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Digital VAT reporting: recapitulative statements end on 1 July 2030

From 1 July 2030 Articles 265 to 271 of the VAT Directive are deleted and recapitulative statements give way to the transmission of data transaction by transaction, at the time the invoice is issued. This is laid down by Directive (EU) 2025/516, in force since 14 April 2025, which already allows every Member State to require electronic invoicing from persons established in its territory without the recipient’s consent. From 1 July 2030 a supplier who fails to report, or reports incorrect data, loses the exemption on the intra-Community supply, unless the shortcoming can be duly justified. In Italy, from 1 January 2027, the domestic rules move to the consolidated VAT act.

On 1 July 2030 recapitulative statements for intra-Community transactions cease to exist: Articles 265 to 271 of Directive 2006/112/EC are deleted and give way to the transmission of data on a transaction-by-transaction basis, at the time the invoice is issued. This is laid down by Council Directive (EU) 2025/516 of 11 March 2025, which reshapes VAT invoicing and reporting in the Union in successive stages. The directive does not stand alone: the same package includes Regulation (EU) 2025/517 and Implementing Regulation (EU) 2025/518, both of 11 March 2025, which deal with administrative cooperation and with the implementing provisions.

The directive has been in force since 14 April 2025, but its immediate effects are limited: it already allows every Member State to require electronic invoicing for domestic transactions without the recipient’s consent. Five dates matter: 14 April 2025, 1 January 2027, 1 July 2028, 1 July 2029 and 1 July 2030, with a final alignment by 1 January 2035.

What has been in force since 14 April 2025

The directive was published in the Official Journal of the European Union of 25 March 2025 and entered into force, under Article 7, on the twentieth day following publication, that is 14 April 2025. Article 1 consists of three points, all taking effect from that date; those bearing directly on the invoicing cycle are points 2) and 3), which Article 6(1) allows Member States to apply from 14 April 2025.

A second paragraph is added to Article 218 of Directive 2006/112/EC: Member States may, under conditions they lay down, require taxable persons established in their territory to issue electronic invoices for supplies of goods and services carried out in their territory, other than those referred to in Article 262. A paragraph is added to Article 232 under which Member States that make use of that option may provide that the use of «electronic invoices issued by taxable persons established within their territory» is not to be subject to the acceptance of the recipient established in their territory. The consent requirement may therefore fall away for domestic transactions, but only in those Member States that exercise both options: until now, any Member State wishing to make electronic invoicing compulsory had to ask the Council for a special measure derogating from the directive.

The detail that deserves operational attention is the personal scope: the option concerns taxable persons established in the territory of the Member State, not those merely identified for VAT purposes there. An Italian business with a VAT registration in another Member State but no fixed establishment therefore falls outside the provision, whereas a subsidiary or a fixed establishment located in that State falls within it. The distinction belongs in the group’s map of foreign positions today, because it determines who will have to adapt the sales cycle, and under which legal system. It must be said, however, that this contrast holds for the 2025 option and does not extend to 2030: the new Article 262 addresses the taxable person «identified for VAT purposes», and the new Article 271a allows Member States to impose domestic digital reporting on taxable persons «established or identified for VAT purposes» in their territory. Anyone concluding that mere identification offers permanent shelter makes an error of perspective.

From 1 July 2030: reporting transaction by transaction

Article 5 of the directive gathers the amendments taking effect on 1 July 2030; the transposition deadline is 30 June 2030, with application from 1 July 2030 (Article 6(5)). It should be noted that the Italian version of the first subparagraph of Article 6(5) refers, through a clerical error, to «Article 4» instead of Article 5: the English version and the scheme of Article 6, whose paragraph 4 already governs Article 4, leave no doubt as to the scope of the provision.

The new Article 262 requires the taxable person identified for VAT purposes to transmit the data listed in Article 264 for: the supplies and transfers referred to in Article 138(1) and Article 138(2)(c); the intra-Community acquisitions referred to in Article 20 and the transactions treated as such under Articles 21 and 22; supplies of goods and services that are not exempt and for which the customer is liable for the tax under Article 194, in so far as the customer is identified for VAT purposes, or under Articles 195, 196 or 197; and the corresponding acquisitions, for which Article 204 also comes into play, that is, the case of a tax representative. Paragraph 2 provides that the data are transmitted to the Member State that issued the VAT identification number used for the transaction; paragraph 3 exempts from transmission those persons registered under the special scheme starting on 1 July 2028, as regards transfers of own goods and transactions treated as such. Paragraph 4 allows Member States to exempt taxable persons from transmitting data on acquisitions, subject to notification to the Commission, which informs the other Member States before the measure enters into force and before it ceases to apply: it is an option, not a rule, and the choice of the Italian legislature cannot be predicted today.

