• Changes in the online data reporting regulations

Changes in the online data reporting regulations

15 December 2020

We would like to draw your attention to some important changes affecting the online invoice data reporting obligation:

  • Online invoicing XSD scheme v3.0 – 1 January 2021
  • New taxpayers subject to reporting obligation


Below we would like to inform you in detail about the most important changes affecting online invoice data reporting obligations.

Online invoicing XSD version 3.0

As of 1 January 2021, online invoice data reporting will be expanded and the Online Invoicing XSD scheme v3.0 will be introduced. This implies that every invoice issued under HU VAT number would fall under reporting obligation regardless the customers, value or any other restrictions[1].

Invoice data should be reported electronically, without human intervention, online, in a pre-defined XML structure and immediately once the invoice has been issued.

There will be a three month grace period until 31 March 2021, where the previous XSD scheme v2.0 still could be used, but from 1 April 2021, only v3.0 will be available, which aim is to whitening the economy, preparation of VAT returns by the Hungarian tax authority, also data protection and paperless invoicing.

The version update could cause IT difficulties, and it will also change the structure of the data to be reported to the Hungarian tax authority.

XSD v3.0 schema is also important from data protection point of view as this specification ensures the anonymity of personal data.

As various international transactions (intra-Community sale of goods and services, exports, export services) will be included in the data reporting obligation from 2021, the structure related to the tax rate will change significantly.


New taxpayers subject to reporting obligation

As of 1 January 2021, the change in the VAT Act on the data reporting will enter into force. It is important to know that sales to non-taxable persons as well as supplies inside and outside the EU will also be required to report invoice data in the Online Invoice system. From 2021, the following customer groups can be separated in the data reporting:


  • Domestic or intra-Community taxable person: name, address and tax number (EU VAT number for an intra-Community customer) have to be indicated on the invoice layout and also during the data reporting.
  • Non-Community taxable person: name and address would be mandatory to report, tax number is optional, but it is possible to indicate it on the invoice layout and during the data reporting.
  • Non-taxable and non-private customer: name and address are mandatory on both the invoice layout and data reporting. This category includes, for example, non-economic associations, foundations and associations engaged in public activity.
  • Private customer: name and address would be mandatory to indicate on the invoice layout, but should not be included in the data reporting.

Grace period

Due to the coronavirus epidemic, the Hungarian tax authority granted a delay in migrating to XSD schema v3.0. Until 31 March 2021, the currently applicable version of the XSD schema v2.0 can still be used without any penalty. Therefore, the migration to XSD 3.0 will not be mandatory from 1 January 2021 as originally planned, but only from 1 April 2021.


[1]Exception: supply of goods or services where the place of supply falls to another Member State, and the taxpayer completed its tax payable liability by special rules of distance sales defined by the Act on Rules of Taxation.