VAT in the Digital Age (ViDA) in 2026: A Practical Compliance Roadmap for Cross-Border and SaaS Businesses

It has been just over a year since the EU formally adopted the VAT in the Digital Age package on 11 March 2025. ViDA is no longer a proposal. It is law, codified in Council Directive (EU) 2025/516, Council Regulation (EU) 2025/517, and Council Implementing Regulation (EU) 2025/518, all published in the Official Journal on 25 March 2025 and in force since 14 April 2025. The next milestones move from policy to plumbing: an updated EN 16931 e-invoice standard approved in February 2026, a Peppol ViDA pilot running through the year, the Secure IOSS pilot in development, and a wave of national mandates that pre-empt the EU-wide deadlines. If you sell digital services, run a marketplace, or move goods across EU borders, the work you do in 2026 will determine whether the 2028–2030 phases are an upgrade or a fire drill.

The legal package, in one paragraph

ViDA amends the VAT Directive 2006/112/EC and the administrative cooperation framework simultaneously. Directive 2025/516 rewrites the substantive rules on invoicing, place of supply, OSS, and platform liability. Regulation 2025/517 upgrades the IT backbone: it modernises the central VIES, adds a digital reporting database, and harmonises how member states exchange transaction-level data. Implementing Regulation 2025/518 sets the technical detail: the data fields, transmission rules, and identifier formats that allow national systems to interoperate. Reading just the directive misses half the picture; the regulations are where the real compliance work lives.

Where the timeline stands in 2026

ViDA rolls out in five waves between 2027 and 2035. Most of the visible action right now is preparation, not enforcement. The Commission spent late 2025 and early 2026 publishing the Implementation Strategy, drafting Explanatory Notes, opening the Peppol ViDA pilot, and approving the revised EN 16931 standard at CEN on 13 February 2026. Member states are running gap analyses, scoping IT projects, and (in several cases) accelerating domestic mandates to land before the EU-wide dates.

Pillar 1: Digital Reporting Requirements and the EN 16931 update

The most operationally disruptive pillar is also the latest to arrive. From 1 July 2030, every cross-border B2B intra-Community supply must be invoiced using a structured electronic format aligned with the European e-invoicing standard EN 16931. Both supplier and customer feed transaction data into a central digital reporting database accessible to all member states.

The 10-day / 5-day clock

ViDA tightens invoicing deadlines significantly. The supplier must issue the structured e-invoice within 10 days of the chargeable event (the supply, or earlier payment receipt). For self-billed invoices and intra-Community acquisitions, the recipient must report the transaction within 5 days of issuance or receipt. The current rule of issuance “by the 15th day of the following month” for intra-Community supplies disappears. For finance teams that batch-invoice at month end, this is a meaningful change in operating rhythm.

EN 16931, post-February 2026

EN 16931 was originally written for B2G invoicing under Directive 2014/55. CEN approved a major revision on 13 February 2026, with formal publication expected in May 2026, that adapts the standard for B2B and adds the data fields the DRR will require. Key additions include a buyer reporting reference, expanded VAT category and exemption codes, identifiers for self-billing, and structured fields to support the platform deemed-supplier flow. If your invoicing system supports the 2017 version of EN 16931 only, it will need an upgrade.

Peppol ViDA pilot

OpenPeppol, the consortium that runs the Peppol network used widely in EU and Asia-Pacific e-invoicing, has spent 2025–2026 running a ViDA pilot to demonstrate that the existing Peppol infrastructure (network, BIS Billing 3.0 specifications, four-corner model) can carry ViDA-compliant invoices and reporting messages. The pilot uses the existing access-point and SMP architecture so businesses already on Peppol can extend rather than replace what they have. National authorities are evaluating Peppol as one route to deliver ViDA reporting alongside their own domestic platforms.

Why DRR matters for SaaS

SaaS companies tend to think of e-invoicing as a B2C concern, but ViDA's DRR is a B2B framework. If you sell to EU businesses and apply the reverse charge, you are creating an intra-Community supply that lands inside DRR scope from July 2030. PDF reverse-charge invoices issued on a Stripe receipt template will not satisfy the rule. Either your billing system natively produces EN 16931 XML, or you bolt on an e-invoicing service (Sovos, Pagero, Avalara E-Invoicing, Storecove, Comarch) that converts your invoice records and transmits them. Decide which path you are on by mid-2027 to leave time for testing.

