Period: April 1, 2026 – June 30, 2026
Wednesday, April 15, 2026 | 11:00 AM Eastern Daylight Time | 1 Hour
Q2 2026 was defined by three dominant themes: the acceleration of e-invoicing mandate timelines across Europe and the Gulf, Brazil entering full enforcement for its Tax Reform consumption taxes, and a high-volume wave of US sales and use tax and information reporting changes.
Europe produced the quarter’s most consequential mandate architecture decision: Spain’s Council of Ministers adopted the mandatory B2B e-invoicing Royal Decree (March 24, 2026) with a confirmed October 1, 2027 go-live for large businesses (>€8M turnover), while Norway’s parliament enacted mandatory B2B e-invoicing legislation in June with confirmed January 1, 2027 issuance and January 1, 2030 receipt deadlines. France’s DGFiP issued informal signals of pragmatic enforcement in the first three months after its September 2026 go-live; these are not a legal relaxation. Slovakia published an expanded e-invoicing FAQ and a draft VAT amendment proposing a Q1 2027 grace period and deferral of buyer-side digital reporting to 2030.
In the Gulf, the UAE extended its Phase 1 ASP appointment deadline to October 30, 2026 while holding the January 1, 2027 go-live firm; Qatar’s Cabinet approved its first e-invoicing law.
Brazil published core IBS/CBS regulations on April 30, activating an August 1 penalty clock and an August 3 document-rejection deadline.
Unsurprisingly for the time of year, state and local sales tax changes generated the highest volume of updates. States continue to adopt penny-rounding rules for cash transactions, while others enact more complex taxability changes such as adjustments to the tax treatment of software in Colorado and California, new and evolving sales tax holidays in Ohio and Illinois, adjustments (and non-adjustments) to the tax treatment of bullion. On the tax information and reporting side, there were IRW (IRS OBBBA threshold changes, Form 1099-DA final instructions, Forms 941/941-X updates, and FIRE system retirements.
| Region | Updates | Countries | Primary Focus Areas |
| Europe | 9 | Belgium, Denmark, France, Greece, Netherlands, Norway, Romania, Slovakia, Spain | B2B e-invoicing mandates; ViDA transposition; France Sept 2026 enforcement posture; Norway confirmed go-lives; Spain full timeline |
| Middle East & Africa | 6 | Cape Verde, Nigeria, Qatar, South Africa, Togo, UAE | E-invoicing mandate launches; ASP deadline extension; Qatar draft law; South Africa framework enacted |
| APAC | 2 | Malaysia, Vietnam | E-invoicing transition extensions; mandate scope expansion to foreign digital platforms |
| LATAM | 4 | Brazil, Chile, Dominican Republic, Mexico | IBS/CBS Tax Reform regulations; Aug 1 penalty clock; NF-e rejection from Aug 3; CFDI hydrocarbon supplement |
| US (SUT) | 12 | FAK, AZ, CA, CO, IL, MA, MD, OH, SC, SD, VA, WA, | Software taxation; local rate changes; bullion exemptions; sales tax holidays |
| US (IRW - Federal) | 11 | IRS | OBBBA threshold changes; tip exemption rules; Form 1099-DA final instructions; 1099-MISC new fields; 941/941-X updates; FIRE retirement |
| US (IRW - State) | 5 | IN, MA, NC, VT | Non-wage withholding; penny rounding; digital asset unclaimed property; 1099 threshold changes; IRIS format adoption; NAUPA III delay |
Three Q2 2026 developments under the September 1, 2026 e-invoicing mandate. (1) France’s 2026 budget law (Loi n° 2026-103, February 19, 2026) introduced graduated enforcement for businesses that fail to designate or use a certified receiving platform (PA) under the September 1, 2026 mandate: the DGFiP must first issue a formal notice opening a three-month correction window before the €500 base penalty applies, rising by €1,000 per subsequent three-month cycle. This correction window covers receiving obligations only; there is no equivalent grace mechanism for issuance. SMBs are subject to receiving obligations from September 1, 2026; issuance is not required until September 2027. Large businesses face both from September 1, 2026. (2) At a Peppol conference in Brussels (June 2026), DGFiP representatives indicated a pragmatic, non-punitive enforcement approach for businesses demonstrating genuine good-faith compliance efforts in the first three months after go-live. This is an informal statement only — not a published policy or legal relaxation. Statutory obligations and enforcement powers are unchanged. Businesses should not use this to delay implementation. (3) AFNOR published guidance FD Z42-029 (May 2026) on the archiving of electronic invoices under the 2026 reform. The document confirms that taxpayers retain their own archiving obligations independently of their PA; invoices must be archived in their legal format (UBL, CII, or Factur-X) as exchanged through the PA. Electronic signatures and associated certificates must also be archived. The guidance recommends NF Z42-013:2020-compliant archiving systems. This is guidance only, not enacted legislation.
Key Dates: September 1, 2026: receiving obligation for all businesses; issuance for large companies (>€8M). September 2027: issuance obligation for SMBs. Three-month correction window: applies to receiving failures only, after formal DGFiP notice. Archiving retention: 6 years (tax/TVA); 10 years (Code de commerce).
Impact: All French VAT-registered businesses; PAs (Plateformes de dématérialisation Accréditées); businesses with archiving obligations under the French mandate.
