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Hungarian real-time invoice data reporting deadline with new encryption algorithm

From 1 April 2020, only XML documents created using the new 2.0 template can be submitted to the Hungarian Tax Authority within the framework of the real-time invoice data reporting service; in addition, a new encryption procedure will have to be used when reporting invoice data. Two months from now, every invoicing software must report invoicing data using the new Online Számla 2.0 XML template.

Two months  to prepare for the introduction of  NAV Online Invoice 2.0

The test system of the Hungarian Tax Authority (NAV) has been accepting documents created using the new XML format, based on the new 2.0 XML template, since the autumn; therefore, opportunities for preparation and testing have been available for quite some time. The Connectax team did not leave the preparations to the last minute either since our real-time invoice data reporting solution has been accepting and forwarding invoice data created using the 2.0 XML template for months. 

The test environment currently supports both solutions (versions 1.1 and 2.0) and the HU TA promised that support for the 2.0 version will become available in the live system in the middle of February. This means that from February onward, the live version of the Online Számla system is going to support invoice data reporting based on versions 1.1 and 2.0 in parallel. However, support for the 1.1 version is going to be discontinued on 1 April, after which the invoice data reporting obligation can only be fulfilled in accordance with the specifications of version 2.0.

Invoicing programs that fail to implement the changes by this deadline in April are going to be disconnected from the system of the tax authority and from that point onward, they are going to be unable to fulfil the obligation to connect, as provided in the applicable legislation. In addition to the post-factum, often manual, data entry that becomes necessary in such cases, the affected companies are going to be obliged to report such malfunctions to the tax authority as well. The failure to comply with the data reporting obligation is relatively easily detected by the tax authority and such a mistake can bring unwanted attention to the taxpayer.

In order to help with the preparations, you can check your own 2.0 XML files here, using our XML validator or get help with the creation of correct XML files from our consultants. The real-time invoice data reporting service is being used by several dozens of our partners successfully via our cloud-based Connectax platform, which allows the technical requirements of the connection to be fulfilled within a few days.

We are aware that not every organisation has had the means to allocate the necessary resources and competence to the required development tasks yet, which necessitates close cooperation between the financial administration of the organisation and the developers of the invoicing software, similarly to the earlier XSD version changes. As technological tax consultants, we endeavor to provide assistance in understanding these changes below.

New encryption procedure for NAV real-time invoice data reporting

The Online Számla 2.0 system makes it mandatory to use the SHA3-512 hash algorithm for the communication link between the invoicing software and the system of the tax authority. This new encryption procedure replaces the commonly used SHA-512 encryption procedure. When updating the data reporting module of an invoicing system, it can cause difficulties if the SHA3-512 hash algorithm is not available on the relevant platform. 

In such cases, a support infrastructure for this algorithm must also be developed; it is not enough to implement the XML template changes only! This can cause issues for example in the case of earlier ERP systems, e.g. SAP versions that only make the standard SHA-512 available out of the box. The solution to this is either the upgrading of the platform or for certain SAP versions, the installation of an external SAP add-on.

Sample NAV XML documents

As opposed to their previous practices, the HU TA did not publish any sample invoice XML documents along with the technical documentation of the Online Számla portal. These sample files were always very useful, since they allowed the developers to familiarise themselves with the elements of the XSD template definition file, which can consist of several thousand lines, through practical examples. 

The Online Számla XML samples, which are valuable for companies for the above reasons, can only be found on the GitHub page of Online Számla 2.0; they were only published on this platform this time.

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New data fields in the Online Számla XML of the HU TA

The most interesting parts of the changes are definitely the new data fields. These apply to mandatory and optional data that might have not been available in the moment of closing and raising the invoice in the invoicing software until now. The first challenge for developers in this case is to obtain the relevant data somehow or request it from the user creating the invoice. The new data fields included in the XML template of Online Számla 2.0 are the following:

  • Regarding invoice items, it is mandatory to complete the related net (lineNetAmount) and net HUF (lineNetAmountHUF) values. Mandatory, according to the template.
  • The related net values also appear as mandatory fields in the VAT summary (vatRateNetAmount and vatRateNetAmountHUF). Mandatory, according to the template.
  • In case of adjusting invoices, the sequence of adjustments must be provided in the modificationIndex component so that the adjustment chain can be retrieved unambiguously. Mandatory, according to the template.
  • The lineNatureIndicatorcomponent that can be used for the rating of product/service/other was included among the data of invoice lines. Optional, according to the template.
  • There is a new component designed to indicate a small business tax taxpayer (smallBusinessIndicator). Optional, according to the template.
  • Periodical settlement can be indicated in the periodicalSettlement data field. Optional, according to the template.

Please find detailed information about the new data fields of 2.0 online invoice in our earlier blog post.

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