Tolerance period for mandatory e-invoicing: six months without penalties

What the proposed amendment introduces

Mandatory e-invoicing is one of the most significant changes to invoicing processes in recent years. The proposed amendment to the VAT Act therefore introduces a tolerance period intended to give businesses room to fine-tune their internal processes and systems.

During the first six months from the effective date of the new rules, the tax authority would not impose penalties for breaching the 15-day deadline for issuing an electronic invoice.

What the tolerance period covers

The tolerance period is intended to apply solely to:

•      Failure to meet the deadline for issuing an electronic invoice

•      Failure to report invoice data to the Financial Administration

What the tolerance period does not change

It is important to stress that the transitional arrangement does not postpone the obligations introduced by the amendment. From 1 January 2027, businesses must still issue and receive invoices in a structured electronic format, deliver them through a certified delivery service provider and retain them in line with the law. The tolerance period softens the penalty regime, not the scope of the obligations.

How to prepare

We recommend focusing on the following areas in particular:

•      Confirming that your accounting or ERP system supports the structured invoice format

•      Selecting a certified delivery service provider and putting contracts in place

•      Reviewing internal invoicing processes and deadlines

•      Training the teams that work with invoices

Contact us

We are happy to help you assess the impact of e-invoicing on your company and prepare for the new obligations as efficiently as possible. Please contact our tax team.