has operations across the Americas and Europe, and is owned by Hg and TA Associates. For more information visit http://www.sovos.com and follow us on LinkedIn and Twitter.

Media contact:

Media@sovos.com

As tax authorities continue to digitize processes in their mission to reduce fraud and close their VAT gaps, they are introducing requirements that provide greater visibility into a company’s financial operations in the form of Continuous Transaction Controls (CTC).

It would be a mistake to think that being prepared to meet obligations in one of the countries where you operate can simply be replicated in another – CTCs are far from a ‘one-size-fits-all’ solution.

Join us on 24 January 2024 in our latest quarterly VAT Snapshot webinar series where regulatory experts Dilara Inal and Marta Sowinska will examine how tax authorities in Poland, Romania, Israel, Greece and Spain – all simultaneously implementing CTC regimes – are doing so with different sets of requirements.

Don’t miss this opportunity to learn more about these unique regimes and what they mean for your business.

Register now.

With the rate of change in tax digitization not set to slow down any time soon, it’s more important than ever to keep up with what’s happening where you do business.

This quarter, our VAT Snapshot webinar looks in detail at CTC and e-invoicing implementation timelines across six different countries.

Join Dilara İnal and Carolina Silva from our Regulatory Analysis and Design team for an examination of scope, key timelines and essential milestones for compliance across these jurisdictions.

The webinar will cover:

As always, please bring your questions for our experts in the Q&A at the end.

Stay up to date with the evolving landscape of tax mandates by registering today.

Register now.

The Electronic Invoicing Law of the Dominican Republic was published on 17 May 2023, mandating e-invoicing throughout the territory as of 18 May 2023.

The law was published in the Official Gazette, whose purpose is to regulate the mandatory use of electronic invoicing in the Dominican Republic, including the establishment of the electronic invoicing tax system and its characteristics, optimisation results and contingencies, as well as the entry periods and tax facilities that taxpayers who take advantage of this system will be granted.

The law includes a Chapter on the Criminal and Tax infractions and penalties for non-compliance and still allows using paper invoices for certain contingencies.

Scope of application for e-invoicing in the Dominican Republic

The law applies to natural and legal persons, public or private. It’s also applicable to entities without legal personality domiciled in the Dominican Republic that carry out the transfer of goods, delivery in use or provision and lease of services for consideration or free of charge.

Recognition and authorisation

All electronic invoice issuers in the country shall:

  1. Be recognised and authorised as such by the General Directorate of Internal Taxes (DGII)
  2. Have a digital certificate for Tax Procedure, issued and signed digitally, by a certification entity authorised by the Dominican Institute of Telecommunications (INDOTEL).

The requirement for holographic or handwritten signatures and commercial seals for electronic invoices is fulfilled by using digital signatures supported by a digital certificate.

Electronic invoices cannot be modified once signed digitally and sent to the DGII.

Validation of the electronic invoice in the Dominican Republic

The electronic invoice must comply with the standard format established by the tax authority, which will be validated by computer systems. E-invoices will only be admissible when they comply with this validation.

Electronic invoices will be sent to the authority and the electronic receiver through electronic applications connected to the internet and in an XML file.

The electronic invoice will have a Printed Representation (RI) of the E-CF which will be delivered as a physical document to non-electronic receivers in exceptions. Otherwise, it will be delivered to electronic receivers when they are in contingency so that they can prove and report purchase transactions to the authority and third parties – as well as support tax credit or consumption, and keep the indicated documents as established by current legislation.

The General Directorate of Internal Taxes (DGII) will be the competent authority for validating and certifying the content and integrity of the electronic invoice.

Dominican Republic: Electronic Invoicing Tax System

The Electronic Invoicing Tax System is administered by the DGII and will be used to validate and accredit all electronic tax receipts resulting from electronic invoices. It will also validate legal forms or electronic tax documents that modify them and that serve as support to back up expenses and tax credits.

The DGII is also responsible for ensuring the integrity of information that is sent instantly for validation and the accreditation of electronic tax receipts (E-CF).

