Pre-Filled VAT Returns in Europe: Current Landscape and Future Plans

What Data is Included in Pre-Filled VAT Returns?

• Domestic Sales and Purchases (B2B and B2C): Most prefilled systems pull data from electronic invoices and receipts:
  • Italy uses data from the SDI e-invoicing platform (covering B2B and B2G invoices) and from daily fiscal cash registers for retail B2C sales. This means Italy’s draft returns include all sales invoices, all purchase invoices (for input VAT), credit notes, and even a record of any VAT credits or advance payments on file. [vatupdate.com]
  • Spain’s Pre303 leverages the SII system: effectively all sales issued and purchases received that the business has reported within the required timeframe are included, so the draft return reflects the company’s own reported invoices. [vatupdate.com]
  • Greece uses the myDATA platform: the sales and expense data that companies report (or transmit from their accounting software) populate the VAT return fields.
  • Hungary’s eVAT aggregates multiple sources: the online invoice reports (which capture virtually all B2B invoices and large B2C invoices), plus data from online cash registers (retail sales) and other filings, to cover a comprehensive set of transactions. [vatupdate.com], [vatupdate.com]
  • Smaller adopters like Slovenia require a detailed transaction listing which in practice means the return is built from all invoices listed by the taxpayer each period.
• Cross-Border Transactions and Special Cases: Many systems are beginning to include data beyond standard domestic trades:
  • Import VAT is prefilled in some countries. France made a notable move in 2022 by auto-populating the import VAT due on its returns using customs declaration data. Taxpayers no longer need to manually input import VAT paid – it appears on the form ready for deduction or payment. Other fields of the French return will await e-invoice data in 2026. [sovos.com]
  • Hungary includes customs records for imports in its eVAT prefill, so import VAT appears alongside domestic VAT. [vatupdate.com]
  • Romania plans to integrate multiple sources (e-Transport for movement of goods, SAF-T accounting data, etc.) so that even things like stock movements or certain exemptions could be reflected. [vatupdate.com]
  • For exports and certain exempt transactions, if the data is reported through the digital system (e.g. an invoice marked as an export), it can be incorporated. If not, the taxpayer might need to add it.
  • Special VAT schemes (e.g. margin schemes, flat-rate farmers, etc.) are generally not handled by prefilled returns as of now. Such sectors were often excluded from early programs (Italy initially excluded various special regimes from its prefill scope). Taxpayers under those schemes must continue to calculate those aspects themselves. [vatupdate.com]

• Where full e-invoicing is mandatory (e.g. Italy, from first issue to last, for almost all transactions), the draft return can be very complete, covering sales and purchases, B2B and B2C.
• In countries with partial data capture, the prefilled return may only cover parts. For example, France’s current system only “knows” import VAT, so that’s all it pre-populates. [sovos.com]
• Generally, purchase (input VAT) data is included whenever the tax authority receives purchase invoices (e.g. via a clearance system or transaction report). Many Latin American countries pioneered this (preloading both output and input VAT); in Europe, Spain, Italy, Hungary, etc., the draft does account for input VAT because the authorities receive supplier invoices. In contrast, if a system only had sales data, the taxpayer would need to add input VAT manually – but most European implementations do capture purchases as well (through suppliers’ sales reports or listing requirements).
• B2C transactions: If they are recorded electronically (like retail cash register data in Italy/Hungary), they are included. If much of B2C is outside the digital system (e.g. invoices not required for small B2C sales), those might not be prefilled. Over time, as more B2C reporting (like cash register integrations or e-receipts) come online, those also feed into prefilled returns.