The new Article 263 sets the timing. Data are transmitted for each individual transaction, at the time the invoice is issued or should have been issued. Where the invoice is issued by the customer on behalf of the supplier, the deadline is five days from the date on which the invoice is issued or should have been issued. On the acquisitions side, transmission takes place within five days of receipt of the invoice. Member States must provide the electronic means for transmission and must allow data to be sent in accordance with the European standard on electronic invoicing under Directive 2014/55/EU. Paragraph 4 specifies that the common electronic message for transmitting the data is to be determined under the procedure of Article 58(2) of Regulation (EU) No 904/2010: that message does not yet exist, a circumstance to bear in mind in dealings with software providers.

Failure to report costs the exemption

This is the point that gives weight to everything else, and it deserves to be quoted in full. Article 138(1a), in the version applicable from 1 July 2030, provides that «the exemption provided for in paragraph 1 of this Article shall not apply where the supplier has not complied with the obligation provided for in Articles 262 and 263 to communicate the data on intra-Community transactions, or where the data transmitted do not contain the correct information concerning the supply as required under Article 264, unless the supplier can duly justify any shortcomings to the satisfaction of the competent authorities».

A mirror provision, this time optional, operates on the input side. The new final paragraph of Article 168 allows Member States to provide that, for transactions subject to the reporting obligations of Article 271a(1), the right to deduct is available only to a customer holding an electronic invoice issued in accordance with Article 218(3).

The mechanism is not new: Article 138(1a) has existed since 1 January 2020, by virtue of Directive (EU) 2018/1910, and in Italy it has operated since 1 December 2021 in Article 41(2-ter) of Decree-Law No 331 of 1993, carried over from 1 January 2027 into Article 39(4) of the consolidated act. What changes in 2030 is the object of the condition: no longer the correct completion of the recapitulative statement, but the correct transmission of the data on the individual transaction, at the time of the invoice. The window in which to spot an error and put it right before the deadline disappears.

The end of recapitulative statements, and the Italian cross-border data return

Point 18) of Article 5 deletes Articles 265 to 271 of Directive 2006/112/EC, that is, the rules on recapitulative statements. The periodic, cumulative model disappears and is replaced by a continuous, transaction-based flow.

Italian businesses currently file those statements under Article 50(6) of Decree-Law No 331 of 30 August 1993, converted with amendments by Law No 427 of 29 October 1993. That provision is repealed, with effect from 1 January 2027, by Article 170(1)(s) of the consolidated VAT act annexed to Legislative Decree No 10 of 19 January 2026, which carries the rules over into Article 101(6). For those businesses the change is not one of forms but of process: there will no longer be a monthly or quarterly window in which to reconcile, correct and complete the data before filing. Accuracy will have to be secured upstream, on the individual document, because transmission will follow issuance immediately and will be a condition of the exemption.

The Italian obligation that overlaps with the new reporting is not only that one: there is also the transmission of data on cross-border transactions, governed together with electronic invoicing by Article 1 of Legislative Decree No 127 of 2015 and carried over, from 1 January 2027, into Article 77 of the consolidated act — the so-called esterometro. Once the new Article 262 is fully in force, the two flows will largely cover the same transactions: rationalising them is a choice for the national legislature, not an automatic effect of the directive. It also remains to be settled, on transposition, what becomes of the statistical return that today accompanies the statement: the VAT directive does not govern it, whereas Article 101(6) of the consolidated act also attributes statistical purposes to the return.

The European electronic invoice: format and deadlines

The new Article 217 defines an electronic invoice as a document containing the information required by the directive which, at least as regards the data referred to in Articles 262 and 271b, has been issued, transmitted and received in a structured electronic format suitable for automatic and electronic processing. The new Article 218 provides, in paragraph 2, that invoices are to be issued as electronic invoices, while Member States remain free to accept documents or messages on paper or in electronic formats other than electronic invoices for transactions not subject to the reporting obligations of Chapter 6. Paragraph 3 requires compliance with the European standard on electronic invoicing and the related list of syntaxes under Directive 2014/55/EU, and allows Member States to authorise other standards for domestic transactions only, other than those covered by Article 262. The standard in question is EN 16931-1:2017, with the list CEN/TS 16931-2:2017, whose references were published by Commission Implementing Decision (EU) 2017/1870. Paragraph 5 permits the use of a public portal, where available.

