Update: 28 March 2023 by Maria del Carmen
On Friday 31 March 2023 the grace period granted by Mexico’s Tax Administration Service (SAT) in the Miscellaneous Tax Resolution 2023 (RMF) ends. Taxpayers must transition to version 4.0 of CFDI, Comprobante Fiscal Digital por Internet, the electronic billing schema.
Document formats that will no longer be accepted following the end of the grace period include:
Authorized CFDI Certification Service Providers (PSCCFDI) must update their integration mechanisms to remain compliant with the new CFDI 4.0. Taxpayers must align their technologies with the changes that their PSCCFDI notifies.
The authority has the power to impose fines for non-compliance with the new CFDI tax provisions, when executing verification powers or within are fund application process.
These fines range from $ 19,700.00MXN ($ 1000.00 USD approx.) to $ 112,650.00MXN ($ 5500.00 USD approx). Repeated non-compliance can result in the tax authority preventively closing the taxpayer’s establishment for a period of three to fifteen days.
Fines of $ 400.00MXN ($ 20.00 USD approx) to $ 600.00MXN ($ 30.00 USD approx) will be issued for tax receipts that don’t include the relevant supplements as outlined in the SAT’s guidelines.
In extreme cases where damage to the federal treasury is proven, this is considered comparable to tax fraud. This would involve when CFDI is used for taxes calculation with non-compliance requirements of Articles 29 and 29-A of the Federal Tax Code.
The CFDI Version 4.0 became the only way to invoice, the tax authority has updated the following documents ahead of CFDI v4.0 transition:
Companies will need to be mindful of these changes and how to implement them to ensure ongoing compliance during the transition to CFDI 4.0.
Need to discuss compliance with Mexico’s e-invoicing requirements? Speak to our experts.
Update: 1 February 2023 by Maria del Carmen
CFDI, which stands for Comprobante Fiscal Digital por Internet, is the electronic billing schema defined by the Mexican federal tax code. It has been mandatory for companies that do business in Mexico since 2011.
CFDI aims to increase visibility into companies’ tax liabilities so the government can ensure it is receiving accurate payments. It has been successful, with audits based on the legislation revealing a 34% increase in VAT collected in a single quarter.
Tax legislation in Mexico requires additional information when companies make certain transactions. Named “complementos” or supplements, the additional information must be attached to the main CFDI.
There are 30 main CFDI ‘complementos’, each with its own essential components and requirements. There is also a validation process and cancellation process to follow and a wide range of penalties for non-compliance.
Read our Mexico e-invoicing guide to learn more and ensure compliance with this complex VAT landscape.
On 27 December 2022, the Mexican Tax Administration Service (SAT) published the Resolution Miscellanea Fiscal (RMF) 2023. Each annual revision sets outs rules and adjustments for CFDI, a key component of Mexico’s electronic invoicing system.
The RMF entered into force on 1 January 2023.
Among the most important rules is the extension of the grace period for issuing certain documents. Now extended to 31 March 2023, the provision covers the following documents:
The RMF 2023 states cancellations of the CFDI cannot be made later than the month in which the annual declaration of the ISR (tax on income) must be submitted. That’s in April for individuals, and in March for companies.
The resolution also states that corrections to the payroll payment CFDI (CFDI de nómina) can only be made once and no later than 28 February 2023.
Taxpayers that carry out volumetric controls of hydrocarbons and petroleum products may continue to issue a daily, weekly, or monthly CFDI for all operations carried out with the public, until 31 December 2023.
Including supplement “Hidrocarburos y Petroliferos” in the CFDI will become mandatory 30 days after the SAT publishes the complement on its website.
The RMF states until 31 July 2023 no fines will be imposed and it will not be considered under the crime of smuggling if the Carta Porte supplement does not have all the requirements indicated in the CFDI Filing Guide.
To prove the transport of goods or merchandise, the intermediary or transport agents must now issue the CFDI type income (CFDI tipo ingreso) with the Carta Porte Supplement – instead of the CFDI type Traslado.
Taxpayers involved in the motor transport of dedicated services are subject to additional rules. Those who provide the service to a single client or contractor through the specific assignment of vehicle units may issue the CFDI type income (CFDI ingreso) to cover the entire service provided without the Carta Porte Supplement.
In these instances, the client or contracting party must issue the CFDI of transport (CFDI de transporte). This includes the Carta Porte supplement for each trip, which must be related to the CFDI type income (CFDI ingreso) issued by its carrier.
Additional regulations are established regarding the issuance of CFDIs related to bareboat charter services, for a specific time, per trip, and ferry modality.
The RMF includes information about the Resource Identification Supplement and Expense Bill of Third Parties provision, this will become mandatory 30 days after the tax authority publishes it on its website.
For further questions don’t hesitate and get in touch with our experts today.
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:
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.
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.
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.
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.”
Still have questions about e-invoicing in Serbia? Speak to our tax experts.
Customers can securely process high volumes of documents for billing and electronic validation in real- time
BOSTON – October 5, 2022 – Global tax software provider Sovos today announced it has acquired Lima, Peru-based Escontech, one of the main leaders in the country in SaaS electronic invoicing and validation services for the issuance of electronic receipts. In the last five years, the company has specially focused on the integration of transactional solutions in Information Technology using world-class standards, achieving in the last two years the fastest growth in the ecosystem of Peruvian companies that provide this type of specialized services.
Escontech’s technology and positioning in the Peruvian market strengthen Sovos’ current capabilities and scope in this type of services, by efficiently covering and supporting major companies in areas such as banking, financial services, insurance, mass market, tolls, and other high transaction industries. The company has been approved as an Electronic Services Provider and Operator by the Peruvian Tax Administration (SUNAT), which allows it to support its users in the issuance, transformation and final computer verification of invoices, bills, and other electronic payment vouchers from a company’s administrative systems.
