EU e-invoicing under ViDA: a client readiness sheet (Directive 2025/516, EN 16931, 10-day invoices and digital reporting from 1 July 2030) for accountants and their small business clients
What you get: a finished ViDA e-invoicing readiness sheet in three tabs: a client tab (one row per client) with a formula that lists every gap and a formula that gives the first EU date that matters for that client; an invoice timing calculator that gives the latest invoice date before and after 1 July 2030 and the 5-day reporting date for the buyer; and an invoice data check listing the Article 226 details that must travel in structured form for cross-border reporting. Four made-up rows show how it fills in, and a short client letter closes the page.
Short answer: Council Directive (EU) 2025/516 ("VAT in the Digital Age", ViDA) changes the VAT Directive in stages. Since 14 April 2025 a Member State may require businesses established there to issue electronic invoices for domestic supplies without the buyer's agreement (new Articles 218 and 232, second paragraphs). From 1 July 2030, invoices are by default electronic invoices in a structured format that complies with the European standard EN 16931, intra-EU B2B supplies and reverse-charge supplies must be invoiced within 10 days, and the data from each invoice is reported transaction by transaction (new Articles 217, 218, 222, 262 to 264). A PDF is not an electronic invoice under the new definition, whether it was typed by a person or read by an AI tool.
Why accountants and bookkeepers should look at this now
- Software contracts signed now will still run in 2030. A client choosing invoicing or bookkeeping software this year should ask whether it can issue and receive EN 16931 invoices in one of the two official syntaxes (UBL or UN/CEFACT CII).
- Some deadlines come earlier. From 1 July 2028 the 15th-of-next-month invoice deadline in Article 222 also covers domestic reverse-charge supplies under Article 194; call-off stock dispatches stop at 30 June 2028 and Article 17a ends on 30 June 2029; and the deemed-supplier rule for short-term accommodation and road passenger transport sold through online marketplaces applies from a national date between 1 July 2028 and 1 January 2030.
- Your own Member State may move first. The Directive lets Member States require domestic e-invoices before 2030. Those national dates are not in the Directive: put them in column M of the client tab from your national tax authority.
- AI invoice reading will change role. Many small firms now use AI or OCR tools to read PDF purchase invoices. Once suppliers must send structured e-invoices, the data arrives machine-readable. Plan to receive the structured file into the bookkeeping software, and keep the AI tool for checking, not for creating the legal record.
Step 1: tab 1, client tab (one row per client)
| Column | What to write | Source |
|---|---|---|
| A. Client | Name | |
| B. Member State | Where the client is established and VAT-identified | |
| C. Intra-EU B2B goods | Yes/No: exempt supplies to business customers in other Member States (Article 138) | Art. 262(1)(a) as replaced |
| D. Reverse-charge sales | Yes/No: services or goods where the customer pays the VAT (Articles 194 to 197), for example B2B services to another Member State | Art. 262(1)(c) as replaced |
| E. Call-off stock | Yes/No: goods sent to another Member State to a known buyer under Article 17a | Art. 17a(2)(a), 17a(8) as amended |
| F. Marketplace for rooms or rides | Yes/No: the client runs an online marketplace or app that facilitates short-term accommodation rental (up to 30 nights) or road passenger transport | New Art. 28a |
| G. Software issues EN 16931 | Yes/No: can the invoicing software issue EN 16931 invoices in UBL or CII? Ask the supplier in writing | New Art. 218(3); Decision (EU) 2017/1870 |
| H. PDF or paper only today | Yes/No | New Art. 217 |
| I. AI or OCR reads purchase invoices | Yes/No | Our working rule |
| J. Bank account on invoices | Yes/No: IBAN or other account identifier | New Art. 226(17) |
| K. Credit notes quote original number | Yes/No | New Art. 226(16) |
| L. Domestic reverse charge (Art. 194) | Yes/No | Art. 222 as amended from 1 July 2028 |
