Short answer
The EU's VAT in the Digital Age (ViDA) reforms are enacted law, but most obligations are phased in. Since 14 April 2025, a Member State may require domestic electronic invoices from locally established taxable persons without first obtaining the old EU derogation, and may remove recipient acceptance for those invoices. This does not create one immediate EU-wide domestic mandate.
From 1 July 2028, with limited timing flexibility for the platform rule, online platforms facilitating short-term accommodation and road passenger transport can become deemed suppliers where the underlying provider does not account for VAT. The same phase expands the One Stop Shop (OSS), introduces a scheme for transfers of own goods, and makes reverse charge more consistent, reducing—but not eliminating—foreign VAT registrations.
From 1 July 2030, specified intra-EU business transactions move from periodic recapitulative statements to transaction-level digital reporting built around structured e-invoices. Data is normally transmitted when the invoice is issued, with short deadlines in self-billing and purchaser reporting situations. Member States may retain or introduce domestic reporting, but new systems must follow harmonised features. Businesses should therefore map each supply, Member State, customer status and implementation date rather than treating “ViDA” as one go-live event.
ViDA is a three-act package with several start dates
Council Directive (EU) 2025/516 amends the VAT Directive 2006/112/EC. Council Regulation (EU) 2025/517 changes administrative cooperation, including central exchange of transaction data. Council Implementing Regulation (EU) 2025/518 adjusts detailed scheme rules.
Published on 25 March 2025, the Directive entered into force on 14 April but requires staged transposition; the regulations apply directly on phased dates. Principal business dates are:
- 14 April 2025: Member States may adopt domestic e-invoicing mandates without the former case-by-case derogation and may remove recipient acceptance for those mandated invoices.
- 1 January 2027: import and Import One Stop Shop (IOSS) safeguards and related rules begin.
- 1 July 2028: most platform-economy, OSS, reverse-charge and transfer-of-own-goods measures apply. Member States may introduce the new deemed-supplier rule between 1 July 2028 and 1 January 2030.
- 1 July 2029: specified transitional recapitulative-statement provisions end.
- 1 July 2030: harmonised intra-EU digital reporting and the new general e-invoicing architecture apply.
- 1 January 2035: qualifying domestic real-time systems existing or legislated before 2024 must align their domestic e-invoicing and reporting features, subject to the Directive's review mechanism.
Domestic duties still depend on national implementation until harmonised rules apply.
No Court of Justice judgment interpreting the enacted ViDA package was found through 31 July 2026. Check the for later developments; older VAT judgments do not answer these new phased duties.
Domestic e-invoicing can arrive before 2030
The reform immediately added an option to Article 218 of the VAT Directive:
“Member States may, in accordance with the conditions they lay down, require taxable persons established within their territory to issue electronic invoices for supplies of goods and services within their territory”. —
This is permission, not an EU-wide obligation. It removes the need for a derogation for the covered domestic mandate. A state may also make recipient acceptance unnecessary. Companies must monitor national scope, formats, transmission channels and dates.
From July 2030, the VAT Directive will define an electronic invoice as one issued, transmitted and received in a structured format allowing automated processing. Electronic invoicing becomes the default, and the European standard and approved syntaxes form the interoperable baseline. Member States may allow other standards for domestic supplies. A PDF sent by email is not automatically a compliant structured e-invoice.
For transactions subject to the harmonised cross-border reporting rules, invoices generally must be issued no later than ten days after the chargeable event. The new invoice data includes identifiers for a corrected invoice and payment-account information. Recipient acceptance generally cannot block European-standard e-invoices issued to taxable persons or non-taxable legal persons, subject to the Directive's detailed domestic options.
Cross-border reporting becomes transaction-level and near real time
From 1 July 2030, revised Articles 262–264 cover intra-Community supplies and acquisitions and specified reverse-charge transactions. Periodic recapitulative statements give way to data for each transaction. The supplier's reporting is tied to invoice issuance:
“The data referred to in Article 264 shall be transmitted for each individual transaction ... at the time when the invoice is issued or should have been issued.” —
Where the customer self-bills, the deadline is no later than five days after the invoice is issued or should have been issued. For reportable acquisitions, customer data is normally due within five days after receipt; a Member State may opt not to require certain purchaser-side reporting. Data can be submitted by the taxable person or a third party, and Member States must allow data compliant with the European e-invoicing standard.