“Escontech will play an important role in our ability to provide customers in these regions, as well as globally, with the technology needed to process high volumes of documents securely for billing and electronic validation, while ensuring compliance with local regulations. These solutions will be a great complement to Sovos’ existing portfolio, simplify the integration process and be supported by the best professional services group in the industry,” said Alvaro Gonzalez, managing director, Latin America.
Leading companies and institutions rely on Escontech to validate their transactions quickly and securely, paving the way for frictionless commerce business environment. Together, Escontech and Sovos will help lead the fight against fraud while ensuring compliance in highly regulated industries.
“The group of professionals that make up the productive force of Escontech value with great enthusiasm to be part of a great global organization and leader such as Sovos. Since our beginnings in the provision of this type of specialized transactional services, we have sought to innovate with value, by delivering a user experience of quality and excellence, but mainly, of commitment and closeness. Now with Sovos’ vision, its technological and financial resources, its multi-territory presence, and its specialized human talent, we will contribute more efficiently to delivering satisfactory experiences to users in different areas and geographies,” said Rogelio Martinez, founder of Escontech.
Sovos is owned by Hg, the London-based specialist private equity investor focused on software and service businesses, and TA Associates. The terms of the deal were not disclosed.
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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/es and follow us on LinkedIn and Instagram.
Escontech is a company dedicated to the integration of information technology and security solutions through world-class standards. Throughout its history, the company has incorporated a special group of human talent that in the last 16 years has provided services to leading companies in Colombia, Ecuador, Peru, Venezuela, and the Caribbean.
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.
If you’re looking for the current KSeF requirements, visit our overview of e-invoicing in Poland.
If you want to learn more about KSEF 2.0 and how the changes will impact your business, read our FAQs or visit our blog about preparing for Poland’s new e-invoicing landscape.
Update 23 September 2025 by Kelly Muniz
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 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:
2026:
2027:
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
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
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.
The signed legislation maintains the phased approach previously outlined:
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
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.
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.
Following the President’s signature, two additional regulations in draft form will complete the KSeF 2.0 framework:
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
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.
The Ministry of Finance has released comprehensive technical documentation, including:
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.
The Ministry has reaffirmed the following implementation roadmap:
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.
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
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:
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:
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.
Several obligations scheduled for mid-to-late 2026 are proposed to be uniformly postponed. This means that until 31 December 2026:
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.
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.
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.
The plan to allow attachments to e-invoices as part of the FA(3) structure remains in place.
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:
Main Technical amendments proposed:
The MoF has also shared the following KSeF Roadmap:
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
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:
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’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
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:
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:
The regulation is planned to enter into force from 1 July 2024.
Update: 19 December 2023 by Marta Sowińska
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
On 26 November, the Ministry of Finance published two long-awaited draft acts regarding mandatory e-invoicing via KSeF.
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).
Update: 26 October 2023 by Marta Sowińska
Both the draft regulation and schema specifications are available to view.
Update: 7 August 2023 by Marta Sowińska
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.
The press information and official announcement from the Ministry of Finance are available to view.
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
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.
The results of the voting in Sejm can be found here: Głosowanie nr 39 na 80. posiedzeniu Sejmu – Sejm Rzeczypospolitej Polskiej
Update: 6 July 2023 by Marta Sowińska
On 29 June 2023, the Ministry of Finance (MoF) published updated schema FA(2) on the ePUAP platform in the Central Repository of Electronic Document Templates (CRWDE), template number (2023/06/29/12648).
Important information about timelines:
Read the official announcement for further information.
Update: 10 May 2023 by Marta Sowińska
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.
Find out more via the official announcement.
Update: 22 March 2023 by Marta Sowińska
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:
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.
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.
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.
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.
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.
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.
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
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:
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.
Looking for more information on e-invoicing in Poland? Speak with our expert team.
With the entry into force of resolutions SAT-DSI-1240-2021 and SAT-DSI-1350-2022, most taxpayers in the country are now obliged to issue electronic invoices under the Online Electronic Invoice System (Regimen de Factura Electronica en Linea – FEL).
The latest taxpayers to join the mandatory electronic billing system are include taxpayers incorporated into the General Value Added Tax (VAT) Regime and the group of natural and legal persons registered in the Small Taxpayer Regime.
With the addition of these last two groups, the Superintendence of Tax Administration of Guatemala (SAT) has practically completed the gradual process of incorporation into the country’s electronic invoicing regime.
Today, the general population should only accept FEL documents from obligated taxpayers. Paper invoices (preprinted) are no longer valid, making them unusable for transactions such as tax credit, among others.
The operating model and the rules applicable to the online electronic invoice of the Republic of Guatemala includes the issuance, transmission, certification, and preservation by electronic means of invoices, credit and debit notes, receipts, and other documents authorised by the Superintendence of Tax Administration, known as Electronic Tax Documents (DTE).
The following tax documents are available for issuance under the Regimen de Factura Electronica en Linea – FEL:
The Guatemalan system follows e-invoice clearance system, the well-established trend in LatAm countries. The clearance system means that the tax authority must authorise the electronic documents before the issuer is able to send them to the recipient.
The issuance process goes through the following mandatory steps:
The SAT store all invoices. This does not exempt senders and receivers from keeping the XML file for the period of four years, established in the Tax Code. The certifiers are also obliged to keep the certified DTE files in XML format, as well as the respective acknowledgments of receipt from the SAT.
Now 98.23% of the total billing of the General VAT Regime is using FEL, with only around 20,000 businesses needing to migrate to the system since it was first launched in 2020.
Online e-invoices for all remaining VAT registered business will be mandatory from 1 April 2023 via the FEL.
Still have questions about e-invoicing in Guatemala? Speak to our tax 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.
