Hungary’s National Tax and Customs Administration (NTCA/NAV), in collaboration with the Ministry for National Economy (NGM), has released a post-consultation information material outlining the country’s conceptual framework for implementing the EU VAT in the Digital Age (ViDA) package. While the document does not constitute a final regulatory position, it signals a fundamental transformation of Hungary’s invoicing landscape.
From Reporting to Mandatory E-Invoicing
Hungary will continue to uphold the principle that invoicing and data supply should be separated. However, the data supply must be based on the invoice. Considering the fact that the data supply obligation for domestic B2B transactions covers the full data contents of the invoice, in the case of invoices issued for these transactions, the electronic invoice must be forwarded to the tax authority as data supply.
Electronic invoicing will be mandatory for:
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Domestic B2B transactions between Hungarian taxable persons
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Cross-border B2B transactions with EU taxable persons
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B2G transactions (business to public institutions)
Paper invoices will only remain permissible for B2C transactions and transactions with non-EU (third-country) buyers. However, even in these cases, the invoice must originate from an underlying XML data structure — there is no format-based exemption from the XML requirement.
Hungary will adopt the data-based invoice concept: a structured XML file compliant with the EN 16931 European standard, including Hungarian local extensions. Hybrid invoice formats will not be accepted.
Key principles governing the new invoice model:
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The XML is always the legally authoritative version of the invoice
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A human-readable representation (e.g., visual or PDF) is optional, except when issuing for B2C, where it is mandatory
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If the human-readable version materially differs from the XML (e.g., in amounts or VAT treatment), the invoice must be cancelled and reissued
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NTCA will provide an XSLT tool to generate visual representations from XML, as well as a ViDA-OSA conversion tool to bridge the current OSA data structure and the new EN 16931-based format, along with field mapping documentation for software developers
The Five-Corner Architecture
Hungary plans to adopt a five-corner model comprising the seller taxpayer, seller’s invoicing program or service provider, buyer taxpayer, buyer’s accounting system or service provider, and tax authority.
Hungary will join the PEPPOL network to enable secure transmission channels, though PEPPOL usage will remain optional for businesses. NAV’s own invoicing program will operate independently of PEPPOL.
Non-secure channels (including email) will not be allowed for invoice transmission for B2B and B2G transactions. All parties must operate through API-based connections. Buyers must be pre-identified before invoice issuance, meaning the buyer’s tax number must be verified and a point of receipt registered before an invoice can be generated.
Software Accreditation
All invoicing programs will require official accreditation from NTCA. The accreditation process will operate through a simplified self-service mechanism:
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Preliminary accreditation: mandatory for invoicing service providers
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Taxpayer accreditation: required for any taxpayer using their own invoicing software, regardless of whether the software itself is separately accredited
The software must verify mandatory data content, tax number validity, and structural correctness before the invoice is generated — and must block creation if validation fails.
Non-accredited data supplies will enter a 30-day pending period; failure to complete accreditation within that window will result in penalties.
NTCA may withdraw accreditation in cases of serious or repeated non-compliance.
Buyer-Side Obligations and the Status Report
Although buyer-side reporting is not mandated by ViDA but optional for the Member States to introduce, Hungary plans to apply it, requiring:
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Buyers to supply data on received invoices within 5 days of receipt
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For domestic transactions, the full invoice must be submitted as buyer-side data supply
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For cross-border EU transactions, a reduced dataset is sufficient
Additionally, Hungary will introduce a status report to be submitted together with the VAT return. Buyers must use this report to identify invoices for which no actual underlying business transaction took place — a mechanism designed to verify the economic reality of transactions beyond simple invoice matching. Status reports must be corrected as soon as incorrect data is identified.
NTCA Support Services
To ease the transition, NTCA has outlined several services it intends to provide:
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Archiving service: legal document retention for both seller and buyer (with support for attachments up to 5 MB, subject to limited retention periods)
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Free NAV invoicing programme: ViDA-compliant invoicing tool, independent of PEPPOL
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Invoice transmission service: available standalone or for integration into invoicing software
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Data supply presentation: invoices and data supplies made visible to both seller and buyer for reconciliation
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ViDA-OSA conversion tool: bridges legacy OSA and new EN 16931 data structures during the transition
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Invoice presentation: standard-compliant invoice XML can be easily presented using XSLT, giving software developers direction and options on how to present the invoice.
As the document explicitly notes that it does not represent a final position and may be revised, businesses should monitor subsequent legislative and regulatory developments from NTCA and NGM closely.
For future updates on Hungary and similar developments across jurisdictions, follow our Regulatory Analysis page.
