6 Implementing Acts
- DRR Implementing Act (Art. 263(4) VAT Directive)
Defines the digital reporting framework for intra-EU B2B transactions, including data fields, timelines, and transmission standards forming the basis of real-time reporting from 1 July 2030. - Central VIES – System Design Implementing Act
Establishes the technical architecture and functionality of the new central VIES platform, replacing EC Sales Lists and enabling real-time transaction validation and exchange across Member States. - Central VIES – Access & Governance Implementing Act
Regulates access rights, data sharing, and governance, including how tax authorities (and potentially businesses) interact with VIES data for control and audit purposes. - OSS/IOSS Security Implementing Act
Introduces security, integrity, and system control requirements for the expanded OSS/IOSS frameworks, supporting the shift to single VAT registration from 2027–2028. - Amendment to Implementing Regulation (EU) 2020/194 – Effective 1 January 2027
Updates OSS/IOSS operational rules to reflect early ViDA changes, including scope extensions and alignment with revised reporting obligations. - Amendment to Implementing Regulation (EU) 2020/194 – Effective 1 July 2028
Further adjusts OSS/IOSS rules for full single VAT registration rollout and platform economy interaction, ensuring consistency with broader ViDA reforms.
(Note: A potential seventh implementing act may follow to ensure harmonised application of the rules entering into force on 1 July 2030.)
Source
Source ec.europa.eu
Article
- Background: ViDA and the Need for Secondary Legislation
The VAT in the Digital Age (ViDA) package represents a fundamental overhaul of the EU VAT system, structured around three pillars:
- Digital Reporting Requirements (DRR) and e-invoicing
- Platform economy rules
- Single VAT registration (OSS/IOSS expansion) [ey.com], [research.ibfd.org]
While the primary legal framework is set out in Directive (EU) 2025/516, Regulation (EU) 2025/517, and Implementing Regulation (EU) 2025/518, the practical operation of ViDA depends heavily on implementing acts. [taxation-c….europa.eu]
These acts are critical to ensure technical harmonisation, IT interoperability, and audit-ready compliance frameworks across Member States—particularly for real-time reporting and system-to-system communication.
- DRR: Implementing Act under Article 263(4) VAT Directive
A central pillar of the implementation strategy is the adoption of an implementing act under Article 263(4) of the VAT Directive, which will govern Digital Reporting Requirements (DRR).
This act is expected to define:
- The data elements to be reported (transaction-level invoice data)
- Timing requirements (near real-time submission aligned with e-invoice issuance)
- Transmission protocols and formats
- Interaction between supplier and customer reporting obligations
DRR will replace the current EC Sales Listing system and requires businesses to report intra-EU B2B transactions and reverse-charge transactions on a transactional basis. [ey.com]
From 1 July 2030, DRR becomes mandatory, forming the backbone of EU VAT digital enforcement. [edicomgroup.com]
- Central VIES: Two Implementing Acts for Design and Access
The ViDA framework introduces a central VIES platform, transforming it from a verification tool into a real-time data exchange infrastructure.
Two implementing acts are foreseen to regulate:
3.1 System Design and Architecture
- Centralised or federated data flow model
- Integration with national systems
- Role in replacing EC Sales Lists
3.2 Access and Data Governance
- Access rights for tax authorities
- Potential access for businesses
- Data protection, storage, and audit trails
The new VIES will enable real-time or near-real-time reporting and validation of intra-EU transactions, strengthening fraud detection and enabling cross-border controls. [vat-consult.be]
- OSS/IOSS: Implementing Act on System Security
With ViDA significantly expanding the One-Stop Shop (OSS) and Import OSS (IOSS) regimes, a dedicated implementing act will address system security and integrity.
This is particularly relevant given:
- The expansion of OSS to additional transactions and business models from 2027–2028 [edicomgroup.com]
- Increased reliance on OSS for single VAT registration across the EU
- The need to safeguard sensitive transactional and financial data
The act will likely cover:
- Authentication and access controls
- Data integrity and cybersecurity requirements
- Cross-border administrative cooperation
- Amendments to Implementing Regulation (EU) 2020/194
Two implementing acts will amend Implementing Regulation (EU) 2020/194, which sets out operational rules for OSS/IOSS.
5.1 First Amendment – Effective 1 January 2027
Expected to address:
- Early OSS extensions (e.g. energy supplies)
- Clarifications on reporting and registration flows
- Alignment with new compliance obligations
5.2 Second Amendment – Effective 1 July 2028
Aligned with:
- Full expansion of OSS schemes
- Introduction of broader single VAT registration
- Interaction with platform economy rules and mandatory reverse charge
These changes reflect the gradual expansion of OSS as the core compliance mechanism in the EU VAT system.
- Additional Implementing Act for 2030 Harmonisation
The implementation strategy anticipates a potential additional implementing act to ensure consistent application of rules entering into force on 1 July 2030, notably:
- DRR and mandatory e-invoicing
- Central VIES integration
- Harmonised reporting standards across Member States
This reflects the risk of:
- Divergent national implementations
- Fragmentation of IT systems
- Inconsistent interpretations affecting cross-border trade
- Key Takeaways for Businesses
From a practical and governance perspective, the implementing acts will:
- Define the operational reality of ViDA, beyond high-level legislative principles
- Drive ERP, invoicing and reporting system redesign
- Require alignment with EU-wide data standards and real-time reporting models
- Increase the importance of centralised VAT governance and digital controls
Most importantly, the staggered timeline (2027 → 2028 → 2030) requires businesses to adopt a phased implementation strategy, ensuring readiness for each milestone.
Latest Posts in "European Union"
- Comments on ECJ C-603/24 (Stellantis Portugal) – Transfer pricing and VAT: Court confirms in Stellantis that not every true-up constitutes a service
- Agenda of the ECJ/General Court VAT cases – 3 Judgments till June 25, 2026
- EGC VAT Case T-231/26 (Agenzia delle Entrate Direzione Provinciale Genoval) – Questions – VAT deductibility of general expenses for auctioneers under margin scheme
- EGC VAT Case T-232/26 (Appellant_1 Srl ) – Questions – VAT deductibility of general expenses for auctioneers under margin scheme
- CJEU Rules on VAT Treatment of Transfer Pricing Adjustments in Stellantis Portugal Case













