In recent months, the tax experts of WTS Klient Hungary have received numerous client enquiries regarding whether the planned phasing out of the ÁNYK (General Form Completion Program) will indeed take place in Hungary, and what businesses should prepare for from 1 January 2027.
Until this morning, we had to assume that there would be no postponement. However, the information published by the Hungarian tax authority on 15 October points to a significant change: instead of a complete, simultaneous phase-out, the tax authority is proposing a gradual transition.
According to its announcement of 15 October, the Hungarian tax authority surveyed accountants, tax professionals and software developers regarding the e-VAT system. Of the approximately 2,000 respondents, 55% of accountants identified the lack of preparation time and the delayed development of accounting software as obstacles. Meanwhile, 64% of software developers had not yet started actual testing.
There were still many open questions
As advisers, we also saw a number of uncertainties regarding the previously planned accelerated transition:
- On the one hand, it was unclear what burden the phase-out of the ÁNYK program with effect from 1 January 2027 would have placed on the systems of the Hungarian tax authority, and whether all affected taxpayers would have been able to prepare adequately for the new operating environment.
- On the other hand, based on the information available to us, certain technical issues had not yet been resolved, such as the future of the EC Sales List, and whether it would be incorporated into the e-VAT M2M system.
- In addition, in the case of the general M2M document submission system, XSD structures were still available for only a relatively limited number of forms.
According to the announcement of the tax authority, more time may now become available to resolve these issues.
What rescheduling does the tax authority propose for the phase-out of the ÁNYK program?
According to the proposal, the phase-out of the ÁNYK program would take place gradually, tax return by tax return and form by form.
According to the announcement:
- first, the largest companies would be required to switch to e-VAT during 2027 (although it is still unclear which companies would qualify as the largest, whether this would be linked to tax performance or transaction volume, and whether the original 1 January deadline would remain unchanged above a certain size threshold);
- the majority of VAT taxpayers, including small and medium-sized enterprises, would receive more time for preparation and testing;
- according to the proposal, the transition to e-VAT would become mandatory for them from 1 January 2028;
- several widely used tax returns, including personal income tax returns and corporate income tax returns, could still be submitted through the existing system during 2027;
- individual forms would only be removed from the ÁNYK program once affected users had sufficient time to become familiar with and test the new solutions.
It is important to stress that the Hungarian tax authority currently presents this revised timetable as a proposal. Therefore, it should not yet be regarded as a final and legally effective transition schedule.
The profession can breathe more easily, but ongoing developments should not be put on hold
The announcement may undoubtedly provide some breathing space for tax professionals, accountants, businesses and software developers. However, in our view, it would be a mistake to interpret this news as meaning that M2M developments have lost their relevance.
Businesses that have already started implementing M2M solutions, or are currently preparing for implementation, therefore have no reason to be concerned.
After all, M2M solutions are important not only for regulatory compliance. When implemented appropriately, they make it possible for the tax return submission process to be automated to a significant extent, reducing manual administration and the related additional workload.
For this reason, the longer preparation period should not necessarily be used to postpone projects. Rather, businesses should use this opportunity to plan, develop and test their digital tax processes without excessive time pressure. According to the wording of the tax authority, only the implementation timeline would change, not the overall direction. The ÁNYK program would still be replaced by more modern digital services. For smaller businesses and private individuals, the tax authority primarily identifies ONYA (Online Form Completion Application) as the alternative, while larger companies are expected to rely on machine-to-machine solutions, and e-VAT specifically in the area of VAT returns.
The tax advisers of WTS Klient Hungary continuously monitor the legislative process surrounding the digitalisation of VAT returns and can provide clients with the most up-to-date answers to questions arising in this area. In addition, the experts of our Digital Solutions business line, who have extensive experience in both IT development and taxation, are ready to assist you with the transition to the Hungarian e-VAT system and preparations for the implementation of M2M VAT reporting. Contact us today to benefit from expert support from the very beginning of the process.
This article is for general information purposes only and should not be considered as advice.
