Why VAT Invoice Requirements Matter
A VAT invoice is not just a payment request — it is a legal document that enables your customer to recover VAT on their purchases. If a VAT invoice is missing required information, your customer's tax authority may disallow their VAT recovery claim, creating a liability that falls back on the transaction.
For suppliers, issuing incorrect or incomplete VAT invoices can also trigger penalties from their own tax authority. Getting VAT invoice requirements right protects both parties in a B2B transaction.
The 13 Mandatory Elements of an EU VAT Invoice
Article 226 of the EU VAT Directive sets out the mandatory information that must appear on all full VAT invoices issued by VAT-registered businesses in EU member states:
- →Date of issue of the invoice
- →Sequential invoice number — a unique number from a sequential series
- →Supplier's VAT identification number (VAT number)
- →Customer's VAT number — required for B2B supplies, intra-EU supplies, and reverse charge invoices
- →Full name and address of supplier
- →Full name and address of customer
- →Description of goods or services — must be sufficient to identify what was supplied
- →Date of supply (if different from invoice date) or the date on which payment was received (for advance payments)
- →Quantity and nature of goods or extent and nature of services
- →Unit price excluding VAT and any discounts or rebates
- →VAT rate(s) applied to the supply
- →VAT amount payable in the currency of the invoice
- →Total amount payable including VAT
Simplified VAT Invoices
EU member states may allow simplified invoices for lower-value transactions. Under Article 220a of the EU VAT Directive, a simplified invoice may be issued where the total amount does not exceed €100 (including VAT), or for certain retail and similar transactions.
A simplified invoice does not need to include the customer's name and address, or the net amount broken down by VAT rate. However, it must still include: the date of issue, the supplier's VAT number, a description of the supply, the VAT amount or the information needed to calculate it, and the gross amount payable.
National rules vary on when simplified invoices are permitted. Some countries allow them for all transactions below a threshold; others restrict them to specific sectors such as hospitality and retail.
Additional Requirements for Special Invoice Types
Reverse charge invoices: Must include the customer's VAT number and the notation "Reverse charge — Article 196 EU VAT Directive" (or equivalent). No VAT amount is shown.
Intra-EU supply invoices (zero-rated goods): Must include the customer's VAT number, a description confirming the goods were dispatched to another EU country, and a reference to the exemption (e.g. "Exempt intra-Community supply — Article 138 EU VAT Directive").
Credit notes: Must reference the original invoice number and date. All other VAT invoice requirements apply.
Self-billing invoices: Where the customer issues the invoice on behalf of the supplier, both parties must agree to self-billing in advance and the invoice must be marked "Self-billing".
Country-Specific Additional Requirements
While Article 226 sets the EU-wide minimum, many member states require additional information:
Germany: The bank account number (IBAN) of the supplier must appear on VAT invoices for taxable supplies. The Steuernummer (domestic tax number) is acceptable instead of the VAT number for domestic supplies.
Italy: Invoices must be issued through the government's SdI (Sistema di Interscambio) interchange system in FatturaPA XML format. Paper and PDF invoices are not legally valid for B2B transactions.
Portugal: All invoices must be generated by AT-certified invoicing software. A certification code (código AT) must appear on each invoice.
Czech Republic and Slovakia: A VAT control statement (kontrolní/kontrolný výkaz) requires invoice-level data to be reported to the tax authority alongside each VAT return.
Greece: The myDATA system requires real-time digital transmission of all invoice data to the tax authority (AADE).
Invoice Retention Requirements
EU businesses must retain copies of all VAT invoices (issued and received) for a minimum period set by each member state. The EU VAT Directive sets a minimum of 5 years, but many countries require longer:
- →Most EU countries: 5–7 years from the end of the relevant tax year
- →Sweden: 7 years
- →Germany: 10 years
- →Ireland: 6 years
Invoices may be stored electronically provided the authenticity, integrity, and legibility can be guaranteed throughout the retention period. Electronic invoices and paper invoices have equal legal status in the EU.