Under the digital reporting requirements that apply from 1 July 2030, the data your business transmits to a tax administration for a cross-border B2B supply contains no names and no addresses. Article 264 of the VAT Directive, as replaced by Council Directive (EU) 2025/516, lists exactly which invoice particulars get reported — and the full name and address of supplier and customer, Article 226 point (5), is not among them for any of the five transaction types. What is reported is both parties’ VAT identification numbers, the invoice number, the number of the invoice being corrected, and the supplier’s bank account.
That single design choice tells you where ViDA readiness actually sits. There is no human-readable fallback in the reported data set. If an identifier is wrong, nothing downstream can rescue it, and from 2030 wrong data has a price attached: the intra-Community exemption itself.
What ViDA readiness actually requires from your data
The reported data set is defined by reference, not by form. Article 264 points to specific numbered items in Article 226, and the combination differs by transaction type. The result is that the same shipment is reported by the two parties with different field counts.
| Reported transaction | Article 226 points transmitted | Count |
|---|---|---|
| Intra-Community supply of goods; supplies where the customer is liable under Articles 194–197 | 1–4, 6, 7, 8, 11, 16, 17 (plus 11a where relevant) | 10 |
| Transfer of own goods under Article 138(2)(c) | 1–4, 6, 7, 8, 11, 16 | 9 |
| Intra-Community acquisition of goods | 1–4, 6, 7, 8, 9, 10, 11, 16, 17 | 12 |
| Transactions treated as acquisitions under Article 21 | 1–4, 6, 7, 8, 9, 10, 11, 16 | 11 |
| Acquisitions where the customer is liable under Articles 194–197 or 204 | 1–4, 6, 7, 8, 9, 10, 16, 17 (plus 15 where relevant) | 11 |
A supplier reporting an intra-Community supply sends ten data points. The customer reporting the matching acquisition sends twelve — the two extra being the VAT rate and the VAT amount, which the supplier does not report because the supply is exempt at their end. Both sides of a single economic transaction are therefore reconstructed from coded reference data on both ledgers, and the tax administration’s cross-check works only if the two sets agree.
Note also what is absent. There is no field for the goods’ commodity code, no procurement classification, and no free-text explanation. Article 226 point (6) asks for the quantity and nature of the goods or the extent and nature of the services — a description, not a taxonomy. ViDA does not impose a product classification scheme at EU level.
Why wrong data now costs money, not rework
Three provisions turn data quality into a financial exposure rather than an operational annoyance.
First, from 1 July 2030 Article 138(1a) is amended so that the exemption for intra-Community supplies does not apply where the supplier has failed to report, or where the transmitted data do not contain the correct information required under Article 264, unless the supplier can justify the shortcoming to the competent authorities. A mistyped customer VAT identification number is no longer a correction to make next month; it is a supply that is prima facie taxable.
Second, a new paragraph in Article 168 lets Member States provide that a customer may deduct or reclaim VAT only where that customer holds an electronic invoice issued in accordance with Article 218(3) — that is, compliant with the European standard. Recital 8 of the directive is explicit that holding a compliant electronic invoice may be made a substantive condition of the right to deduct. Greece already runs a version of this: expense documents without the platform’s registration mark are not deductible.
Third, from 1 July 2028, Article 28a(4) allows Member States to require platforms treated as deemed suppliers to validate their underlying supplier’s VAT identification number by means established in national law. Verification stops being prudent practice and becomes a mandated control.
Legal entities and VAT identification numbers
The VAT identification number carries almost all of the identity load in the reported data set, so the register behind it has to be accurate, current and mapped to the right legal entity.
The VIES service is the only Union-wide way to check one. Supplying your own VAT number alongside the number you are checking returns a consultation number — a timestamped record that you performed the check, which is the evidence you will want when a customer’s registration is cancelled after the transaction. VIES reports current status only; it keeps no history for you, so the log is yours to maintain.
Two further changes make counterparty status a determination input rather than a reference detail:
- Mandatory reverse charge from 1 July 2028. The replaced Article 194 makes the customer liable where the supplier is neither established nor identified for VAT in the Member State where VAT is due, provided the customer is already identified there. Whether you charge VAT now turns on your own registration footprint and your counterparty’s, in a specific Member State, at a specific date.
- The transfer of own goods scheme from 1 July 2028. A new special scheme lets a business report cross-border movements of its own stock under a single identification, and call-off stock arrangements are phased out — no new arrangements after 30 June 2028, and the provisions cease to apply on 30 June 2029. Warehouse and plant master data has to know which entity, under which registration, holds stock where.
