ViDA implementation by country: state of play autumn 2026

ViDA implementation by country entered a new phase in August 2026. On 22 August 2026 the European Commission published the implementing rules for the ViDA changes covering Single VAT Registration, and one day earlier it updated the explanatory notes to the VAT e-commerce rules for the ViDA reforms. In that same week several member states either submitted national bills or opened consultations. For organisations that invoice across borders, this means the European framework and its national translation are now moving at the same time, at different speeds per country.

This article sets out what has been published, how the national mandates relate to the ViDA framework, and which steps Dutch and Belgian organisations can take now.

Why this matters now

Until recently, ViDA was mainly a directional framework with a horizon in 2030. That has changed. The Digital Reporting Requirements establish a common baseline for intra-EU B2B transactions from 1 July 2030, but national mandates run years ahead of that date. Belgium has required structured B2B e-invoicing since 1 January 2026. France starts its first phase on 1 September 2026. Germany and Slovakia follow on 1 January 2027. Croatia has had its model running since the beginning of 2026.

The consequence is that organisations cannot wait for 2030. Anyone invoicing to or from these countries in 2026 and 2027 already falls under obligations that differ per country in format, channel, timing and additional data fields. Publication of the Single VAT Registration implementing rules reinforces that picture: the European foundation is becoming more concrete, but it does not remove the national differences.

What ViDA fixes and what member states decide themselves

ViDA rests on three pillars: digital reporting requirements, the treatment of the platform economy, and Single VAT Registration. The package harmonises the what and the when at European level. It establishes that member states must base their reporting obligations on a common standard for intra-EU transactions, and it removes the earlier requirement for member states to apply for a derogation before introducing a domestic e-invoicing mandate.

What ViDA does not do is fully determine the how. Member states decide which exchange model they apply, which additional national fields are mandatory, which validation regime applies, and which deadlines attach to submission or acknowledgement of receipt. That is exactly where the practical complexity arises.

This is also the core of our analysis. ViDA lays a common floor, but national rules continue to determine whether an invoice is legally and technically valid. Within that picture, Peppol is an exchange and interoperability mechanism: it governs how documents move reliably from A to B and ensures that parties can process each other’s messages. It is not a guarantee of national compliance. An invoice delivered technically correctly across the network can still be rejected if a mandatory national field is missing, or if a fiscalisation step was not performed within the prescribed deadline. That separation between transport and substantive compliance is the most important thing organisations should take from the current state of play.

Single VAT Registration and the new implementing rules

On 22 August 2026 the EU published the implementing rules for the ViDA changes concerning Single VAT Registration. This pillar is intended to reduce the number of VAT registrations a business needs in other member states, by broadening the One Stop Shop and applying the reverse charge more consistently. For businesses with stock, platform sales or call-off stock in several member states, this is the pillar with the most direct administrative impact.

One day earlier, on 21 August 2026, the European Commission updated the explanatory notes to the VAT e-commerce rules for the ViDA reforms. Explanatory notes are not legislation, but in practice they largely determine how national tax authorities and advisers interpret the rules. The combination of implementing rules and updated notes in the same week is a clear signal that the Commission wants member states aligned on a single interpretation before national implementing legislation is finalised.

For ViDA implementation by country this means national legislators now have a firmer reference point. Luxembourg and Croatia, which came forward with proposals in the same week, are visibly building on it.

Country overview: ViDA implementation by country

The table below sets out the state of play per country at a high level. A short explanation per country follows underneath.

Belgium

Since 1 January 2026 Belgium has required structured B2B e-invoicing via Peppol in a 4-corner setup. Sender and recipient each work with their own Peppol Serviceprovider, and exchange runs across the network without the tax authority intervening in the invoice flow itself. That intervention comes in a second phase: near real-time e-reporting follows on 1 January 2028. Belgian organisations already running e-invoicing operationally therefore have roughly two years to get their data quality in order before that same data also flows to the tax authority. See also our earlier analysis of the draft e-reporting law approved by the Belgian cabinet.

France

France starts its first phase on 1 September 2026. From that date a receiving obligation applies to all businesses in scope, and a sending obligation applies to large and medium-sized companies. Smaller businesses follow on 1 September 2027. Exchange runs via platforms approved by the French tax authority, the Plateformes Agréées, in conjunction with the PPF. For Dutch and Belgian companies with a French entity or French customers this is the most immediate deadline: the receiving obligation is broad and starts first.

Germany

Germany has chosen a phased approach based on company size. Large companies must comply from 1 January 2027, all other businesses from 1 January 2028. For companies with a German establishment this means internal planning cannot be built around a single date, but around the date attached to their own size category.

Netherlands

The Netherlands has chosen Peppol as its mandatory exchange infrastructure, with phased introduction between 2030 and 2032. That is later than most neighbouring countries and aligns with the ViDA horizon of 1 July 2030 for intra-EU transactions. For Dutch organisations the pitfall is that the domestic deadline is far away, while the obligations of trading partners in Belgium, France and Germany already apply today. More background in our article on the Netherlands, ViDA and e-invoicing. The Netherlands Peppol Authority (NPA) plays a central role in supervision and registration as the rules are worked out.

Luxembourg

On 21 August 2026 Luxembourg submitted a draft law implementing the first ViDA measures from 1 January 2027. The accompanying material of 20 August 2026 shows that this first phase covers platforms, OSS and call-off stock. Luxembourg is therefore taking up the Single VAT Registration pillar and the platform provisions first, rather than the reporting pillar. That is a relevant signal: the order in which member states implement the pillars differs, and a country that is early on one pillar may be late on another.

Croatia

Croatia is the most fully developed example of how far a national implementation can go. Fiscalization 2.0 has been operational since 1 January 2026 and requires structured e-invoicing for domestic B2B and B2G transactions of VAT taxable persons established in Croatia. Non-VAT taxable persons must be able to receive e-invoices during 2026; their sending obligation follows on 1 January 2027.

The Croatian model is based on EN 16931 with UBL 2.1, supplemented by national rules. These include the mandatory KPD 2025 product and service classification, with a six-digit code at invoice line level. In addition, both sender and recipient carry fiscalisation obligations: the recipient has five working days after receipt to complete its part.

This illustrates the earlier analysis concretely. An invoice can fully comply with EN 16931 and be delivered cleanly across the network, and still not be compliant in Croatia because the KPD code is missing or because the recipient did not perform its fiscalisation step within five working days. Transport and compliance are two different things.

Separately, on 20 August 2026 Croatia consulted on VAT in the digital age rules covering OSS, IOSS and e-invoicing, following an earlier consultation on 11 August 2026 on the first ViDA-related amendments to the VAT act. Croatia is therefore layering the ViDA adjustments on top of a system that is already running.

Slovakia

On 21 August 2026 Slovakia declared its e-invoicing infrastructure fully operational, well ahead of the 1 January 2027 mandate. That is notable in a field where postponement has been more common than early readiness. For companies with Slovak activities it means testing is possible now, rather than in the final weeks before the deadline. Read our earlier coverage of the Slovak e-invoicing mandate for 2027.

Norway

As of 20 August 2026 Norway is moving towards mandatory structured B2B e-invoicing from 1 January 2027, with broader electronic accounting and receipt requirements in a later phase. Norway is not an EU member state and therefore does not fall under ViDA, but it aligns substantively with the same movement. That is relevant for companies that have set up Norway as a separate exception in their invoicing landscape: that exception is about to become the rule.

Spain

On 19 August 2026 the Spanish Senate pressed for a uniform digital VAT reporting system. Spain currently runs several parallel tracks, including regional systems alongside national obligations. The call for uniformity shows that complexity can be a problem within a member state as well as between member states. See also our earlier analysis of the first stage of Spain’s ViDA implementation.

