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NAV Online Invoice - there is no delay, but there is a 3-month sanction-free period

Due to the difficulties caused by the coronavirus, the tax authority will not sanction, until 30 September 2020, the new taxpayers subject to the online data supply obligation from July, who are not yet able to comply with the regulations. The deadline for extending the data supply obligation is therefore not delayed, but NAV (Hungarian Tax Authority) will not penalise its omission for the first 3 months if taxpayers register in the Online Invoice system.

As it turned out from the government's announcement over the weekend, with the abolition of the HUF 100,000 VAT value limit, the obligation to provide online invoice data will apply to all taxpayers, as well as those who choose VAT exemption from 1 July 2020. However, for the first three months after its entry into force, the tax authority will waive the sanctioning of new obligors. It has not yet been clarified whether the missed data supplies will have to be supplemented at a later date or whether the tax authority will investigate and sanction the non-compliance after 30 September 2020. Our experience shows that NAV calls on taxpayers to supplement the missing invoice reports when checking the online data supply.

NAV Online Invoice registration is required for relief from sanctions

An important condition for the relief from sanctions is for the companies concerned to register in the Online Invoice system as soon as possible, before 1 July or before the first invoice is issued. During registration, taxpayers receive special IDs with which they can later send invoice reports to NAV. Whatever solution a company chooses for the submission of the invoice data at a later date, registration is essential for testing and live operation. For those who, up to this point, issued only a few paper-based invoices each month, there is a free online invoicing program created by NAV, also available for mobile phones, to convert their invoicing into digital form.

What else changes from 1 July other than the online invoice value limit?

Let us not forget that from 1 July 2020, other changes will take effect in addition to the abolition of the value limit! Thus e.g. the current 15-day deadline for issuing invoices will be reduced to 8 days. The application of the NAV 2.0 XSD scheme will become mandatory and the issuance of an invoice for the performance of certain tax-exempt transactions (e.g.: other education) will also be mandatory.

Why is it worthwhile complying with the online invoice reporting rules already from 1 July?

There are a few reasons why you should comply as soon as possible with the online invoicing rules, which take effect on 1 July 2020.

  1. In addition to the NAV 2.0 XSD schema change, which will take effect on 1 July 2020, the NAV Online invoice interface also provides a number of data retrieval options for businesses.  Thus, among other things, we can query the data of the invoices of our suppliers issued to us and reported to NAV, all this can be automated and connected, or we can compare it with the data of the invoicing or accounting program or the corporate governance system. Even if our ERP system cannot provide this, there are software solutions that in some cases already allow us to automate the process of preparing the entire VAT return, as well as to automate the preparation of M-sheets.
  2. NAV has developed a free Online Invoicing program, which will be available as a mobile application from June, making invoicing quick and easy, and also may be suitable for replacing paper-based invoices.
  3. Electronic invoicing can also provide a good solution to the challenges of the coronavirus epidemic - whether on the NAV platform, other free interfaces, or a paid program - as it could end the paper invoice era. Instead of handing over and receiving invoices issued on paper, it is also worth switching to some digital solution due to health considerations and for hassle-free operation. With electronic invoicing, the authentic document can be handed over to the customer without contact.
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