Article 226 of the VAT Directive: which particulars become software controls

01

What Article 226 requires

Article 226 of the VAT Directive 2006/112/EC lists the mandatory particulars for VAT purposes for invoices issued under Articles 220 and 221, unless special provisions apply. These include the date of issue, a sequential number uniquely identifying the invoice, the VAT identification number of the taxable person supplying the goods or services, and the VAT identification number of the customer or recipient. A software system can turn each particular into a mandatory check to be performed before issuance.

02

Why the obligation arises upstream of issuance

Article 220 requires the taxable person to ensure an invoice is issued for supplies of goods or services to other taxable persons, and also for advance payments received before the transaction. Article 233 adds that the authenticity of origin, integrity of content and legibility of an invoice must be ensured from the moment of issue until the end of the storage period, and that this can be achieved through business controls that create a reliable audit trail between the invoice and the underlying transaction.

03

How to translate Article 226 into controls

Steps

1. Check that every invoice shows a date of issue before final saving.
2. Verify that the sequential number uniquely identifies the invoice within its series.
3. Validate the VAT identification number of the person supplying the goods or services.
4. Validate the VAT identification number of the customer or recipient for the transactions concerned.
5. If the amount is not expressed in national currency, verify the conversion under Article 230.

04

A hypothetical case: batches of electronic invoices

Hypothetical example: a company sends several electronic invoices to the same recipient in a single batch. Under Article 236, particulars common to several invoices may be mentioned only once, provided that the totality of the information remains accessible for each invoice. A software control can therefore verify that each invoice in the batch, even without repeating the common data, keeps all required particulars individually retrievable.

05

Minimum checklist before issuance

• Date of issue present and correct.
• Unique sequential number assigned to the invoice.
• VAT number of the issuing taxable person verified.
• VAT number of the customer or recipient verified, where required.
• Audit trail between the invoice and the underlying transaction documented (Art. 233).

06

What a company can configure in a management system

A company can ask its software partner to configure roles and review steps that verify, before issuance, the presence of the particulars required by Article 226. It can also organize a trail linking each invoice to the underlying transaction, consistent with the idea of a reliable audit trail under Article 233, and arrange orderly storage of copies so they can be made available to the competent authorities on request, as provided by Articles 244 and 245. These are suggested operational choices, not product requirements.

07

Frequently asked questions on the control flow

The recipient's agreement is relevant for electronic invoicing: Article 232 makes it subject to the recipient's consent, unless Member States set exceptions.

Accounts must be sufficiently detailed to allow VAT to be applied and checked, under Article 242.

The VAT return must be submitted within a deadline set by Member States, which may not exceed the end of the tax period by more than two months, under Article 252.

08

Next step

Compare the checklist with your current invoicing cycle and ask your software partner to activate the missing checks on the Article 226 particulars before the next invoicing run.