Pre-Filled VAT Returns in Europe: Landscape, legal effect, operational maturity and ViDA implications

Executive summary

Pre-filled VAT returns are no longer a single model. Europe now includes authority-generated draft returns, partial pre-population, pre-filled ledgers, and comparison statements that sit alongside the taxpayer-filed return. Spain, Greece, Italy, Portugal, Romania and Albania illustrate materially different legal and operational designs.
The most mature services remain assistance tools rather than substitutes for tax governance. Spain’s Pre303 supports Form 303 preparation; Greece uses myDATA to pre-fill editable amounts; Italy provides precompiled VAT documents for selected taxpayers; Portugal offers an eligibility-limited provisional return; and Romania sends an authority reconstruction that is not itself a tax claim title.
The highest multinational risk is false reliance. Authority data can aggregate invoices, receipts and customs messages, but normally cannot determine partial exemption, business use, fixed-establishment outcomes, capital-goods adjustments, bad-debt relief, chain-transaction analysis or all period-end journals. “Reported” therefore does not mean “legally correct.”
The next strategic wave is broader use of e-invoicing and transaction data. Poland proposes a phased e-VAT service from Q4 2029, Serbia is reported to target 2027, and Portugal is redesigning return fields from July 2027. These dates must be monitored against binding local acts.
ViDA does not itself create EU-wide pre-filled VAT returns. It creates a harmonised data foundation for intra-EU transactions from 1 July 2030 and requires domestic digital reporting systems to converge by 1 January 2035. Taxpayer responsibility and substantive deduction analysis remain central.

Key conclusions and recommendations

Treat the authority draft as a control input
- Do not replace the company-calculated return with an authority draft without line-by-line reconciliation and documented approval.
Build a three-way reconciliation
- Reconcile ERP/subledger results, digital-reporting submissions and the authority-prepared view. Add customs and manual-adjustment reconciliations where relevant.
Protect the purchase side
- Do not let absence from a draft automatically determine deduction. Investigate supplier reporting, timing, invoice validity, business use and local recovery conditions.
Design globally, execute locally
- Use a common control framework and data model, but preserve country-specific approval, amendment, portal access and evidence requirements.
Prepare for ViDA without assuming pre-filling
- Adopt structured invoice data, durable transaction identifiers and correction links that can support both DRR and future authority-generated returns.

ViDA and pre-filled VAT returns

The ViDA package was adopted on 11 March 2025 and entered into force on 14 April 2025. Intra-EU digital reporting requirements apply from 1 July 2030. Member States with domestic digital real-time transaction reporting must align those systems with the EU framework by 1 January 2035. These rules increase the quantity and standardisation of authority-held data, but they do not establish a common EU pre-filled return or transfer filing responsibility to tax authorities.

DRR data can support pre-population of intra-EU supplies, acquisitions, cross-border services, counterparty VAT numbers and corrections. It normally cannot settle deductibility, private use, partial exemption, capital-goods adjustments, import VAT, bad-debt relief, cash accounting or establishment questions without additional data and legal analysis.

Detailed country profiles

Albania

Model: Fiscalisation-based pre-filled VAT return
Classification and status: Partially pre-filled VAT return | Live
Key date: Operational through fiscalisation; sources indicate current model since 2022
Scope: Taxpayers within Albanian fiscalisation/VAT reporting
Data and technology: Fiscalisation/e-invoice data; Central fiscalisation platform
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Supplier-reported invoice data may drive purchase-side visibility; taxpayer review remains necessary
Assessment: Albania uses fiscalisation data to populate VAT return information. The taxpayer must reconcile authority data to accounting records and correct missing or misclassified items.
Next milestone: Monitor scope and data-quality improvements
VATupdate articles: Albania Introduces Pre-Filled VAT Returns for Streamlined Reporting Starting April 2025; Albania introduces system generated VAT returns and lowers cash transaction limits

