Regulatory updates - Hungary

Hungary has had longstanding real-time invoice reporting (RTIR) requirements; however, recent developments, announced by the Hungarian authorities, indicate that the country is now set to introduce a mandatory e-invoicing and reporting system aligned with the EU's VIDA legislation. The following aspects have been discussed and are open for feedback. 

New e-invoicing and reporting system 

Hungarian authorities are expected to implement mandatory B2B and B2G e-invoicing, compliant with the EN16931 standard, for domestic and intra-community transactions. The Peppol Network will be one of the options for distributing these documents. Hybrid e-invoice formats (PDF attached to XML) and email as a means of distributing e-invoices will no longer be allowed. 

For DRR, a Decentralized CTC Exchange Model will be introduced for B2B and B2G transactions. Sellers and buyers will be required to report the complete e-invoice for domestic transactions, together with an electronic stamp. For intra-community transactions, reporting the complete e-invoice will also be possible. Buyers will have five days from receipt to report the e-invoice to NAV. 

B2C will continue as it does currently, where only the seller reports; however, instead of submitting invoice data to NAV, the complete XML invoice must now be reported. 

Paper and PDF exceptions 

Visual representations of an invoice will only be allowed in B2C transactions and cross-border transactions outside the EU (non-intra-community transactions). For B2B domestic and intra-community transactions, visual representations may be issued, but XML invoices will always prevail as the legally valid tax document. 

Prefilled VAT returns 

The system launched in 2024, eVAT (eÁFA), will use invoices reported to NAV to offer pre-filled VAT returns to taxpayers with greater precision than before, thanks to status reports. Status reports will be introduced for buyers to indicate which invoices did not correspond to actual economic events related to the VAT return period, offering better reconciliation between systems. The status report must be submitted in accordance with the VAT return period and by its submission deadline. 

Accreditation required 

E-invoicing service providers will be subject to an accreditation process to ensure secure e-invoice exchange and reporting. This requirement will also apply to businesses that wish to implement an in-house solution. 

Hungary becoming a Peppol Authority 

NAV has confirmed that Hungary will become a Peppol Authority to facilitate the implementation of this network and oversee service providers offering this distribution method. 

Open Feedback 

Stakeholders are invited to provide feedback on the new e-invoicing system until January 20, 2026. It’s important to outline that this is a concept which can keep changing. 

Government Decree 159/2025 states in Section 3: “From 1 January 2026, the water utility service provider will only issue electronic invoices to non-residential users” Therefore, businesses must prepare to receive only e-invoices from the water sector. 

As a reminder, it has already been mandated that, from July 1, 2025, the energy sector (electricity and gas supply) must issue only e-invoices to businesses, except for residential users. 

The NGM wants to contribute to developing the operational, technological, and organizational infrastructure to successfully implement ViDA. Therefore, in cooperation with KPMG, they have launched an autonomous questionnaire survey for the taxpayers and organizations that provide services related to taxation, accounting, invoicing, etc.

The goal is to gather the opinions of the representatives of large businesses, accountants, and tax advisors in the sector, who may contribute with their insights on invoicing, data reporting and VAT reporting processes.

The questionnaire links are available here, with April 18, 2025, as the submission deadline.