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 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.
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.
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 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 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.
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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On 19 May 2022, the Danish Parliament passed a new bookkeeping law – Lov om bogføring – introducing requirements for companies to use a digital bookkeeping system.
Section 16 of the Law requires many Danish companies to use a digital bookkeeping system and make their bookings electronically. The final deadline is yet to be announced but is expected to be July 2024, with the Danish Business Authority announcing they will give businesses enough time to comply with the e-bookkeeping requirements.
The subjective scope of the digital bookkeeping requirements covers all companies in Denmark that are liable for accounting according to section 3(1) of the Financial Statements Act. Moreover, other companies whose net turnover exceeds DKK 300,000 in two consecutive income years are subject to digital bookkeeping requirements. Finally, the rules cover bookkeepers and others who carry out bookkeeping for other companies.
These companies will be required to record company transactions and store records in a digital bookkeeping system. Companies can use a digital bookkeeping system registered with the Danish Business Authority, Erhvervsstyrelsen, or any other bookkeeping system. However, companies who choose the latter option must ensure their systems meet the requirements according to Law for digital bookkeeping systems.
While the new bookkeeping law doesn’t introduce any mandatory e-invoicing or continuous transaction controls (CTC) obligations for businesses, it is envisaged that the digital bookkeeping systems must support continuous registration of the company’s transactions and the automation of administrative processes. This includes automatic transmission and receipt of e-invoices.
This requirement was further detailed in the draft executive order on requirements for standard digital bookkeeping systems, which outlines that the taxpayers:
Moreover, the new bookkeeping law authorised the Minister for Industry, Business, and Financial Affairs to introduce rules:
(a) that require companies to record their transactions regarding purchases and sales with e-invoices as documentation of the transactions,
(b) on transmission of records by digital bookkeeping systems to a public receiving point through the shared public digital infrastructure for the exchange of e-documents and the storage of such records.
Although Denmark’s e-invoicing journey is still in the early phases, it seems that the new bookkeeping law and requirements for digital bookkeeping systems lay the foundation for a future e-invoicing mandate to be duly introduced by the Minister for Industry, Business, and Financial Affairs.
It will be interesting to see how and when Denmark’s plans for e-invoicing will take shape and be affected by the upcoming results from the EU Commission on the VAT in the Digital Age project.
If you have any question about Denmark’s new bookkeeping law or e-invoicing requirements in Denmark, please reach out to us: Speak to our tax experts. Refer to this guide for a comprehensive overview about e-invoicing in general.
It’s a good year to be an IT leader. After far too many years of the phrase “do more with less” being the mantra of most organizations when it came to technology spending, things are finally looking up.
According to research firm Gartner, IT spending will reach an estimated $4.5 trillion in 2022. This represents a 5.1% increase over 2021 and is a much-needed boost for businesses in need of technology updates that may have been placed on the backburner due to the COVID-19 pandemic.
IT departments are also eager to switch focus from just keeping things afloat to more long-term projects that will strategically and successfully support the future of work. This assertion is backed by numbers provided by IT management solutions firm Flexera in its State of Tech Spend Report.
When asked where budgets were being allocated to this year, 54% of those surveyed expected increased investment and resources to be applied to technology that makes it easier and more seamless for employees to work from home. Another 42% of those surveyed stated a newfound willingness to move to the cloud to support the realities of a post-pandemic world. Participants in this survey were all executives and high-level managers in IT with significant knowledge of their organizations’ overall IT budgets, weighed in on what to expect in the year to come.
These findings show the level of importance businesses are putting on hybrid and flexible work environments. The likelihood that working from home, at least in some capacity, is here to stay has IT departments rethinking their strategies to be prepared to tackle any challenges that may arise.
The strategies being outlined by IT departments are sound and inline with the world in which we now exist. However, there is another post-pandemic force at work with the potential to derail the best laid plans and devour a vast amount of budget and resources. Government mandated e-invoicing.
If you work as an IT leader at a multinational company, you likely fall into one of the two following categories. One, you’ve been brought into deal with the new realities of real-time oversight and enforcement from regulatory authorities. Or two, you are about to be brought into the fray with your own internal mandate, solve this problem for good.
Why am I so definitive in this declaration? Because I work with some of the biggest brands on the planet and I am witnessing firsthand the impacts these mandates are having on their IT organization.
When it comes to IT projects, most are not reactionary but the result of careful and methodical planning over a long period of time. However, the government is changing the rules here. No longer are projects and upgrades on your timeline. When they implement new laws and mandates it’s either you move quickly to address the issue and make it right or you pay the consequences which can range from hefty fines to even losing your license to operate.
As government mandated e-invoicing laws quickly ramp up around the world, they represent a credible threat to your IT budgets. IT departments must be prepared for the new realities that accompany government mandated e-invoicing. With authorities now in the data stack of your businesses examining transactions in real-time as they traverse your network, you will need a solution that enables you to deliver the information in the format required in real-time.
Bottom line, compliance is no longer a tax issue. IT leaders and other senior leadership must work together to align business functions across the board. IT needs to ensure the resources and tools are in place to meet government mandated obligations, no matter the company’s industry or location.
A failure to address the problem early will only lead to more complex and costly problems down the road that will absorb critical budgets and resources earmarked for other priority projects.
If you aren’t sure where to start in building your strategy, reach out to our experts.
France is implementing a decentralised continuous transaction control (CTC) system where domestic B2B e-invoicing constitutes the foundation of the system, adding e-reporting requirements for data relating to B2C and cross-border B2B transactions (sales and purchases).
Under this upcoming regime, data or invoices can be directly sent to the Invoicing Public Portal ‘PPF’ (Portail Public de Facturation, so far known as Chorus Pro) or to a Partner Dematerialization Platform ‘PDP’ (Plateformes de Dématerialisation Partenaires). In addition, there are also Dematerializing Operators (Operateurs de dématérialisation) that are connected to either the PPF or a PDP.