Croatia

Model: Fiscalisation 2.0 pre-filled VAT return
Classification and status: Draft / partially pre-filled VAT return | Live / phased
Key date: Fiscalisation 2.0 from 1 January 2026
Scope: Domestic taxpayers within new e-invoicing/fiscalisation scope
Data and technology: Fiscalisation 2.0 e-invoices and fiscal data; Central platform/service providers
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Invoice reporting supports matching; legal deduction requires taxpayer validation
Assessment: Croatia’s Fiscalisation 2.0 architecture is designed to support authority-prepared returns. Because implementation is recent, practical completeness and treatment of adjustments require continued monitoring.
Next milestone: Stabilisation and scope refinement during 2026-2027
VATupdate articles: Briefing Document & Podcast: E-Invoicing & E-Reporting in Croatia; Croatia E-invoicing & Digital Reporting Guide

France

Model: Import VAT pre-population; broader pre-filled return potential
Classification and status: Partial pre-population only | Live for import VAT; broader model not confirmed
Key date: Import VAT auto-liquidation/pre-population since 2022
Scope: French VAT returns with import VAT; broader e-invoicing data use future-facing
Data and technology: Customs import data; future domestic e-invoice/e-reporting data; VAT portal; future accredited platforms/data hub
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Import VAT figures must be checked against customs records
Assessment: France pre-populates import VAT information but does not currently provide a universal authority-prepared business VAT return. The e-invoicing/e-reporting programme creates a future data foundation, but this should not be described as a live full pre-filled return.
Next milestone: Assess post-2026 e-invoicing data use; no universal pre-filled return confirmed
VATupdate articles: Import VAT: how to check that the amount pre-filled on your VAT return is correct?; Import VAT pre-filled on VAT returns as of January 1, 2022 – what if the number is incorrect?

Greece

Model: myDATA pre-filled VAT return
Classification and status: Draft / partially pre-filled VAT return | Live
Key date: 5 December 2022 for periods from 1 January 2022
Scope: Greek taxpayers using myDATA
Data and technology: myDATA income, expense and classification data; myDATA APIs and portal
Taxpayer interaction: Approval: Yes; taxpayer may amend and submits. Deemed acceptance: No
Input VAT: MyDATA classification and matching influence pre-fill, but taxpayer remains responsible
Assessment: AADE uses myDATA information to pre-fill VAT return amounts. Amounts remain editable, and the taxpayer remains responsible for correct and accurate filing.
Next milestone: Greater alignment with mandatory e-invoicing and myDATA controls
VATupdate articles: Greece: MyDATA prefills the VAT Returns; Greece to Cut VAT Gap with MyDATA E-Invoicing, Pre-Filled VAT Returns

Hungary

Model: eVAT / eÁFA
Classification and status: Draft VAT return and machine-to-machine validation service | Live; mandatory use announced for 2027 in current secondary reporting
Key date: Voluntary service from 2024; 2027 mandatory milestone should be verified in final legislation
Scope: Hungarian VAT taxpayers; functionality and mandatory scope may vary
Data and technology: Online Invoice, online cash register and customs/authority data; Web and M2M services
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Taxpayer must validate purchase entitlement and add adjustments
Assessment: Hungary’s eVAT service uses transaction data held by NAV to support return preparation and validation. It should be treated as a draft and reconciliation environment, not proof of the underlying VAT treatment.
Next milestone: Verify 2027 mandatory scope and transition rules
VATupdate articles: Hungary eVAT digital ledgers & pre-filled returns Jan 2024; Hungary Makes eVAT Mandatory from 2027; Hungary Launches eÁFA Tool to Support Digital VAT Return Preparation

