ViDA is a package of EU VAT reforms adopted on 11 March 2025 and rolling out progressively until 2035. Much of it concerns goods movements, platform rules for accommodation and passenger transport, and simplifications for businesses holding stock across member states.
For a typical SaaS company, the main changes are different. National e-invoicing mandates are already taking effect, and from 1 July 2030 the EU's Digital Reporting Requirements introduce structured e-invoicing and transaction-level reporting for covered cross-border B2B transactions.
The July 2028 reverse-charge reform is much less significant for pure SaaS than it may first appear. Standard cross-border B2B SaaS services already fall under the existing Article 44 and Article 196 reverse-charge rules. The 2028 change concerns Article 194 and is more relevant where a non-established supplier makes a supply taxable locally under another rule.
The rules already taking effect
ViDA removed an EU-level procedural barrier to national e-invoicing mandates. Council Directive (EU) 2025/516 was published in the Official Journal on 25 March 2025 and entered into force on 14 April 2025. Member states now have more freedom to require domestic e-invoicing without going through the previous derogation process.
Several countries already have domestic systems or phased mandates.
Germany changed its definition of an e-invoice from 1 January 2025 and requires domestic businesses to be able to receive structured e-invoices. Issuing is being phased in. During 2025 and 2026, suppliers can generally still issue other forms of invoice. Businesses with previous-year turnover of €800,000 or less retain that transition through the end of 2027, with the general domestic B2B issuance requirement applying after the transitional periods expire.
Belgium requires structured electronic invoices for covered transactions between Belgian VAT-taxable businesses from 1 January 2026, generally using Peppol BIS through the Peppol network. A non-established business without a Belgian fixed establishment is outside the mandate even if it has a Belgian VAT number, which is a useful example of why VAT registration alone does not determine whether a national mandate applies.
Italy already operates a broad domestic e-invoicing system through Sistema di Interscambio.
Poland introduced mandatory KSeF issuance in stages. Taxpayers whose 2024 sales exceeded PLN 200 million entered from 1 February 2026, with most remaining businesses following from 1 April 2026. The smallest taxpayers, where invoiced monthly sales remain within the PLN 10,000 transitional limit, can defer issuance until 1 January 2027. Receiving KSeF invoices became mandatory from 1 February 2026 for businesses within the receiving rules. Foreign taxpayers without a Polish establishment or participating fixed establishment are excluded from mandatory issuance.
France began its rollout on 1 September 2026. All businesses in scope must be able to receive electronic invoices. Large companies and intermediate-sized enterprises must also issue them from that date, while SMEs and micro-businesses move to mandatory issuance on 1 September 2027.
These are national mandates with different scope rules. Establishment, fixed establishment, transaction type, company size and local legislation can all matter. A VAT registration on its own does not automatically mean a foreign SaaS company falls within every country's domestic mandate.
ViDA scope for software companies
ViDA comprises three legal texts: Council Directive (EU) 2025/516, Council Regulation (EU) 2025/517 and Council Implementing Regulation (EU) 2025/518, all published in the Official Journal on 25 March 2025.
The reforms cover several separate areas.
Platform economy: New deemed-supplier rules apply from 1 July 2028 to platforms facilitating short-term accommodation rental and passenger transport by road. Standard SaaS products do not fall within these platform rules.
Single VAT Registration: The reforms beginning in July 2028 are designed largely to reduce multiple VAT registrations created by movements and local supplies of goods. They include an extension of OSS coverage and a new scheme for transfers of own goods. These changes are more relevant to businesses moving physical goods across the EU than to a pure SaaS company with no stock.
OSS and IOSS changes: Further changes begin in 2027 and 2028, but the core OSS model remains in place. For SaaS, OSS continues to be primarily relevant to B2C digital services.
Article 194 reverse charge: From 1 July 2028, Article 194 changes so that, subject to its conditions, the customer becomes liable for VAT when the supplier is neither established nor individually VAT-identified in the member state where the VAT is due and the customer is identified there. Member states can also apply reverse charge more broadly to some non-established suppliers.
Digital Reporting Requirements: From 1 July 2030, the EU introduces transaction-level digital reporting and structured electronic invoicing for covered cross-border B2B transactions. For a SaaS business making intra-EU B2B supplies, this is generally the ViDA deadline that deserves more attention.
The July 2028 Article 194 change
The existing VAT rules already put ordinary cross-border B2B SaaS into a reverse-charge model.
Article 44 says that, for general-rule services supplied to a taxable business customer, the place of supply is where that customer is established or where the relevant fixed establishment is located. Article 196 then makes the customer liable for the VAT when those Article 44 services are supplied by a taxable person not established in that member state. These rules have applied since 2010.
Take an Irish SaaS company selling a subscription to a German business. Assuming the normal B2B general rule applies, the service is taxable where the German customer belongs. The Irish supplier does not wait until 2028 to use reverse charge. The German customer already self-accounts under Article 196.
The 2028 reform changes Article 194 instead. Article 194 covers supplies taxable in a member state by a supplier that is not established there. From July 2028, the customer must account for the VAT where the supplier is both non-established and not individually VAT-identified in that country, provided the customer is VAT-identified there.
