Invoices and Article 226: the checklist of mandatory software controls

01

What Article 226 says

Article 226 of the VAT Directive lists the mandatory indications an invoice must contain, unless special provisions apply: date of issue, unique sequential number, VAT identification number of the supplier and, where required, of the customer. A management system can translate these obligations into automatic controls that verify the presence and consistency of these fields before issuance, reducing the risk of incomplete invoices.

02

Where the obligation comes from

The obligation to issue an invoice arises from Article 220 for supplies of goods and services to other taxable persons or non-taxable legal entities, including advance payments. Article 226 then sets the minimum mandatory content. Article 230 allows amounts in different currencies, provided the VAT amount is expressed in the national currency of the Member State. Article 232 subjects electronic invoicing to the recipient's acceptance, subject to national derogations.

03

From mandatory indications to controls

Steps

1. Verify that every invoice issued shows the date, unique sequential number and the supplier's VAT number, as required by Article 226.
2. Check consistency of the customer's VAT number when the transaction requires it.
3. Ensure authenticity of origin, integrity of content and legibility from issuance until the end of the storage period, as required by Article 233.
4. Set up a reliable audit trail between the invoice and the underlying supply of goods or services.
5. Store a copy of every invoice issued and received as required by Article 244, freely choosing the storage location under Article 245.

04

Hypothetical example

Hypothetical example: a company issuing electronic invoices to other taxable persons sets up a control that blocks sending if the sequential number or the customer's VAT number is missing, and checks that the VAT amount is expressed in the national currency even when the document is issued in a foreign currency.

05

Checklist of minimum controls

• Date of issue present and consistent with sequential numbering (Art. 226).
• Supplier's VAT number and, where required, the customer's (Art. 226, Art. 220).
• VAT amount expressed in the national currency when the invoice is in a foreign currency (Art. 230).
• Recipient's acceptance recorded before sending electronic invoices, subject to national derogations (Art. 232).
• Audit trail and storage of every copy issued or received (Art. 233, Art. 244).

06

How management software can support these controls

A company can ask its software provider to configure mandatory fields for date, sequential number and VAT number, blocking issuance when data is missing, in line with Article 226. This is an operational choice, not an obligation imposed by the software.

To support the audit trail required by Article 233, it is useful to assign clear roles to those who prepare, verify and store the invoice, and to keep a change log. Storage of copies, under Article 244, can be organized in a traceable repository chosen by the company, as permitted by Article 245.

07

In summary

• The mandatory indications of Article 226 concern the date, sequential number, supplier's VAT number and, where required, the customer's.
• Article 233 requires authenticity, integrity and legibility of the invoice from issuance until the end of the storage period.
• Article 244 requires storage of copies of every invoice issued or received.

08

Next step

Before automating invoice issuance, map which fields of Article 226 your management system already verifies and which require an additional manual check.

Expected result: A checklist of software controls aligned with the mandatory indications of Article 226.