Italy

Model: Precompiled VAT documents
Classification and status: Draft VAT ledgers / periodic settlements / annual return for eligible taxpayers | Live / extended trial
Key date: Introduced progressively from 2021; eligibility trial extended to start of 2027
Scope: Selected resident/established taxpayers; limited eligibility, including transaction-count conditions
Data and technology: SdI e-invoices, cross-border data and telematic receipts; Revenue Agency portal/downloads
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Based on SdI and other data; taxpayer must verify deductibility and adjustments
Assessment: Italy provides precompiled VAT registers and draft VAT documents for eligible taxpayers. The service is not a universal replacement for the annual VAT return and remains dependent on coverage and taxpayer review.
Next milestone: Trial/eligibility extension through early 2027
VATupdate articles: Pre-filled VAT Return Pilot Extended to 2026: Online Assistance Program Continues; Italy Extends Pre-Filled VAT Returns for Small Taxpayers Using SdI E-Invoicing Data

Poland

Model: e-VAT pre-filled JPK_VAT/JPK_V7
Classification and status: Announced draft return | Planned / draft initiative
Key date: Phased from Q4 2029 proposed; initially up to 5% of taxpayers
Scope: Opt-in selected taxpayers initially; projected expansion through 2035
Data and technology: KSeF, fiscal receipts and connected KAS datasets; Planned e-Tax Office service
Taxpayer interaction: Approval: Active approval envisaged. Deemed acceptance: No
Input VAT: Taxpayer remains responsible; KSeF presence alone does not establish deductibility
Assessment: Poland’s e-VAT is a proposal, not a live service. Current materials envisage an opt-in draft JPK_V7 prepared by KAS from Q4 2029, with active taxpayer approval and no automatic filing.
Next milestone: Council of Ministers/adoption and detailed design
VATupdate articles: Poland Plans Pre-Filled VAT Declarations, But Taxpayer Responsibility Remains; Poland plans pre-filled VAT returns, but taxpayer review will remain essential

Portugal

Model: Declaração periódica provisória / Automatic VAT Return
Classification and status: Draft VAT return requiring approval | Live for eligible taxpayers
Key date: 1 July 2025
Scope: Eligible Portuguese-resident taxpayers; exclusions include cash accounting and periods with imports/exports, reverse charge or special schemes
Data and technology: e-Fatura invoice data and authority records; Portal/integrated tools
Taxpayer interaction: Approval: Yes, except qualifying nil provisional return can be deemed submitted. Deemed acceptance: Limited: nil return may be automatically submitted if no alternative filed
Input VAT: Purchase invoices must be correctly classified; manually entered invoices not reported by issuer may be excluded
Assessment: Portugal generates a provisional periodic return for a restricted resident population. The design is notable for limited deemed submission of a nil return, but complex periods are excluded and taxpayers must classify purchase documents.
Next milestone: Redesigned return fields mainly from periods starting 1 July 2027
VATupdate articles: Portugal Rolls Out Automated VAT Return System for Domestic Taxpayers; Portugal Overhauls the Periodic VAT Return: New Fields for VAT Groups, Pre-Filled Data

Romania

Model: RO e-TVA pre-filled statement
Classification and status: Pre-filled comparison statement | Live
Key date: 1 August 2024 for transactions from 1 July 2024
Scope: VAT-registered persons under Article 316
Data and technology: RO e-Factura, e-Transport, e-Seal, SAF-T, e-cash registers, customs and informative returns; Portal plus published JSON/API specifications
Taxpayer interaction: Approval: Separate D300 remains taxpayer-filed. Deemed acceptance: No; pre-filled statement is not a tax claim title
Input VAT: Mismatch may trigger compliance notice; substantive entitlement remains taxpayer responsibility
Assessment: ANAF sends a pre-filled comparison statement after the filing deadline. It does not replace D300 and is not a tax assessment. Material differences can trigger a compliance notice, so it operates mainly as an authority-side reconciliation control.
Next milestone: Ongoing technical refinement and possible deeper SAF-T integration
VATupdate articles: RO e-TVA Precompleted Declaration Brochure for Taxable Persons Registered for VAT Purposes; eVAT Pre-Filled VAT returns – Text of Emergency Ordinances, notices & ANAF orders; ANAF Updates Annex to RO e-TVA Pre-Completed VAT Return Form