Taxpayer Obligations and Process for Pre-Filled Returns

• Reviewing the Draft: The taxpayer is expected to carefully review the pre-populated return against their own accounting records before submission. The draft is essentially a proposal. For example, Italian authorities explicitly advise businesses to cross-check every figure in the prefilled annual return with their internal ledgers. Similarly, Spanish companies using Pre303 have been told to compare the tax agency’s totals with their own VAT books to catch any missing invoices. The onus is on the taxpayer to ensure correctness. [vatupdate.com]
• Adding or Correcting Data: In every current system, taxpayers can modify the prefilled return as needed. The prefilled forms are not locked:
  • Taxpayers can edit any amounts or add transactions that were not accounted for by the authority’s data. For instance, if an invoice was issued very late and didn’t make it into the authority’s system in time, the taxpayer should add it manually to the return. Or if an amount is wrong due to an input error in an e-invoice (say, wrong tax rate), the taxpayer should correct the VAT figure on the return (and likely correct the source invoice as well). [vatupdate.com]
  • This editability is universally allowed because the taxpayer’s submitted return is what legally counts. The tax office’s draft does not override the taxpayer’s numbers; it’s the taxpayer’s responsibility to submit a correct return. Even in the most automated regimes, the act of submission is an explicit taxpayer action. [vatupdate.com]
  • There is no country in Europe yet where doing nothing is considered acceptance of the draft. If a taxpayer fails to actively file/confirm, it’s treated as non-filing (similar to not submitting a return at all). For example, in Italy, if you don’t formally submit the prefilled return, it’s not sent automatically; you’d be in violation for missing the deadline. In Spain, the Pre303 draft is a courtesy – you still have to actually file the return in the system to fulfill your obligation. [vatupdate.com]
  • In practical terms, using a prefilled return might be as easy as clicking “Accept/Submit” if everything matches, but that click (or its equivalent) is mandatory to finalize the return. The taxpayer’s approval is what makes it an official filing. [vatupdate.com]
• Legal Responsibility: Importantly, the taxpayer remains legally responsible for the accuracy of the VAT return – prefilled or not. By submitting (even if they made no changes to the draft), they take ownership of those numbers. If an error was in the draft and the taxpayer didn’t catch it, it becomes the taxpayer’s error once filed. Tax authorities are clear that the convenience of a draft does not shift the blame for mistakes. For instance, Romania’s guidance around its eTVA explicitly stated that companies “must still prepare and submit their VAT returns by deadlines,” underscoring that the obligation isn’t waived by receiving a draft. Taxpayers can typically file corrections or amendments later under normal procedures if they discover an issue, just as they would with a self-prepared return. [vatupdate.com]
• Submission Method: Depending on the country, the mechanics differ:
  • Some have an online portal where the draft return is displayed and the taxpayer can amend and then hit submit (e.g. Italy’s portal for quarterly/annual VAT returns; Hungary’s eVAT web interface for small businesses).
  • Others allow API interactions where companies can pull the draft data into their own systems, reconcile, then push back the confirmation (Hungary for large companies has this, Spain’s SII participants often use their own software to basically mirror the Pre303).
  • A few, like early days in Spain, provided the data in a separate view and taxpayers then manually keyed it into their usual filing form if they agreed. This is merging into one step now (for efficiency).
  • Regardless of method, the final step is always the taxpayer’s submission of the return. The prefilled draft by itself does not fulfill the requirement until the taxpayer actively files it.

1. Obtain the draft (login to portal or via API).
2. Verify every relevant line item against their invoices and records.
3. Edit anything that is incorrect or incomplete.
4. Submit/approve the return by the due date.

