Article 226 of the VAT Directive: which mandatory invoice details to translate into software controls

01

The mandatory details to check

Article 226 of the VAT Directive makes certain details on issued invoices mandatory, unless special provisions apply: the date of issue, a sequential number that uniquely identifies the invoice, the VAT identification number of the party making the supply, and, in the cases set out in that provision, the VAT identification number of the customer or recipient.

These elements are the first block of controls to configure before issuing invoices, checking case by case when the recipient's VAT number is also required.

02

Why these details are mandatory

The obligation to issue an invoice arises from Article 220 for supplies of goods and services to another taxable person or a non-taxable legal entity, as well as for advance payments received before the transaction is carried out.

Amounts may be expressed in any currency, but the VAT amount payable must be expressed in the national currency of the Member State, applying the conversion rate mechanism provided for.

03

How to translate Article 226 into operational controls

Steps

1. Automatically record the date of issue when the document is generated.
2. Assign a unique sequential number for each invoicing series used.
3. Validate the format of the supplier's VAT identification number before issuance.
4. Check the VAT identification number of the customer or recipient in the cases where the transaction requires it.
5. Convert the VAT amount into the national currency when the invoice is issued in another currency.

04

Hypothetical example

Hypothetical example: a company issues invoices to customers in three different Member States, in different currencies. The system assigns a sequential number for each series, checks the supplier's VAT number and, when required, the recipient's, and converts the amount due into the national currency of the competent Member State, as provided by the conversion rate mechanism.

05

Controls to verify before issuance

• The date of issue is present and consistent with the time of generation.
• The sequential number is unique and does not repeat across series.
• The supplier's VAT identification number is present and in the correct format; the customer's is checked in the cases where this detail is required.
• The VAT amount is expressed in the national currency of the Member State.
• For electronic invoices, the recipient's agreement is recorded, unless a national exception applies.

06

What a company can configure with its software partner

A company can ask its software partner to configure fields for date, sequential numbering and the applicable VAT numbers, with validation controls before issuance. This is a suggested operational choice, not a legal requirement imposed by the tool.

For archiving, the company can define roles and responsibilities for who keeps copies of issued and received invoices and how to make information quickly available if requested, maintaining an audit trail between the invoice and the transaction.

07

Frequently asked questions

Article 233 requires that the authenticity of origin, integrity of content and readability of the invoice be ensured from the time of issue until the end of the archiving period, including through management controls that create a reliable audit trail.

Article 236 allows, in the case of batches of electronic invoices sent to the same recipient, common information to be mentioned only once, provided that the full information for each invoice remains accessible.

Article 242 requires accounting records detailed enough to allow VAT to be applied and checked by the tax authority.

08

Next step

Check with your software partner which mandatory fields under Article 226 are already automatically controlled and which require additional configuration, including the archiving rules set out in Articles 244 and 245.