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E-Invoicing & E-Reporting developments in the news in week 42 & 43/2025

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Follow the latest updates on E-Invoicing and Real Time Reporting on www.vatupdate.com and the LinkedIn pages on E-Invoicing/Real Time Reporting and ViDA.


HIGHLIGHTS OF WEEKS 42 & 43/2025

Denmark advances e-invoicing strategy and digital bookkeeping requirements

  • Advancement of Document Standards: The Danish Business Authority is finalizing its document standards strategy and has published a Release Candidate of the updated OIOUBL 2.1 e-invoicing format, which includes optional fields for climate data (CO2) to facilitate reporting. The final results of the document standards strategy, initially expected in October 2025, are now anticipated in the first quarter of 2026 due to delays.
  • SAF-T 2.0 and G2B Initiatives: The final version of SAF-T 2.0 is nearing completion and is expected to be published by the end of 2025. Additionally, there is a recommendation for public entities to send e-invoices to businesses, aligning with current B2G e-invoicing requirements, which is under review by the Economic Development Agency.
  • Future Digital Bookkeeping Requirements: In preparation for the upcoming ViDA requirements effective July 2030, the Danish Business Authority is evaluating new mandates for digital bookkeeping systems. Proposed measures aim for 70% e-invoicing adoption by 2027, registration in the Nemhandelregister (NHR), and API integration to automate e-invoice recipient identification, with a goal to enhance digitalization and data quality across businesses.

Germany Issues Second Guidance on B2B E-Invoicing: Key Clarifications for Compliance and Operations

  • Mandatory e-Invoicing Implementation: Germany’s Ministry of Finance has clarified that domestic B2B e-invoicing is mandatory from January 1, 2025, with the new guidance applicable to supplies after December 31, 2024, and transitional arrangements in place until December 31, 2027. Businesses must ensure readiness to issue and receive structured e-invoices while complying with detailed operational requirements.
  • Error Classification and Validation: The guidance outlines three categories of errors—formatting, business rule, and content errors—each with specific implications for compliance. Proper validation processes are essential, and businesses must implement thorough checks to ensure all mandatory data is correctly included in the structured e-invoice format.
  • Retention and Compliance Obligations: Taxable entities must retain copies of all incoming and outgoing invoices for eight years, ensuring that the structured data remains intact and accessible. The guidance emphasizes the importance of due diligence in invoice validation and outlines the responsibilities of both issuers and recipients regarding e-invoice accuracy and completeness.

Philippines Extends E-Invoicing Compliance Deadline to December 31, 2026 for Large Taxpayers

  • The Bureau of Internal Revenue (BIR) has extended the deadline for taxpayers to comply with the e-invoicing obligation from March 14, 2026, to December 31, 2026, as per Revenue Regulations No. 026-2025.
  • Taxpayers required to issue electronic invoices include those engaged in e-commerce, large taxpayers, and those using computerized accounting systems, who must provide invoices in formats such as XML or JSON from BIR-accredited invoicing systems.
  • The regulations also highlight that the obligation for sales data reporting is contingent upon the establishment of a BIR system capable of effectively storing and processing the necessary data.

Portugal Delays QES and SAF-T: 2026 Budget Impact on E-Invoicing and VAT Compliance

  • The 2026 State Budget proposes to delay the Qualified Electronic Signature (QES) requirement for PDF e-invoices to January 1, 2027, and the mandatory SAF-T (PT) Accounting submission to 2028.
  • PDF e-invoices remain legally equivalent to paper invoices through December 31, 2026; from 2027, a QES will be mandatory on all PDF e-invoices.
  • Non-resident VAT-registered businesses must use certified invoicing software with ATCUD, include a QR code on invoices, and submit monthly SAF-T (PT) Billing files.
  • The proposed changes are pending parliamentary approval, with a final vote scheduled for November 27, 2025.

Madagascar Moves to Implement Comprehensive E-Invoicing Mandate

  • Centralized E-Invoicing Platform: Following the adoption of the 2024 Amended Finance Law, Madagascar is establishing a national centralized electronic invoicing platform aimed at combating VAT fraud and modernizing the economy.
  • Universal Mandate: Madagascar’s e-invoicing requirement will be comprehensive from the outset, applying to all taxpayers across all sectors and covering all economic transactions, including B2B, B2C, and B2G.
  • Implementation Timeline: Although final technical specifications have not yet been released by the General Tax Administration (DGI), the mandatory e-invoicing system is anticipated to be implemented starting in 2025.

New Zealand mandates B2G e-invoicing for large suppliers from 2027

  • Introduction of E-Invoicing Requirement: Effective from January 1, 2027, New Zealand Government agencies will require large suppliers—those with total revenue exceeding NZ$33 million in the past two accounting periods—to send e-invoices as part of the updated Government Procurement Rules.
  • Supplier Preparation and Compliance: While sending e-invoices is not legally mandated, suppliers who cannot comply may face difficulties in securing contracts with Government agencies. Businesses are encouraged to prepare for e-invoicing readiness well before the deadline, as agencies will assess supplier capabilities in advance.
  • Implementation Timeline and Payment Terms: Government agencies will identify large suppliers prior to the January 2027 deadline and will start requiring e-invoices in procurement processes. Additionally, from January 1, 2026, agencies must pay 95% of all domestic trade e-invoices within five business days and standard invoices within ten business days, further emphasizing the shift towards digital invoicing.

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