This is not a new insight so much as an old one that has finally acquired a deadline. Writing years before any of these mandates existed, the e-invoicing analyst Bruno Koch identified “unique identification of trading partners based on compliant master data” as the precondition for automated invoicing, not an optional refinement.
Tax codes: mapping your chart of codes to ten categories
Most ERP systems carry dozens to hundreds of internal tax codes accumulated over years of country rollouts. EN 16931 recognises ten. The VAT category code at line and breakdown level draws on code list UNCL 5305, and the subset permitted by the standard is: S, Z, E, AE, K, G, O, L and M — standard rate, zero-rated, exempt, reverse charge, intra-Community supply, export, out of scope, and the two Canary Islands and Ceuta/Melilla categories.
Every internal code has to resolve to one of those, plus a rate, plus — where the category is an exemption or a reverse charge — a reason. Article 226 point (11) requires a reference to the applicable provision of the Directive, the corresponding national provision, or another indication that the supply is exempt, and Member States differ on which of those they accept. Croatia, Hungary and Romania have required a citation of national VAT law specifically; France, Germany, Poland, Portugal and Spain have accepted either the national provision or the Directive. National content rules move, so treat this as a mapping to be maintained per jurisdiction rather than configured once.
The same applies to currency. Some Member States require the VAT amount to be stated in euro, others in the national currency, and the two are not interchangeable in a structured invoice — the standard carries both a document currency and a VAT accounting currency, and populating the second one only when a particular tax administration expects it is a rules-driven decision, not a default.
Addresses, countries and electronic addresses
Postal addresses are not in the ViDA reported data set, but they determine what goes in it. Place of supply, the applicable rate, whether an exemption exists, and whether reverse charge applies are all derived from country and establishment data. An address that is good enough to print on a document is not necessarily good enough to drive determination: a country code, a reliable ship-to versus bill-to distinction, and a clean mapping between establishments and VAT registrations are the parts that matter.
Routing is a third identifier again, separate from both the legal entity and the VAT number. EN 16931 carries an electronic address qualified by a scheme identifier from the Electronic Address Scheme code list maintained by the Commission, alongside party identifiers qualified by ISO 6523 scheme codes. In practice a single counterparty can hold a legal registration number, a VAT identification number, and a network address that resolves to a different service provider — three values that must be maintained together and that drift apart independently.
Product and service data: what ViDA requires and what it doesn’t
ViDA requires a description, not a classification. That is worth stating plainly because vendors sometimes imply otherwise. Nothing in Article 264 asks for a Combined Nomenclature code, a CPV code or an industry taxonomy.
National systems are a different matter, and they are where classification obligations actually arise. Greek B2G invoices carry a Common Procurement Vocabulary code alongside the contracting authority reference, and the Greek digital delivery note regime adds product-level detail for goods in transit. If your operating footprint includes jurisdictions running their own clearance or goods-movement systems, the classification work is real — it is simply not an EU-level ViDA requirement, and budgeting it as one will misallocate the effort.
Correction logic is now a reported field
Two new items enter Article 226 from 1 July 2030. Point (17) requires the supplier’s bank account numbers, virtual account numbers, or other identifiers that unambiguously identify the accounts into which the invoice can be paid — recital 16 explains the purpose as letting administrations follow the financial flows as well as the goods. Point (16) requires, for a corrective invoice within the meaning of Article 219, the sequential number of the invoice being corrected.
Point (16) is the one that breaks poorly designed systems. It makes the original invoice number a foreign key that has to remain unique, stable and resolvable for as long as corrections can be issued. Three consequences follow:
- Number reuse becomes dangerous, and the rules are not uniform. Where a clearance platform rejects an invoice outright, Italy treats the document as never having been issued, which frees the number; India’s registration portal does not permit reuse of a document number after cancellation. A single global numbering policy has to satisfy the strictest jurisdiction you operate in.
- Document type has to be modelled, not inferred. EN 16931 codes the functional type of the document from UNTDID 1001 — 380 for a commercial invoice, 381 for a credit note, 384 for a corrected invoice, 389 for a self-billed invoice. A process that issues everything as a credit note because the finance system finds it simpler will not survive validation against national profiles that restrict the permitted subset.
- There is no periodic restatement to hide behind. Recapitulative statements go: Article 262(2) is deleted from 1 July 2029 and Articles 265 to 271 from 1 July 2030. Corrections travel as linked transactions in the same real-time stream that carried the original, within the same tight windows — the supplier transmits when the invoice is issued or should have been issued, a self-biller within five days of issue, and a customer reporting an acquisition within five days of receiving the invoice.
