VAT in the Digital Age (ViDA) and E-Invoicing Requirements in the Netherlands
Transition to E-Invoicing: Key Insights
In the Netherlands, e-invoicing is already a requirement for transactions with government bodies. This obligation will soon extend to all business-related invoicing, including business-to-government (B2G), business-to-business (B2B), and business-to-consumer (B2C) transactions. Given these developments, businesses need to understand what constitutes a valid e-invoice under the new rules and how the changes may impact their operations.
It is important to recognize that an electronic invoice (e-invoice) is not the same as a digital invoice, a PDF file, or an invoice simply sent via email. The EU e-invoicing directive specifies that an e-invoice in the Netherlands must be issued, transmitted, and received in a structured electronic format, which allows for automated, electronic processing.
Under Dutch invoicing rules, e-invoices must be issued by the 15th day of the month following the supply of goods or services—a requirement that aligns with standard invoice rules. Businesses are advised to consult with their advisors to ensure compliance, as regulations may vary and change across countries. For those with international operations, coordination with global colleagues is recommended.
Legal Framework for E-Invoicing in the Netherlands
E-invoicing in the Netherlands is governed by Directive 2014/55/EU, which has been transposed into national legislation. At present, e-invoicing is mandatory only for B2G transactions. This means that suppliers to government bodies must issue e-invoices in a structured format that complies with the European standard EN 16931. Currently, there is no further specific e-invoicing legislation in the Netherlands. Draft legislation to implement e-invoicing based on ViDA is expected by 2028.
Requirements for E-Invoicing
To be considered valid, an e-invoice in the Netherlands must be created, transmitted, and received in a structured format compliant with EN 16931. A simple PDF attached to an email does not qualify as an e-invoice. Preferred formats include those that are UBL/XML-based. Sector-specific formats may also be used, provided they are correctly mapped to EN 16931.
There are no restrictions on how invoices are transmitted; however, the Dutch Tax Authorities strongly promote Peppol as the preferred secure exchange network. For public sector transactions, Digipoort and a Supplier Portal are available as official entry points.
Electronic signatures or seals are not required for invoices in the Netherlands. Compliance with the structured format and transmission through trusted networks is considered sufficient to ensure the authenticity and integrity of e-invoices.
Archiving and Accessibility of E-Invoices
Dutch tax law requires invoices to be archived in their original format for a period of seven years. Businesses must ensure the long-term readability of the original UBL/XML file and should not rely solely on PDF conversions or printed copies. Storage of e-invoices outside the Netherlands is permitted, provided the invoices remain immediately accessible to the Dutch Tax Administration. Businesses must be able to grant online access to stored data upon request.
During the retention period, businesses are responsible for guaranteeing the authenticity, integrity, and legibility of e-invoices.
Additional Considerations
Until the EU ViDA legislation takes effect, the Netherlands is not expected to take a leading role in the development of e-invoicing. This is largely due to the backlog in IT system updates at the Dutch Tax Authorities and a relatively low incidence of fraud compared to other EU countries. One of the main challenges is that other countries have different, often more advanced, requirements that are not harmonized with those of the Netherlands. This lack of harmonization creates uncertainty about future regulations abroad.
Direct Reporting and SAF-T System
The Netherlands has not implemented the Standard Audit File for Tax (SAF-T) system and currently has no confirmed plans to introduce it.