ÁNYK phase-out: gradual transition proposal and preparation

By Kovács András

NAV proposes gradual ÁNYK migration: largest companies during 2027, most VAT filers from 2028. Exact enterprise start unspecified; not final legislation.

NAV’s earlier communication envisaged a universal ÁNYK switch-over. The 15 October announcement instead proposes a phased timetable by return and form. On 15 October 2026, NAV proposed a gradual ÁNYK phase-out by return and form. The largest companies would move to mandatory eVAT during 2027, but no exact start date has been announced: 1 January 2027 is not fixed. For most VAT filers, including SMEs, the proposed start is 1 January 2028. Personal income tax and corporate income tax returns would remain fileable through ÁNYK during 2027. This is a NAV proposal, not final legislation; the detailed scope and exact dates require further official announcements. Preparation still requires work on data, validation, permissions and approval chains; organise the steps below into an internal implementation plan.

NAV has published an updated, user-group-based transition knowledge base. See the current timetable and the separate rules for VAT returns, other processes, and self-revisions of earlier periods in our update.

What does the ÁNYK phaseout actually mean?

ÁNYK was one of the key tools of Hungarian tax administration for nearly two decades: submitting returns, data reports, and official forms became a daily routine through it. In recent years, however, it became increasingly clear that the framework's operating logic — file-based, client-side completion, post-submission upload — does not fit NAV's data-driven strategy. The phaseout of ÁNYK means that the familiar operating routine will disappear at multiple points in the filing process. The change does not stop at the submission interface: it affects data preparation, the approval chain, error handling, and reconciliation. The authority already performs automated risk analysis based on data from the Online Invoice system, customs and cash register data, and other databases. In this environment, a tax return is increasingly a data verification and validation checkpoint, not a starting point for data disclosure. The autumn 2025 tax consultation definitively closed the uncertainty that had been dragging on for years: this is not a reform, but a phaseout.

In many organizations, ÁNYK-based operations are still highly manual today. Exports, local machines, person-dependent controls, and partially undocumented steps hold the process together. If these points are not addressed in time, the transition can easily become a series of temporary fixes:

which interface is used to prepare the return

how validation and error handling are performed

who approves and with what logging

how much of the entire process can be automated.

What replaces ÁNYK in practice?

Based on the current situation, no single tool will replace ÁNYK-based operations. For simpler cases manageable through a user interface, online form-based operations are expanding, while for regular, structured, and high-volume processes, machine-to-machine connections are coming to the fore.

This distinction is especially important in the area of VAT. Here it is not simply a matter of switching interfaces, but of how the organization produces the basis for the return, how it validates, and where final approval takes place.

ONYA – Online Form-Filling Application

ONYA has been operating since 2018 and is continuously expanding. It is a web-based interface, accessible from any device without installation. For new forms, it is increasingly common that a given form is only available on the ONYA platform — it never appeared in ÁNYK at all.

Recommended for: individuals and smaller taxpayers who handle tax matters manually at low volume, and for simpler forms.

Limitations: VAT returns are not planned to be submittable through ONYA.

eÁFA system

eÁFA has been available as a VAT filing system since February 1, 2024. It is built on data available to NAV — online invoices, cash registers, customs — in a web-based environment, while in the machine-to-machine version the tax authority compiles the return from submitted data. VAT returns can currently be prepared in three ways:

Via web interface – NAV prepares a draft with automatic tax coding, which the taxpayer reviews and approves.

Via machine-to-machine (eÁFA M2M) connection – structured XML data submission, integrated with the company's own ERP or accounting system. A standalone solution is also suitable if the ERP or accounting software does not provide this.

Check ÁNYK availability for the specific form and period; NAV proposes a gradual phase-out.

NAV M2M – machine-to-machine connection

NAV M2M (machine-to-machine) is API-based, fully automated data submission. It is not manual form-filling, but a direct, programmatic connection between the solution used by the company and NAV. Importantly, it is not the same as the eÁFA M2M system. Some elements of the service are already usable; software developers and end users must register in advance in the NAV Client Portal under the M2M registration menu. The new Document API has been live since August 3, 2026.

Which channel should you choose? Decision matrix

The July 1, 2026 M-schedule change – a strategic dilemma

Under Act LXXXIII of 2025, from the tax assessment period that includes July 1, 2026, the M-schedule of the VAT return must mandatorily report the amount of tax actually deducted, broken down by tax rate (5%, 18%, 27%) and apportionment, with invoice-level detail. Previously, only the total tax amount charged on the invoice was included — this represents a significant change.

The dilemma is as follows:

Compare the cost of maintaining the existing process with eVAT preparation for the specific obligation and implementation horizon. NAV’s 15 October proposal does not support a universal 1 January 2027 cut-off or a fixed six-month payback assumption. Plan preparation for each obligation and client: data assessment, channel selection, permissions, testing and professional approval. Keep internal project dates separate from filing due dates and the transition proposal, which is not final.

In other words: the legislator is also steering toward eÁFA with this change. Every further short-term ÁNYK development is becoming increasingly difficult to justify economically.

What does this mean for accounting firms?

