Worldwide updates on E-Invoicing/Real Time Reporting/SAF-T in March 2025

AFRICA

Angola’s E-Invoicing Mandate: A Phased Approach

Angola’s Ministry of Finance is drafting a law to mandate invoicing through certified software that submits real-time data to the General Tax Administration (AGT), requiring electronic invoicing for certain taxpayers if approved.
The e-invoicing mandate will roll out in three phases: Phase 1 for transactions over Kz 25 million (EUR 25,000) within six months; Phase 2 for large taxpayers and government suppliers within the first year; and Phase 3 for all taxpayers under the VAT regimes after one year.
Taxpayers may voluntarily opt into the e-invoicing system, and enforcement will begin six months after the law’s official publication, with ongoing discussions before finalization.

ASIA

Malaysia Updates e-Invoice Guideline in Regard to MyInvois System Disruptions

Release of Updated Guidelines: The Inland Revenue Board of Malaysia (IRBM) published e-Invoice Guideline Version 4.3 on March 18, 2025, which includes new provisions addressing system disruptions of the MyInvois System.
Guidance on System Disruptions: Subsection 2.5.4 outlines the IRBM’s acknowledgment that disruptions, failures, or service outages of the MyInvois System can hinder taxpayers’ ability to timely transmit e-Invoices for validation.
Case-by-Case Evaluation: In instances where the MyInvois System is down due to maintenance or technical issues, taxpayers can present evidence of their compliance efforts. The Director General of Inland Revenue will assess these cases individually, potentially absolving taxpayers from compliance penalties during the disruption if justifications are deemed valid.

Philippines Mandates Cross-border E-Invoicing for Imports

The Philippines has issued Joint Administrative Order (JAO) 001-2025, mandating exporters to provide cross-border electronic invoices as part of new customs procedures introduced by the Committee on Pre-border Technical Verification and Cross-border Electronic Invoicing.
The Cross-border E-Invoicing System (CEI) will require real-time submission of digitally signed e-invoices for all goods imported by air or sea, with penalties for non-compliance.
Key deadlines for implementation include registration within 30 days of the Customs Order, mandatory use of CEI for specific cargo within 60 days, and compliance for all other imports within 90 days of the Order’s issuance.

Singapore: Adopting the GST InvoiceNow Requirement: A Guide for Businesses in Singapore

Introduction of InvoiceNow Requirement: The Inland Revenue Authority of Singapore (IRAS) has released an e-Tax Guide detailing the GST InvoiceNow Requirement for GST-registered businesses, which mandates the digital submission of invoice data through the nationwide InvoiceNow framework based on the Peppol standard, aimed at reducing errors and ensuring compliance with tax submission requirements.
Implementation Timeline: The adoption will be phased: a soft launch for early adopters begins on May 1, 2025; newly incorporated companies must comply by November 1, 2025; all new voluntary GST registrants must adhere by April 1, 2026, with plans for future expansion to all GST-registered businesses.
Data Submission Requirements: GST-registered businesses must submit various types of invoice data that align with GST return reporting, including standard-rated and zero-rated supplies, while following strict deadlines for submission and handling of credit notes, with validation checks in place to prevent errors.

Philippines: Understanding the New e-Invoicing Regulation: Key Changes and Compliance Guide

Mandatory Compliance for Specific Taxpayers: The new Revenue Regulations by the Philippines Bureau of Internal Revenue require mandatory electronic invoicing and sales reporting for companies engaged in e-commerce, large taxpayers, and entities within the Large Taxpayer Service, with a compliance deadline set for March 2026.
Implementation of Electronic Sales Reporting System (ESRS): Taxpayers must electronically transmit sales data in structured formats (e.g., JSON or XML) to the BIR, avoiding traditional formats like PDFs, to facilitate efficient data analysis.
Incentives and Penalties: Businesses adopting the new systems can receive tax deductions (100% for micro and small taxpayers, 50% for medium and large taxpayers), while non-compliance may result in penalties under the Tax Code. A transitional period is provided for initial compliance groups to adapt to these changes.

