What is audit data export?

Audit data export is a mandatory feature in invoicing software that enables businesses to provide their invoicing data to the Hungarian National Tax and Customs Administration (NAV) in a structured format during a tax audit. The legal basis is Government Decree No. 23/2014 (VI. 30.) of the Ministry for National Economy (NGM), which requires all invoicing software to support the generation of such data exports.

This feature plays a key role in ensuring that audits are carried out quickly and efficiently, as NAV auditors can receive the required information in a standardized, machine-readable format.

Why is the audit export function necessary?

The aim of the audit export function is to give tax authorities clear and direct access to invoice data during inspections. Digital data export eliminates manual data entry errors, speeds up the audit process, and helps uncover irregularities.

NAV may request audit data export in the following cases:

• During targeted or random audits,
• In tax investigations (e.g. VAT audits),
• If there is suspicion of fraud or misconduct.

What does the regulation require?

According to Decree No. 23/2014 of the Ministry for National Economy:

• All invoicing software must include a function called “data export for tax authority audit”,
• The taxpayer must be able to provide invoice data to NAV on an electronic medium (e.g. USB drive, email, cloud service),
• The data must be produced in a specific structure, namely in XML format, following the schema provided in the annex to the regulation.

What formats can be used for export?

Currently, two XML formats are accepted:

• The original XML schema defined in the decree, which represents the classic audit export format,
• The XML schema used for online invoice reporting, which offers a more modern and detailed structure.

Businesses can choose either format, but it is essential that the exported data be complete, consistent, and include all mandatory invoice elements.

What data must be included in the export?

The exported file must include all data that is required on an invoice, such as:

• Issuer and buyer information,
• Invoice number, date of issue, and date of performance,
• Description of goods or services,
• Quantity and value details (net, VAT, gross),
• Payment method and due date.

The newer XML structure (based on online invoice reporting) may include additional details, such as the buyer’s full name and address — even for individuals — which are not always required in real-time invoice reporting.

What does this mean in practice for businesses?

Any business using its own invoicing software must ensure that it complies with the requirements of the NGM decree. During an audit, providing the data export is not optional — it is a legal obligation.

Therefore, it is important to:

• Keep the software up to date,
• Regularly test the export functionality,
• Train staff to prepare and submit the export correctly.

What are the penalties for non-compliance?

If a company uses invoicing software that does not comply with the regulation or lacks the audit export function, NAV may impose a penalty. Fines can amount to several hundred thousand forints, especially if there is evidence of intent or abuse.

Summary

Audit data export is a key element of digital tax control in Hungary. This function is mandatory in all invoicing software and enables NAV to inspect invoice data in a structured, machine-readable format. Either the original schema from the decree or the online invoice reporting XML format may be used — what matters most is that the export be complete, accurate, and up to date.

Official definition

According to Decree No. 23/2014 (VI. 30.) of the Ministry for National Economy, all invoicing software must include a “data export for tax authority audit” function, enabling taxpayers to provide their invoicing data to NAV on an electronic medium in a structured format during tax audits.

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