Requirements for these portal and platforms have been published.
The Ministry of Economy published Decree No. 2022-1299 and Order of 7 October 2022 on the generalisation of e-invoicing in transactions between taxable persons for VAT and the transmission of transaction data (together known as ‘new legislation’), providing long-awaited details for PDP operators and PPF.
The new legislation introduces rules concerning the application process for PDP operators. Although French establishment isn’t required, PDP operators must fulfill a number of requirements, such as operating their IT systems in the EU.
France is implementing a model where third-party service providers are authorised to transmit invoices between the transacting parties. With the mandatory use of the PPF or PDPs for exchanging e-invoices, trading parties cannot exchange invoices between them directly. Therefore, PDPs must be able to receive and send invoices in structured formats, whether the ones supported by the PPF (CII, UBL, or FACTUR-X) or any other required by their clients. Also, to ensure interoperability, PDPs are expected to connect with at least one other PDP. Besides this requirement, it’s stated by the new decree that PDPs must be able to send e-invoices to PDPs chosen by their recipients which implies a complete interoperability between PDPs.
It was previously announced that taxpayers could submit PDF invoices for a transitional period. The new legislation outlines the transitional period as until the end of 2027. During this period PDPs and PPF must be able to convert the PDF into one of the structured formats.
The new legislation also provides information about the content of e-invoices, which has new mandatory fields, and the content of transaction and payment data to be transmitted to the tax authority.
It also announced frequencies and dates of data transmission. Deadlines for transaction and payment data transmission are based on the tax regimes of taxpayers. For example, taxpayers subject to the normal monthly regime should transmit payment data within ten days after the end of the month.
With the aim of having traceability over documents, the lifecycle statuses of the domestic B2B e-invoices are exchanged between the parties and transmitted to the PPF. Lifecycle statuses that are mandatory (“Deposited”, “Rejected”, “Refused” and “Payment Received”) are listed in the new legislation.
Further details regarding the Central Directory, which consists of data to properly identify the recipient of the e-invoice and its platform, are provided within the Order.
PDP operator candidates can apply for registration as of Spring 2023 (precise date still to be confirmed), instead of September 2023 as previously set. From January 2024, a six-month test run is expected to be conducted for enterprises and PDPs before the implementation in July 2024.
Still have questions about France’s upcoming continuous transaction control mandate? Get in touch with our tax experts.
Portugal’s state budget entered into force on 27 June 2022 after protracted negotiations. The budget contained an interesting provision: the obligation to present invoice details to the tax authorities was extended to all VAT-registered taxpayers including non-resident taxpayers, who had long been exempt from this obligation.
VAT-registered non-residents now have three options for communicating invoice details:
In practice, the Billing SAF-T file is the least onerous option for taxpayers. It is worth discussing the contents of this file, which is submitted separately from Portugal’s Accounting SAF-T file.
Portugal was the first country in the world to adopt SAF-T, and its requirements are based on the original OECD 1.0 schema. The current schema for the Billing SAF-T is set out in Portaria no. 302/2016 consisting of 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.
Importantly, the Billing SAF-T file must be generated by “certified billing systems,” as designated by the tax authorities, a requirement unique to Portugal. As of 2021 this requirement extends to non-resident taxpayers as well, a strong indicator that they would eventually be required to submit Billing SAF-T.
Although the Billing SAF-T only has four sections, it is nevertheless a complex file to generate. Portaria no. 302/2016 containing guidance on fields and definitions is over 100 pages long in the official gazette. Taxpayers must be able to generate required fields within their source systems and must know what conditionally required data they are able to provide.
The latest state budget has adjusted the monthly deadline for submitting Billing SAF-T. The deadline is now the fifth day of the month following the reporting period, previously taxpayers could submit by the twelfth day of the month following the reporting period.
For these reasons, the introduction of this obligation to non-resident taxpayers represents a significant burden. Existing and potential non-resident taxpayers in Portugal should immediately familiarise themselves with the Billing SAF-T requirement and ensure they are using certified billing software to remain compliant.
Need to ensure compliance with Portugal’s Billing SAF-T requirements? Get in touch with our tax experts.
Brazil is known for its highly complex continuous transaction controls (CTC) e-invoicing system. As well as keeping up with daily legislative changes in its 26 states and the Federal District, the country has over 5,000 municipalities with different standards for e-invoicing.
The tax levied on consumption of services (ISSQN – Imposto Sobre Serviços de Qualquer Natureza) lies under the competence of the municipalities. Each municipality has authority over the format and technical standard of the services e-invoice (NFS-e – nota fiscal de serviço eletrônica). This poses a significant compliance challenge, as e-invoicing is mandatory for nearly all taxpayers in the country.
However, important steps have been taken towards changing this scenario. An agreement (Convênio NFS-e) recently signed by the Brazilian Federal Revenue Agency (RFB), the National Confederation of Municipalities (CNM), and other relevant entities, has established the National System of the NFS-e with a countrywide unified standard for the services e-invoice.
The SNNFS-e introduces a unified standard layout for the issuance of the NFS-e, as well as a national repository of all e-documents generated within the system. Adhesion to the system is voluntary for municipalities. Since the bill proposed to regulate this issue (PLP 521/2018) has been static in Congress since 2019, the agreement was designed to allow municipalities to voluntarily adopt the national standard, which then becomes mandatory for taxpayers.
The system will allow issuance of the NFS-e in a national standard, through the web portal, mobile app or API (application programming interface). It also creates the National Data Environment (ADN), the NFS-e unified repository.