Sources: France — graduated enforcement and correction window (budget law) | France — AFNOR FD Z42-029 e-archiving guidance
The Belgian Council of Ministers approved a preliminary draft law partially transposing ViDA Directive 2025/516. The draft addresses two sets of provisions: Pillar 2 Platform Economy (updated deemed-supplier VAT rules for digital platforms, effective January 1, 2027) and Pillar 3 (repeal of call-off stock simplification, effective July 1, 2029). A separate legislative wave is required for digital reporting requirements (the EU’s 2030 e-invoicing deadline). The draft has been referred to the Council of State for an advisory opinion.
Key Dates: Pillar 2 (platform economy): January 1, 2027. Pillar 3 (call-off stock): July 1, 2029. Digital reporting requirements: separate legislative wave, timeline TBD.
Impact: VAT-registered businesses operating digital platforms in Belgium; businesses using call-off stock arrangements; cross-border platform operators with EU exposure.
Source: Belgium — Council of Ministers approves partial ViDA transposition
The Danish Business Authority announced that the national e-invoice format OIOUBL 2.1 will be phased out and replaced by NemHandel BIS 4, a Danish adaptation of the international Peppol BIS 4 standard. The transition aligns Denmark’s e-invoicing framework with European Norm standard EN 16931. Phaseout timeline to be confirmed through further regulatory guidance.
Key Dates: OIOUBL 2.1 phaseout timeline: TBD.
Impact: All businesses issuing electronic invoices under Danish government mandates; ERP vendors and e-invoicing service providers certified for OIOUBL 2.1.
Source: Denmark — OIOUBL 2.1 phaseout
Greece postponed Phase B of its e-transport mandate (digital monitoring of goods movement) for the second time via Ministerial Decision A.1094/2026. Originally mandatory from December 1, 2025, then delayed to May 1, 2026, Phase B is now split into two stages: from October 12, 2026, loading, transshipment, and receipt processes including quantitative and qualitative control data transmission to the myDATA platform become mandatory; from January 1, 2027, mandatory TARIC-aligned commodity coding takes effect. Phase A (digital issuance and transmission of transport documents) remains in force from December 1, 2025 — no relief for non-compliant Phase A entities. Optional early transmission of Phase B data to myDATA is permitted ahead of each deadline. Sovos’s cloud and SAP framework solutions are already adapted to Phase B requirements; no further product change is expected as a result of this postponement.
Key Dates: Phase A in force: December 1, 2025 (unchanged). Phase B Stage 1 (loading, transshipment, receipt; quantitative and qualitative data): October 12, 2026. Phase B Stage 2 (TARIC commodity coding): January 1, 2027.
Impact: Businesses involved in goods movements in Greece: suppliers, transport companies, 3PLs, and recipients. ERP and logistics systems must support quantitative and qualitative data transmission to myDATA.
Source: Greece — e-transport Phase B postponed (second delay)
The Dutch Ministry of Finance transmitted to parliament an advisory report recommending structured e-invoicing and near-real-time digital reporting for all domestic B2B transactions via Peppol (EN 16931 standard). The advisory recommends mandatory domestic e-invoicing before July 1, 2030 and digital reporting for domestic transactions in 2032. A cabinet position is expected by summer 2026, with public consultation on draft legislation planned for Q4 2026.
Key Dates: Mandatory domestic e-invoicing: before July 1, 2030. Digital reporting: 2032. Cabinet position: expected summer 2026. Public consultation: Q4 2026.
Impact: All VAT-registered businesses conducting domestic B2B transactions in the Netherlands. Given the Netherlands’ role as a pan-European logistics and financial hub, the mandate will affect multinational supply chains beyond Dutch operations.
Source: Netherlands — domestic B2B e-invoicing and digital reporting framework
Norway’s parliament enacted amendments to the Bookkeeping Act on June 1, 2026, introducing mandatory B2B e-invoicing and digital bookkeeping. All bookkeeping-obligated parties — broadly any business subject to Norwegian income/wealth tax or VAT, regardless of place of establishment — must issue and receive invoices in a structured electronic format suitable for automated processing, and conduct bookkeeping in an electronic accounting system. There is no distinction between local and foreign ERPs. The Ministry of Finance subsequently confirmed go-live dates: the deadline for mandatory B2B e-invoice issuance has been brought forward by a full year from January 1 2028 to January 1, 2027; mandatory e-invoice receipt and digital bookkeeping from January 1, 2030. The law requires 5-year archiving of electronic invoices in original format; storage abroad is currently permitted in the EEA, UK, and Switzerland subject to notification. No specific technical format is prescribed; implementing regulations from the Norwegian Tax Administration are expected to follow. The tax authority has proposed EHF (Elektronisk Handelsformat) as the mandatory standard in consultation, but a decision has not yet been made. Norway is not an EU member and not bound by ViDA; however, as an EEA member, CTC/DRR requirements analogous to ViDA could emerge around 2030. Businesses selecting a Peppol-only service provider now carry long-term risk if Norway moves toward a CTC/DRR model. Sovos intends to support through Peppol.
Key Dates: Legislation enacted: June 1, 2026. Mandatory e-invoice issuance: January 1, 2027 (confirmed). Mandatory e-invoice receipt and digital bookkeeping: January 1, 2030 (confirmed). Technical format implementing regulations: expected to follow.
Impact: All bookkeeping-obligated businesses in Norway, including non-established entities subject to Norwegian tax or VAT. ISVs must ensure solutions support forthcoming format requirements once implementing regulations are published.
ANAF published Order No. 378/2026 (Official Gazette No. 250, March 31, 2026), amending Order No. 3789/2024. The key change restructures Form 082 to function as a combined registration and deregistration request for the RO e-Invoice Register, enabling eligible taxpayers to deregister as well as register.