Requirement to Reconcile and Align Data

• Proactive Reconciliation (Before Filing): Tax authorities encourage businesses to resolve any differences before submitting the return. For example: [vatupdate.com], [vatupdate.com]
  • In Italy, companies are urged to cross-check the prefilled return figures with their ERP or accounting system. If something doesn’t match (say the total sales in the draft is lower than in their ledger), they should investigate why. It could be an invoice not transmitted via SDI or a timing issue – in any case, the taxpayer should correct the return (and possibly fix the source data) prior to filing.
  • In Spain, since the draft uses the company’s SII submissions, any mismatch usually indicates an invoice wasn’t reported in SII. The taxpayer should then upload the missing invoice or correct it and ensure the final return includes it. [vatupdate.com]
  • In Hungary, the eVAT platform provides tools for comparison. A business can see the list of invoices the tax authority has; if their own list differs, they should use the portal to add or correct entries so that by the time they “close” the return, it’s consistent. [vatupdate.com]
  • This proactive reconciliation is essentially now a best practice in all these jurisdictions: companies often perform a monthly routine of matching government-reported transaction data (accessible via the tax authority’s system) with their internal records to catch any mismatches early. This reduces issues at filing time.
• Ability to Adjust Drafts: As noted, taxpayers can always adjust the draft return. This is a primary mechanism of reconciliation – you edit the draft to make it match reality. All European prefill programs allow edits. There is no penalty for doing so; in fact, it’s expected that you will if needed. For instance, if Hungary’s NAV system missed an invoice (perhaps a B2C invoice below certain thresholds not in RTIR), the taxpayer should add it in eVAT to accurately reflect the liability. If Portugal’s prefill for a small business doesn’t include a certain adjustment, the business enters it manually. [vatupdate.com]
• Reactive Reconciliation (Post-Filing Checks): Some countries have implemented automated checks after the return is filed to enforce reconciliation:
  • Romania is a clear case: after filing, the system compares the taxpayer’s submitted return with the eTVA draft. If there’s a difference beyond a set tolerance (20% or RON 1,000), the taxpayer must provide an explanation to the authorities, typically within 20 days. This essentially forces reconciliation – either you aligned with their data or you need to justify why not (maybe the authority’s data was missing something, which you have to show evidence for). [vatupdate.com], [fintua.com]
  • Mexico (though not Europe, it provides a blueprint referenced by tax advisors) plans to send automatic “invitations” or notices if a taxpayer files a return that doesn’t match the invoices in the system. European countries are moving in this direction gradually. [vatupdate.com]
  • Other European countries haven’t formalized a specific post-filing discrepancy notice yet, but it’s implicit that large gaps will raise red flags. For example, if in Spain a company’s filed VAT due is much less than what their SII data would suggest, the agency is likely to investigate informally even if no fixed rule exists.
• Expectations of Alignment: Over time, tax authorities expect that the taxpayer’s filed return will converge with the prefilled data, given that the source of that data is the taxpayer’s own invoices. If the systems work correctly, there should be little difference. Authorities view discrepancies as indicators of one of two things: either
  1. the taxpayer has legitimate transactions that weren’t captured by the standard system (which should be rare and shrinking over time), or
  2. the taxpayer made an error or omission.
  In either case, the burden is increasingly on the taxpayer to resolve it – either by informing the tax office of the missing data or by correcting their reporting. This represents a shift: instead of the tax office trying to find taxpayer errors via audits long after filing, the system itself spotlights differences upfront.
• Tools and Practices: Businesses are adapting by developing robust reconciliation practices:
  • Many companies now perform periodic downloads of tax authority data (e.g., pulling all invoices received by the tax portal) and comparing it to their ERP data to ensure completeness. This catches issues like a supplier not reporting an invoice, or an invoice recorded differently. [vatupdate.com]
  • Some have implemented automated internal controls that ensure every invoice issued is successfully accepted by the tax authority’s platform (no rejections) and that every purchase invoice from suppliers is accounted for in both the supplier’s and buyer’s reports.
  • Essentially, VAT reporting is becoming a continuous process. Instead of waiting until month-end to reconcile, companies are having to monitor their data in real time. This is a direct consequence of prefilled returns: since the return is being built in real time, any delay or mistake in reporting transactions immediately shows up.
• Consequences of Not Reconciling: If a taxpayer were to simply ignore discrepancies and file a return that doesn’t match the authority’s data:
  • In the short term, as long as they file on time with their best figures, they might not be automatically penalized (except Romania’s case and similar). But they are very likely inviting an audit or at least a query. The tax authority has the data to see the mismatch; the taxpayer might get a notice asking for clarification or be put on a risk list for future audits.
  • If the discrepancy involves underpaid tax (taxpayer’s figures lower than authority’s), and the taxpayer has no solid justification, they could face the usual penalties for underpayment or late payment once the authority catches it. The difference now is the catching is much faster and more certain.
  • Some advanced systems plan to prevent discrepancies through tech means: e.g., India’s “hard lock” on GST data from 2025 will simply not allow the taxpayer to file a return that deviates from the sales invoices on record. While no European country has this hard lock for VAT yet, the trend is toward tightening the room for divergence. [vatupdate.com]
  • In sum, failing to reconcile doesn’t carry a unique fine in many cases, but it heightens the risk of standard tax penalties (since any discrepancy likely means something was misreported).

