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

01

What Article 226 requires and what the software must check

Article 226 of the VAT Directive lists the particulars an invoice must contain: date of issue, unique sequential number, VAT identification number of the supplier, and VAT identification number of the customer when required. An invoicing system must translate these obligations into automatic checks that verify the presence and consistency of each item before accounting entry.

In addition to these checks are the rules on the currency of the VAT amount, the recipient's consent for electronic invoicing, and ensuring the authenticity, integrity, and legibility of the document from the moment of issue until the end of the storage period.

02

Why this data matters in the VAT process

The obligation to issue an invoice applies to supplies of goods and services made to another taxable person or to a non-taxable legal entity, including intra-Community supplies and advance payments received before the transaction.

Every taxable person must also keep accounts detailed enough to allow VAT to be applied and checked by the tax authority, and must store copies of invoices issued and received.

03

Control flow before accounting entry

Steps

1. Check that every invoice shows the date of issue and a unique sequential number before entry.
2. Check the presence of the supplier's VAT identification number and, when required, the customer's.
3. Convert the VAT amount into the national currency at the required rate when the invoice is expressed in another currency.
4. Record the recipient's agreement to use electronic invoicing, subject to exceptions set by the Member State.
5. Set up business controls that create a reliable audit trail between the invoice and the underlying transaction.

04

Hypothetical example of an automatic check

Hypothetical example: a business selling services to another taxable person issues an invoice with a date, sequential number, and its own VAT number. The system checks that the customer's VAT number is present, as required by Article 226, and blocks entry if a mandatory field is missing.

05

Checklist of fields to check

• Date of issue present and consistent with sequential numbering.
• Supplier's VAT number and, where necessary, the customer's VAT number recorded.
• VAT amount converted into national currency when the invoice is in another currency.
• Trail of business controls linking the invoice to the transaction.
• Invoice copy stored and accessible on request by the tax authority.

06

Setting up controls with a software partner

Without documented product features covered here, a business can ask its software partner to configure mandatory fields for date, sequential number, and VAT number, with distinct roles for those who issue and those who approve the invoice, making each step traceable.

This is a suggested operational choice, not a software legal requirement: consider an automatic check that flags incomplete invoices and keeps a change log, consistent with the authenticity and integrity needs set out by the directive.

07

Quick clarifications on the mandatory particulars

• The mandatory particulars under Article 226 apply unless special provisions of the directive say otherwise.
• The electronic invoicing obligation requires the recipient's agreement, with possible national exceptions.

08

Next step

Map the Article 226 fields into the invoice template of the management system and have a tax advisor check consistency with the storage rules set out in Articles 244 and 245.