Article 232 is rewritten for 2030 as well: issuing an electronic invoice compliant with the European standard is no longer subject to acceptance by the recipient, whereas issuing invoices compliant with other standards, or in other electronic formats, remains subject to acceptance. With two derogations: for transactions not subject to the reporting obligations of Chapter 6, Member States that have used the option in Article 218(2) — which in the version applicable from 2030 has a different content from the second paragraph added in 2025 — may continue to make even invoices compliant with the European standard subject to acceptance; and, conversely, Member States that have used the option in Article 218(3) may provide that invoices compliant with other standards are not subject to acceptance by a recipient established in their territory. It is the second derogation that bears directly on a national format such as FatturaPA.

The invoicing deadlines change too. The new first paragraph of Article 222 provides that, for intra-Community supplies under Article 138 and for transactions on which the tax is payable by the customer under Articles 194 to 197, the invoice is to be issued within ten days of the day on which the chargeable event occurs; the same period runs from receipt of a payment on account for transactions on which the customer is liable. The new Article 223 narrows summary invoicing: it is allowed only where the VAT on the transactions listed becomes chargeable in the same calendar month; for the transactions covered by Article 222 alone, the summary invoice must be issued within ten days of the end of the calendar month to which it relates; Member States may in addition exclude summary invoicing in sectors at risk of fraud, informing the VAT Committee. For Italy the friction lies not in the length of the period, which is already monthly, but in the deadline: invoices for intra-Community supplies are today issued by the fifteenth day of the month following that in which the transaction is carried out (Article 46(2) of Decree-Law No 331 of 1993), so the new time limit is shorter than the current one.

Finally, the mandatory content of the invoice grows. Article 226 is amended to add, in point 16), the sequential number identifying the invoice being corrected and, in point 17), the supplier’s bank account or virtual account numbers, or any other identifier unambiguously identifying the account to which the recipient may pay; point 11a requires, for supplies on which the customer is liable under Article 197, the additional wording «triangular transaction». Since Article 264 refers to Article 226, those data also enter the transmitted flow: this is master-data work, and it must be planned.

Italy, the expiring derogation and the 2035 date

Italy’s general electronic invoicing obligation has been in force since 1 January 2019 under Article 1 of Legislative Decree No 127 of 5 August 2015, with transmission through the Exchange System (Sistema di Interscambio). From 1 January 2027 those rules are carried over into Article 77 of the consolidated VAT act annexed to Legislative Decree No 10 of 19 January 2026; at the same time Article 170(1)(lll) of that consolidated act repeals Article 1 of Legislative Decree No 127 of 2015. The obligation still rests on a special measure derogating from Articles 218 and 232 of the VAT directive: Council Implementing Decision (EU) 2018/593 of 16 April 2018, whose effects were extended to 31 December 2027 by Council Implementing Decision (EU) 2024/3150 of 10 December 2024. That decision also provides that the authorisation ceases to apply on the day a general system for electronic invoicing adopted by the Council enters into force, and sets 31 March 2027 as the deadline for any request for a further extension. The 2027 expiry does not, however, call the Italian obligation into question: since 14 April 2025 the derogation is no longer needed, because the second paragraph of Article 218 gives Member States a direct legal basis, to be exercised by national rule. It is indeed debated whether the authorisation has already lapsed, by virtue of the clause just referred to. The point has limited practical bearing, but it should be kept in mind when reading the 31 March 2027 deadline.

Point 19) of Article 5 then inserts a new Section 2 into Chapter 6, comprising Articles 271a, 271b and 271c: Member States may require digital reporting for domestic transactions made to themselves or to other taxable persons as well, with transmission for each individual transaction at the time the invoice is issued, or within five days in cases of self-billing and of receipt, and may limit the obligation to certain categories of taxable persons or types of transaction. Article 271b(3) allows other data formats than the European standard to be authorised «provided that the other data formats ensure interoperability with that standard»: this is the technical basis on which a national format such as FatturaPA may rest. Article 271c requires the Commission to submit to the Council, by 31 March 2033, an interim evaluation report.

Alongside this operates the new Article 273, which is the real safeguard for legal systems already equipped. On the one hand it forbids Member States from implementing new general transaction-by-transaction reporting obligations beyond those of Chapter 6; on the other it allows Member States which on 1 January 2024 already imposed general transaction-by-transaction reporting obligations other than those of Article 262 to maintain them «until they implement a digital and real-time reporting system of supplies of goods and services which complies with the requirements laid down in Chapter 6, Section 2», with an equivalent rule for the acquisitions side.