The SNNFS-e offers several service modules and municipalities can choose which ones to adopt. The ADN is the only mandatory module, as it ensures the integrity and availability of information contained in the documents issued is in the unified standard. Additionally, the ADN allows adhering municipalities to distribute issued NFS-e among themselves and taxpayers.
Once the agreement is signed, the municipality must activate the system within a certain deadline, which hasn’t been established. Activation involves configuring system parameters and amending municipal legislation to reflect the national system requirements. Only after complete activation will taxpayers be able to issue invoices based on the unified standard.
Technical documentation of the NFS-e has also been released, but these are not the definitive specifications, which are still to be approved by the National Standard Electronic Service Invoice Management Committee (CGNFS).
The NFS-e national standard provides substantial simplification of taxpayers’ e-invoicing obligations. With a standard layout, compliance with multiple formats can be drastically reduced. The document format for issuance of the standard NFS-e is XML and it must be digitally signed.
Another benefit is that one of the available modules allows taxpayers to pay the ISSQN owed in several municipalities at once, using one single document (Guia Única de Recolhimento) issued by the system.
Although municipalities may choose to keep their current NFS-e issuance system, they must still adhere to the communication deadlines, layout, and security standards of the national NFS-e. They must also ensure transmission of all issued documents to the national data environment. This ensures that taxpayers will only be required to issue the NFS-e in one standard layout.
The first phase of production started on 23 July 2022 with five pilot municipalities. Transmission will be available through different methods, with gradual implementation. According to the initial implementation schedule of the National Confederation of Municipalities, API transmission is set to happen from mid-October 2022 or later, depending on the stability of the other transmission methods. Further development of this schedule can be expected in the coming months.
São Paulo, Salvador, and Florianópolis are among the many municipalities that have already signed the agreement. The success of this national NFS-e standard relies on significant adoption by municipalities, so taxpayers must ready themselves to comply as this takes place across the country.
Need to ensure compliance with the latest e-invoicing requirements? Get in touch with our tax experts.
Update: 8 March 2023 by Kelly Muniz
Spain launches public consultation for B2B mandatory e-invoicing
The Ministry of Economic Affairs and Digital Transformation (Ministerio de Asuntos Económicos y Transformación Digital) has launched a public consultation on the upcoming B2B e-invoicing mandate.
The mandate will enable citizens to participate in elaborating norms before its development. This public consultation is carried out through the web portal of the competent department and all interested parties have until 22 March 2023 to send feedback.
Based on the feedback received, the government will develop and approve the regulatory framework that is needed according to the law adopting mandatory B2B e-invoicing which was published on 29 September 2022.
The public consultation consists of 32 specific questions on seven different areas that the regulatory framework will address. These areas are:
You can find the official text of the public consultation here.
Looking for more information on e-invoicing in Spain? Speak to a member of our expert team. For more information about VAT compliance in Spain read this page.
Update: 16 September 2022 by Victor Duarte
The Congress of Spain has approved the Law for the Creation and Growth of Companies, and it is expected to be published in the Official Gazette (BOE) in the following days.
This Law also amends Law 56/2007 on Measures to Promote Information to adopt the mandatory electronic invoice issuance requirement for all entrepreneurs and professionals in their commercial relationships.
According to this Law, all entrepreneurs and professionals must issue, send, and receive electronic invoices in their business relationships with other entrepreneurs and professionals. Additionally, the recipient and the sender of electronic invoices must provide information on the status of the invoices.
The main rules of the Law related to e-invoicing establishes that:
The process for accreditation of interconnection and interoperability of the platforms will be determined by the regulations at a later stage.
The law establishes that companies providing the supply of certain services to final consumers must issue and send electronic invoices in their relations with individuals who agree to receive them or who have explicitly requested them. This obligation affects companies supplying telecommunication services, financial services, water, gas, and electricity services among other sectors and activities prescribed in Article 2.2 of Law 56/2007.
These companies must provide access to the necessary programs so that users can read, copy, download and print the electronic invoice for free without having to go to other sources to obtain the necessary applications. They must also enable simple and free procedures so users can revoke the consent given to the receipt of electronic invoices at any time.
Companies within scope that refrain from offering users the possibility to receive electronic invoices will be sanctioned with a warning or a fine of up to 10,000 euros.
The Government will develop provisions of this Law in accordance with the regulations, and within the scope of its powers. Therefore, the Ministries of Economic Affairs and Digital Transformation and of Finance and Public Administration will determine the information and technical requirements to be included in the electronic invoice to verify the payment dates and obtain the payment periods.
It is also necessary to establish the minimum interoperability requirements between the providers of electronic invoice technology solutions, and the security, control, and standardisation requirements of the devices and computer systems that generate the documents.
The Government will have 6 months from the publication of this Law in the Official Gazette to approve the regulatory framework.
The provisions regarding mandatory B2B electronic invoicing will be effective according to their annual turnover:
This means that the B2B e-invoicing obligation could be effective for large taxable persons by the first quarter of 2024.
It is important to highlight that the entry into force of the B2B e-invoicing obligation is subject to obtaining the community exception to articles 218 and 232 of the VAT Directive. This exception is less difficult to obtain the previously as has been granted to other Member States such as Italy, France, and Poland to allow them to adopt the mandatory e-invoicing regime in their jurisdictions.
Need to ensure compliance with the latest e-invoicing requirements in Spain? Get in touch with our tax experts.
Many countries have recently started their continuous transaction controls (CTC) journey by introducing mandatory e-invoicing or e-reporting systems. We see more of this trend in the European Union as the recent reports on the VAT in the Digital Age Initiative discuss that the best policy choice would be to introduce an EU-wide CTC e-invoicing system covering both intra-EU and domestic transactions.