Key Dates: Order No. 378/2026 published: March 31, 2026.
Impact: Taxpayers registered or eligible for registration in the RO e-Invoice Register; businesses undergoing restructuring or ceasing VAT-registered activity.
Source: Romania — ANAF Order 378/2026 amends RO e-Invoice registration
Three significant Q2 2026 developments ahead of Slovakia’s January 1, 2027 e-invoicing mandate. (1) Slovakia’s Financial Administration published an updated e-invoicing FAQ adding 29 new Q&As. The update confirms: entities registered under §5 are not required to receive e-invoices via service providers during 2027–2030; alternative delivery channels with recipient consent are permissible; a 3-working-day deregistration deadline for provider switching is formalised. One open item — reporting mechanics for consent-based alternative delivery channels — remains unresolved. (2) The Slovak Ministry of Finance published a draft amendment to the VAT Act proposing a Q1 2027 grace period (January 1–March 31, 2027) during which failure to issue e-invoices in the required format or within prescribed timeframes and associated financial penalties would not be enforced. The draft also proposes removal of the buyer-side digital reporting obligation (5-day reporting window for received invoices) until July 1, 2030. This is draft legislation only — not yet enacted. (3) Under the Peppol framework, each taxpayer can register only one service provider on the eFaktura-PFS portal for inbound (AP) invoices — a winner-takes-all constraint for Peppol AP flows. Outbound (AR) flows allow multiple providers via bilateral agreements. The Slovak Ministry of Finance expects 90% of entrepreneurs on the Slovak market to use the Peppol delivery service. The Slovak Peppol AP constraint makes provider selection a strategic control-point decision, not a standard compliance project.
Key Dates: Mandate entry into force: January 1, 2027 (unchanged). Proposed Q1 2027 grace period: January 1–March 31, 2027 (draft; not yet enacted). Proposed buyer-side DRR deferral: July 1, 2030 (draft; not yet enacted).
Impact: All VAT-registered businesses issuing or receiving B2B invoices in Slovakia. The single-provider Peppol AP constraint requires businesses to make a final provider selection before the mandate goes live; delay risks being locked out of the AP flow.
Three developments in Q2 2026. (1) On March 24, 2026 (Royal Decree 238/2026), Spain’s Council of Ministers adopted the Royal Decree mandating electronic invoicing for domestic B2B transactions between companies and professionals, implementing Article 12 of Ley Crea y Crece (Law 18/2022). Scope clarification from PwC consultation confirms the obligation applies to both established and non-established suppliers carrying out B2B transactions where the recipient is established in Spain — non-established customers cannot be automatically excluded. (2) The Spanish Tax Authority (AEAT) published for public consultation a draft Ministerial Order regulating the AEAT-operated public e-invoicing solution (consultation closed May 8, 2026). The Order defines the full implementation timeline: October 1, 2026 (Ministerial Order entry into force); estimated August 2027 (AEAT public solution operational); October 1, 2027 (private platforms meet faithful copy, interoperability, and technical requirements; large businesses >€8M comply with e-invoicing, e-reporting, and invoice status reporting with a 12-month PDF copy obligation unless waived by recipient); October 1, 2028 (all remaining businesses comply); October 1, 2029 (invoice status reporting deferred for sole traders / IRPF attribution entities ≤€8M). Invoice format: EN 16931-compliant UBL. Private platforms must submit faithful copies to AEAT in UBL. Recipients must report payment and rejection. Authentication requires qualified electronic certificates. (3) The Bizkaia Provincial Council published Provincial Decree 22/2026 and Provincial Order 219/2026 formalising structural changes to the BATUZ LROE for Corporate Income Tax entities filing under Model 240, retroactive to January 1, 2026. A new aggregate reporting subcategory applies to VAT-exempt supplies and purchases above €1,000 per counterparty per year.
Key Dates: Royal Decree 238/2026 adopted: March 24, 2026. Ministerial Order entry into force (planned): October 1, 2026 (trigger for all compliance countdowns). AEAT public solution operational: estimated August 2027. Private platforms + large businesses (>€8M): October 1, 2027 (subject to Ministerial Order). All remaining businesses: October 1, 2028 (subject to Ministerial Order).. Sole traders / IRPF entities (≤€8M) invoice status reporting: October 1, 2029. Bizkaia LROE changes: retroactive from January 1, 2026.
Impact: All companies and professionals conducting domestic B2B transactions in Spain, including non-established suppliers transacting with Spanish-established recipients. Corporate Income Tax entities in Bizkaia filing under Model 240. ERP and e-invoicing service providers operating as private platforms must build direct AEAT integration (faithful copy, status messages, retrieval service).
Sources: Spain — B2B e-invoicing Royal Decree adopted | Spain — AEAT public e-invoicing draft Ministerial Order | Spain (Bizkaia) — BATUZ LROE structural changes
Two Q2 2026 developments. (1) The UAE Ministry of Finance amended Ministerial Decision No. 244 of 2025, extending the deadline for Phase 1 businesses (annual revenue ≥ AED 50 million) to appoint an Accredited Service Provider (ASP) from July 31, 2026 to October 30, 2026. The mandatory go-live of January 1, 2027 is unchanged. The amendment also introduces a white-label mechanism permitting UAE firms to partner with international providers while keeping compliance responsibility with the accredited provider. The implementation window between ASP appointment and mandatory go-live has effectively compressed; businesses should not treat this extension as a delay signal. Phase 2 (revenue < AED 50M and government entities): ASP appointment March 31, 2027; go-live July 1, 2027. Government entities: go-live October 1, 2027. (2) Sovos Compliance Network is now officially certified for UAE e-invoicing through accredited ASP partner InvoiceNow, listed on the UAE Federal Tax Authority website. The ASP onboarding and selection process is handled within the Sovos product workflow; there is no change to contracting or the customer experience.