| M. National e-invoice date | Date the client's own Member State requires domestic e-invoices, from national law (blank if none announced) | New Art. 218, second paragraph; national law |
| N. Gaps | =TEXTJOIN("; ",TRUE,IF(AND(OR(C2="Yes",D2="Yes"),G2<>"Yes"),"software cannot issue EN 16931 e-invoices (needed by 1 Jul 2030)",""),IF(AND(OR(C2="Yes",D2="Yes"),H2="Yes"),"PDF or paper will not count as e-invoice for reported sales from 1 Jul 2030",""),IF(J2<>"Yes","add bank account to invoices (Art 226(17))",""),IF(K2<>"Yes","credit notes must quote the corrected invoice number (Art 226(16))",""),IF(E2="Yes","call-off stock: last dispatch 30 Jun 2028",""),IF(F2="Yes","deemed-supplier rule for rooms or rides from national date 1 Jul 2028 to 1 Jan 2030",""),IF(L2="Yes","Art 194 sales: invoice by 15th of next month from 1 Jul 2028",""),IF(I2="Yes","plan to import structured e-invoices instead of AI reading PDFs",""),IF(M2<>"","national e-invoice mandate from "&TEXT(M2,"d mmm yyyy"),"")) | Formula is our working rule |
| O. First EU date that matters | =LET(z,DATE(2099,1,1),d,MIN(IF(M2<>"",M2,z),IF(E2="Yes",DATE(2028,6,30),z),IF(OR(F2="Yes",L2="Yes"),DATE(2028,7,1),z),IF(OR(C2="Yes",D2="Yes"),DATE(2030,7,1),z)),IF(d=z,"none in ViDA: check national law",d)) (format as date) | Dates from Directive 2025/516 Arts 2, 3, 5, 6; formula is our working rule |
LET works in current Excel and Google Sheets. In older Excel, replace z with DATE(2099,1,1). Column J and K checks apply to the invoice details list as amended from 1 July 2030; adding them earlier does no harm. National law may already ask for more.
Step 2: tab 2, invoice timing calculator
| Cell | What to write or the formula | Source |
|---|---|---|
| A2 chargeable event date | Date of the supply (or of the payment on account) | |
| B2 type | single or summary (monthly summary invoice) | New Art. 223 |
| C2 latest invoice date for an Art. 138 or reverse-charge supply | =IF(A2>=DATE(2030,7,1),IF(B2="summary",EOMONTH(A2,0)+10,A2+10),DATE(YEAR(A2),MONTH(A2)+1,15)) | Art. 222 as amended from 1 July 2028 (15th day of next month) and from 1 July 2030 (10 days); new Art. 223 |
| D2 invoice received by the buyer | Date | |
| E2 buyer's latest reporting date (from 1 July 2030) | =IF(D2="","",D2+5) | New Art. 263(2): "no later than 5 days after the invoice is received" |
The seller reports "at the time when the invoice is issued or should have been issued" (new Art. 263(1)); where the buyer issues the invoice for the seller (self-billing), the limit is 5 days. Member States may exempt buyers from reporting acquisitions (new Art. 262(4)). Before 1 July 2028, domestic Article 194 supplies follow national invoice deadlines. Counting "10 days following" as event date plus 10 calendar days is our working reading: check how your Member State counts days.
Step 3: tab 3, invoice data check (what must be in structured form)
From 1 July 2030 the data reported for each Article 138 supply and each reverse-charge supply is the Article 226 information in points (1) to (4), (6), (7), (8), (11), (16) and (17), plus (11a) where relevant (new Art. 264(a)). Tick each one against a sample invoice from the client's software:
| Art. 226 point | Detail | In the structured file? (Yes/No) |
|---|---|---|
| (1) | Date of issue | |
| (2) | Sequential number that uniquely identifies the invoice | |
| (3) | Supplier's VAT identification number | |
| (4) | Customer's VAT identification number | |
| (6) | Quantity and nature of goods, or extent and nature of services | |
| (7) | Date of supply or of payment on account, if different from date of issue | |
| (8) | Taxable amount per rate or exemption, unit price excluding VAT, discounts | |
| (11) | Reference to the exemption or reverse-charge provision | |
| (11a) | "Reverse charge" and, for Article 197 supplies, also "triangular transaction" | |
| (16) | For a corrective invoice: the number of the invoice it corrects | |
| (17) | Supplier's bank or virtual account numbers, or other identifiers of the account to be paid |
Result cell under the table: =IF(COUNTIF(C2:C12,"No")=0,"DATA READY","FIX "&COUNTIF(C2:C12,"No")&" FIELD(S) WITH SOFTWARE SUPPLIER") (our working rule).