Those windows sit alongside a shortened issuance deadline: from 1 July 2030 an invoice for a cross-border supply must be issued within 10 days of the chargeable event, replacing the fifteenth day of the following month. Summary invoices survive, but must be issued within 10 days of month end, and Member States may exclude them entirely in fraud-sensitive sectors.
The audit trail you will need to keep
ViDA removes some reporting obligations and leaves the record-keeping ones firmly in place. Records under the new transfer-of-own-goods scheme must be kept for 10 years from 31 December of the year of the transfer, and the platform record-keeping obligation in Article 242a carries the same 10-year period.
The amended Article 273 draws a line worth understanding. Member States may no longer impose additional invoicing obligations beyond Chapter 3, nor create new general transaction-based reporting obligations on top of the digital reporting requirements. But they may still require taxable persons to store transaction data for preparing a VAT return or for audit — which is exactly why SAF-T obligations survive ViDA rather than being displaced by it. Real-time reporting and periodic file extraction are separate obligations drawing on the same underlying records, and both have to reconcile to the ledger.
One thing is genuinely not yet known. Article 263(4) provides that the common electronic message for transmitting the data will be determined through the committee procedure under Article 58(2) of Regulation (EU) No 904/2010. Until that message is published, nobody can build the final transmission layer — which is an argument for spending the intervening years on the data rather than on the pipe.
What to fix, and in what order
The sequence follows the transposition dates rather than the headline 2030 one.
- Now. Deduplicate legal entities and map each to its VAT registrations by Member State and validity period. This is the input to every determination rule that follows, and it is the longest-lead item on the list.
- Now. Instrument VIES checking and retain the consultation numbers with the transaction, not in a separate spreadsheet. The evidence has to be retrievable per invoice.
- By end-2026. Member States must have transposed the 1 January 2027 changes. Review the OSS and IOSS clarifications against your registration footprint before then.
- 2027–2028. Rebuild tax determination around counterparty establishment and identification status, ready for mandatory reverse charge and the transfer-of-own-goods scheme on 1 July 2028. Retire call-off stock arrangements ahead of 30 June 2028.
- 2028–2029. Fix numbering and correction logic. Enforce uniqueness at the level of the issuing entity, model document types explicitly, and make the reference to the corrected invoice a first-class field rather than a note.
- By 1 July 2030. Bank account master data becomes reportable tax data. Decide now who owns it, how changes are authorised, and how it is protected.
- By 1 January 2035. Member States with a domestic real-time reporting system in place on 1 January 2024 align it with the EU model. If you operate in Italy, Hungary, Spain, Poland, Portugal or Greece, this is when your existing national integration gets rebuilt.
Nothing on that list is a provider selection decision. A provider connects you to a network and formats a message; it cannot tell you which legal entity made the supply, which registration applied, or whether the number on the customer master record was valid on the date of the chargeable event. Those answers live in your systems, and the directive now attaches a cost to getting them wrong.
Frequently asked questions
Does ViDA require me to report customer names and addresses?
Not for the cross-border digital reporting requirements. Article 264 lists the Article 226 points to be transmitted, and point (5) — full name and address of the taxable person and the customer — appears in none of the five data sets. Names and addresses remain mandatory invoice content under Article 226; they are simply not part of what is reported.
Can I lose the intra-Community exemption over a data error?
Yes, from 1 July 2030. The amended Article 138(1a) withholds the exemption where the supplier has not complied with the reporting obligation or where the transmitted data do not contain the correct information required under Article 264 — subject to the supplier being able to justify the shortcoming to the competent authorities. The safety valve exists, but it is a defence you have to mount rather than an automatic tolerance.
Do I need a product classification scheme for ViDA?
No. The reported data set requires the quantity and nature of the goods or the extent and nature of the services, not a coded taxonomy. Classification obligations arise from national systems — Greek public-sector invoicing, goods-movement reporting, and similar regimes — rather than from the directive.
Does ViDA replace SAF-T?
No. The amended Article 273 explicitly preserves the ability of Member States to require taxable persons to store transaction data for preparing a VAT return or for audit purposes, and the recitals name SAF-T as an example of a tool Member States may keep alongside real-time reporting. Plan for both.
How many invoice fields does EN 16931 actually contain?
The core semantic model runs to roughly 160 business terms, of which a much smaller set is mandatory in every invoice. Figures in the several-hundred range usually count national extensions and optional groups. The practical constraint is rarely the number of fields — it is how many of them your source systems can populate with values that pass Schematron validation without manual intervention.