Reference · VAT in the Digital Age

VAT in the Digital Age: the timeline, and when national divergence ends

Germany, France and Poland each run a different e-invoicing system today because, until recently, each had to ask the Council's permission separately to require one. That permission structure ended in April 2025. Here is what changed, what happens next, and the date the national differences are due to close.

The EU's VAT in the Digital Age package was adopted by the Council on 11 March 2025, published in the Official Journal on 25 March 2025, and entered into force on 14 April 2025. It is three linked instruments: Council Directive (EU) 2025/516, Council Regulation (EU) 2025/517, and Council Implementing Regulation (EU) 2025/518.

Why every country had a different rulebook before this

Under the EU VAT Directive as it stood before 14 April 2025, an electronic invoice for a domestic supply generally required the recipient's acceptance, and a Member State that wanted to mandate e-invoicing for its own domestic supplies had to obtain an individual derogation from the Council to do so. That is the reason Germany, France and Poland arrived at e-invoicing on separate timetables and with separate technical rules. Each had negotiated its own permission, on its own schedule, with the Council specifying what that Member State, specifically, was allowed to require.

This is also why a national mandate can still look different from one country to the next even after the derogation era ended.

Recital 6 of Directive (EU) 2025/516 says electronic invoices should in principle comply with the European standard referenced in Commission Implementing Decision (EU) 2017/1870 (that is, EN 16931) while Member States remain free to allow other standards for domestic supplies. That carve-out is precisely what keeps a national schema such as Poland's, or any other country's domestic format, legal for domestic use until the alignment date below.

What is scheduled, and when

The package's remaining substance is a sequence of application dates rather than a single cutover. The ones that touch invoicing and reporting directly:

• 1 January 2027: clarifications to the One Stop Shop (OSS) and Import One Stop Shop (IOSS), and deemed-supplier rules for low-value imports.
• 1 July 2028: platform-economy deemed-supplier rules for short-term accommodation and passenger transport, and the Single VAT Registration package: mandatory reverse charge for non-established suppliers, an expanded OSS, and a transfer-of-own-goods scheme. Member States may defer the platform deemed-supplier measures to 1 January 2030.
• 1 July 2029: recapitulative statement obligations (EC Sales Lists) are removed.
• 1 July 2030: Digital Reporting Requirements apply to intra-EU B2B supplies.
• 1 January 2035: Member States that already run a domestic real-time transaction reporting obligation must align it with the EU model and standards.

From 1 July 2030, structured e-invoicing becomes the default for intra-EU B2B supplies. The invoice must be issued no later than 10 days after the chargeable event, and transaction-level data reported to tax authorities takes over the role that the recapitulative statements played until their removal the year before.

When does the divergence end?

1 January 2035 is the date by which a Member State running a pre-existing domestic real-time transaction reporting obligation must have aligned it with the EU model and standards — the point at which the national differences this article opened with are due to close. Recital 24 conditions that deadline on a Commission assessment of whether the cross-border reporting system is working as intended, so the date can move if that assessment finds shortcomings.

What this does not cover

EUInvoice does not transmit invoices or file reports of any kind, to any tax authority or network, at any point in this timeline. The dates above are obligations that fall on Member States and on taxable persons. They describe when a government must permit or require something. They are not a product roadmap for any particular tool. This article also does not cover the platform-economy deemed-supplier rules or the Single VAT Registration package in detail; both are named above only to place them correctly on the timeline.