VAT in the Digital Age: the ViDA Timeline to 2035

ViDA is one directive, Council Directive (EU) 2025/516, adopted on 11 March 2025, published in the Official Journal on 25 March 2025 and in force since 14 April 2025. It carries three pillars: digital reporting requirements with electronic invoicing, new VAT rules for the platform economy, and Single VAT Registration.

The reason so much commentary contradicts itself is structural. The directive is built as five separate blocks of amendments, each with its own application date: Article 1 from entry into force, Article 2 from 1 January 2027, Article 3 from 1 July 2028, Article 4 from 1 July 2029 and Article 5 from 1 July 2030. An article that says ViDA starts in 2028 is describing one block and ignoring four.

That staging matters commercially, because the pillars land on different businesses. A goods marketplace is affected in 2027, a seller with stock in several countries in 2028, a travel platform in 2028 or 2030, and essentially every business making cross-border B2B supplies in 2030.

The quietest part of ViDA is the part that has already reshaped Europe. Article 1 added a paragraph to Article 218 of the VAT Directive allowing Member States to require taxable persons established in their territory to issue electronic invoices for domestic supplies. A matching change to Article 232 means those invoices no longer need the recipient's acceptance.

Before this, a Member State wanting a domestic e-invoicing mandate had to request a derogation from the Commission and wait for a Council implementing decision. That requirement is gone, and Member States were allowed to apply the change from 14 April 2025. This is the legal reason national mandates across the EU could be scheduled so quickly.

France is the clearest illustration, and it is where the practical work is happening now rather than in 2030. A French VAT number alone does not put a foreign business in scope. The national timetable matters where it carries out French-situs transactions for which it is liable for French VAT, or specified buyer-side reverse-charge and intra-Community acquisition transactions: see France e-reporting for foreign companies for the 2026 and 2027 start dates and what falls inside the scope.

Article 1 also tightened the import scheme. It requires the Commission to adopt an implementing act linking the unique consignment number to the IOSS VAT identification number, an anti-fraud measure aimed at the misuse of IOSS numbers on low-value imports.

The table below is the whole programme in one place, including the pieces that sit outside the marketplace rules. Dates come from the directive itself and from its transposition article, not from proposal-stage commentary, which described a different and earlier schedule before the final text was agreed.

A new Article 28a makes a platform the deemed supplier of short-term accommodation rental, defined as uninterrupted rental to the same person for a maximum of 30 nights, and of road passenger transport. The platform is treated as having received and supplied the service itself, so it accounts for the VAT.

There is an important escape. The rule does not apply where the underlying provider gives the platform a VAT identification number for the Member State of supply, or a number under the non-Union or Union special schemes, and declares that it will charge the VAT due. In other words, this targets the untaxed long tail of individual hosts and drivers rather than professional operators who are already in the system. Member States may also require the platform to validate that number, and may exclude supplies made under the SME scheme.

Two supporting provisions keep the mechanics clean: Article 136b exempts the underlying provider's supply to the platform, and Article 172a stops those deemed supplies from damaging the platform's own right of deduction. Member States may apply the regime from 1 July 2028 and must apply it by 1 January 2030, so a two-speed period across the EU is not just possible, it is designed in.

This is a services regime and it is regularly confused with the goods rule for marketplaces, which is a different article of the directive and has applied since 2021. If your question is about physical goods sold through Amazon, eBay or similar, the relevant rule is in EU marketplace deemed supplier VAT instead.

This is the pillar with the most direct commercial value for cross-border sellers. A new special scheme for transfers of own goods exempts the intra-Community acquisition in the destination Member State and, notwithstanding Article 214(1), expressly does not create a registration obligation there. For a business moving its own stock around Europe, that removes the single biggest cause of extra VAT registrations.

Alongside it, the amended Article 194 makes the reverse charge mandatory: where a supplier is neither established nor VAT identified in the Member State where the VAT is due, and the customer is already identified there, the customer becomes liable. Member States may extend the reverse charge more widely for non-established suppliers. The Union OSS is also extended to cover more supplies, including domestic supplies by non-established businesses.

The conditions are where the value gets decided. The scheme is optional but applies to all covered transfers once chosen. It does not cover transfers of goods without a full right of deduction in the destination country. Input VAT in the departure and arrival countries is recovered through the refund directives rather than the scheme return. Any registration required by another activity, such as an import or a local sale, survives untouched. And the call-off stock simplification in Article 17a closes to new movements after 30 June 2028 and ends completely on 30 June 2029.

The practical preparation is an inventory of why each existing registration exists. We work through that with sellers in if Amazon collects VAT, do you need VAT registration?, which separates the registrations 2028 can close from the ones it cannot.

The 2030 block is the largest change in the package and the least discussed, because it is furthest away. It replaces periodic recapitulative statements with transaction-level reporting and makes structured electronic invoicing the default for the transactions in scope.

The revised Article 217 defines an electronic invoice as one issued, transmitted and received in a structured electronic format that allows automated processing, and Article 218 requires invoices to be issued as electronic invoices, complying with the European standard under Directive 2014/55/EU. A PDF sent by email is not an electronic invoice for this purpose.

Two operational details will hurt anyone who leaves this late. Under the revised Article 222, invoices for intra-Community supplies and for supplies where the customer is liable must be issued no later than 10 days after the chargeable event. Under the revised Article 263, the data is transmitted for each individual transaction at the time the invoice is issued or should have been issued, rather than in a periodic listing.

The enforcement design is what makes it serious. The amended Article 138(1a) denies the exemption for an intra-Community supply where the supplier has not complied with the reporting obligation, or where the data transmitted is incorrect, unless the shortcoming can be justified to the authorities. Article 168 also lets Member States make the customer's right of deduction conditional on holding a compliant electronic invoice. Reporting failures stop being a penalty question and start being a VAT-liability question.

Member States may additionally impose domestic digital reporting under Article 271a, limiting its scope to certain taxable persons or transactions. Those that already had a domestic real-time reporting system in place on 1 January 2024, or an authorisation for one, have until 1 January 2035 to converge with the EU rules. The Commission must deliver an interim evaluation report by 31 March 2033.

Nothing in the 2028 and 2030 blocks requires action this quarter, but two things do. The first is any national e-invoicing mandate that already applies to you, because those are running now under the April 2025 change. The second is the 2027 marketplace change, if you sell goods through platforms.

Everything else is a planning exercise, and the businesses that will find 2028 easy are the ones that start the registration inventory in 2026 rather than in 2028. For accountants and agencies, that inventory is also where the advisory work moves: from opening registrations to deciding which ones remain legally necessary. We work with partners and referral firms on exactly that.

If you want your own position mapped against these dates, contact our VAT team with your entity, your stock countries, your sales channels and any existing registrations.