Key Dates: Phase 1 ASP appointment deadline: October 30, 2026 (extended from July 31, 2026). Phase 1 mandatory go-live: January 1, 2027 (unchanged). Phase 2 ASP appointment: March 31, 2027. Phase 2 go-live: July 1, 2027. Government entities go-live: October 1, 2027.
Impact: All UAE businesses with annual revenue ≥ AED 50M (Phase 1); government entities; subsequent phases covering remaining businesses. Roughly 50% of Phase 1 companies had not yet selected an ASP as of late May 2026.
Sources: UAE — Phase 1 ASP appointment deadline extended to October 30 | UAE — Ministry of Finance operational e-invoicing guidance
Qatar’s Cabinet approved a draft e-invoicing law and its executive regulations, developed by the Ministry of Finance in coordination with the General Tax Authority (GTA). The law establishes the legal framework for the issuance of electronic invoices and notices. No implementation timetable or technical specifications have been released. The relationship between the e-invoicing framework and the anticipated VAT regime remains unconfirmed. Proposed; subject to final legislative steps.
Key Dates: Cabinet approval: May 2026. Formal enactment and effective date: TBD.
Impact: Multinationals operating in Qatar should begin readiness assessments. GCC pattern — Saudi Arabia 2021, UAE 2026/2027, Oman 2026 — suggests rapid progression once a legal framework is established.
Sources: Qatar — Cabinet approves draft e-invoicing law (Sovos feed) | Qatar — Cabinet announcement (official source)
The Cape Verde Government approved the 2026 State Budget Law Proposal, expanding the e-invoicing framework in place since June 2021. All invoices and tax-relevant documents must be issued electronically through tax-authority-certified software. Each document must carry a QR Code and unique document identifier. Certified software requirements are extended to accounting record maintenance.
Key Dates: Budget Law Proposal approved: Q2 2026. Effective date for expanded mandate: TBD pending formal enactment.
Impact: All taxpayers issuing invoices or tax-relevant documents in Cape Verde; software providers requiring Tax Authority certification.
Source: Cape Verde — 2026 Budget Law expands e-invoicing mandate
The Nigeria Revenue Service (NRS) announced continuation of the phased rollout of its E-Invoicing and Electronic Fiscal System (EFS), also known as the Merchant-Buyer Solution (MBS), to medium and emerging taxpayers. Large taxpayer go-live (annual turnover above ₦5 billion, approximately €3.1M) occurred in November 2025.
Key Dates: Large taxpayer go-live: November 2025. Medium and emerging taxpayer rollout: phased — dates per NRS notice.
Impact: Medium and emerging taxpayers in Nigeria; all businesses in subsequent rollout phases.
Source: Nigeria — NRS e-invoicing rollout timeline for medium taxpayers
Togo’s Finance Law 2026 introduces a certified electronic invoicing obligation for B2B transactions, applying to any VAT taxpayer delivering goods or services to another VAT taxpayer. A certified electronic invoice must be created, transmitted, and stored electronically with a required certification process.
Key Dates: Finance Law 2026 enacted; compliance effective date TBD per implementing regulations.
Impact: All VAT taxpayers conducting B2B transactions in Togo.
Source: Togo — Finance Law 2026 certified e-invoicing obligation
SARS enacted the Tax Administration Laws Amendment Act, 2026 (Act No. 4 of 2026), published April 1, 2026 in Government Gazette No. 54447. The Act introduces a formal legal foundation for e-invoicing and e-reporting under the Value-Added Tax Act No. 89 of 1991. The mandate is not yet compulsory; the Act establishes the enabling legal framework ahead of a future mandatory phase.
Key Dates: Act No. 4 of 2026 enacted: April 1, 2026. Mandatory e-invoicing effective date: TBD.
Impact: VAT-registered businesses in South Africa; ERP and e-invoicing vendors preparing for future mandatory requirements.
Source: South Africa — Tax Administration Laws Amendment Act 2026
Malaysia’s Inland Revenue Board (HASiL) extended the transition period for the last taxpayer group (annual turnover between RM 1 million and RM 5 million) from 12 months to 24 months, running from January 1, 2026 to December 31, 2027. Mandatory compliance for this group is now January 1, 2028.
Key Dates: Extended transition period: January 1, 2026 – December 31, 2027. Mandatory compliance: January 1, 2028.
Impact: Taxpayers with annual turnover between RM 1 million and RM 5 million. Larger businesses remain in mandatory scope.
Source: Malaysia — e-invoicing relaxation extended to end of 2027
Vietnam enacted a new Law on Tax Administration replacing the 2019 e-invoicing framework, explicitly extending e-invoicing obligations to foreign organizations and individuals operating on e-commerce and digital platforms from July 2026. Foreign suppliers without a permanent establishment in Vietnam had the option to register voluntarily since June 2025; that path is now mandatory for in-scope operators.
Key Dates: Expanded e-invoicing scope effective: July 2026.
