Briefing Document: SAF-T Implementation Across Europe

Sources from RTCsuite

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This briefing document provides a review of the main themes and important facts regarding the implementation of the Standard Audit File for Tax (SAF-T) across various European countries, based on the provided sources. SAF-T is a standardised electronic format for exchanging tax and accounting data between businesses and tax authorities, aiming to enhance transparency, simplify audits, and improve compliance.

Overall Theme: The sources highlight a clear trend towards the mandatory adoption of SAF-T or similar digital bookkeeping/reporting requirements across Europe. While some countries have implemented it on a phased or on-demand basis, the general direction is towards comprehensive digital tax compliance.

Key Themes and Important Ideas:

1. Varying Approaches to SAF-T Implementation:

Mandatory vs. Voluntary: While many countries are making SAF-T mandatory, Belgium stands out with a purely voluntary adoption approach.
“Belgium’s implementation of the Standard Audit File for Tax (SAF-T) is on a purely voluntary basis, distinguishing it from other European countries that have set mandatory requirements.” – Belgium’s Voluntary SAF-T Adoption: Everything You Need to Know
In contrast, Lithuania and Poland have made SAF-T mandatory for all VAT-registered businesses. “Yes, SAF-T reporting is mandatory for all businesses that are registered for VAT in Lithuania.” – SAF-T in Lithuania: Declaration, Requirements & Deadlines and “Yes. SAF-T is mandatory for all VAT-registered businesses in Poland…” – SAF-T in Poland: Declaration, Requirements & Deadlines
Phased Rollouts: Several countries are implementing SAF-T or digital bookkeeping requirements in phases, often based on company size or turnover.
Bulgaria has a detailed phased rollout from 2026 to 2030, starting with large businesses and eventually including micro businesses. “Bulgaria’s approach to implementing SAF-T is methodical, with a phased rollout designed to accommodate businesses of different scales…” – Bulgaria Mandates SAF-T Reporting from 2026: A Complete Guide for Businesses
Denmark is implementing digital bookkeeping in phases from 2023 to 2026, based on company type and turnover. “Denmark is implementing digital bookkeeping in several phases:” – Denmark SAF-T & Digital Bookkeeping Guide
Romania introduced SAF-T in phases starting in 2022 for large taxpayers, extending to small taxpayers and non-residents by 2025. “Standart Audit File tax in Romania was introduced in phases…” – SAF-T in Romania: Declaration, Requirements & Deadlines
Ukraine’s SAF-T UA, initially optional in 2023, becomes mandatory for annual reporting for large taxpayers in 2025 and all taxpayers by 2027. “Initially introduced as an optional measure in 2023, it will become mandatory for annual reporting for large taxpayers starting January 1, 2025, and will extend to all taxpayers by 2027.” – SAF-T in Ukraine: Declaration, Requirements & Deadlines – RTC Suite

2. On-Demand vs. Periodic Submission:

Some countries require SAF-T submissions only upon request by tax authorities (on-demand). Austria, Denmark, and Lithuania follow this approach.
“Instead, SAF-T Austria data is provided upon request by the Austrian Federal Ministry of Finance (BMF), typically in preparation for a tax audit.” – SAF-T in Austria: Declaration, Requirements & Deadlines
“Importantly, Denmark employs a demand-based approach, meaning that companies are only required to submit SAF-T files upon explicit request from the tax authorities.” – Denmark SAF-T & Digital Bookkeeping Guide
“Instead, businesses must be prepared to submit their SAF-T records upon request from tax authorities.” – SAF-T in Lithuania: Declaration, Requirements & Deadlines
Other countries mandate periodic submissions, often monthly or annually. Bulgaria, Poland, and Portugal have periodic reporting requirements.
Bulgaria requires monthly reporting for certain data from 2026 and annual reporting for fixed assets from 2027. “Monthly Reporting (Starting 01.01.2026): Required by the 14th of each month following the reporting period.” and “Annual Reporting (Starting 01.01.2027): Covers fixed asset data…” – Bulgaria Introduces SAF-T: New E-Invoicing and Reporting Mandate for Tax Compliance
Poland requires monthly or quarterly JPK_VAT submissions by the 25th of the following month, with other JPK files on demand. “JPK_VAT (JPK_V7M/JPK_V7K): Submitted by the 25th of the following month after the reporting period.” – SAF-T in Poland: Declaration, Requirements & Deadlines
Portugal requires monthly SAF-T submission for invoicing data by the 5th day of the following month and annual submission for accounting records by the corporate tax filing deadline. “Monthly SAF-T submission for invoicing data – Due by the 5th day of the following month.” and “Annual SAF-T for accounting records – Must be submitted before the deadline for corporate tax filings.” – SAF-T in Portugal: Declaration, Requirements & Deadelines
Romania requires monthly or quarterly SAF-T submission by the last calendar day of the following month, based on VAT reporting frequency. “Monthly or Quarterly SAF-T submission – Due by the last calendar day of the following month…” – SAF-T in Romania: Declaration, Requirements & Deadlines