Penalties and Consequences for Discrepancies

• No Automatic Penalties for Edits: Simply changing a prefilled value is not penalized. Tax authorities recognize the draft can be imperfect. For example, Italy assured that making corrections to the prefilled annual return incurs no penalty as long as you file on time. Likewise, adding data in Hungary’s or Spain’s system to reflect missing info is expected behavior, not an offense. The goal is accurate reporting, not blind acceptance of the draft. [vatupdate.com]
• Discrepancy Flags: As discussed, some authorities will flag and require explanations for discrepancies:
  • Romania: The most clear-cut case – differences above 20%/RON 1,000 must be justified or else the taxpayer is subject to sanction. If the explanation is not provided timely (within 20 days) or is unsatisfactory, the authorities can impose fines or take corrective action. [vatupdate.com], [fintua.com]
  • Others: While not formalized, any major discrepancy (especially underpayment of VAT) can trigger an audit or assessment. For instance, if a taxpayer in Spain files a return that shows significantly less VAT due than what their SII data would indicate, the tax agency can be expected to investigate and potentially issue an adjusted assessment or penalties for underreported tax if no valid reason is found.
• Penalties for Non-Filing: If a taxpayer fails to submit their return (perhaps thinking the draft alone suffices), the usual failure-to-file penalties apply. As noted, no country considers the draft “filed” by default. So, a taxpayer who doesn’t take action is in the same position as if they missed the deadline entirely. This is a crucial point to communicate to companies transitioning to these systems. [vatupdate.com]
• Accuracy Penalties: All normal penalties for inaccuracies, underpayments, or late payments of VAT remain in force:
  • If the prefilled return was correct but the taxpayer edits it to something wrong (thus filing an incorrect return), they can be penalized for that just as they would in the old system.
  • Conversely, if the prefilled return had an error and the taxpayer failed to catch it, and consequently underpaid tax, the taxpayer can face penalties for that underpayment (because the responsibility was theirs to fix the error before filing).
  • The presence of a prefilled draft might be considered a mitigating factor in some cases (for example, if a taxpayer can argue they reasonably relied on government-provided data), but legally the liability is on the taxpayer. We haven’t seen tax authorities explicitly stating leniency if the draft was wrong – rather, they emphasize the taxpayer must ensure it’s right.
• Specific Sanctions Regimes: Some countries might integrate prefilled returns with their compliance ratings or penalty regimes indirectly:
  • In Hungary, there is a concept of a risk rating for taxpayers. While Hungary hasn’t said this explicitly for eVAT, one could imagine that consistently aligning with the prefilled data keeps a taxpayer in a low-risk category, whereas frequent mismatches might push them into a higher risk category, leading to more frequent audits or smaller errors being penalized.
  • Italy and others might use discrepancies as part of their analytic criteria for selecting audits. There may not be a fixed fine for “your draft vs filed didn’t match,” but if they see a pattern, they might audit and then impose penalties for whatever errors are found in that audit.
• Penalties for Data Reporting Failures: Since prefilled returns rely on underlying digital reporting (e.g. e-invoicing, SAF-T, etc.), the enforcement often happens at that level too:
  • If a business fails to submit required invoice data (which then causes the prefilled return to be incomplete), there are usually penalties for not complying with the invoice reporting mandate. For example, in Spain, failing to upload invoices to SII on time can lead to fines per invoice. In Greece, not using myDATA properly can be penalized. Those are separate from the VAT return itself, but they indirectly ensure the prefilled return has all data.
  • Thus, the penalty environment is twofold: one for feeding the system (invoice reporting compliance) and one for the return accuracy. Together, they incentivize taxpayers to both report transactions in real-time and double-check their returns.
• No “Safe Harbor” Yet: Unlike some income tax prefill systems where if you accept the prefill you’re basically safe from audit (since it’s the authority’s numbers), that is not the case for VAT. Accepting the prefilled return without change doesn’t grant immunity. If it turns out some transactions were missing, the taxpayer is liable. The tax authority expects you to add them, not that their omission absolves you. The overarching principle remains that the taxpayer carries the final responsibility. [vatupdate.com]