Impact: Foreign digital-platform operators and e-commerce sellers supplying Vietnamese customers without a Vietnamese permanent establishment; portal onboarding with the General Department of Taxation and invoice schema alignment required immediately.
Source: Vietnam — e-invoicing scope expanded to foreign digital platform operators
Three interlocking Q2 2026 developments. (1) On April 30, 2026, Brazil published core regulations governing IBS (state-municipal consumption tax) and CBS (federal consumption tax) through CGIBS Resolution No. 6/2026, Decree No. 12,955/2026, and Joint Ordinance MF/CGIBS No. 7/2026. These instruments establish foundational operational rules for the new taxes and activate the compliance deadline in Article 3 of Joint Act RFB/CGIBS No. 1/2025: penalties may be imposed for missing CBS/IBS fields in tax documents from August 1, 2026. (2) Technical Note 2025.002-RTC Version 1.40 (published May 20, 2026) establishes that from August 3, 2026, all NF-e documents must include the IBS and CBS tax groups. Documents missing this data will be rejected by the tax authority — impacting operations, like halt shipments and payments. (3) The Tax Reform transforms the electronic invoice document structurally: the XML becomes the primary source for IBS/CBS Apuração Assistida (assisted filing calculation), incorporating more than 200 additional records, new validation rules, and new fiscal codes. New document types include NFGas, NFCom, and updated NF-e with IBS/CBS groups. Customers need to validate end-to-end readiness across tax determination, CBS/IBS fields in all document types (NF-e, NFC-e, NFS-e, CT-e), tax events, assisted assessment traceability, and Special Declarations (DeRE) for specific regimes, like financial services and insurance.
Key Dates: IBS/CBS regulations published: April 30, 2026. Penalty exposure begins: August 1, 2026. NF-e without IBS/CBS fields rejected: August 3, 2026.
Impact: All Brazilian taxpayers issuing NF-e documents; businesses subject to IBS and CBS; ERP vendors and fiscal document technology providers. Customers with fragmented ecosystems face the greatest risk of data inconsistency across determination, XML, and assessment.
Sources: Brazil — IBS/CBS go-live regulations and penalty exposure | Brazil — NF-e without IBS/CBS rejected from August 3
Chile’s tax authority (SII) published Exempt Resolution No. 52 on April 10, 2026, postponing the effective date of additional requirements for dispatch guides and invoices used in the transfer of goods.
Key Dates: Postponement published: November 1st, 2026. Revised effective date: per Exempt Resolution No. 52.
Impact: Businesses issuing dispatch guides and invoices for goods transfers in Chile.
Source: Chile — SII Resolution 52 postpones dispatch guide and e-invoice requirements
The Dominican tax authority extended the electronic invoicing implementation deadline for Small, Micro, and unclassified taxpayers to November 15, 2026 via RNC Notice 401-50625-4.
Key Dates: Revised deadline: November 15, 2026.
Impact: Small, Micro, and unclassified taxpayers in the Dominican Republic; service providers and software vendors supporting these implementations.
Source: Dominican Republic — e-invoicing deadline extended to November 15, 2026
Effective April 24, 2026, all fuel and diesel sales transactions must include the Concept Complement for the Invoicing of Hydrocarbons and Petroleum Products in their CFDI. The complement requires permit numbers issued by the energy authority and information on fuel type. The Mexican tax authority also published the technical documentation specifying schema and field requirements.
Key Dates: Mandatory in CFDI: April 24, 2026. Technical documentation: published Q2 2026.
Impact: All taxpayers engaged in the sale of gasoline and diesel in Mexico; ERP and billing systems requiring CFDI generation with the hydrocarbon complement.
Sources: Mexico — new CFDI requirements for fuel and diesel sales | Mexico — technical documentation for hydrocarbon CFDI complement
State legislation and local change: (1) Alaska passed House Bill 1, which exempts certain gold and silver bullion from local sales and use tax. The legislation also recognizes select specie as a form of legal tender in the state. Both provisions are effective August 28, 2026. (2) The City of Chignik completed the process to join the Alaska Remote Sellers Sales Tax Commission (ARSSTC). Remote sellers must begin collection effective June 1, 2026; filing forms updated to include Chignik effective July 1, 2026.
Key Dates: (1) Effective August 28, 2026; (2) Collection begins: June 1, 2026. Forms updated: July 1, 2026.
Impact: (1) Retailers selling gold and silver bullion in Alaska locals; (2) Remote sellers with economic nexus in Alaska required to collect for Chignik.
Sources: Alaska — City of Chignik joins ARSSTC | Alaska — Exempts certain bullion from local sales & use tax
Effective July 1, 2026, South Tucson passed Ordinance 26-01, reducing the tax rate on food for home consumption from 1.5% to 0%.
Key Dates: Effective July 1, 2026.
Impact: Grocery retailers and POS operators in South Tucson.
Originally proposed as a part of the new budget, Governor Newsom signed budget trailer bill, Senate Bill 122, imposing sales tax on electronically delivered software, including cloud-based and downloaded software, effective January 1, 2027. Previously, California sales tax applied to prewritten software only when sold on physical media. State revenue projections estimate approximately $450 million in the first year, rising to approximately $900 million annually.
Key Dates: Effective January 1, 2027.
mpact: Every business purchasing or reselling SaaS, cloud infrastructure, or downloaded software with California nexus. Tax teams should model liability exposure now.