The alignment clause in the third subparagraph of Article 6(5) operates on the same ground. Member States which on 1 January 2024 imposed a national real-time transaction-by-transaction digital reporting obligation, or which before that date had obtained an authorisation under Article 395 or adopted national rules providing for such an obligation, are to apply by 1 January 2035 the measures of Article 5, point 5 (the new Article 218) and Article 5, point 19 (Articles 271a and 271b) as regards domestic electronic invoicing and reporting. If the interim report reveals shortcomings, the Commission is to assess whether further measures are needed and, if appropriate, propose postponing that deadline.

The clause is drafted so as to capture legal systems that already had a national obligation, and the Italian system came into being before the European one. Whether, and to what extent, the Italian obligation falls within that description, and how the clause relates to the safeguard in Article 273, is nevertheless a question of classification to be settled on transposition: the provision lays down a condition, not an accomplished fact. What can be said today is that the direction is convergence on the European standard and the permitted syntaxes, and that the transitional period is not a period of inactivity.

The intermediate stages, and the call-off stock calendar

Article 2 of the directive gathers the amendments taking effect on 1 January 2027, to be transposed by 31 December 2026: among them the recasting of Article 14a on the deemed supplier and the changes to the one-stop shops and to the special schemes of Title XII, which we examined in connection with the EUR 10,000 threshold in electronic commerce. Article 3 provides for amendments taking effect on 1 July 2028, to be transposed by 30 June 2028: the platform economy with the new Article 28a, the recasting of Article 194 and the special scheme for transfers of own goods. As regards Article 3, point 1) — the new Article 28a on the deemed supplier for platforms in short-term accommodation rental and passenger transport — Member States are to apply the measures no earlier than 1 July 2028 and no later than 1 January 2030.

Article 4 contains only two provisions, taking effect on 1 July 2029 and to be transposed by 30 June 2029: the deletion of Article 243(3) and Article 262(2), that is, of the register and the reporting relating to call-off stock. The end of the regime itself comes earlier and is laid down in Article 2: with effect from 1 January 2027, point (a) of Article 17a(2) is replaced so as to cover only goods dispatched or transported «on or before 30 June 2028», and a paragraph 8 is added under which the article «shall cease to apply on 30 June 2029». For a business holding stock at a foreign customer’s premises the calendar is therefore this: no new call-off stock arrangements for dispatches after 30 June 2028; existing arrangements to be wound up by 30 June 2029; the related documentary obligations disappearing from 1 July 2029. The alternative is the special scheme for transfers of own goods, which Article 3 introduces with effect from 1 July 2028.

It is worth noting, finally, that the first EU stage, 1 January 2027, coincides with the date on which Italian domestic law is rewritten in its entirety: from that day the provisions of the consolidated VAT act annexed to Legislative Decree No 10 of 19 January 2026 apply (Article 171), repealing among other things Articles 37 to 52 of Decree-Law No 331 of 1993 and Article 1 of Legislative Decree No 127 of 2015, and carrying their content over into its own articles. Anyone looking in 2027 for Article 50 of Decree-Law No 331 of 1993 will no longer find it: references to the repealed provisions are to be construed as references to the corresponding provisions of the consolidated act (Article 170(3)).

In practice

• By 1 January 2027 — update internal statutory references. Contracts, procedures, invoice notes and forms citing Decree-Law No 331 of 1993 or Legislative Decree No 127 of 2015 should be updated to cite the corresponding articles of the consolidated act: the references remain valid by virtue of Article 170(3), but a document citing a repealed provision loses authority. It is the only item on this list that can already be carried out in full.
• By 2026-2027 — map the foreign VAT positions and classify each one. For every Member State it is necessary to record whether the group is established there (fixed establishment, subsidiary) or merely identified: that distinction governs exposure to the national electronic invoicing obligations that Member States have been able to impose since 14 April 2025. This is work for the finance function, with input from those who follow the foreign holdings.
• By 2027 — decide the fate of call-off stock arrangements. Contracts providing for dispatches after 30 June 2028 must be identified, and the winding-up of the stock must be planned by 30 June 2029, considering the move to the special scheme for transfers of own goods, available from 1 July 2028.
• At the first renewal — put the software provider’s commitments in writing. Since the common electronic message has not yet been adopted, the request should be framed as an undertaking to adapt by the dates set in the directive, not as a declaration of conformity with a specification that does not exist, and it must cover receiving as well as issuing.
• By 2029 — complete the master data required by the new Article 226: the supplier’s payment accounts, the sequential reference of the invoice being corrected, the wording «triangular transaction» where applicable. These data will enter the transmitted flow and should be collected in advance, not on the eve of the deadline.
• By 2029 — review invoicing times and self-billing arrangements. It is necessary to identify the transactions that will have to be invoiced within ten days of the chargeable event. Arrangements with customers who issue the document on the supplier’s behalf must then be rewritten, setting delivery times, traceability and liability for delay, since in those cases transmission must take place within five days.
• On an ongoing basis — move upstream the controls now concentrated at the periodic deadline. The completeness of master data and VAT numbers must be checked when each document is recorded: from 2030 an incorrect item will not be a formal irregularity, but may cost the exemption on the intra-Community supply. The evidence needed to «duly justify» any shortcoming should also be retained: transmission receipts, rejection logs, correspondence with the software provider.