The reporting fields draw on invoice data and include transaction parties, dates, taxable amount, relevant VAT treatment, corrective-invoice reference and payment-account identifiers. Regulation 2025/517 supports exchange and cross-checking through an electronic central system replacing the present central VIES architecture for the relevant information.
Domestic transaction reporting remains a Member State option. If a state requires it under future Articles 271a–271b, the system must accept the European standard, use transaction-level timing and follow the harmonised framework, although the state can choose covered taxpayers, transactions, data and additional compatible formats. Legacy systems receive the special 2035 alignment window. ViDA therefore standardises important features without creating one identical domestic portal or filing process across the EU.
Platforms can become the supplier for VAT purposes
The platform reform targets facilitated short-term accommodation—an uninterrupted rental to the same person for no more than 30 nights—and passenger transport by road within the EU. Future Article 28a provides:
“shall be deemed to have received and supplied those services themselves” —
This applies unless the provider supplies the required VAT identifier and declares that it will charge the VAT due. The rule is a VAT legal fiction, not a general reclassification of employment or commercial relationships. The underlying supply to the platform is exempt, while the platform accounts for VAT to the customer. A platform that is not deemed supplier still has record-keeping duties, generally for ten years.
Important boundaries remain. The rule does not apply where the provider gives the required VAT number and declaration. Member States may exclude providers using their domestic small-enterprise scheme from the deemed-supplier rule, and special travel-agent arrangements are excluded. The implementing regulation also distinguishes true facilitation from payment processing, mere listing or advertising, and redirecting customers without further intervention.
Because Member States may apply Article 28a from 1 July 2028 but no later than 1 January 2030, a multi-country platform may face different national start dates during that window.
“Single VAT registration” reduces registrations but does not abolish them
The registration reforms work through three main mechanisms from July 2028.
First, the Union OSS expands beyond its present categories. Eligible non-established sellers can report more domestic supplies of goods to non-taxable customers, certain installation or assembly supplies, and other covered transactions through one Member State of identification.
Second, a new special scheme covers transfers of a business's own goods between Member States. It uses a monthly electronic return and treats the corresponding intra-Community acquisition as exempt without creating a destination registration solely for that acquisition:
“A taxable person making use of this special scheme shall, for the taxable transactions carried out under this special scheme, be identified for VAT purposes in the Member State of identification only.” —
Third, future Article 194 generally shifts VAT to a VAT-identified business customer where the supplier is neither established nor individually VAT-identified in the Member State of taxation. Member States retain an option to extend reverse charge under specified conditions.
These measures do not create a universal EU VAT number or one return for every activity. A fixed establishment, supplies outside the schemes, local B2B sales, excluded goods, import duties, domestic deduction needs or another local obligation may still require registration. VAT incurred cannot simply be deducted in the transfer-of-own-goods special return; refund procedures or an ordinary local return may be needed. OSS choices also generally apply to all eligible supplies within the chosen scheme, not selected transactions.
A practical preparation sequence
- Map invoicing and reporting by Member State; identify domestic mandates already enacted under the 2025 option.
- Separate intra-EU supplies, acquisitions, reverse-charge transactions and domestic transactions.
- Confirm whether invoice systems create structured, machine-processable data conforming to the European standard—not merely PDFs.
- Build controls for the ten-day invoice deadline, five-day reporting cases, corrections and payment-account fields before July 2030.
- For accommodation and road-transport platforms, classify facilitation, obtain and validate provider VAT information, record declarations and track each Member State's Article 28a start date and small-enterprise option.
- Model whether expanded OSS, transfer-of-own-goods reporting or reverse charge removes an existing registration, and document activities that remain outside those mechanisms.
Conclusion
ViDA replaces a patchwork of periodic cross-border reporting with structured invoicing and transaction-level data, puts defined platform transactions into a deemed-supplier model, and extends schemes that reduce multiple registrations. But it is a phased framework, not one immediate digital VAT system.
The answer depends on the transaction and date. Domestic e-invoicing can already be mandated nationally; platform and registration measures arrive mainly from July 2028; and harmonised intra-EU reporting arrives in July 2030. National choices and residual activities still determine required systems, registrations and filings.
Sources
This article provides general legal information, not advice for a specific matter. Laws, facts and procedural deadlines may change the result. Follow the linked primary sources and obtain local advice before acting.