Source: California — budget proposal: sales tax on cloud software
State legislation and two rate adjustments: (1) Colorado House Bill 1223, signed in to law on June 2, 2026, repeals the sales and use tax exemption for downloaded software beginning January 1, 2027. The legislation, however, provides a narrow exemption for downloaded software governed by a negotiable license agreement or developed for an individual user. (2) The Retail Delivery Fee increases for the period July 2026–June 2027 (inflation-adjusted, now $0.31). The fee applies to all motor vehicle deliveries with at least one item of tangible personal property subject to state sales or use tax. Additionally, the Daily Vehicle Rental Fee adjusts to $5.34 for the same period. Both effective July 1, 2026.
Key Dates: (1) Effective January 1, 2027; (2) Effective July 1, 2026.
Impact: (1) Retailers of downloaded software unless the software meets the narrow exemptions. (2) Retailers making taxable deliveries by motor vehicle in Colorado; motor vehicle rental operators.
Sources: Colorado — retail delivery fee increase | Colorado— vehicle rental fee adjustment | Colorado — repals downloaded software exemption
Two legislative changes: (1) Effective July 1, 2026, 56 municipalities and 3 counties will begin imposing the 1% grocery tax, following the 600+ localities that began imposing the tax on January 1, 2026. (2) Illinois has reinstated its back-to-school sales tax holiday under Public Act 104-0468. From August 7–16, 2026, the state sales tax rate on qualifying clothing under $125 and eligible school supplies drops from 6.25% to 1.25%.
Key Dates: (1) Effective July 1, 2026; (2) August 7-16, 2026
Impact: (1) Grocery retailers, food delivery platforms, and POS operators with Illinois locations. Teams should build a recurring review process for Illinois local grocery tax changes. (2) Retailers selling clothing and back-to-school items in Illinois.
Source: Illinois — additional localities impose 1% grocery tax | Illinois — reenacts sales tax holiday
Two legislative actions. (1) Emergency legislation enacted May 12, 2026 establishes penny-rounding rules for cash transactions: prices ending in 1, 2, 6, or 7 cents round down; prices ending in 3, 4, 8, or 9 cents round up. Applies to cash transactions only, took effect immediately. (2) House Bill 898, enacted May 12, 2026, provides a sales tax exemption for data and IT services, software publishing services, digital codes, and digital products when both vendor and buyer are members of the same affiliated group within IRC §1504.
Key Dates: Both enacted: May 12, 2026. Effective immediately.
Impact: All retailers handling cash transactions in Maryland. Businesses within affiliated groups should review compliance posture; the exemption may generate refund opportunities for tax collected since July 1, 2025.
Sources: Maryland — penny rounding emergency legislation | Maryland — affiliated group IT services exemption
Change: Massachusetts published Directive 26-1 providing guidance on sales tax calculation following the US Treasury’s elimination of the penny (last minted November 12, 2025). Vendors must calculate and remit sales tax based on the actual pre-rounding transaction price, not the rounded cash amount. Systems calculating tax on the rounded amount will under- or over-remit.
Key Dates: Directive 26-1 published: Q2 2026.
Impact: All retailers in Massachusetts processing cash transactions.
Source: Massachusetts — Directive 26-1 penny elimination guidance
Ohio House Bill 186 (2025) canceled the expanded August 2026 sales tax holiday as a part of a legislative package aimed at restructuring property taxes in the state. As a result, the Ohio sales tax holiday on August 7-9, 2026, reverted to the historic back-to-school holiday for clothing and certain school supplies. On June 24, 2026, the governor signed House Bill 479, which re-established the expanded sales tax holiday to a fifteen-day period beginning in August 2027. Under the expanded holiday, retail sales of qualifying tangible personal property priced at $500 or less are exempt.
Key Dates: August 7-9, 2026
Impact: Retailers selling qualifying clothing, school supplies, or school instructional materials in Ohio.
Source: Ohio — cancels August 2026 expanded sales tax holiday | Ohio — again expands sales tax holiday for 2027
Change: Effective May 1, 2026, Williamsburg County imposed a 1% Capital Projects Tax. Certain food sales are exempt.
Key Dates: Effective: May 1, 2026.
Impact: Retailers in Williamsburg County.
Source: South Carolina — Williamsburg County 1% Capital Projects Tax
Three legislative actions effective July 1, 2026. (1) HB 1245 allows municipalities to impose a temporary sales tax not exceeding 1% for capital improvements, subject to voter approval. (2) HB 1254 exempts sales of soil amendments from sales tax if used in agriculture and sold in quantities of 500 pounds or more. (3) SB 96 allows counties to enact a 0.5% sales tax pending voter approval, with revenue dedicated to property tax reduction. Additionally, SB 245 (signed March 12, 2026) captures revenue from the scheduled state sales tax increase (4.2% to 4.5% in July 2027) and dedicates it to a homeowner property tax reduction fund.
Key Dates: HB 1245, HB 1254, SB 96: effective July 1, 2026. SB 245: signed March 12, 2026; rate increase and diversion effective July 2027.
Impact: Municipalities and counties; agricultural sellers; retailers statewide subject to the July 2027 rate increase.
Sources: SD HB 1245 — municipal capital improvement tax | SD HB 1254 — soil amendment exemption | SD SB 96 — county 0.5% sales tax | SD SB 245 — sales tax revenue diversion
Under Virginia House Bill 1600 (2025) the exemption for gold, silver, or platinum bullion and legal tender coins (VA §58.1-609.1(19)) was set to expire June 30, 2026. However, as part of Virginia House Bill 30, signed in the final hours before the budget deadline on June 29, 2026, Virginia has now extended the exemption to expire June 30, 2028.
