Nav online invoicing system 2.0 – Online invoice data disclosure 2020-2021

3 deadlines regarding the most important changes in online invoice data reporting:

According to extraordinary government decisions due to Coronavirus: 1st of July 2020 (originally 1st of April 2020)– new online invoice data reporting structure to be applied (reporting obligation for domestic B2B, at least 100.000 huf VAT content)

1st of July 2020 – eliminating 100.00 huf VAT threshold. Reporting obligation for all domestic B2B transactions as well as reverse charge and VAT free transactions.

1st of January 2021 – extension the reporting obligation for all B2B transactions and domestic B2C transactions issued according to the Hungarian invoicing regulations as well)

Let’s see the details!

What technical changes do the version 2.0 of NAV data supply bring?

  • One of the most important innovations of this version is that not only invoices submitted by the company can be queried through the software, but also those that were issued to the company by the suppliers. Full visibility of the invoices can be used not only for data supply purposes but also the automatic processing of the incoming invoices can be implemented.
  • The length of some data fields has been changed as well. For example, ZIP code field will accept already 3 characters and it can contain space and dash. This change serves the more efficient handling of foreign ZIP codes. In the new data disclosure system, the invoicing date cannot be modified with a correction invoice.
  • In the schema of the data supply, some optional fields have been also introduced, which are not compulsory to use. Such fields are for example the mark of Small taxpayers or mark of periodic settlement.
  • Technical change in data provision that data providers or invoicing program information have become a mandatory field.

Changes of legislation related to data disclosure

  • Legislation changes will create serious administrative burdens for businesses that issue invoices manually using invoice blocks. If the VAT amount on the invoice is less than 500,000 HUF than the company has only 4 calendar days to fulfill the data supply obligation instead of the current rule of 5 days.
  • Data disclosure regulation will change regarding final invoices as well. The law makes it clear, that in the case of final invoices the data supply should contain only the amount decreased by the advance payment.
  • Taxpayers should be prepared not only for changes in the data supply but also in the content of the invoices. Invoices issued to domestic taxpayers must contain the tax number of the customer as well.
  • ”Reasonable time” defined by the VAT law for invoice issuing will be reduced to 8 days instead of the previous 15 days.
  • Certain VAT-exempt transactions will be also subject to data disclosure, so instead of accounting vouchers invoices must be issued about these transactions.
  • The 100,000 HUF VAT limit will be canceled, which means that all invoices issued to domestic taxpayers will be subject to reporting, from 1st of July, 2020 irrespective of the VAT amount.
  • From 2021 the range of invoices included in the data supply will be further expanded and all invoices should be reported that are issued according to the Hungarian invoicing regulations.
  • The regulation should be applied for B2B and B2C transactions as well, invoices issued to private persons will be also subject to reporting.
  • The data disclosure must also contain invoices issued to non-taxpayer organizations (for example foundation, association, condominium), EU and 3rd country sales transactions.

The separation of invoices in the invoicing software based on the taxpayer and the non-taxpayer customer will need to be applied later on, because data supply about invoices issued to private persons will be limited and will not contain the name and address of the customer

However, the law limits the data disclosure obligation only to invoices. Vouchers issued manually still won’t be subject to this regulation.

A company obliged to invoice issuing may authorize an accounting service provider to prepare the invoices, or its customer issues the invoices through self – invoicing. In these cases, the responsibility remains on the seller company to ensure the correct data disclosure.

For companies using international ERP systems, it is often a problem to connect the ERP system to the local accounting software or directly to the NAV online invoicing system. Parameterization and development of this connection can cause a significant cost for the company.

However, BPiON has developed the TAXapiON solution that helps our client to be compliant with the regulations in a truly cost-effective and professionally accurate manner. The solution includes monitoring service, GDPR proof communication channel and professional IT and VAT support.

If you would like to learn more about our TAXapiON service, please contact our consultants at [email protected]!

TAXapiON_NAV 2.0


Rafał Nadolny
MD Poland,

Daniela Zsigmond
MD Romania,

Tamás Kovács
MD Hungary,

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