Serbia

Model: SEF-based pre-filled VAT return
Classification and status: Announced / under development | Planned
Key date: 2027 indicated in current published overviews; verify legal act
Scope: Expected Serbian VAT taxpayers using SEF
Data and technology: SEF e-invoices and fiscal data; SEF
Taxpayer interaction: Approval: Expected taxpayer review. Deemed acceptance: To be confirmed
Input VAT: Likely linked operationally to SEF data; legal details pending
Assessment: Serbia is reported to be developing a pre-filled VAT return based on SEF data for 2027. Treat timing and legal effect as planned until confirmed in binding Serbian legislation and specifications.
Next milestone: Official legislation and technical specifications
VATupdate articles: Serbia Updates E-Invoicing Rules and Introduces Preliminary VAT Return Framework; Serbia Postpones Preliminary VAT Return Requirement to January 2027

Slovenia

Model: Pre-filled VAT return
Classification and status: Draft / partially pre-filled VAT return | Live
Key date: July 2025
Scope: VAT taxpayers covered by the authority service
Data and technology: Electronic reporting and authority-held transaction data; Authority portal
Taxpayer interaction: Approval: Yes. Deemed acceptance: No
Input VAT: Taxpayer remains responsible for deduction eligibility
Assessment: Sources report that Slovenia introduced pre-filled VAT returns from July 2025. The draft should be independently reconciled because tax authority data cannot determine all adjustments or deduction limitations.
Next milestone: Monitor operational guidance and expansion
VATupdate articles: Slovenia: Mandatory VAT Reporting & Pre-filled VAT Returns from July 2025; VAT Records: FAQs for Businesses in Slovenia

Spain

Model: Pre303 assistance service
Classification and status: Partially pre-filled / draft return | Live
Key date: Expanded service live; 2026 service available
Scope: All taxpayers receive assistance; depth varies by profile, especially SII
Data and technology: SII ledgers, imported electronic books, customs/import information and authority records; Web service; SII and book import functions
Taxpayer interaction: Approval: Yes, taxpayer files Form 303. Deemed acceptance: No
Input VAT: Informational; taxpayer retains deduction responsibility
Assessment: AEAT describes Pre303 as an assistance service for Form 303 available to all taxpayers according to their activity profile. It is a filing aid, not an automatic assessment. The taxpayer reviews and submits the return.
Next milestone: Continue expansion of Pre303 functions
VATupdate articles: Spanish VAT returns, modelo 303, prepopulated with invoices already reported through the SII platform; A new tool is available to complete Spanish VAT returns – Pre303

Multinational control framework

Coverage gaps
- Authority data may exclude imports, reverse charge, manual journals or special schemes. Recommended control: Reconcile ERP, subledgers, customs and authority downloads by box.
Input VAT
- Reported invoice does not prove business use or deductibility. Recommended control: Validate legal entitlement, matching, partial exemption and document quality.
Timing
- Tax point, invoice date and reporting timestamp may differ. Recommended control: Maintain period cut-off and late-invoice controls.
Adjustments
- Bad debt, pro rata and capital goods items rarely derive from invoices. Recommended control: Maintain controlled manual adjustment register with evidence.
Foreign registrations
- Resident-only services may exclude non-established registrations. Recommended control: Map eligibility by VAT registration and establishment status.
Deemed acceptance
- Silence may create filing effect in limited models. Recommended control: Calendar, ownership and escalation controls for portal drafts.
API maturity
- Portal-only services increase manual effort. Recommended control: Assess download/API capabilities and retain versioned source files.
Minimum control set: authority-download retention; ERP-to-authority and GL-to-return reconciliation; invoice matching; customs reconciliation; controlled manual adjustments; review evidence; access governance; deadline escalation; and root-cause tracking for recurring mismatches.

Methodology and limitations

The review prioritised official tax authority and EU sources. Where an accessible official source was not identified, the conclusion is labelled as secondary-source based, planned or unverified. Only jurisdictions with an identified live, adopted, pilot, announced or partially pre-filled VAT return model are included. Local-language legal confirmation is required before implementation decisions.

VATupdate further reading

The following articles provide cross-country context and practical control considerations: