According to information recently published on the Government’s website, the tightening that entered into force on 1 July will not be applied after all. Although, due to legislative deadlines, its regulation at statutory level is still pending, the uncertainty is somewhat eased by the above-mentioned information, according to which “the Government plans to submit a proposal to Parliament in order to ensure that the stricter rules do not actually have to be applied for any reporting period.”

The essence of the planned tightening was that Act LXXXIII of 2025 on the amendment of certain tax laws for the purpose of reducing administration and ensuring legal harmonisation would have significantly expanded the data content to be completed in the domestic recapitulative statements, i.e. the M sheets. In relation to incoming invoices, the data content currently includes, in addition to the tax number of the invoice recipient, broken down by invoice issuer:

• the name of the invoice issuer
• the first eight digits of the tax number of the invoice issuer or, in the case of VAT group taxation, of the group identification number
• the invoice number
• the date of performance or, in its absence, the date of issue of the invoice
• the net amount of the invoice
• the amount of VAT charged. In the case of a final invoice received in connection with advance invoice(s), the full tax base and tax amount of the completed transaction must be indicated, as well as the tax base and tax difference resulting from the consideration of the advance payment(s).

Before 1 July 2026, the data that could be completed on a voluntary basis included the amount of tax actually deducted from the total amount of VAT charged, broken down by tax rate and by the amount of tax deducted through apportionment.

The planned tightening would have made this data reporting, which had previously been possible on a voluntary basis, mandatory, supplemented by the requirement that, in the case of invoice amendments or cancellations, this also had to be indicated in the relevant parts of the return.

This would have resulted in much more accurate and, according to the purpose of the regulation, better-quality data reporting, through which the tax authority would have received invoice-level data on the amount of VAT deducted by the invoice recipient.

The Government’s information does not indicate exactly what legislative technique will be used to resolve the current discrepancy whereby a statutory provision in force does not have to be applied in practice. However, it is entirely clear that there is no intention to impose sanctions if taxpayers do not comply with the prescribed data reporting obligation with expanded content.