• If you under-report relative to that data, you are likely to get caught much sooner.
• New rules like Romania’s make it compulsory to address differences or face sanction, effectively penalizing non-reconciliation.
• The margin for error is smaller, so taxpayers need to be vigilant. While there isn’t a unique “pre-fill penalty,” the practical effect is that discrepancies can swiftly lead to standard penalties.

Future Outlook: EU-Wide Plans (VAT in the Digital Age)

• The European Commission’s proposed VAT in the Digital Age (ViDA) reforms (expected to roll out by the end of the decade) explicitly encourage the use of digital reporting to enable harmonized pre-filled VAT returns across Member States by around 2030. The idea is that once all EU businesses report their transactions in real-time (through Continuous Transaction Controls or other Digital Reporting Requirements), tax authorities could collaborate to pre-populate VAT declarations, even for cross-border VAT like OSS/IOSS or intra-EU supplies. [vatupdate.com], [vatcalc.com]
• This means countries that currently have no prefill system may adopt one after implementing e-invoicing or real-time reporting. For example, Germany, the Netherlands, Sweden and others are observing the pioneers; as they introduce their e-invoicing mandates (likely in the next few years as part of EU reforms), they may follow with prefilled return services.
• Non-EU European countries might also join the trend for competitiveness and efficiency. The UK, for instance, while currently only requiring digital bookkeeping (MTD), could in the future consider leveraging the digital records to offer prefilled returns – especially as neighboring EU practices evolve (though no official plan yet).
• Norway and Switzerland, with advanced digital tax administrations, may evaluate similar moves. Norway already has SAF-T data from companies; theoretically, it could assemble a draft return, but as of 2025 no such project is announced. Switzerland’s federal VAT administration is also observing EU developments; any move there would require legal changes.
• Countries like Poland, which will have mandatory e-invoicing by 2026, are strong candidates for prefilled VAT returns afterwards. While not officially declared, the infrastructure (KSeF e-invoicing and extensive JPK reports) will be in place, so a prefilled VAT return could naturally follow to simplify filings.
• In summary, the trajectory is clear: as electronic invoicing and digital reporting become ubiquitous in Europe, tax authorities gain the data needed to prepare returns. Prefilled VAT returns align with the goals of reducing the VAT gap and easing compliance. We can expect that by the end of this decade, the majority of European countries will either have implemented prefilled returns or be in pilot stages, under the guiding framework of EU standards.

• Benefits: They promise easier compliance (taxpayers spend less time filling forms), fewer errors (since data flows directly from source documents), and more immediate audit capability for authorities (closing the information loop in real time).
• Challenges: Taxpayers must adapt by ensuring high-quality, real-time data reporting and by embracing a continuous reconciliation mindset. There is little room for last-minute adjustments if the underlying data wasn’t reported correctly in the first place.
• Current state: Several European countries are leading the way with implemented systems (Spain, Italy, etc.) or imminent plans (France, Croatia, etc.), covering both B2B and B2C transaction data where available. Taxpayers in those countries are expected to review, confirm, or amend the prefilled returns, and they remain fully responsible for the results.
• Ability to change data: In all cases, yes – taxpayers can change the pre-filled data. The prefilled return is a starting point, not the final word. [vatupdate.com]
• Reconciliation: It is not just expected, it’s effectively required – either by explicit rules or by the practical necessity to avoid errors. [vatupdate.com], [vatupdate.com]
• Penalties: While no new “pre-fill penalties” exist apart from Romania’s strict measures, failing to reconcile and accurately report will trigger the usual VAT penalties, now backed by stronger evidence from tax authorities’ own datasets. [fintua.com]