EUROPE

European Union: ViDA – Council Directive with changes to the VAT Directive 2006/112/EC published

Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age published in the Official Journal of the EU.
The Council Directive (EU) 2025/516 amends Directive 2006/112/EC to modernize VAT rules in response to the digital economy, aiming to improve tax collection on cross-border transactions and reduce the administrative burden for businesses by implementing unified digital reporting requirements.
The directive establishes a deemed-supplier model for platforms facilitating short-term accommodation and passenger transport services, requiring them to charge VAT in situations where underlying suppliers do not, while also ensuring the definition of “electronic invoice” aligns with European standards for better interoperability.
To enhance compliance and combat VAT fraud, the directive eliminates the need for recapitulative statements for intra-Community transactions, mandates timely reporting of invoice data, and introduces a phased-out end date for existing call-off stock arrangements, promoting a streamlined VAT system across the EU.

France’s E-Invoicing Mandate Delayed Again: New Deadlines and Business Implications

Delays in E-Invoicing Mandate: France’s e-invoicing mandate has been postponed again, with new deadlines set for businesses to comply—large and mid-sized enterprises by September 2027 and small businesses by September 2028—providing additional time for preparation.
Changes in Implementation Framework: The French government has altered the Public Portal framework, now indicating that it will not serve as a free platform for e-invoicing, necessitating businesses to explore alternative solutions for invoice management.
Continued Business Preparation Needed: While the delays offer temporary relief, businesses should continue to prepare for the eventual transition to e-invoicing and remain attentive to further developments, with the next key legislative vote scheduled for April 24, 2025.

Denmark – The final release of OIOUBL 3 is postponed to October 2025

Delay in OIOUBL 3 Release: The final release of OIOUBL 3, originally scheduled for April 10, 2025, has been postponed to October 2025, as announced by the Danish Business Authority.
Reason for Postponement: The delay is attributed to several inquiries directed to the Danish Business Authority that require additional analysis before finalizing the new version of the Danish e-invoicing format.
Future Announcements: The Danish Business Authority has indicated that further updates regarding the results of the analysis will be provided at a later date.

Belgium: No obligation to receive structured electronic invoices for non-resident VAT taxpayers

The obligation for structured electronic invoicing primarily applies to transactions between Belgian VAT-registered suppliers and VAT-registered customers in Belgium, regardless of the customer’s location.
Exceptions include bankrupt VAT-registered taxpayers, businesses conducting only exempt transactions, VAT-registered taxpayers without a permanent establishment in Belgium, and flat-rate VAT taxpayers phasing out by January 1, 2028.
There is no obligation to send or receive structured electronic invoices for businesses engaged exclusively in exempt transactions or for VAT-registered taxpayers not established in Belgium without a fixed establishment.

Spain Opens Public Consultation on B2B E-Invoicing Mandate

The Ministry of Economic Affairs and Digital Transformation in Spain has initiated a second public consultation on the upcoming B2B e-invoicing mandate to enhance citizen participation in the regulatory development process.
Feedback from this consultation will inform the creation of a regulatory framework in line with the Law on mandatory B2B e-invoicing, published on September 29, 2022, with proposed modifications addressing definitions, obligations, and compliance formats.
The revised draft decree, open for public consultation until April 7, 2025, aims to align Spain’s B2B e-invoicing system with EU VAT reforms under the VIDA initiative, with the obligation to issue e-invoices set to take effect one year after the approval of the relevant Ministerial Order.

European Union – European Council Adopted the VAT in the Digital Age (ViDA) package on March 11, 2025

Mandatory E-Invoicing and Digital Reporting:
Effective immediately, the Member States do not longer require the approval of the European Commission to introduce an E-Invoicing mandate for domestic entities between established entities in that country.
The ViDA package, adopted on March 11, 2025, mandates Member States to introduce mandatory e-invoicing for B2B transactions of intra-EU transactions under specific conditions, starting from July 1, 2030. This initiative aims to standardize e-invoicing processes across the EU and improve compliance and tax collection
Implementation Timeline: Key dates include:
- January 1, 2027: Updates to the One-Stop Shop (OSS) framework and minor legislative clarifications for users.
- July 1, 2028: Platforms in short-term accommodation and passenger transport must comply with new deemed supplier measures.
- January 1, 2030: Mandatory e-invoicing becomes effective for cross-border B2B transactions, with national systems required to align with EU standards by January 1, 2035.
Phased Approach to Compliance: The implementation of ViDA will occur progressively, with an emphasis on enhancing the Import One-Stop-Shop (IOSS) for better controls, transitioning to the mandatory reverse charge for non-identified suppliers, and ensuring that domestic digital reporting systems are harmonized with EU standards by the end of the rollout in 2035.