Pillar 2: Platform economy and deemed-supplier rules

From 1 January 2030 (with optional adoption from 1 July 2028), digital platforms that facilitate short-term accommodation rentals and passenger transport by road become deemed suppliers for VAT purposes when the underlying provider does not charge VAT. The rule was watered down from the original Commission proposal. The accommodation cap dropped from 45 to 30 nights, and member states retain several opt-outs. The substance, however, remains: platforms collect and remit VAT in cases where today's hosts and drivers do not.

Mechanics

The deemed-supplier model creates a fiction of two supplies: the host or driver supplies the platform (VAT-free), and the platform supplies the end customer (with VAT at the destination rate). The platform is responsible for charging, collecting and remitting the VAT, and may use a dedicated OSS return to do so without registering in every member state. Where the underlying provider is VAT-registered and confirms a valid VAT number, the deemed-supplier fiction does not apply and normal rules continue.

The SME opt-out

One of the most consequential negotiated additions is the SME opt-out. Member states may choose to disapply the deemed-supplier rule when the underlying host or driver qualifies for the cross-border SME scheme (introduced separately in 2025). For platforms, this means the deemed-supplier obligation is jurisdiction-by-jurisdiction: in some member states a small host stays out of scope, in others the platform must collect VAT regardless. Platform tax engines will need a per-supplier, per-country eligibility check.

Scope limits to remember

• Accommodation: stays of up to 30 nights to the same person, on a continuous basis. Long-term lets fall outside.
• Passenger transport: by road only, within the EU. Air, rail and water are excluded for now. Goods transport is also excluded.
• Other digital platforms (food delivery, gig services, marketplaces for goods, SaaS marketplaces) are out of scope for ViDA's deemed-supplier rule, although they remain subject to the existing Article 14a rules for distance sales of low-value goods and DAC7 reporting.

Pillar 3: Single VAT Registration

For most cross-border businesses, this is the pillar with the clearest upside. From 1 July 2028, the OSS becomes a substantially broader simplification, and a new mandatory reverse charge reduces the situations where a non-established supplier needs a local VAT number.

Transfer of own goods OSS (“Be2Me OSS”)

Today, when an e-commerce seller moves stock from a warehouse in Belgium to a warehouse in Germany, the movement is a deemed intra-Community supply and acquisition that requires a German VAT registration. From 1 July 2028, the seller can opt into a new OSS scheme that lets the same movement be reported via a monthly return in the country of identification, with no German registration needed. The scheme covers most own-goods movements, including stock for fulfilment-by-marketplace inventory.

Call-off stock simplification phased out

The 2020 Quick Fix call-off stock simplification disappears in two steps: no new arrangements from 1 July 2027, and the regime fully ends on 30 June 2029. Existing arrangements run off naturally. The transfer-of-own-goods OSS is the replacement.

Mandatory reverse charge for non-established suppliers

From 1 July 2028, all member states must apply the reverse charge for B2B supplies where the supplier is not established and not VAT-identified in the country of taxation, and the customer is VAT-identified there. This already exists in many member states under Article 194; ViDA makes it mandatory and harmonised across the EU. The practical effect: if you sell B2B and your customer is VAT-registered in a country where you have no establishment, you do not need to register there.

Expanded OSS for goods with installation, on-board supplies, and energy

• From 1 January 2027, OSS covers gas, electricity, heating and cooling supplied to non-taxable persons.
• From 1 July 2028, OSS extends to supplies of goods with installation or assembly, on-board supplies on ships and aircraft, and supplies of certain margin-scheme second-hand goods.
• The deemed-supplier OSS variant lets platforms report deemed supplies through a single return.

The Secure IOSS pilot

Often overlooked alongside the headline pillars, ViDA also tightens the Import One Stop Shop (IOSS) used for low-value imports up to EUR 150. The Commission identified IOSS number misuse, where fraudsters use legitimate IOSS numbers without the holder's knowledge, as a leakage point in the EUR 128 billion VAT gap. The Secure IOSS pilot, which entered IT build in early 2026, introduces tokenised IOSS identifiers and authentication steps so customs systems can verify in real time that an import is genuinely covered. Live operation is planned for late 2026, with broader rollout aligned to ViDA's main milestones.