3. Scope of Data Covered:

SAF-T generally covers a wide range of financial and accounting data, including general ledger entries, master data (customers, suppliers, products), sales and purchase invoices, inventory movements, and fixed assets.
Belgium’s initial voluntary phase focuses on Header, Masterfiles, and GeneralLedger. “For the initial voluntary phase, the Ministry of Finance focuses on the Header, Masterfiles, and GeneralLedger.” – Belgium’s Voluntary SAF-T Adoption: Everything You Need to Know
Austria’s SAF-T includes Enterprise Master Data (Chart of Accounts, Customer and Supplier Master Data, Product Master Data) and Accounting and Financial Data (General Ledger Entries and Accounting Journals, Inventory Movements, Sales and Purchase Invoices, Fixed Asset Statements). – SAF-T in Austria: Declaration, Requirements & Deadlines
The planned SAF-T Hungary structure is expected to include Master Data, Transactional Data, and Reporting Data. – SAF-T in Hungary: Declaration, Requirements & Deadlines
Lithuania’s i.SAF is used for VAT invoice data, while i.SAF-T covers accounting transaction data. – SAF-T in Lithuania: Declaration, Requirements & Deadlines
Norway has two types: SAF-T Financial Data (Accounting & tax reporting, Chart of accounts, journal entries, invoices) and SAF-T Cash Register (Detailed sales transaction reporting). – SAF-T in Norway: Declaration, Requirements & Deadlines
Poland’s JPK files cover various records, including VAT, general ledger, profit & loss, fixed asset and inventory registers, and income records. – SAF-T in Poland: Declaration, Requirements & Deadlines
Romania’s D406 form includes General Ledger Data, Accounts Receivable and Payable, Fixed Assets, and Inventory Reporting. – SAF-T in Romania: Declaration, Requirements & Deadlines
Ukraine’s SAF-T UA includes General Ledger Entries, Sales and Purchase Ledgers, Cash Receipts and Payments, Fixed and Intangible Assets, and Tax Reconciliation. – SAF-T in Ukraine: Declaration, Requirements & Deadlines – RTC Suite
Customs-related records are explicitly excluded in Belgium’s SAF-T scope. “Customs-related records are explicitly excluded.” – Belgium’s Voluntary SAF-T Adoption: Everything You Need to Know

4. Technical Specifications and Submission Methods:

The standard file format for SAF-T is XML, aligning with the OECD SAF-T version 2 model in countries like Denmark and Norway.
“File Format: XML” – Bulgaria Introduces SAF-T: New E-Invoicing and Reporting Mandate for Tax Compliance
“Denmark’s SAF-T files follow the OECD SAF-T V.2 XML format.” – Denmark SAF-T & Digital Bookkeeping Guide
“All SAF-T Austria files must be formatted in XML according to Austria’s tax authority guidelines.” – SAF-T in Austria: Declaration, Requirements & Deadlines
“The SAF-T file format in Norway is structured in XML.” – SAF-T in Norway: Declaration, Requirements & Deadlines
Submissions are typically made electronically through tax authority portals, often requiring a qualified electronic signature (QES) or utilising authorized APIs for automated submissions.
“Submissions must be made electronically via the National Revenue Agency’s (NRA) digital portal using a qualified electronic signature (QES).” – Bulgaria Introduces SAF-T: New E-Invoicing and Reporting Mandate for Tax Compliance
“Businesses can log into TastSelv Erhverv using: MitID, Personal MitID for businesses, E-tax password (self-key)” and mentioning API integration. – Denmark SAF-T & Digital Bookkeeping Guide
“Submissions are made through official tax reporting portals, supporting both manual file uploads and API-based submissions…” – SAF-T in Norway: Declaration, Requirements & Deadlines

