The «Prefilling» headache

The ViDA directive fundamentally alters the definition of electronic invoices in Article 217 of the VAT Directive, shifting from a broad definition of “any electronic format” to a more restrictive requirement for invoices to be issued, transmitted, and received in a structured electronic format (e.g., XML or EDI). This means unstructured formats like PDFs will no longer be legally recognized as electronic invoices, necessitating a transition to compliant formats.
The directive also removes the requirement for recipient acceptance of electronic invoices under Article 232, meaning suppliers can send structured e-invoices without needing prior consent from customers, who are then obligated to receive them in the specified format. This change may disrupt traditional invoice processing practices, as businesses can no longer request paper or simple PDF invoices.
A significant consequence of these changes is the introduction of pre-filling, where invoices reported to tax authorities may not align with a company’s internal bookkeeping if invoices are parked (not booked or approved) in the accounting system. This discrepancy could lead to conflicts during tax reporting, prompting a need for companies to revise their accounts payable processes to ensure timely processing and approval of invoices.

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