Accounting firms face a portfolio-level challenge. They must simultaneously ensure:

the uninterrupted operation of existing ÁNYK-based processes for the remainder of the year,

the gradual transition to new channels, client by client,

stricter auditability of data and access management (in M2M, every return has a clear digital trail),

client communication and explanation of new workflows.

Moving a large client portfolio from Excel- and ÁNYK-export-based processes requires a staged plan. Group clients, arrange permissions and standardise data preparation according to each client’s obligations; do not assume a universal 1 January 2027 start.

What does this mean for mid-sized and large enterprises?

For mid-sized and large enterprises, the transition is rarely just about a "new submission interface". The real work lies at the source of the data.

ERP and tax code assessment

Is the tax coding behind the VAT return lines consistent? Can the current data structure serve the required fields of the eÁFA M2M XSD schema without data quality degradation? The eÁFA M2M XML data structure does not use the company's internal tax codes, but NAV-standard tax codes — the quality of the mapping determines whether the draft will be correct.

VAT analytics audit

Most VAT analytics do not contain all the data fields required by the eÁFA system, or if they do, not necessarily at the required quality. One of the first steps in preparation is to compare the structure of the VAT analytics against eÁFA requirements.

Responsibility matrix and audit trail

Who prepares the data, who validates it, who approves it, who submits it? NAV is performing an increasing number of checks digitally, based on data; on the company's side, it must also be documented who approved what, when, and based on what data. In M2M systems, access management must be handled by the software used, since in machine-to-machine communication the submission authorization is tied to the organization and its associated identifier keys, not to the individual user who prepared the return.

Parallel run and testing schedule

For other tax types, the route is NAV M2M, or ONYA for smaller, simpler cases. It is advisable to run the new channel in parallel with ÁNYK for several months to ensure adequate preparation time and the establishment of new processes.

The 2026 decision point: transitional development or direct future-proof investment?

Due to the 2026 regulatory changes, many organizations must decide whether to maintain the existing process with short-term, transitional development, or to move directly toward the target state. This is not purely an IT decision — it is also a cost, risk, and resource decision.

The approach that works better is one that does not develop the transitional and future models separately. If the organization builds on the same data, rules, and control points, the transition can later be carried out with far less friction.

ERP and tax code assessment

redesign of the responsibility matrix

testing and parallel run scheduling

establishing the approval and audit trail

Who stands to lose the most from delay?

Primarily mid-sized and large enterprises where the filing operation is assembled from multiple systems, manual additions, and coordination with external parties. For them, the transition is not a simple interface swap, but a reorganization of data, access rights, control points, and responsibilities.

Accounting firms and tax advisory teams are similarly affected, because they must solve at portfolio level how existing processes continue to work in 2026 while new processes are being built at the same time.

Preparation timeline – what to do in the remaining months?

The exact timing depends on the size and complexity of the organization — there is little time left for a transition of this complexity, so preparation cannot be delayed.

Common mistakes worth avoiding

The "we'll look at it in the autumn" attitude. Anyone who postpones the start until autumn will be forced into emergency solutions at year-end.

Treating the transition as an IT project. The change is also a process management and access control question — an ERP configuration only scratches the surface.

Missing parallel run. Without comparing old and new outputs, there is no certainty that the eÁFA draft says the same thing as your own analytics.

Neglecting tax code mapping and data quality checks. The eÁFA M2M XML does not use the company's internal tax codes, but NAV tax codes.

Frequently asked questions

When exactly does ÁNYK shut down?

On 15 October 2026, NAV proposed a gradual ÁNYK phase-out by return and form. The largest companies would move to mandatory eVAT during 2027, but no exact start date has been announced: 1 January 2027 is not fixed. For most VAT filers, including SMEs, the proposed start is 1 January 2028. Personal income tax and corporate income tax returns would remain fileable through ÁNYK during 2027. This is a NAV proposal, not final legislation; the detailed scope and exact dates require further official announcements.

What is ONYA, and who is it for?

ONYA (Online Form-Filling Application) is NAV's web-based, installation-free form-filling tool. It is ideal for individuals, smaller taxpayers, and occasional returns. Assess eVAT separately for VAT returns; the transition timetable follows the 15 October NAV proposal.

What is the eÁFA system?

The VAT filing system operating since 2024, which prepares an automatic return draft based on data available to NAV (online invoices, cash registers, customs). In the machine-to-machine eÁFA M2M version, the tax authority compiles the return from submitted data. NAV’s 15 October proposal envisages mandatory eVAT for the largest companies during 2027, with no exact start date, and for most VAT filers from 1 January 2028; this is not final legislation.

What is the NAV M2M connection?

NAV M2M (machine-to-machine) is API-based, automated data submission between the solution or software used by the business and NAV. It is recommended primarily for accounting firms and mid-sized or large enterprises.

Sources

NAV: ÁNYK transition page (Hungarian)

NAV: ÁNYK transition knowledge base (Hungarian)

Government Decree 322/2024 (XI. 6.), Section 152(13) (Hungarian)

Hungarian VAT Act (Act CXXVII of 2007), Section 184 (Hungarian)

NAV eVAT GitHub: correcting returns filed via ÁNYK (NAV answer, Hungarian)

NAV: ÁNYK phase-out presentation, National Tax Consultation 2025 (PDF, Hungarian)

NAV M2M GitHub: the new Document API goes live (Hungarian)