ViDA package published – should we be afraid of the EU “schema”?

ViDA package published – announced DRR dates unchanged

On 25 March 2025, the VAT in the Digital Age (ViDA) package was officially published in the Official Journal of the European Union as Council Directive (EU) 2025/516. This is the legislative final of a long-awaited reform at European Union level to modernise VAT settlements and make the system itself more fraud-proof.

Recent reports from the European Court of Auditors or the European Public Prosecutor’s Office point to the still significant risks of VAT fraud in EU countries. Undoubtedly, a key area of this reform is the so-called Pillar I or digital reporting (DRR).

In terms of dates, three aspects are key:

1. 2025 (20 days after the publication of the ViDA): European Commission approval for national e-invoicing (derogation) will no longer be required;
2. from 1 July 2030, e-invoicing will become mandatory for intra-EU B2B transactions. National e-invoicing systems (excluding those introduced before 2024) must comply with EU standards. The deadline for the issuance of an invoice for cross-border transactions should be set at 10 days after the chargeable event has taken place.
3. From 1 January 2035, national e-invoicing systems in place before 2024 must comply with EU standards.

Are these 2030/2035 dates definitive? We’ll see.

In the past, such as in the case of the VAT E-Commerce package, due to insufficient preparation of some countries’ administrations, the implementation date was postponed. Despite “only” 2030/2035, it may be difficult for some countries to meet these dates.

EU schema vs. national schema – what next?

The ViDA package rightly assumes that e-invoices in Europe should be issued according to a single standard (schema). This is to apply not only to intra-Community transactions, but also when EU countries decide to make e-invoicing mandatory for domestic transactions. In this area also, after a transitional period (after 2035 at the latest), EU countries must guarantee the right to invoice according to the European standard.

The ViDA package did not create from scratch and work separately on the European schema, but referred to the standard used for B2G transactions. Work is currently underway within CEN (European Committee for Standardisation) to ‘adapt’ the European standard to B2B transactions, which at CEN level is expected to be completed by mid-2025.

Of utmost importance in this area are the possible differences between the structure (schema) adopted at EU level by reference to the European standard (EN 16931) used to date for B2G relationships and the schema adopted in the laws of individual countries.

A specific example is Poland, where the KSeF schema (incidentally presented earlier than ViDA referring to EU standard) is built according to a completely different philosophy than the European standard and is much more detailed. In Poland, the KSeF becomes mandatory at the beginning of 2026, so in principle all invoices, including those documenting international transactions, will be issued in the domestic schema (although made available to international counterparties in a form agreed with them).

So will there be a need for another implementation of a second EU schema this time? All indications are that it will not, at least according to the Ministry of Finance. However, no details are yet available. On the positive side, the ViDA itself here allows countries to introduce schema conversion (interoperability) – which may well happen in Poland – and the schemas will be converted.