Netherlands: Proposed e-invoicing and digital reporting framework under ViDA

The Dutch Ministry of Finance on March 10, 2026, submitted to the Dutch Parliament a third-party analysis (Dutch) on implementation options of mandatory e-invoicing and digital reporting in line with the EU VAT in the Digital Age (ViDA) initiative and potential extension to domestic transactions. The report recommends a decentralized, Peppol-based e-invoicing model with near real-time reporting, covering both cross-border and domestic B2B transactions. While no legislative proposal has been adopted, the analysis outlines a roadmap for phased implementation between 2030 and 2032.

The Dutch government announced (Dutch) that they will provide further communication about the finally preferred direction in the summer of 2026 and will publish draft legislation for consultation at the end of 2026. 

Background

The ViDA Directive requires all member states to implement mandatory e-invoicing for intra-EU B2B transactions and near real-time digital reporting of invoice data by July 1, 2030. Member states may also extend these requirements to domestic transactions. The Netherlands is now considering this extension as a key policy decision, but is still “carefully weighing” pros and cons. Back in June 2025, the Dutch State Secretary for Finance outlined these obligations and the national implementation approach in a letter to Parliament (Nr. 4090, June 26, 2025). This third-party analysis explores the potential roadmap, choices to be made, and the basic details of the implementation of the e-invoicing mandate in the Netherlands.

Overview of currently preferred roadmap

Although final decisions have not yet been taken, the direction is clear: 

• E-invoicing as default for B2B transactions: The report expresses a preference for making e-invoicing the standard for both cross-border and domestic B2B transactions. In the preferred option, invoices must be issued in a structured electronic format (EN16931), gradually replacing paper and PDF invoices.
• Near real-time digital reporting: The system would introduce transaction-level reporting, first for intra-EU B2B transactions and in a second phase also for domestic ones. Invoice data must be reported to the tax authority (Belastingdienst) at or near the time of issuance. For intra-EU transactions, the seller reports in real time, while the report suggests as the (initial) preferred option that the Netherlands opts out for buyer reporting. The seller reporting would replace traditional periodic reporting, such as EC Sales Listing.
• Decentralized model (no clearance): The report makes a strong case for rejecting a clearance model. Invoices are not submitted to or approved by the tax authority before exchange. Instead, reporting occurs in parallel to business-to-business transactions, aligning with a “continuous transaction controls (CTC) without clearance” model.
• Peppol-based infrastructure: The report recommends Peppol as the mandatory infrastructure for invoice exchange. Businesses would use Peppol Access Points in a four-corner model, ensuring interoperability across EU markets and leveraging existing infrastructure.
• Standardization requirements: The advocated system would require the EN16931 e-invoice standard and structured formats such as UBL or CII, with a single harmonized infrastructure (Peppol) to avoid fragmentation and enable seamless cross-border compliance.

Policy options put forward for consideration

• ViDA-A (minimum implementation): Applies only to cross-border (intra-EU) transactions, with limited impact on domestic processes.
• ViDA-B (recommended): Extends obligations to domestic B2B transactions, introducing mandatory e-invoicing and domestic digital reporting for the seller, but not for the buyer. The report concludes that ViDA-B offers greater long-term benefits, including improved compliance and efficiency. 

Implementation timeline (indicative)

Phase	Timeline	Key measures
Preparation	2026–2028	Political decision making, market consultation and legislative development
Domestic e-invoicing	~Jan 1, 2030	Start mandatory B2B e-invoicing
EU ViDA go-live	July 1, 2030	Cross-border digital reporting and e-invoicing
Domestic reporting	~2032	Extend digital reporting to domestic transactions

This phased approach aims to avoid a “big bang” implementation and allow businesses to adapt gradually.

Next steps

The report is an exploratory study by a third party, and not yet a formal policy direction nor binding legislation. The Dutch government is expected to make a first formal direction decision in the summer of 2026 and, afterwards, to launch consultations of draft legislation (provisionally announced for Q4 2026) and submit legislation to Parliament by mid-2028. Businesses should monitor developments and begin assessing readiness.

For more information, contact a KPMG tax professional:

Lennert Janssen | Janssen.Lennert@kpmg.com

Lyubov Skenderova | skenderova.lyubov@kpmg.com

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com