For a pure SaaS business using the Article 44 general rule, this usually does not create a new reverse-charge treatment.
It becomes more relevant where a company has transactions that are taxable locally for another reason. Depending on the facts, that can include local supplies connected with physical goods, hardware or stock, property-related services, admission to physical events, and other supplies governed by special place-of-supply rules.
A SaaS company that also ships hardware, installs equipment, holds local stock or provides location-specific services should therefore check whether Article 194 affects those parts of the business.
For ordinary cross-border B2B SaaS, VAT-number validation remains useful today. It supports correct customer classification and invoicing under the rules already in force; it is not something that first becomes necessary in 2028.
See our EU VAT reverse charge guide for the existing treatment of cross-border B2B SaaS.
Digital reporting from July 2030
From 1 July 2030, ViDA introduces structured electronic invoicing and transaction-level reporting for covered cross-border B2B transactions.
The invoice deadline is tied to the chargeable event. For supplies covered by the relevant rules, Article 222 requires the invoice to be issued no later than 10 days after the chargeable event. It is therefore incorrect to describe the reporting deadline as ten days after an invoice has already been issued.
For transactions reported under Article 262(1)(a) and (c), the supplier transmits the required transaction data when the invoice is issued or when it should have been issued.
The customer side also matters. For the covered acquisitions in Article 262(1)(b) and (d), the customer generally transmits the required data no later than five days after receiving the invoice. The Directive allows member states to dispense with customer-side reporting for certain categories, so this part of the implementation can vary.
Structured electronic invoices must support automated electronic processing. A normal PDF on its own does not meet that standard. XML is not automatically sufficient either: the structured data needs to comply with, or be interoperable with, the required European e-invoicing standard and accepted syntaxes.
The legislation does not make Peppol the single mandatory EU-wide transmission network. National systems can use different infrastructure, provided the ViDA requirements and interoperability rules are met.
The current EC Sales List, or recapitulative statement, is replaced for the covered transactions by transaction-level reporting when the 2030 rules take effect.
The Commission originally proposed an earlier implementation date. The legislation adopted in March 2025 sets the cross-border DRR changes for 1 July 2030. Member states must transpose the relevant provisions before that date.
For SaaS companies that currently generate ordinary PDFs for EU B2B invoices, the practical work is likely to involve invoice generation, structured data, customer VAT information and integration with whichever reporting or e-invoicing infrastructure applies to the business.
National e-invoicing can apply before 2030
The 2030 system does not replace the national mandates already taking effect.
National rules generally deal with domestic transactions. The EU-wide DRR focuses on covered cross-border transactions. A company can therefore face a domestic e-invoicing requirement before 2030 and then have separate ViDA obligations for cross-border B2B activity from July 2030.
Germany is a useful example. Domestic businesses have had to be capable of receiving structured e-invoices since January 2025, while the obligation to issue them is subject to transitional periods. France uses a different timetable based partly on company size. Belgium and Poland have their own scope tests and technical systems.
Do not assume that being VAT-registered in a country automatically puts a foreign company inside that country's mandate. Belgium excludes certain non-established VAT-registered businesses without a Belgian fixed establishment, and Poland excludes taxpayers without a Polish establishment or participating fixed establishment from mandatory KSeF issuance.
The formats also differ. Germany accepts formats such as XRechnung and qualifying ZUGFeRD implementations. Belgium's B2B system is built around structured invoices compatible with EN 16931 and generally Peppol BIS. Poland uses KSeF. France uses its own accredited-platform model.
ViDA is intended to improve interoperability over time. Member states with qualifying pre-existing domestic real-time transaction reporting systems have until 1 January 2035 to align those domestic systems with the relevant EU requirements.
The national information in this article reflects rules in force or announced as of October 2026. Local implementation should be checked again before changing an invoicing system.
The timeline
Date | Change | Relevance for SaaS |
|---|---|---|
14 April 2025 | ViDA enters into force and the framework for national e-invoicing mandates changes. | Relevant because domestic mandates can apply before the EU-wide DRR deadline. |
1 January 2027 | Further OSS/IOSS changes begin. | Limited effect for ordinary SaaS; OSS remains primarily relevant to B2C digital services. |
1 July 2028 | Article 194 mandatory reverse-charge reform, platform rules and major Single VAT Registration changes begin. | Usually limited for pure Article 44 B2B SaaS. Check it if you also have goods, hardware, local stock or supplies taxable locally under special rules. |
1 July 2030 | Cross-border Digital Reporting Requirements and structured e-invoicing rules take effect for covered transactions. | The main ViDA deadline for many EU B2B SaaS invoicing workflows. |
1 January 2035 | Qualifying pre-existing domestic real-time reporting systems must be aligned with the EU framework. | Relevant where a company is already subject to national reporting systems. |
The adopted legislation confirms the 2030 DRR date. As implementation guidance and national systems continue to develop, the technical requirements still need to be monitored.
