New M sheet rules to enter into force as of 1 July 2026

The legislative change carries two closely interrelated messages to taxpayers.

First, from the second half of 2026, new data-content requirements will apply to the M Sheet. Taxpayers that continue to submit their VAT returns in the traditional manner via ÁNYK will be required to report, on the M-02 and M-02-K sheets, the VAT actually deducted on an invoice-line basis, broken down by VAT rate (5%, 18% and 27%) and, where applicable, on a pro-rated basis.

Second, taxpayers opting for the eVAT system will be fully exempt from the obligation to complete the M Sheet.

The question is therefore clear: will businesses continue to submit their VAT returns via ÁNYK, or will they move towards eVAT? More importantly, is it worth launching a costly IT development project now, when version 2.0 of eVAT is scheduled to go live only from 1 August 2026, with with testing available only from July?

What will change from 1 July 2026?

The “Receipt of invoices” section will be amended so that, from the tax assessment period including 1 July 2026, taxpayers will be required to report:

• the amount of VAT charged on the invoice, which has already been mandatory;
• the amount of VAT actually deducted on the basis of the invoice, broken down by VAT rate (5%, 18% and 27%); and
• the amount of input VAT deducted on a pro-rata basis.

The data content of the K Sheet, which relates to amending and cancellation invoices, will also be expanded. Amounts deducted or reversed as payable VAT on the basis of correction documents will also have to be reported by VAT rate.

The completion guide for the 2665 VAT return, published by the Hungarian Tax Authority, highlights that the completion of the new data fields will remain voluntary in the first half of 2026, but will become mandatory from 1 July 2026 for taxpayers submitting their returns via ÁNYK. By contrast, eVAT users will be exempt from this obligation, irrespective of whether they fulfil their VAT return filing obligations through the web interface or via an M2M connection.

What does this mean in practice?

If a business continues to use ÁNYK, its accounting or ERP system will need to be prepared to allocate, to each incoming invoice, the VAT rate of the amount actually deducted and the result of any pro-rata calculation at invoice-line level. Where this is not feasible from an IT development perspective, or would require significant implementation effort, the M Sheet will need to be supplemented manually with the relevant data.

This may result in considerable development and testing efforts for a system which, in line with the Hungarian Tax Authority’s plans, is expected to be replaced by eVAT approximately six months later, on 1 January 2027, when ÁNYK is planned to be phased out.

eVAT is the future – but not necessarily immediately

The Hungarian Tax Authority launched the eVAT system on 1 January 2024, making two versions available to taxpayers. The web interface is primarily recommended for smaller businesses with lower invoice volumes, while the M2M connection, i.e. machine-to-machine communication, enables automated, direct integration for businesses with higher transaction volumes.

Currently, version 0.9 of eVAT is available to taxpayers. However, businesses that have not yet started development or testing may wish to consider waiting for the release of version 2.0. Testing of the new version will only be possible from July 2026, and with its go-live on 1 August 2026, the current 0.9 version will also be phased out.

It is therefore open to question whether it is worthwhile switching to eVAT now, or whether it would be more appropriate to wait for version 2.0 to go live – while also taking into account the expanded M Sheet reporting obligation.

Managing the transition: our M Sheet completion service

Forvis Mazars Hungary’s automated domestic recapitulative statement service offers a practical solution for businesses that do not yet wish to embark on a costly eVAT implementation project and would prefer to outsource the administrative burden associated with completing the M Sheet to an experienced professional adviser.

How does it work?

Using Forvis Mazars’ proprietary in-house conversion technology, the editable .enyk file to be submitted to the Hungarian Tax Authority is generated automatically from the client’s VAT analytics, with minimal manual intervention.

Through our service, compliance with the new M Sheet rules effective from 1 July 2026 becomes our responsibility rather than yours. There is no need to initiate ERP development or modify your existing solution for the sake of a six-month transitional period and you do not need to worry about your accounting team’s capacity being absorbed by the manual handling of invoice-line level data broken down by VAT rate.

When the time comes to transition to eVAT, our eVAT services will also be available to support you. Depending on the selected service package, this may include not only technical data reporting, but also data processing, structuring, multi-layer logical validation, and the submission of the VAT return via M2M — even as of today.

In other words, the transition does not need to take place in a single step. Businesses can move towards the new era of digital tax compliance at their own pace and in line with their own operational needs.

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Should you have any questions in relation to the above, our advisers would be pleased to assist you.