Estonia Approves Optional Mandatory E-Invoicing from July 2025

By July 2025, businesses can register for machine-readable e-invoices, marking a voluntary phase for system integration. The mandatory e-invoicing in 2027 is projected to add €16 million annually to state revenue, improve VAT collection, and streamline administrative processes for taxpayers.

Greece – Formal EU Approval for B2B E-Invoicing Mandate Published

Authorization for B2B E-Invoicing: The Council of the European Union has formally adopted Council Implementing Decision 2025/502, allowing Greece to implement a country-wide mandate for B2B e-invoicing for domestic transactions between taxpayers established in Greece, effective from July 1, 2025.
Integration with myDATA Platform: The Decision emphasizes that the implementation of e-invoicing will enable direct transmission of e-invoice data to Greece’s existing myDATA platform, facilitating the issuance of pre-filled tax returns and enhancing compliance and efficiency.
Future Compliance Framework: The Decision is valid until December 31, 2027, after which Greece will no longer need to request extensions for its e-invoicing mandate due to the adoption of the EU VAT in the Digital Age (ViDA) package. The Greek government is expected to publish local legislation to clarify compliance deadlines for businesses following this approval.

Croatia Proposes Mandatory Electronic Invoicing as of Jan 1, 2026 – DRAFT law in English

Mandatory eInvoicing Implementation: Croatia’s proposed law mandates that all companies in the value-added tax (VAT) system must begin issuing electronic invoices (eInvoices) starting January 1, 2026, with a complete transition from paper invoices to eInvoices required by January 1, 2027. Entities outside the VAT system, including local governments and state-funded organizations, will have an additional year to comply.
Enhanced Fiscalization and Tax Monitoring: The law expands the fiscalization framework to cover all invoices related to final consumption (B2C), as well as business (B2B) and government (B2G) transactions. It aims to improve transparency, reduce VAT fraud, and streamline tax compliance by requiring real-time data reporting to the Tax Administration.
Administrative Efficiency and Cost Savings: The transition to mandatory eInvoicing is expected to significantly reduce administrative burdens and costs for businesses, potentially saving over EUR 120 million. The law also promotes a free application for small taxpayers to facilitate the digital transition, leading to a more efficient and environmentally friendly invoicing process.

Latvia – Mandatory B2B E-Invoicing and E-Reporting as of Jan 1, 2026

Mandatory Structured E-Invoicing: As of January 1, 2026, all invoices issued by Latvian companies to one another (excluding budget institutions) must be in a structured electronic format compliant with EU standards, facilitating automatic and electronic processing.
Exceptions and Special Cases: Certain transactions are exempt from the e-invoicing requirement, including those confirmed via specific electronic payment documents or generated by certain government systems, as well as invoices from state security institutions until relevant legislation is enacted.
E-Reporting and Data Submission: The law mandates that structured electronic invoice data be submitted to the State Revenue Service starting January 1, 2026, with procedures defined by the Cabinet of Ministers. Additionally, businesses can convert paper documents to electronic format for archiving, and electronic confirmations can replace traditional signatures for internal documents.

Norway Explores Mandatory E-Invoicing for B2B Transactions

Extension of E-Invoicing Requirements:Norway is considering extending its existing e-invoicing mandate for B2G transactions, established in 2012 using the PEPPOL framework, to include B2B transactions, aiming to enhance tax compliance and reduce fraud.
Evaluation of Regulatory Needs:The Ministry of Finance is conducting a study to assess the regulations necessary for electronic accounting systems to support mandatory e-invoicing, with the Danish bookkeeping model being explored as a potential framework.
Future Developments:While no specific timeline has been established for the implementation of these changes, businesses are encouraged to stay informed as Norway aligns with global trends in digital tax compliance.

