Online data reporting for invoicing was launched in Hungary on 2 July, though we may still see some technical problems in the course of the reporting. WTS Klient Hungary believes it would be useful if the penalty grace period of 1 month, i.e. until 31 July, were somewhat longer, given the processes at companies working with non-Hungarian invoicing systems.
Practical experience with online data reporting for invoicing
Parallel to the system that went live from 2 July, the test system for online data reporting for invoicing is also available, so special-case invoicing can still be run through the test system first to see whether the taxpayer receives a positive or negative response. (Don’t forget that providing incorrect data can leave taxpayers facing substantial default penalties.
Initially there were differences between the invoicing software programmes developed by Hungarian software developers. Most of the developers were successful in their endeavours, and the online data reporting for invoicing worked well right from the outset; others experienced problems with communications in the first weeks. And in some cases it is not easy to identify where the problem is. We feel it is important to note that the law only requires reporting on the data content of invoices, which means the obligation does not relate to other documents, pro forma invoices and receipts produced by accounting systems.
Technical and secondary registrations
The online data reporting for invoicing system resembles the EKÁER system in that here too it is the company’s representative or authorised representative who can set up the primary registration, and they can configure the technical registration as well, which is a prerequisite for M2M communication. Separate technical registration is also recommended for self-billing and in the case of all self-billing structures, while requesting separate technical registrations is advisable too when using various invoicing programmes at the same time. Two types of authorisation can be set during a technical registration:
- invoice management and invoice queries, or
- invoice management and own invoice queries
The primary user can also give access to secondary users, and can define the activities that these secondary users can perform.
Access to the Hungarian government portal is not required for secondary registrations, which means, for example, a foreign finance director or foreign experts at international companies can also view the system, check the data reporting, query the list of invoices issued for their company, and authorise their invalidation if mistakes have to be corrected.
If an original invoice has been issued incorrectly, for example the wrong tax number, VAT rate or net amount, etc. is stated, then in line with Hungarian invoicing regulations a correction document must be issued that refers to the number of the original invoice for the transaction. The system has to record the data content of the original invoice and the correction invoice.
What is important is that errors can be corrected in cases that deviate from the above as well. For example, if the data reporting cannot be processed or if a technical error slips in to the online data reporting for invoicing, then the mistake must be corrected. First of all, the data reporting must be repeated electronically in that the correction must be approved online either by the primary user or by a secondary user authorised for such tasks (i.e. the error can only be corrected [technical invalidation] after a manual step). If the developer cannot resolve the problem within 3 working days for whatever reason, then the data can be reported manually. Do not forget that the manual data reporting also has to take place on the https://onlineszamla.nav.gov.hu/ website in Hungary if the taxpayer uses a printed invoice book to issue invoices instead of invoicing software.
Grace period for penalties
According to information from the Hungarian Ministry of Finance the NAV will not impose penalties until 31 July if taxpayers register themselves in the system for online data reporting for invoicing before issuing their first invoice, and then subsequently load the invoices in by 31 July. The penalties are not to be sneezed at since at any given taxpayer they can total up to HUF 500,000 (roughly EUR 1,500) per incomplete or failed data transfer or invoice.
We will keep our readers updated of the initial lessons learned from the roll-out of the online invoicing system. Please feel free to contact us if you have any questions or comments. Together with our developers we will work on finding solutions for even the most challenging of situations.