Domestic e-invoicing mandates: the parallel reality

ViDA's 2030 deadline is a long way off. Domestic mandates are not. Several member states have used ViDA's removal of the prior derogation requirement (effective 14 April 2025) to accelerate or formalise their own systems.

By 1 January 2035, every domestic system above must accept and produce EN 16931 structured invoices that interoperate with the central DRR. Until then, multinational businesses face a multi-format reality: an invoice issued in Poland goes to KSeF in FA(3) XML, in Italy to SdI in FatturaPA XML, in France through a PDP in Factur-A or UBL, and in cross-border B2B contexts increasingly via Peppol BIS 3.0. The harmonisation does not arrive evenly.

What this means for SaaS and digital-services businesses

Pure SaaS sales are a Pillar 3 story more than a Pillar 1 story, but the Pillar 1 obligations creep in faster than most people expect.

If you're a non-EU SaaS seller (US, UK, Canada, Australia)

• Non-Union OSS: Mostly unchanged in 2026. You continue to file quarterly Non-Union OSS returns for B2C digital services. Watch for the 2027 OSS housekeeping changes (mainly clarifications around correction periods and bad-debt relief).
• Reverse-charge B2B: The substantive rule does not change. B2B digital services to EU VAT-registered customers are reverse-charged by the customer. From July 2030, however, the invoice you issue must be in EN 16931 format, and the customer's report into the central system depends on you transmitting structured data.
• Customer location evidence: No change from ViDA itself, but member states are increasingly cross-checking digital reporting against the two-piece evidence rule. Tighten your evidence collection now.

If you're an EU-established SaaS seller

• Union OSS: No change for B2C digital services. From 2028, it becomes more useful for adjacent supplies (movement of own equipment between data centres, hardware bundled with software, energy resale within data-centre offerings).
• Domestic mandate exposure: If you are established in, or sell B2B into, Italy, Romania, Belgium, Poland, France, Germany, or Spain, the immediate compliance cost is the domestic mandate, not ViDA. Build to EN 16931 once and route nationally where required.
• Intra-Community B2B reporting: Plan now for a structured-invoice generator that is EN 16931 compliant and connectable to Peppol or to a service provider that can fan-out to national platforms.

If you build a platform (marketplaces, OTA-style sites, ride-hailing)

• Accommodation/transport: Plan the deemed-supplier flow now. You will need (a) per-supplier VAT status capture and validation, (b) per-supplier SME-status capture for member states that opt out, (c) a VAT calculation engine that can apply 27 destination rates, (d) an OSS or local registration path for remittance, and (e) invoice issuance to the end consumer in the platform's name with VAT.
• Other platforms: Out of ViDA's deemed-supplier scope, but watch DAC7 reporting, the Article 14a low-value-goods regime, and forthcoming OECD work on digital platform reporting.

A quarter-by-quarter readiness plan

Use 2026 to do the cheap, slow work. The expensive, fast work happens in 2027–2029.

Q2 2026: Map and decide

• Document every EU VAT registration you hold and the reason for it. Tag those that could disappear under Pillar 3 from July 2028.
• Inventory invoice flows: domestic vs cross-border, B2B vs B2C, supplier-issued vs self-billed. For each, note the current format and the future ViDA obligation.
• Decide on your e-invoicing architecture: native ERP/billing capability, a dedicated e-invoicing service provider, or a Peppol access point.

Q3 2026: Stand up EN 16931

• Procure or build EN 16931 generation. The revised standard published in May 2026 is your target.
• Test against Peppol BIS 3.0. Even if you don't transmit through Peppol in production, conformance gives you optionality.
• For French PPF and Italian SdI, run end-to-end tests in sandbox.

Q4 2026: Domestic mandates first

• Belgium B2B has been live since January. Confirm all in-scope flows are issuing through Peppol.
• Poland KSeF reached its large-taxpayer phase in February and its smaller-taxpayer phase in April. Verify readiness if you are in scope.
• France PPF reception became mandatory in September. Ensure you can receive structured invoices from French suppliers.

2027: OSS expansion and call-off stock cutover

• 1 Jan 2027: confirm OSS coverage of energy supplies if applicable.
• 1 Jul 2027: stop creating new call-off stock arrangements; plan run-off of existing ones.
• Begin testing the transfer-of-own-goods OSS (“Be2Me”) when guidance is published.