Practical steps for SaaS companies
If you sell only to consumers through OSS or non-Union OSS, the 2030 cross-border B2B DRR is not directed at those B2C sales. Your VAT collection and OSS reporting continue under the applicable scheme. A national rule can still matter if you have an establishment or other local footprint that brings separate transactions into scope.
If you sell ordinary SaaS to VAT-registered businesses in other EU countries, do not treat July 2028 as the date when reverse charge starts. Article 44 and Article 196 already govern the standard cross-border B2B service model.
Your current process should already capture and validate the customer information needed to support correct B2B VAT treatment. VIES validation is therefore useful now rather than as preparation for a new 2028 SaaS rule.
For those B2B sellers, the larger infrastructure deadline is July 2030. Review whether your billing system can produce structured invoices, retain the required VAT data and support transaction-level reporting.
If your company is established in a member state with a domestic mandate, check the local timetable separately. Do the same if you have a fixed establishment. A foreign VAT registration by itself is not a reliable test because national scope rules differ.
A merchant of record, including tiun, can handle VAT and invoicing obligations for transactions processed under its MoR model. ViDA's 2028 Article 194 reform does not create a new reverse-charge treatment for standard B2B SaaS, so there is no basis for saying that 2028 by itself reduces the value an MoR provides for EU B2B SaaS. The relevant comparison remains the wider set of tax, payment, billing and compliance responsibilities the MoR assumes.
See our merchant of record guide for a full explanation of the model and the responsibilities an MoR takes on.
For non-EU SaaS companies, the position under the 2030 DRR needs more care.
A US company using the non-Union OSS scheme is using it for B2C services; OSS does not turn those sales into intra-EU B2B transactions.
For B2B services, Article 262 expressly includes transactions where the customer is liable for VAT under Article 196. That means an EU business receiving a qualifying Article 196 service from a third-country supplier can fall within the acquisition-side DRR framework.
The supplier-side position is different where the non-EU supplier has no EU establishment or EU VAT identification. Article 262 frames the supplier reporting obligation around taxable persons identified for VAT purposes. It would therefore be too broad either to say that every US SaaS supplier is subject to the same 2030 reporting obligation as an EU VAT-identified supplier or to say that US-to-EU B2B services sit completely outside DRR.
For a third-country SaaS company without EU VAT identification, the practical supplier-side e-invoicing and reporting treatment should be checked against the final implementation rules and the customer's member-state requirements before 2030.
See also our EU VAT compliance guide for US sellers.
Frequently asked questions
Does ViDA replace OSS?
No. OSS continues to operate for the supplies covered by its schemes. ViDA makes changes to OSS and Single VAT Registration over several stages, but it does not abolish the system.
For a typical SaaS company, OSS remains most relevant to B2C digital services. The 2028 Single VAT Registration reforms are more significant for businesses dealing with goods, transfers of own stock and other transactions that can create multiple local VAT registrations.
Do I need to issue e-invoices to EU customers today?
It depends on the transactions you make and the countries in which your business is established or has a relevant fixed establishment.
Germany already requires domestic businesses to be able to receive structured e-invoices, while issuance is being phased in through transitional periods. Belgium's covered domestic B2B mandate has applied since January 2026. Poland's KSeF issuance rules started in stages during 2026. In France, all businesses in scope have had to receive e-invoices since September 2026, while large and intermediate-sized companies must already issue them; SMEs and micro-businesses follow in September 2027.
National scope rules are not uniform. Check the rules for each relevant country rather than assuming that an EU VAT number alone triggers the mandate.
The EU-wide cross-border B2B DRR begins on 1 July 2030.
Does ViDA apply to companies outside the EU?
Parts of it can.
The July 2028 Article 194 rule specifically concerns suppliers that are not established in the member state where VAT is due and, under the mandatory limb of the rule, are not individually VAT-identified there.
The 2030 DRR also includes transactions for which an EU customer is liable under Article 196. This can include services purchased by an EU business from a non-EU supplier.
That does not mean a US supplier with no EU VAT identification automatically has the same supplier-side reporting obligation as an EU VAT-identified company. Third-country suppliers should assess their own identification status, the type of transaction and the final implementation rules separately.
Non-Union OSS remains a B2C scheme and should not be used as the basis for determining the DRR treatment of B2B services.
What happens to recapitulative statements?
The EC Sales List, also called the recapitulative statement, is replaced by the new transaction-level reporting system for the transactions brought into the DRR framework from 1 July 2030.
Until the relevant DRR provisions apply, businesses that currently have recapitulative-statement obligations continue to follow the existing rules.
Have the ViDA dates changed?
The Commission's original ViDA proposal contemplated an earlier start for the digital reporting reforms. The legislation adopted in March 2025 sets 1 July 2030 as the application date for the new cross-border DRR provisions.
The Article 194 reverse-charge reform and the main Single VAT Registration changes apply from 1 July 2028. For ordinary Article 44 B2B SaaS, however, that date should not be confused with the start of reverse charge. Standard cross-border B2B SaaS already uses the Article 196 reverse-charge mechanism today.