Hungary Launches Public Consultation on Mandatory E-Invoicing

The Hungarian National Tax and Customs Administration (NAV) and the Ministry of National Economy (NGM) have released a draft concept and launched a public consultation regarding the implementation of the EU’s VAT in the Digital Age (ViDA) package.

The proposal outlines a significant transformation of Hungary’s digital tax landscape, moving beyond the current Real-Time Invoice Reporting (RTIR) framework toward a comprehensive mandatory electronic invoicing system. Stakeholders are invited to submit their feedback on the planned reforms by January 20, 2026.

Proposed E-Invoicing Mandate

Under the draft concept, Hungary intends to introduce a combined e-invoicing and e-reporting model that strictly adheres to the European EN 16931 standard. The new rules effectively separate the issuance of the invoice from the data reporting obligation while modernizing the definition of a legal invoice.

Scope and Format

• E-invoicing will become mandatory for all domestic B2B, intra-EU B2B, and B2G transactions.
• The structured XML file will constitute the only legally valid document, meaning that “hybrid” formats (where a PDF is merely attached to an XML file) and the distribution of invoices solely via email for in-scope transactions will not be permitted.
• Businesses may continue to issue paper invoices for B2C transactions (unless the consumer requests an electronic version) and for exports to non-EU countries. However, an EN 16931-compliant XML must still be generated for reporting purposes.

Enhanced Real-Time Reporting Requirements

The concept document proposes a Decentralized Continuous Transaction Control (CTC) model. This significantly expands reporting obligations, particularly for invoice recipients, to facilitate better data reconciliation.

• Issuers must report complete invoice data in real-time for domestic B2B transactions. For intra-EU transactions, reporting will require either core or complete data sets. Notably, reporting remains mandatory for both B2C and non-EU export transactions, regardless of the delivery method used to the customer.
• A new requirement mandates that domestic taxpayers report received invoices to NAV within 5 days of receipt.
• Buyers will be required to submit a status report by their VAT return deadline. This report must confirm which invoices correspond to actual economic events, ensuring alignment with the eVAT (eÁFA) system, which aims to provide taxpayers with precise pre-filled VAT returns.

Infrastructure and Accreditation

To support this ecosystem, Hungary plans to adopt a five-corner model involving the seller, the buyer, their respective service providers, and the tax authority.

NAV has confirmed that Hungary will become a Peppol Authority. While the tax authority will join the Peppol network to facilitate secure transmission, the use of Peppol will remain optional for private businesses.

All invoicing software and service providers (including in-house solutions) will be subject to a mandatory accreditation process:

• Preliminary Accreditation: Required for software vendors before offering services.
• Taxpayer Accreditation: Required for businesses utilizing proprietary in-house invoicing tools.

Accredited systems must demonstrate the ability to process NAV-provided test XMLs, block non-compliant data, and perform pre-verification checks on mandatory VAT data.

Implementation Timeline

The authorities have not yet specified a domestic go-live date for these new obligations. However, the proposal aligns with the broader EU ViDA timeline, which mandates intra-community real-time reporting by July 2030.

Stakeholders are encouraged to send professional comments regarding technical requirements, timelines, and operational processes to vida-tsi@nav.gov.hu before January 20, 2026.

There’s more you should know about e-invoicing in Hungary – learn more about the new and upcoming regulations.