However, the efforts to fight tax fraud aren’t limited to mandatory e-invoicing or e-reporting systems. Many governments prefer to look beyond and introduce another tool that gives them greater insight into their economy: e-transport documents. When introducing e-transport systems, we see that one country differs from other EU Member States with the early adoption of an e-transport system – Hungary.
The Electronic Public Road Transportation Control System or Elektronikus Közúti Áruforgalom Ellenőrző Rendszer (EKAER) has been in place in Hungary since 2015. Operated by the Hungarian tax authority, the EKAER is intended to monitor compliance with tax obligations arising from the transportation of goods on public roads in the national territory.
The system was initially introduced to monitor the movement of all goods in the national territory. However, after several letters from the EU Commission asking Hungary to bring their system in line with the EU regulations, the scope of the system was narrowed down to the so-called risky products in January 2021. The risky products are defined in 51/2014. (XII. 31.) NGM decree, which consists of foodstuffs or other risky products (such as flowers, all kinds of natural sands, different types of minerals, etc.).
According to 13/2020. (XII. 23.) decree on the operation of the Electronic Road Traffic Control System, Hungarian taxpayers are required to report specific data regarding the transport of risky products by using the EKAER system before the transportation of goods begins. It’s also important to mention that it’s necessary to be registered in the EKAER system and provide a risk guarantee for certain types of transport unless there is an exemption in the law.
Taxpayers are obliged to report the transport of risky goods in XML format to the EKAER system. This information includes data regarding the sender, the recipient, and the goods. Moreover, businesses must also report additional specified data to the tax authority based on the transport type (domestic, intra-community acquisitions and intra-community supplies).
Following the report by the taxpayer, the EKAER system generates an EKAER number, an identification number assigned to a product unit. This number will be valid for 15 days; therefore, the delivery of goods must be performed within this period. Businesses must communicate the EKAER number to the carrier, and it should accompany transported goods.
Although no future changes are foreseen for the EKAER system, different countries worldwide continue to introduce e-transport requirements similar to the EKAER system. Taxpayers must ensure that their transport processes are flexible and compatible with changes that the tax authorities are introducing to stay compliant.
For the UK and other non-EU businesses it’s vital to determine the importer of the goods into the EU as this will impact the VAT treatment.
For goods under €150 there are simplified options such as the Import One Stop Shop (IOSS) or special arrangements through the postal operator. However, when supplying goods over €150, businesses need to consider how they want to import the goods.
One option is for businesses to deliver on a Delivered Duty Paid (DDP) basis and be the importer of the goods into the EU. This improves the customer experience for B2C transactions but creates a liability to be registered in the county of import and to charge local VAT, along with additional compliance requirements. If goods are moved from that country to other EU countries, then depending on the supply chain, the One Stop Shop (OSS) could be used to avoid further VAT registration requirements.
Due to increased compliance costs many businesses have chosen not to be the importer and pass this obligation to the end customer. If a business chooses this route, options are still available.
The business could simply place the full obligation on the customer., The customer would be sent a payment request for the VAT and any duty by the carrier before delivery., There could also be a handling fee passed on to the customer. Once paid the goods would be delivered This approach doesn’t provide the best customer experience.
This is why many businesses have opted for a ’landed cost method’ offered by many couriers. The customer is still the importer on the import documentation, but the business collects the VAT and duty from the customer at the time of sale and settles the carrier’s invoice on their behalf. In theory, this avoids the need for the business to register in the EU and still offers the customer a seamless experience. However, this raises the question: is the customer actually the importer?
Some tax authorities are beginning to take a different view of arrangements for goods with a value above €150 where goods are imported directly into the Member State of delivery. A law change on 1 July 2021 included the concept “where the supplier intervenes indirectly in the transport or dispatch of the goods”. This is to counter arrangements that allowed the seller to argue they were not distance selling but making a local sale, so only had to account for VAT in the Member State of dispatch of the goods.
Following the law change some tax authorities are arguing this concept means if a seller sells to a private individual in their country and the seller arranges for the goods to be delivered from a non-EU country and customs cleared in their EU Member State, the place of supply is the Member State as the supplier has indirectly intervened in the transport.
As a result, the supplier must register and account for VAT in the Member State even if the customer is the importer of the goods. This argument could result in double taxation and can create additional compliance obligations along with tax authority audits – all of which add additional costs and time for businesses.
It’s important that businesses adopting a method where the customer is the importer put correct arrangements in place. This includes ensuring website terms and conditions reflect the fact the customer is the importer and giving the company the power to appoint a customs declarant on their behalf. It’s also important that customs documentation is completed correctly. Avoiding terms such as DDP on the website is also key as this implies that the business is the importer.
For help with EU import queries or if your company needs VAT compliance assistance get in touch to speak with one of our tax experts.
The Colombian tax authority (DIAN) continues to invest in the expansion of its CTC (continuous transaction controls) system. The latest update proposes an expansion of the scope of documents covered by the e-invoicing mandate.
In this article we’ll address the newly published Draft Resolution 000000 of 19-08-2022. This advances important changes for taxpayers covered by mandatory e-invoicing rules.
These draft changes include a new obligation to issue equivalent documents (documentos equivalentes) in electronic format, a schedule for its implementation, updated technical documentation and other significant developments, all of which require taxpayers to ready themselves to comply.
Amongst many proposed changes, the draft resolution’s main purpose is to regulate the electronic issuance of the equivalent document.
These documents correspond to the sales invoice under Colombian law, but cover specific types of transactions and are regulated in the draft resolution, as follows:
This means that all taxpayers subject to the Colombian e-invoicing mandate who issue one of these equivalent documents will be required to do so in an electronic format, according to the Technical Annex of the Electronic Equivalent Document version 1.0 (Anexo técnico del Documento Equivalente Electrónico), introduced by the draft.