2028: Single VAT Registration go-live

• 1 Jul 2028: deregister where Pillar 3 lets you, opt into transfer-of-own-goods OSS, switch B2B-only flows to mandatory reverse charge.
• If you operate accommodation or transport platforms, consider opting into the deemed-supplier rule early in member states that allow it. Getting ahead of the curve simplifies the 2030 transition.

2030: DRR cutover

• 1 Jan 2030: deemed-supplier rule mandatory across the EU.
• 1 Jul 2030: cross-border B2B structured e-invoicing live; EC Sales Lists abolished; central VIES carries near-real-time data.

Risks and open questions

Member-state implementation drift

ViDA gives member states a number of options: when to adopt the deemed-supplier rule (2028 vs 2030), whether to apply the SME opt-out, whether to mandate domestic e-invoicing earlier than 2030, and how to interface their existing platforms with the central DRR. Expect a multi-year period of regulatory drift before everything aligns in 2035.

EN 16931 governance

The February 2026 revision is significant but not final. CEN expects continued evolution as DRR data needs are refined. Build to the standard, but expect to follow minor versions over the next 4–5 years.

Audit and dispute

Real-time reporting reduces the lag between transaction and audit. Tax authorities will be able to query mismatches between supplier and customer reporting almost immediately. Expect more contemporaneous queries and fewer multi-year retro audits, which is operationally different from today's audit cadence.

Data residency and security

Transaction-level data flows from your ERP through service providers to national authorities and into the central VIES. The Regulation 2025/517 framework includes data-protection commitments, but multinational businesses should validate where and how invoice data is stored and who in the chain has visibility.

Frequently asked questions

What is the legal basis for ViDA?

Three instruments adopted on 11 March 2025 and published in the Official Journal on 25 March 2025: Directive (EU) 2025/516 (substantive rules), Regulation (EU) 2025/517 (administrative cooperation and IT systems), and Implementing Regulation (EU) 2025/518 (technical detail). They entered into force on 14 April 2025.

What is the 10-day rule?

From 1 July 2030, intra-Community B2B invoices must be issued within 10 days of the chargeable event. Self-billed and intra-Community acquisition reporting must happen within 5 days. The current “15th of the following month” deadline is replaced.

Will domestic mandates disappear?

Not until 1 January 2035, when national systems must align with the EU DRR standard. Until then, expect parallel compliance with national platforms (Italy SdI, Romania e-Factura, France PPF, Poland KSeF, Germany B2B, Belgium Peppol, Spain Verifactu/Crea y Crece) alongside the EU framework.

How does ViDA affect a US SaaS company selling into the EU?

Non-Union OSS for B2C digital services is largely unchanged. The bigger impact is on B2B sales: from 2030, the reverse-charge invoice you issue must be EN 16931 structured. Many EU customers will demand structured invoicing earlier due to domestic mandates. Plan for an EN 16931 capability by 2027.

What is the platform SME exemption?

Member states may exclude underlying suppliers using the SME VAT scheme from the platform deemed-supplier rule. If a host or driver is below the local SME threshold and uses the SME regime, the platform is not the deemed supplier for that supply. Adoption varies by member state.

Does ViDA replace the OSS or IOSS?

No. It expands them. OSS coverage broadens from 2027 (energy) and 2028 (transfer of own goods, installation supplies, deemed-supplier OSS for platforms). IOSS continues, with a Secure IOSS pilot launching in 2026 to address number misuse. See our dedicated OSS explainer for the underlying mechanics.

What happens to EC Sales Lists?

EC Sales Lists are abolished from 1 July 2030 once DRR is fully operational. The same data flows through the structured e-invoice and digital reporting channel into the central VIES.

Where to read next

• ViDA Explained: How the Package Affects Your Business. An executive-level overview of the three pillars.
• E-Invoicing Requirements by Country: A 2026 Global Tracker. Live status of every country mandate.
• The EU One-Stop Shop (OSS) Explained. The foundation that ViDA builds on.
• Reverse Charge VAT Explained. The mechanism that the expanded mandatory reverse charge generalises.
• Place of Supply Rules for Digital Services. The substantive rules ViDA does not change.
• Global VAT Rate Changes 2025–2026. Rate updates that flow into your DRR data.