Example rows (made up)
| A | C | D | E | F | G | H | I | J | K | L | M | O |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Web shop selling parts to traders in 3 countries | Yes | No | No | No | No | Yes | Yes | Yes | No | No | 1 Jul 2030 | |
| Design studio billing EU clients | No | Yes | No | No | Yes | No | No | Yes | Yes | No | 1 Jul 2030 | |
| Manufacturer with call-off stock at a foreign customer | Yes | No | Yes | No | Yes | No | No | Yes | Yes | No | 30 Jun 2028 | |
| Holiday flat booking app | No | No | No | Yes | No | Yes | No | No | No | No | 1 Jul 2028 |
These rows are made up for illustration and do not describe any real business. For the first row, column N reads: "software cannot issue EN 16931 e-invoices (needed by 1 Jul 2030); PDF or paper will not count as e-invoice for reported sales from 1 Jul 2030; credit notes must quote the corrected invoice number (Art 226(16)); plan to import structured e-invoices instead of AI reading PDFs". For the booking app, check whether its Member State applies the deemed-supplier rule from 1 July 2028 or later (up to 1 January 2030), and whether it excludes small-enterprise hosts (new Art. 28a(5)).
What else changes on 1 July 2030 (for the client letter)
- No buyer consent for EN 16931 e-invoices. Issuing a standard-compliant e-invoice to a business or non-taxable legal person "shall not be subject to acceptance by the recipient" (new Art. 232). Invoices in other formats still need acceptance unless national rules say otherwise.
- Losing the zero rate. The Article 138 exemption does not apply where the supplier has not reported the transaction data or the data is wrong, unless the supplier "can duly justify any shortcomings" (new Art. 138(1a)).
- Deduction may depend on the e-invoice. For transactions under domestic digital reporting, a Member State may make the buyer's deduction conditional on holding a compliant electronic invoice (new Art. 168, second paragraph).
- Third parties can do it. The client or "a third party acting in the name and on account of" the client may issue compliant e-invoices; Member States may also allow a public portal (new Art. 218(5)).
- Hybrid invoices. An invoice that combines structured data and a readable image counts if all the reportable data is in the structured part (Recital 9).
- Later domestic alignment. Member States that already had domestic real-time reporting in place on 1 January 2024 have until 1 January 2035 to align their domestic systems (Art. 6(5)).
What to tell a client in one paragraph
"From 1 July 2030, invoices for your sales to businesses in other EU countries must be structured electronic invoices to the European standard, issued within 10 days, and their data goes to the tax authority invoice by invoice. A PDF will not be enough. Before you renew or buy invoicing software, get the supplier to confirm in writing that it issues and receives EN 16931 invoices in UBL or CII, shows your bank account and quotes the original number on credit notes. If you use an AI tool to read supplier PDFs, plan to receive the structured file instead. Your own country may require e-invoices earlier, so we will check national law each year." Penalties and national start dates are set by each Member State: check the national VAT law before advising.
Keep the AI tool list in one place
If a client uses AI tools to read invoices, chase payments or answer customers, list them in the EURO AI Register free edition. It runs in your browser with no account and no upload, covers your first 10 AI systems and 10 evidence records, the screening questions, duties by role with dates, and a printable Article 4 AI-literacy record. Attach the software supplier's EN 16931 confirmation as the evidence record for the invoicing tool.
When you need more than 10 systems, the EURO AI Register membership starts at $19 a month and adds unlimited systems, rule updates and email help. Neither tool is tax or legal advice or proof of compliance.
Partner programme opening soon
Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.
Free start: list the client's AI tools in the EURO AI Register free edition, then add this sheet. Related: EU VAT invoice details checklist (Article 226) · EU invoice deadline today (Article 222) · EC Sales List today (Articles 262 and 263) · Reverse charge invoice wording
Sources
- Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age (OJ L, 25.3.2025), Recitals 9 to 12, Articles 1, 2 (Art. 17a), 3 (Arts 28a, 222), 5 (Arts 138(1a), 168, 217, 218, 222, 223, 226(11a), (16), (17), 232, 262, 263, 264, 271a, 271b) and 6, read on EUR-Lex on 28 October 2026: EUR-Lex
- Council Directive 2006/112/EC, Article 226 (details required on invoices), original text read on EUR-Lex on 28 October 2026 (later amendments apply): EUR-Lex
- Commission Implementing Decision (EU) 2017/1870 publishing EN 16931-1:2017 and the list of syntaxes CEN/TS 16931-2:2017 (UN/CEFACT CII and UBL), read on EUR-Lex on 28 October 2026: EUR-Lex
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