5. Compliance and Penalties:

Maintaining SAF-T compliant financial records is crucial, even in countries with on-demand submission.
“Businesses must ensure their accounting data is readily available and compliant with SAF-T Austria standards to avoid penalties or delays in reporting.” – SAF-T in Austria: Declaration, Requirements & Deadlines
“Companies must maintain accurate and structured financial records to generate SAF-T Denmark files efficiently when required.” – Denmark SAF-T & Digital Bookkeeping Guide
Failure to submit required files or submitting incorrect data can lead to penalties.
“If the initial submission is found to be invalid due to formatting errors, schema non-compliance, or missing QES, it will be rejected. Companies are then given seven days to correct and resubmit the file.” – Bulgaria Introduces SAF-T: New E-Invoicing and Reporting Mandate for Tax Compliance
“Failure to provide SAF-T Denmark data when required can lead to penalties or compliance issues.” – Denmark SAF-T & Digital Bookkeeping Guide
“Failure to submit required files, or submitting incorrect data, can lead to administrative fines and further scrutiny from authorities…” – SAF-T in Poland: Declaration, Requirements & Deadlines
“Failure to meet these deadlines can result in penalties or tax compliance issues…” – SAF-T in Portugal: Declaration, Requirements & Deadelines
“Compliance with SAF-T ensures businesses avoid penalties…” – SAF-T in Lithuania: Declaration, Requirements & Deadlines

6. The OECD SAF-T Standard:

Several countries explicitly mention aligning their SAF-T implementation with the OECD SAF-T standard, indicating a move towards international consistency in tax reporting.
“organizations that proactively align their systems with the OECD-based SAF-T standard may benefit from smoother audits and future compliance.” – Belgium’s Voluntary SAF-T Adoption: Everything You Need to Know
“The Danish Business Authority (Erhvervsstyrelsen) oversees SAF-T, aligning with the OECD SAF-T version 2 model.” – Denmark SAF-T & Digital Bookkeeping Guide
“Denmark’s SAF-T files follow the OECD SAF-T V.2 XML format.” – Denmark SAF-T & Digital Bookkeeping Guide

7. Future Developments:

Some sources mention anticipated changes or expansions of SAF-T requirements in the future.
Hungary expects SAF-T to become mandatory in the near future. “Currently, SAF-T is not mandatory in Hungary. However, it is expected to become a requirement in the near future…” – SAF-T in Hungary: Declaration, Requirements & Deadlines
Denmark anticipates future updates will mandate comprehensive data, including master data and general ledger accounts. – Denmark SAF-T & Digital Bookkeeping Guide
Poland has scheduled additional JPK files to be on a periodic submission basis after 1 December 2025. – SAF-T in Poland: Declaration, Requirements & Deadlines
Portugal’s obligation to submit the SAF-T accounting file has been postponed until 2027 for the tax year 2026. – SAF-T in Portugal: Declaration, Requirements & Deadlines

8. Luxembourg’s FAIA:

Luxembourg’s version of SAF-T is known as the FAIA (Fichier Audit Informatisé de l’Administration de l’Enregistrement et des Domaines). “SAF-T is an electronic format designed to facilitate the structured exchange of accounting and tax data between businesses and tax authorities. In Luxembourg, this standard is implemented as the Fichier Audit Informatisé de l’Administration de l’Enregistrement et des Domaines (FAIA).” – SAF-T in Luxembourg: Declaration, Requirements & Deadlines

In summary, the sources demonstrate a widespread adoption of the SAF-T standard or similar digital reporting initiatives across Europe. While the specific implementation details, such as mandatory versus voluntary adoption and submission frequencies, vary by country, the overarching goal is to enhance tax compliance, streamline audits, and leverage digital technologies for financial reporting. Businesses operating in these countries must stay informed about the specific SAF-T requirements and deadlines applicable to them to ensure compliance and avoid penalties.

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Briefing Document: SAF-T Implementation Across Europe

Key Themes and Important Ideas:

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