Where is eInvoicing compulsory?

European compliance

Italy distinguished itself by becoming the first country to make B2B eInvoicing obligatory with effect from 1 January 2019.

In France and Spain, where the automotive, retail and pharmaceutical sectors are highly developed, a mixed scheme for eInvoicing was preferred over a centralized model like Italy’s.

In these countries, it will therefore be sufficient to communicate VAT data to the government.

In Germany, EDI has always been widely used by the leading companies in the automotive, retail, and pharmaceutical sectors that comprise the solid industrial fabric of the country.

The recently introduced ZUGFeRD initiative aims to extend the dissemination of eInvoicing to SMEs in Germany, too. The ZUGFeRD format is also compatible and interchangeable with the French FacturX standard.

SAF-T reporting in Europe

In Europe, the international SAF-T (standard audit file for tax) standard is widely used for communicating tax information to tax authorities for VAT compliance purposes, but also for exchanging other electronic accounting data.

The countries currently using the SAF-T system are Lithuania, Norway, Poland, Portugal, Romania and Hungary.

In Lithuania from 2016 it became obligatory for large organizations to file i.MAS VAT returns. The obligation includes recording, sending, and analyzing tax and accounting declarations in the SAF-T format.

Norway introduced SAF-T reporting in 2017 and it became mandatory from January 2020. The information is sent to the government portal Altinn via the SAF-T standard.

Poland uses the SAF-T JPK_VAT system for electronic VAT returns. As of 1 January 2018, it became obligatory for all taxpayers to submit their VAT returns monthly.

Portugal began implementing the SAF-T system in 2013 with a legislative change that obliged companies to migrate to the electronic SAFT-PT system. In 2015, the country introduced e-Factura, a system for approving invoices using a personal tax number or NIF (Numero de Identificacao Fiscal) via digital signature.

The SAF-T system in Romania became mandatory for large companies in 2022. The National Agency for Tax Administration (ANAF) requires the submission through the SAF-T D406 system of the tax and accounting information embedded in a PDF.

Hungary also recently joined the list of countries that require the issuance of a SAF-T report.The SAF-T HU was introduced by the National Tax and Customs Authority (NAV). Companies must be ready to send SAF-T files whenever requested by the tax authority.

USA

The promotion of e-invoicing in the US was initiated during 2021 and 2022 by means of a pilot project conducted with 80 organizations. The objective is to adopt a system-agnostic electronic invoicing model similar to the one used in Europe that allows invoices to be exchanged across the network independently of the invoicing software being used.

It should be noted that the USA is the only major economy in the world that does not have a federal VAT system but 45 of the 50 states apply a sales and use tax at different rates. The sales tax in the USA is only levied on the final buyer at the end of the manufacture-and-supply chain as opposed to VAT which levies a tax at each stage of the supply chain.