Additionally, the draft provides an initial regulation of the electronic documents of the invoicing system (documentos electrónicos del sistema de facturación). These are documents that aid control by the tax and customs authority, to support tax or customs declarations and/or to support the procedures carried out before DIAN, under the provisions of subsection 1 of article 616-1 of the Tax Statute.
Finally, the technical specifications of the system’s main electronic invoice, the sales e-invoice, is updated to version 1.9 (Anexo técnico de la Factura Electrónica de Venta version 1.9).
The obligation to issue the equivalent document in electronic format will be implemented gradually, according to the type of equivalent document. It starts on 1 March 2023 and will cover all equivalent documents on 1 July 2023.
Early voluntary implementation will also be possible, once the functionality is available in DIAN’s system. Until the deadlines for the electronic implementation of the equivalent document are fulfilled, these must continue to be issued in accordance with Resolution No. 000042 of 2020.
The draft also sets a schedule for implementation of the electronic documents of the invoicing system, during the taxable years of 2023 and 2024. These documents will be further regulated in the six months following the validity of the official resolution, as well as the adoption of its technical annex, which hasn’t been presented with the draft resolution.
Lastly, the proposal establishes the deadline for implementation of the Technical Annex of the electronic sales invoice version 1.9 by taxpayers. This will be at least three months following its official publication.
The draft resolution, once officially published, will derogate DIAN Resolution No. 000042 of 2020 in all provisions that are contrary to it, except those related to equivalent documents, which will remain in force until the DIAN establishes their electronic implementation.
Taxpayers can also expect new legislation regulating the remaining electronic documents of the invoicing system, in the months following the official publication of this draft resolution.
Until then, companies should prepare for the significant upcoming changes and adjust their businesses processes to comply with the new Colombian mandate.
Need help with evolving e-invoicing requirements in Colombia? Get in touch with our tax experts about how Sovos can help your business meet your VAT compliance obligations.
Update: 14 February 2023 by Andrés Landerretche
As of February 2023, new rules came into force in Colombia. These are for the issuance threshold of equivalent documents generated by Point of Sale (P.O.S.) systems.
As a result, a ticket issued by cash registers with P.O.S. systems (tickets de máquinas registradoras con sistemas P.O.S.) must not exceed the maximum amount of five Tax Value Units (UVT), without including the amount of tax for each sale or service provision operation.
For sales operations and the provision of services exceeding this amount – excluding taxes – taxpayers must issue an electronic sales invoice as part of the country’s e-invoicing mandate.
It is important to note that the equivalent documents generated by cash registers with a P.O.S. system do not entitle the purchaser to discountable sales tax (VAT) or costs and deductions in income and complementary taxes.
However, purchasers may request that the seller issue a sales invoice when they have the right to request deductible taxes, costs, and deductions. In this case, the supplier must issue an electronic sales invoice.
The Colombian tax authority (DIAN) officialised the implementation of the five UVT thresholds for tickets generated through P.O.S. systems through Resolution 1092, published on 1 July 2022.
The Resolution implemented the phased roll-out of this mandate, following the calendar below:
Every 1 January from the taxable year 2024, taxpayers obliged to issue a sales invoice that choose to issue the equivalent document, called a ticket for a cash register with a P.O.S. system, must adjust the value of the applicable UVT to comply with the limitation of five UVT in the issuance of each ticket.
Speak with a member of our expert team for further clarification of e-invoicing in Colombia.
Update: 23 August 2022 by Kelly Muniz
The Colombian tax authority (DIAN) has concentrated heavily on expanding its electronic invoicing regime over recent years. The DIAN introduced the first schedule for mandatory implementation of e-invoicing in the country in 2018, and, since then, the system has gradually encompassed more transactions and taxpayers.
In this article, we’ll look at the two latest new mandates in Colombian e-invoicing:
These new obligations have significant impact and require adjustments by taxpayers. These changes also represent a substantial expansion of Colombia’s e-invoicing to include entirely new transactions under its scope.
The Colombian tax authority has created a new e-document type, the support document for acquisitions from subjects not obliged to issue e-invoices. This support document and its corrective notes were introduced by Resolution 167 of 2021. It expands the e-invoicing scope to ensure more transactions fall within the mandate and allows support for tax deductions.
Taxpayers obliged to generate this e-document are those under the country’s e-invoicing regime. It includes those subject to income and complementary tax payments and responsible for VAT when purchasing goods and/or services from suppliers not obliged to issue e-invoices or equivalent documents and require support for costs and deductions in the mentioned tax declarations. To generate the support document, the taxpayer must be authorised by the DIAN as an electronic issuer.
The support document and its corrective notes must be generated in XML format and contain a CUDS: unique support document code (código único del documento soporte). This alphanumeric code allows it to be unequivocally identified. After generation, the e-documents must be transmitted for clearance by the DIAN either in real-time or, at the latest, on the last calendar day of the week, for accumulated operations with the same supplier carried out during that same week.
Having been postponed from its original implementation date, the generation of the acquisitions support document became mandatory on 1 August 2022.
According to this mandate, cash register tickets generated through POS systems (tickets de máquinas registradoras con sistemas P.O.S.) may be issued by subjects obliged to invoice, provided that the sale of the good and/or the provision of the service recorded therein doesn’t exceed five (5) UVT (tax value unit) for each document, excluding taxes.
This means that, for operations covering sales of goods and/or provision of services exceeding the amount of five (5) UVT, taxpayers under the country’s e-invoicing mandate must issue an electronic sales invoice. The purchaser of goods and/or services below the threshold may still require the issuance of a sales invoice, in which case the supplier must provide it.
The threshold was de facto introduced in 2021 by Law 2155, but it was only in July 2022 that the DIAN established a phased roll-out of the mandate, through Resolution 1092, following the calendar below:
While the generation of the support document for acquisitions is already srequired, taxpayers must start preparing to comply with the new threshold for e-invoice issuance in place of POS tickets. Sovos can help your company adjust to e-invoicing and ensure compliance with Colombia’s new mandates.