Issuance, conservation, types and sequence of electronic tax receipts

The three forms of Issuance of Electronic Tax Receipts (E-CF) are as follows:

  1. Self-developed systems: The DGII will authorise taxpayers who wish to join electronic invoicing through its own development system, if they meet the requirements established for the issuance and receipt of E-CF
  2. Electronic invoicing service providers: The taxpayer may implement an electronic invoicing system through a service provider that has been certified in compliance with the current regulations established by the DGII
  3. Free billing: The DGII will have a free technological facility for issuing electronic tax receipts, aimed at taxpayers who meet the criteria defined for the use of this tool and dictated by the means established by the DGII

Online validation

The electronic tax receipts sent to the DGII will be validated online through the information system, according to the schemes published by the technical documentation and complementary standards that define their structure and behaviour.

Once they’ve been compared and validated against the criteria, the DGII will respond by delivering a response number identified as “trackID” with which the E-CF issuer can consult the document’s status.

Types of electronic tax receipt (E-CF) or electronic tax documents

There are 10 types of electronic tax receipts or documents as part of the law. These include:

  1. Electronic Tax Credit Invoice
  2. Electronic Consumption Bill
  3. Electronic Debit Note
  4. Electronic Credit Note
  5. Electronic Voucher for Special Regimes
  6. Electronic Government Receipt
  7. Electronic Proof of Purchase
  8. Electronic Receipt for Small Expenses
  9. Electronic Receipt for Foreign Payments
  10. Electronic Proof for Exports

Sequence of electronic tax receipts

All E-CFs must have an electronic tax receipt number (E-NCF), authorised by the DGII, which consists of an alphanumeric sequence.

The number and type of electronic tax receipt numbers will be authorised according to the economic activity registered in the National Taxpayer Registry (RNC), operational volume, and level of compliance of the taxpayer – as well as the risk profile of the taxpayer, in accordance with the parameters established by the DGII.

Duties of Electronic Issuers

The duties required of electronic issues, in order, consist of:

  1. Sign all E-CFs issued with a valid Digital Certificate
  2. Receive all E-CFs from their suppliers that are validly issued
  3. Comply with the technical requirements that the DGII provides
  4. To exhibit all the information that the DGII requires
  5. Keep the E-CF in accordance with the provisions of the Tax Code

Standard format for the structure

The standard format for the structure of E-CFs is as follows:

  1. Document identification data
  2. Data relating to the Electronic Issuer
  3. Data relating to the Electronic Receiving Buyer
  4. Data relating to the good or service traded
  5. Data relating to the value of the transaction
  6. Tax data
  7. Date and time of the digital signature
  8. Digital signature

Taxpayers must indicate data that modifies or affects electronic tax receipts of credit and debit notes.

Implementation schedule for e-invoicing in the Dominican Republic

  1. Large national taxpayers: 12 months from the law’s entry into force (18 May 2024).
  2. Large local and medium-sized taxpayers: 24 months from the law’s entry into force (18 May 2025).
  3. Small, micro and unclassified taxpayers: 36 months from the law’s entry into force (18 May 2026).

The DGII will publish the list of taxpayers required by law to issue E-CF. With the approval of the DGII, taxpayers may agree to extend the deadline for compliance with electronic invoicing regulations.

Voluntary period and incentives

A voluntary period is provided for all taxpayers who wish to be issuers of electronic invoices before implement the previous calendar. The DGII is providing incentives consisting of tax credits for MIPYMES and Large National Taxpayers.

Looking for further information on e-invoicing in the Dominican Republic? Contact our expert team.

As CEO, Kevin Akeroyd sets the strategy and tone of the company. Kevin can best be described as a leader who embraces transformation and innovation and understands the role that data and analytics play in driving company growth. He is a big thinker who encourages big ideas from his teams and balances those ambitions against the organization’s financial and operational realities.

He believes in being a purpose-driven organization that exists for the greater good. Culture is not a buzzword for him, but something he considers to be the fabric of the company. Kevin understands that having an organization where everyone feels included and can bring their true selves to work everyday leads to better outcomes. As a people leader first and foremost, he cares deeply about our employees, customers and partners as people.

Kevin is well-versed in technology, globalization and go-to-market strategies for sophisticated product portfolios. He understands the complexities of international business and how companies struggle to scale operations across a multitude of different borders, regulations and government overseers.

When not in the office, Kevin spends as much time as possible with his family. He is passionate and always welcomes a conversation about sports, travel, music and mother nature. A good debate about old world vs. new world wine is also something he will also actively entertain.

For more, see Kevin’s LinkedIn profile.