Key Dates: Exemption expires: June 30, 2028. Tax applies: July 1, 2029.
Impact: Retailers selling gold, silver, platinum bullion, and legal tender coins in Virginia.
Source: Virginia — bullion and coins exemption expiring | Virginia — extends exemption for bullion and coins
Change: The Washington legislature enacted Senate Bill 6346, modifying and clarifying the scope of sales tax changes imposed in October 2025 on custom software, live presentations, and a range of new services. SB 6346 expands existing exemptions and refines taxability rules for specific service categories, effective July 1, 2026.
Key Dates: Effective: July 1, 2026.
Impact: Businesses selling custom software, live presentations, and newly taxable services in Washington.
The IRS introduced guidance on qualified long-term care distributions under SECURE 2.0 Act section 334, applicable to distributions made after December 29, 2025. Two new reporting requirements are created: a new Form 1099-LPS (Long-Term Care Premiums Paid Statement) must be filed with the IRS and furnished to the covered individual by issuers of certified long-term care insurance filing a premium statement with a defined contribution plan; and qualified long-term care distributions must separately be reported on Form 1099-R. The 2026 annual cap on these distributions is $2,600.
Key Dates: Applicable to distributions after December 29, 2025. Plan amendment deadline: December 31, 2027.
Impact: Issuers of certified long-term care insurance.
Source: IRS — IRS Releases Internal Revenue Bulletin 2026-24
The IRS released the 2026 version of Form 1099-NEC with structural changes to both the preamble and the form itself. The payer address field is now broken into separate boxes (street address, city, phone number). More significantly, Box 1 is restructured into subfields: 1a (gross non-employee compensation), 1b (tip income qualifying for the tip tax exemption), 1c (Treasury Tipped Occupation Codes relevant to reported tipped income), and 1d (overtime compensation qualifying for the overtime tax exemption). Amounts in 1b and 1d should also be included in the gross total reported in 1a. These Box 1 changes reflect new income tax exemptions introduced under the One Big Beautiful Bill Act (OBBBA). Form instructions have not yet been released.
Key Dates: Applies to 2026 tax year reporting.
Impact: All payers filing Form 1099-NEC who have tipped or overtime workers.
Source: IRS — IRS Releases 2026 Form 1099-NEC
The IRS updated Publication 1220 (May 2026 revision) covering electronic filing specifications for the FIRE system. The IRS has announced the retirement of the FIRE system: new TCC applications will no longer be accepted after July 21, 2026. Existing applications can be updated through December 2026, after which they become read-only. All electronic filers must transition to the IRIS for all filings — including current year, prior year, and corrections — beginning January 1, 2027.
Key Dates:
July 21, 2026: FIRE stops accepting new TCC applications.
December 2026: Existing FIRE applications become read-only.
January 1, 2027: IRIS required for all electronic information return filing.
Impact: All transmitters and issuers filing information returns electronically.
The only substantive change is the addition of four forms to the waiver-eligible checkbox list in Block 5: 1098-VLI, 1099-LPS, 5498-QA, and 5498-TA.
Key Dates: Revision date May 2026.
Impact: Filers of the four newly added form types who may qualify for or wish to request an electronic filing waiver. Note that 1099-LPS is among the additions, which aligns with its introduction under Notice 2026-33 (IRS Bulletin 2026-24) — filers of that new form should be aware a waiver pathway exists.
Source: IRS — IRS Revises Form 8508 (Application for a Waiver from Electronic Filing of Information Returns)
The IRS released the 2026 edition of Form 15397 with two notable changes. First, Forms 1099-NEC and 1099-QA no longer have dedicated line items for reporting delayed recipient copy counts — those counts are now folded into the general 1099 line. Second, the instructions now provide additional specificity on what information is required when explaining the reason for an extension request.
Key Dates: 2026 edition; no new deadline changes.
Impact: Filers requesting extensions to furnish recipient statements.
The IRS released draft regulations implementing information reporting threshold changes under the One Big Beautiful Bill Act. The general reporting threshold for Forms 1099-MISC, 1099-NEC, W-2, and W-2G rises from $600 to $2,000 for payments made after December 31, 2025, with annual inflation adjustments beginning in 2027. Bingo, keno, and slot machine winnings thresholds are aligned to $2,000. The wagering loss deduction is capped at 90% of losses. Regulations are in a 60-day comment period. The $2,000 threshold is already statutory; these draft regulations implement the change in regulatory text.
Key Dates: Threshold change effective: payments made after December 31, 2025 (effective on finalization). Comment period: 60 days from publication.
Impact: All payers of non-employee compensation, rents, prizes, and gambling winnings. 1099 filing volumes will decrease materially for payers with significant sub-$2,000 payee populations.
Source: IRS — draft regulations implementing OBBBA 1099 threshold changes
The IRS released final rules (91 FR 19026, codified as 26 CFR §1.224-1) for reporting of tips made tax-exempt by the OBBBA. Tip compensation qualifies if paid for a qualifying occupation listed in the rules (with assigned Treasury Tipped Occupation Codes), reported on Forms W-2, 1099-K, 1099-MISC, 1099-NEC, or self-reported on Form 4137, and offered voluntarily in excess of any mandatory minimum fee. Payers must report qualifying tips broken down by occupation code on the appropriate information return.
Key Dates: Applicable: tax years 2025–2028.
Impact: Hospitality, food service, beauty, and other tipped-occupation employers. Payroll and tip-reporting systems require a new data field for Tipped Occupation Codes.