Poland

Poland is rolling out KSeF during 2026. The Polish system is a central platform through which invoices must pass, which differs fundamentally from the Belgian and Dutch network model. For companies active in both countries this means two different integration patterns running side by side.

What this means outside the EU

The ViDA movement has effects beyond the European Union. Norway is one example within Europe, but the clearest signal comes from further afield. Between 18 and 20 August 2026 the South African Revenue Service (SARS) opened a formal consultation on a digital VAT model with e-invoicing and near-real-time reporting.

The choices on the table there closely resemble the European debate: which exchange model, what degree of real-time reporting, what role for certified service providers. For multinational organisations, investment in structured invoice data and a well-designed exchange layer is therefore not only a European necessity. The underlying data structure is largely reusable; the national rules layered on top of it are not.

Practical checklist for Dutch and Belgian organisations

The following steps are concrete and follow directly from the current state of play.

1. Map your country exposure. Build an overview of every country in which you issue or receive invoices, and attach the applicable start date to each. Start with France, because 1 September 2026 is the next hard deadline.
2. Separate transport from compliance in your own documentation. Record per country which channel is used and which substantive requirements apply on top of it. Treat these as two separate control points, not as a single tick box.
3. Check your master data for national fields. Croatia requires a KPD 2025 code at line level, other countries set their own requirements. This data must come from your source system, not from a manual correction afterwards.
4. Test your receiving process, not only your sending process. Several countries place obligations on the recipient, with deadlines attached. Croatia allows five working days. A receiving process that depends on a manual check will structurally miss those deadlines.
5. Ask your Peppol Serviceprovider explicitly about country coverage. Do not ask whether they support Peppol, but whether they support the national profiles, validations and fiscalisation steps of your specific countries, and from when.
6. Prepare for Single VAT Registration. If you hold stock, call-off stock or platform sales in several member states, assess whether registrations can be withdrawn once the new implementing rules take effect.
7. Schedule your test windows early. Slovakia already has its infrastructure operational. Where testing is possible, waiting until shortly before the deadline is an avoidable risk.
8. Follow national trilogues and consultations. Croatia, Spain and Luxembourg are currently in a phase where details can still change. A decision that appears settled today may be worked out differently in three months.

Conclusion

Publication of the Single VAT Registration implementing rules and the wave of national proposals in August 2026 show that the ViDA framework is taking its definitive shape while member states are already building. Anyone tracking ViDA implementation by country sees a common floor emerging beneath obligations that continue to differ sharply in format, timing and detail. Peppol solves exchange and interoperability, but the question of whether your invoice is legally and technically valid in Croatia, France or Poland is answered by national rules. Organisations that deliberately design those two layers separately are better prepared than organisations looking for a single solution to both.

Sources

1. EU publishes implementing rules for ViDA Single VAT Registration changes, VATupdate, 22 August 2026
2. EU Commission updates VAT e-commerce notes for ViDA reforms, VATupdate, 21 August 2026
3. Luxembourg draft law implements first ViDA measures from 1 January 2027, VATupdate, 21 August 2026
4. Croatia proposes VAT digital age rules with OSS, IOSS and e-invoicing, VATupdate, 20 August 2026
5. Croatia connects e-invoicing, fiscalization and transaction reporting, VATupdate, 22 August 2026
6. Slovakia launches fully functional e-invoicing infrastructure, VATupdate, 21 August 2026
7. Norway moves towards mandatory structured B2B e-invoicing from 2027, VATupdate, 20 August 2026
8. Croatian Tax Administration, information on eRacun and fiscalisation
9. French tax authority, facturation électronique et plateformes agréées
10. The Netherlands, ViDA and e-invoicing, Peppol.nu

Compare Peppol Serviceproviders on country coverage

Which Peppol Serviceprovider suits your organisation depends on the countries in which you operate and the national profiles you need. Use the Peppol Serviceprovider comparison tool to place providers side by side and assess them against the ViDA implementation by country that applies to your own list.