According to a statement of the Hungarian Ministry of Finance also published on the website of the Hungarian tax authority (NAV), based on the government’s plans, the invoice-level reporting obligation to be fulfilled by invoice recipients as part of the VAT return, i.e. the so-called form M, would continue to be completed in an unchanged manner even after 1 July 2026. The statement recalls that the rules governing the reporting obligation for received invoices were tightened by Act LXXXIII of 2025 with effect from 1 July 2026.
The stricter rules were originally intended to apply for the first time to VAT returns covering 1 July 2026. At the same time, the Hungarian Ministry of Finance indicated that the Hungarian government plans to submit a proposal to the Parliament to ensure that the stricter rules do not have to be applied in practice for any VAT return period.
Why did the change raise questions?
In recent months, we have participated in several professional consultations with NAV regarding the introduction of the M2M (Machine-to-Machine) VAT return solution. During these consultations, the question repeatedly arose as to what justified the tightening of the form M reporting requirements during a period when, according to current plans, VAT data reporting will already take place through an M2M connection or the e-VAT web interface from 1 January 2027.
This question was particularly relevant because the new VAT return solutions do not require the completion of the form M (as detailed invoice data are submitted through these systems anyway). Therefore, the reporting obligation introduced from 1 July 2026 would likely be relevant only on a temporary basis.
What did the NAV say during the consultations?
The response of the NAV was clear: as long as the applicable legislation prescribes a specific obligation, the Hungarian tax authority cannot act differently.
During the professional consultations, representatives of the tax authority emphasised that compliance with the effective statutory provisions is mandatory. Consequently, the question of applying the form M rules is fundamentally not a tax authority issue but a legislative matter.
The solution may come from the legislative side
Based on the statement of the Hungarian Ministry of Finance that has now been published, it appears that this issue has also reached the legislative agenda. According to the statement, the government’s objective is to ensure that the stricter rules do not have to be applied in practice during any VAT return period.
If the Hungarian Parliament adopts the planned amendment, businesses in Hungary will be able to continue fulfilling the form M reporting obligation applicable to invoice recipients in the same way as before, without having to apply the stricter rules introduced from 1 July 2026.
What should businesses monitor in the upcoming period?
At present, the statement of the Hungarian Ministry of Finance reports on a planned legislative amendment. Accordingly, businesses should continue to monitor legislative developments and official communications issued by the NAV to ensure they are informed of the final rules in a timely manner.
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 provides general information and does not constitute advice.