Frequently asked questions

Can an Italian business with a VAT registration in another Member State, but no fixed establishment there, be required to issue electronic invoices on domestic transactions under the directive?

Under the option introduced in the second paragraph of Article 218, in force since 14 April 2025, no: that option concerns taxable persons established in the territory of the Member State, and a person merely identified there does not fall within it. The conclusion does not extend to 2030, however, because the new Article 271a allows Member States to impose domestic digital reporting on persons who are merely identified as well. The domestic rules of the Member State concerned, and the legal basis on which they rest, naturally remain to be checked.

Are recapitulative statements still due?

Yes. Articles 265 to 271 of Directive 2006/112/EC are deleted with effect from 1 July 2030. Until 31 December 2026 the obligation remains the one laid down by Article 50(6) of Decree-Law No 331 of 1993; from 1 January 2027, the one laid down by Article 101(6) of the consolidated VAT act annexed to Legislative Decree No 10 of 19 January 2026, which reproduces its content. Replacement by transaction-by-transaction reporting still requires domestic transposition.

Does the Italian Exchange System come to an end in 2030?

The directive does not abolish national systems; on the contrary, the new Article 273 allows Member States which on 1 January 2024 already imposed general transaction-by-transaction reporting obligations to maintain them until a system compliant with Chapter 6, Section 2, has been implemented. On the technical side, Article 271b(3) admits formats other than the European standard provided they ensure interoperability with it. The clause in the third subparagraph of Article 6(5) nevertheless sets, for those legal systems, an alignment by 1 January 2035. What remains of the Italian model, and in what form, depends on the transposition choices.

However, the foregoing describes the text of the directive, not the domestic law that will follow from it. None of the obligations taking effect in 2027, 2028, 2029 and 2030 is directly applicable to Italian taxpayers today without national transposing rules; Regulation (EU) 2025/517 is a different matter, since as a regulation it requires no transposition and concerns administrative cooperation between Member States rather than the obligations of taxable persons. On significant points, moreover, the directive leaves choices to the Member States that have not yet been made: the optional waiver on the acquisitions side, the extension of digital reporting to domestic transactions, whether to make the right to deduct conditional, the permitted formats and the classification of the Italian obligation for the purposes of the 2035 clause. The operational indications given here therefore serve as preparation and impact analysis, not as compliance steps: they will need to be revisited in the light of the implementing measures and the practice that accompanies them.

Sources

Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age (Official Journal of the European Union, L series, 2025/516 of 25 March 2025), Articles 1, 2, 3, 4, 5, 6 and 7; Council Regulation (EU) 2025/517 and Council Implementing Regulation (EU) 2025/518, both of 11 March 2025; Council Directive 2006/112/EC of 28 November 2006, Articles 14a, 17a, 20, 21, 22, 28a, 138, 168, 194, 195, 196, 197, 204, 217, 218, 222, 223, 226, 232, 243, 262, 263, 264, 265 to 271, 271a, 271b, 271c, 273 and 395; Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014; Council Regulation (EU) No 904/2010, Article 58; Commission Implementing Decision (EU) 2017/1870 of 16 October 2017 (standard EN 16931-1:2017 and list of syntaxes CEN/TS 16931-2:2017); Council Directive (EU) 2018/1910 of 4 December 2018; Council Implementing Decision (EU) 2018/593 of 16 April 2018 and Council Implementing Decision (EU) 2024/3150 of 10 December 2024; Legislative Decree No 127 of 5 August 2015, Article 1; Decree-Law No 331 of 30 August 1993, Articles 41, 46 and 50, converted with amendments by Law No 427 of 29 October 1993; Legislative Decree No 10 of 19 January 2026, consolidated VAT act, annex, Articles 39, 77, 101, 170 and 171; European Commission, Directorate-General for Taxation and Customs Union, page on VAT rules for the digital age; Council of the European Union, press release of 11 March 2025 on the adoption of the package.