Contact our team of experts today to ensure your company is complying with Colombia’s e-invoicing mandates.
The European Commission (EC)’s action plan for fair and simple taxation – ’VAT in the Digital Age’- continues to progress. After a public consultation process, the EC has published Final Reports discussing the best options for the European market to fight tax fraud and benefit businesses with the use of technology.
The areas covered are:
The EC is expected to propose legislative amendments in the VAT Directive this autumn.
The report focusing on VAT reporting and e-invoicing evaluates ‘Digital Reporting Requirements (DRR)’. This is any obligation for VAT taxable persons to periodically or continuously submit transaction data digitally to the tax authority, e.g. by use of SAF-T, VAT listing, real-time reporting or e-invoicing.
According to the report, the best policy choice would be the introduction of a DRR in the form of an EU-wide continuous transaction controls (CTC) e-invoicing system covering both intra-EU and domestic transactions. Member States with an existing e-invoicing system would be able to keep this in the short term via a standstill clause, provided they ensure interoperability with the new EU system. However, in the medium term of five to ten years, national e-invoicing systems would be required to converge to the EU system.
The report clearly favours the policy option of a full EU harmonisation through a CTC e-invoicing system, meaning the invoice will be submitted to the authorities before or after issuance. The harmonisation focus seems to be primarily on form, with a suggestion of an EU-wide common protocol and format. Whereas important decisions regarding architecture risk being left to the Member States include whether the system will be clearance or simply reporting, whether to leverage an existing domestic B2G platform and the periodicity of the reporting etc. The only requirement on Member States seems to be accepting issued and transmitted e-invoices based on a common protocol and format.
The report suggests aligning the scope of requirements and excluding non-registered taxable persons and those covered by the SME VAT scheme. In the short term, only B2B and B2G transactions are covered, with B2C transactions remaining out of scope.
Finally, the report suggests that to ease the burden on businesses Member States must consider a number of measures such as jointly removing other reporting obligations, providing pre-filled VAT returns, supporting the investment in business automation (especially for SMEs) and providing public support to the adoption of the IT compliance systems
How this will be jointly coordinated isn’t discussed but it doesn’t sound like the EC expects such measures to be harmonised by the EU.
Although the report concludes implementing an EU-wide mandatory e-invoicing system is the best and most future-proof measure, how to design an effective e-invoicing system is not explained in the report and doesn’t seem to be in scope for harmonisation.
However, the design of the e-invoicing system may have an important impact on fiscal and economic results. As the independent expert report ʻNext Generation Model Decentralized CTC and Exchange’ (supported by EESPA, openPEPPOL and other key stakeholder groups) describes, the greatest benefits can only be realised when an e-invoicing system allows businesses to automate other processes as well as invoicing.
It’s a welcome start that the Commission is aiming for an EU-wide CTC e-invoicing scheme. It remains to be seen how effective this harmonisation will be. When Europe’s politicians return from this year’s summer break, we’ll start to gain more insight into the overall feasibility of the Commission’s views.
As a vendor that has implemented CTC and VAT compliance solutions around the world for several decades now, our desire would be for the debate to go beyond interoperability on a data level, so that Europe can take bold steps towards a future that preserves supply chain automation and technological innovation.
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The Italian Customs Authorities recently updated their national import system by applying the new European Union Customs Data Model (EUCDM). These new changes came into effect on 9 June 2022.
According to the new procedure, the old model of paper import declarations has been abolished. The import declarations are now transmitted to the Italian Customs Authorities’ information system with a digital signature.
The acceptance of a customs declaration is notified to the economic operator (that can be the importer, the Customs Agent, etc.) through a Master Reference Number (MRN), an alphanumeric string of 18 characters.
The old IM message (telematic track to be submitted at the time of the import to the Italian Customs Authorities through the Customs Telematic Service (i.e. Servizio telematico doganale (STD)) has been replaced by the following paths as defined by EU legislation:
At the time of the release of the goods, Italian Customs Authorities make available the “summary statement for accounting purposes of the customs declaration” (prospetto di riepilogo ai fini contabili della dichiarazione doganale). The summary includes all data necessary to detect customs duties, import VAT and any other charges due.
The summary mentioned above is made available to the importer and the declarant/representative in the reserved area of the single portal of Italian Customs Authorities through the “Document management – customs declarations” service.
We recommend that importers contact their Customs Agent to receive a copy of this summary for their accounting purposes.
As per Italian VAT Law, possessing a Single Administrative Document (SAD) is needed to exercise the right to recover import VAT in Italy. As the SAD is now unavailable, Italian Customs Authorities, in agreement with the Italian Revenue Agency, agreed that the new accounting summary is sufficient to allow the importer to exercise the right to recover the import VAT.
Therefore, the new accounting summary is needed to exercise your right to recover the import VAT paid to the Italian tax authorities.
Moreover, the right to recover import VAT is exercised only once the summary is reported in the Purchase VAT Ledger as per art. 25 of Italian VAT Law.
Finally, the import document must be included in your quarterly VAT return and your annual VAT return which must mirror your Italian VAT Ledgers.
To ensure your import VAT is not lost, we recommend considering that the last day to recover the import VAT, related to an import of goods carried out in 2022, is 30 April 2023.
In addition to the Summary Prospetto di riepilogo ai fini contabili della dichiarazione doganale, discussed above, economic operators will be able to receive:
Italian Customs Authorities advise customs operators to provide the Prospetto di svincolo to transporters as proof of the fulfilment of customs formalities in the case of checks.
Speak to our team if you have any questions about the latest Italian importing requirements and their impact on your business’s compliance.