The IRS released final instructions for Form 1099-DA for tax year 2026. Most consequential change: the transitional basis-reporting waiver is removed. Basis information is now mandatory for covered digital assets acquired in 2025 and forward. De minimis rules introduced for certain digital asset payment processors (≤$600/year), qualifying stablecoin sales (≤$10,000), and specified NFT sales (≤$600). All 2025-specific transitional guidance has been removed.
Key Dates: Applicable: tax year 2026, filing season 2027.
Impact: Digital asset brokers, exchanges, and custodians. Systems relying on 2025 transitional rules must be updated before year-end.
The IRS released Form 1099-MISC for tax year 2026 (filing season 2027). Payer information expands from a single block to 8 individual fields; recipient address expands from 2 to 6 fields. Box 13 is split into cash tips (Box 13a) and Treasury Tipped Occupation Codes (Box 13b). Box 14 now captures overtime compensation. Both new boxes feed taxpayer deductions introduced by the OBBBA.
Key Dates: Applicable: tax year 2026, filing season 2027.
Impact: All payers of miscellaneous income. Information-reporting systems need schema and data-mapping updates ahead of the 2027 filing season.
Source: IRS — Form 1099-MISC for 2026
The IRS updated Form 941 and Form 941-X for 2026. Notable changes: new Aggregate Return Filers Only section; new deductions for qualified tips (up to $25,000) and qualified overtime compensation (up to $12,500, or $25,000 married filing jointly) for 2025–2028; updated Social Security wage base ($184,500); restructured Line 15 with new direct deposit option for refunds. Form 941-X tightens rules on COVID-19 retention credit corrections for Q3–Q4 2021 with a 6-year assessment extension.
Key Dates: Effective: 2026 tax year.
Impact: All employers and payroll processors. Tightened Form 941-X COVID-era credit correction rules create a finite correction window that affected employers should address without further delay.
The IRS released Notice 2026-20, extending relief for eligible taxpayers to use alternative methods of adequate identification under Treas. Reg. §1.1012-1(j)(3)(ii) for digital asset units held in broker custody through December 31, 2026. This extends the temporary relief first provided in Notice 2025-7 by one year.
Key Dates: Relief extended through: December 31, 2026.
Impact: Taxpayers holding digital assets in broker custody subject to cost basis identification rules.
Indiana Senate Bill 243 (SB 0243), signed March 5, 2026, amends Indiana Code on taxation. Key provisions: new penny rounding rules under IC 5-36.5; new adjusted gross income deductions; increased gambling withholding thresholds.
Key Dates: Signed: March 5, 2026. Penny rounding effective per IC 5-36.5 commencement.
Impact: Indiana employers and payors subject to withholding; retailers; gambling payors.
Source: Indiana — Senate Bill 243
North Carolina enacted House Bill 1029, the Digital Asset and Stablecoin Act (introduced April 22, 2026; amended and enacted May 2026). The Act provides requirements for digital asset businesses and embeds amendments to the unclaimed property act for digital assets: presumed abandoned five years after the last owner-generated activity; holders must remit in native form to a qualified custodian designated by the state Treasurer; liquidation applies if the Treasurer cannot accept the asset.
Key Dates: Enacted: May 2026. Effective per Act provisions.
Impact: Digital asset businesses in North Carolina; financial institutions, exchanges, and custodians holding digital assets for North Carolina residents. Native-asset remittance requirements differ materially from traditional unclaimed property.
Source: North Carolina — HB 1029 Digital Asset and Stablecoin Act
The Massachusetts Department of Revenue updated its withholding regulation effective June 5, 2026. The key change: when gross payment to an individual performer exceeds the taxable income threshold under M.G.L. c. 62, § 4(d), the withholding rate on amounts above that threshold is the standard Part B rate plus an additional 4%. This reflects the state’s surtax on income exceeding $1,000,000 (inflation-adjusted). The update also includes minor clarifying corrections.
Key Dates: Effective June 5, 2026.
Impact: Withholding agents paying compensation to individual performers in Massachusetts. Agents should review payment arrangements where total compensation to a single performer could exceed the $1,000,000 threshold and adjust withholding calculations accordingly.
Source: Massachusetts Updates Withholding Regulation 830 CMR 62B.2.1
Vermont’s Department of Taxes announced it will accept 2026 1099 filings in the new IRS IRIS XML format beginning December 2026, following the same formatting guidelines as the IRS. Technical filing specifications from Vermont have not yet been published.
Key Dates: IRIS format acceptance begins: December 2026.
Impact: All filers of 1099s with Vermont; systems transitioning from FIRE to IRIS.
NAUPA is shifting the planned transition to the NAUPA III reporting format from Fall 2026 to a two-phase rollout beginning Spring 2027. Phase 1 moves reporting to XML while maintaining existing property code structure with minor updates. Phase 2 (date TBD) introduces comprehensive property code restructuring with a crosswalk guide.
Key Dates: NAUPA III Phase 1: Spring 2027. Phase 2: TBD.
Impact: All holders filing unclaimed property reports; software vendors supporting NAUPA format compliance. Phase 2 planning should begin in parallel once the ‘crosswalk guide’ is published.
Generated: March 23, 2026 | Source: Sovos Regulatory Analysis Feed
Period: Q1 2026 (January 1 – March 23, 2026) | Total Updates: 48 country/topic entries across 5 regions
Regions: Europe, Middle East & Africa, APAC, LATAM, US | Report Version: 3.0.0