Sweden Adopts Peppol for Customs Invoicing in 2025

Transition to Peppol Format: Starting March 1, 2025, Swedish Customs will implement a new customs invoicing system based on the Peppol format, replacing the current XML format to standardize and structure invoice data for better compliance and efficiency.
Requirements for Businesses: All businesses and individuals receiving invoicing data from Swedish Customs must adjust their systems to the new Peppol format, which includes obtaining a Peppol ID and appointing a Peppol operator to ensure they can receive custom invoice data and meet customs payment obligations.
Availability of PDF Invoices: While customs invoices will still be accessible in PDF format through the government’s e-services portal, the content will change to align with the Peppol requirements. Businesses are urged to prepare promptly to comply with the new system, as it impacts VAT reporting timelines to the Swedish Tax Agency.

LATIN AMERCIA

Costa Rica Clarifies Electronic Invoice Rules for Imports

Clarification on Electronic Invoices: Costa Rica’s Tax Authority issued Private Letter Ruling No. MH-DGT-0006-2025 on March 3, 2025, stating that electronic invoices are not required for tangible goods imported from non-resident suppliers if the transaction is supported by the Single Customs Document (DUA) and the supplier’s invoice.
Mandatory E-Invoicing for Intangible Goods: For intangible goods or services purchased from non-residents, the ruling confirms that an electronic invoice is mandatory, aligning with the country’s Electronic Invoicing Regulations.
Extension of E-Invoice Version Deadline: The Ministry of Finance announced an extension of the deadline for implementing amendments to electronic invoices (version 4.4) to September 1, 2025, as detailed in bulletin CP-08-2025 issued on February 11, 2025.

Bolivia revises the digital tax document issuing deadline for taxpayer groups 9, 10, 11 and 12

The Bolivian National Tax Service has postponed the requirement for taxpayer groups 9, 10, 11, and 12 to issue digital tax documents via the assigned online billing modality until October 1, 2025.
This change follows the publication of Resolution No. 102500000008, 102500000009, and 102500000010, which revised the initial deadline from March 1, 2025.
Taxpayers in the affected groups can find more information on the National Tax Service’s dedicated website.

MIDDLE EAST

Saudi Arabia announces 21st wave of Phase 2 e-invoicing integration

On February 28, 2025, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) announced that taxpayers with a taxable turnover exceeding SAR 1.25 million during the years 2022, 2023, or 2024 are included in the 21st wave of Phase 2 e-invoicing integration, requiring compliance between September 1, 2025, and November 30, 2025.
The implementation of e-invoicing in Saudi Arabia began with Phase 1 in December 2021, which mandated e-invoice generation, followed by Phase 2 starting January 2023, which requires integration of taxpayer systems with ZATCA’s e-invoicing platform for real-time invoice transmission.
Affected taxpayers must prepare their IT systems for compliance with the new e-invoicing requirements to avoid penalties, while those not in the current waves should stay informed of future ZATCA announcements regarding their integration timelines.

Saudi Arabia Announces Wave 22 of Phase 2 E-Invoicing for High-Revenue Taxpayers

Announcement of Phase 2 Compliance: The Saudi Arabia Zakat, Tax and Customs Authority (ZATCA) has announced that taxpayers with a taxable turnover exceeding SAR1 million in 2022, 2023, or 2024 must comply with the Phase 2 e-invoicing integration by December 31, 2025.
Integration Timeline: Affected taxpayers will need to integrate their electronic invoicing systems with ZATCA’s platform (Fatoora) between October 1, 2025, and December 31, 2025, with notifications being issued by ZATCA to the relevant businesses.
Background on E-invoicing Phases: E-invoicing was introduced in Saudi Arabia in December 2020, with Phase 1 requiring e-invoices generation and Phase 2 mandating system integration and e-invoice transmission, which is being implemented in multiple waves based on taxable turnover thresholds.

UAE releases service provider accreditation requirements

The UAE Ministry of Finance has established accreditation requirements for service providers as a key element in the development of the upcoming 5-corner model, where accredited providers will validate, exchange, and report invoice data to the tax authority.
Only certified service providers will be permitted to participate in the invoice exchange, making the accreditation process essential for engagement in this system.
The accreditation criteria include successful completion of testing and certification processes, Peppol certification, a minimum two years of operational experience, compliance with UAE insurance requirements, and possession of ISO certifications (ISO/IEC 27001 and ISO 22301).

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