Mandatory eVAT in Hungary: who switches in 2027, and who in 2028
Bill T/927 would make Hungarian eVAT mandatory for the largest taxpayers from the July 2027 period, due in August, and for all VAT filers from 2028.
Hungary is making electronic VAT filing compulsory, in two waves. Bill T/927, submitted to Parliament on 27 October 2026, would require the largest taxpayers to file through eVAT from the tax period that includes 1 July 2027, and all other VAT filers from the period that includes 1 January 2028. It follows NAV’s announcement of 15 October, which dropped the plan to switch off the ÁNYK form-filling software for everyone at the end of 2026.
This guide is for finance and tax teams, including foreign-owned groups and businesses registered for Hungarian VAT without being established in Hungary. It covers who falls into the first wave, what “largest tax performance” means, which return will be the first mandatory one, what changes for self-revisions and the EC Sales List, and why it pays to move before the deadline. Our eight-part series eVAT migration in practice walks through the preparation step by step.
The key dates in the bill
- 15 Dec 2026 NAV notifies the first wave
- 1 Jul 2027 first mandatory eVAT period for the first wave
- 1 Jan 2028 mandatory for all other VAT filers, with narrow exceptions
- 3 cumulative conditions decide first-wave status
Source: Bill T/927, Section 33 – proposed VAT Act Section 383
When does eVAT become mandatory, and for whom?
The proposed path to mandatory eVAT
Click the numbers or use the Previous and Next buttons to move between the steps.
- 2026: NAV changes course — Instead of switching off the ÁNYK filing software at the end of 2026, the tax authority proposed a phased move: the largest companies during 2027, most VAT filers from 1 January 2028. (15 Oct)
- 2026: Bill submitted — Bill T/927 turns the phased approach into specific conditions and tax periods. (27 Oct)
- 2026: First wave notified — NAV would notify the first wave electronically. (by 15 Dec)
- 2027: Transaction-level EC Sales List — Businesses filing VAT through eVAT could choose to report EC Sales List (A60) transactions one by one instead of in aggregate. (1 Jan)
- 2027: First wave goes live — eVAT becomes mandatory for the first wave from the tax period that includes 1 July 2027. For monthly filers that is the July return, due by 20 August. Everyone else may still file under the old rules for the rest of 2027. (1 Jul)
- 2028 onwards: Mandatory for all — From the tax period that includes 1 January 2028, eVAT becomes the rule for all other VAT filers, with two narrow exceptions. (1 Jan)
Based on Sections 33–34, 37 and 124 of Bill T/927 and NAV’s announcement of 15 October 2026. The bill has not yet been enacted.
The bill would remove the general option of filing the VAT return on a paper-equivalent form in ÁNYK from 1 July 2027. Section 383(3) softens the transition: taxpayers outside the first wave may keep filing under the rules in force on 30 June 2027 until the end of that year, and switch to eVAT from the tax period that includes 1 January 2028.
Who is in the first wave?
Under proposed Section 383(2) of the VAT Act, a taxpayer falls into the first wave only if all three of the following apply:
it is classified as a taxpayer with the largest tax performance for 2026;
it is required to file VAT monthly in the tax period that includes 1 September 2026;
it is economically established in Hungary.
Size alone does not decide it, and neither does monthly filing. For international businesses the third condition matters most: a Hungarian VAT number is not establishment. Under Section 254(1) of the VAT Act, a business is established where it has its seat or a fixed establishment. A Hungarian subsidiary is therefore established in Hungary; a foreign company that is only VAT-registered there is not, and moves to eVAT with everyone else in 2028. NAV would notify the first wave electronically by 15 December 2026.
First wave or second? Five typical situations
All three first-wave conditions must be met at the same time. Pick an answer for each case; the explanation points back to the bill.
- A Hungarian subsidiary of an international group is classified as a taxpayer with the largest tax performance and filed VAT monthly in September 2026. When does eVAT become mandatory for it?
- From 2028, because the parent company is foreign — No. What matters is the Hungarian entity: it has its seat in Hungary, so it is established there.
- Only if the group uses a particular ERP — No. The bill does not depend on the ERP used; it depends on the three conditions.
- Correct: From the tax period that includes 1 July 2027 — Correct. A Hungarian subsidiary is established in Hungary, and with the other two conditions met it falls into the first wave.
- A foreign company is registered for VAT in Hungary but has no seat or fixed establishment there. It has high volumes and files monthly. First wave?
- Yes, because it holds a Hungarian VAT number — No. A VAT number on its own is not economic establishment; under VAT Act Section 254(1), establishment means a seat or fixed establishment.
- Correct: No, it moves to eVAT from 2028 — Correct. Without economic establishment in Hungary, the first-wave rule does not apply; the general rule from 2028 does.
- No, non-established businesses are exempt from eVAT — No. The exceptions cover two narrow groups linked to new means of transport, not foreign VAT registrants.
- A large Hungarian company filed quarterly in the period that includes 1 September 2026. Is it in the first wave?
- Correct: No, because it did not file monthly in that period — Correct. The conditions are cumulative; without monthly filing in the September 2026 period, eVAT becomes mandatory from 2028.
- Yes, size is what counts — No. Monthly filing in the reference period is a separate condition.
- Only if NAV notifies it — No. The notification would go to taxpayers that meet all three conditions; here one is missing.
- A first-wave company that still files monthly in 2027 submits its June 2027 return in July. Does that return already have to go through eVAT?
- Yes, because it is filed in July — No. The bill ties the new rules to the tax period, not to the filing date.
- Correct: No, the first mandatory eVAT return is for July 2027 — Correct. The new rules apply from the tax period that includes 1 July 2027, so the first mandatory eVAT return is the July return, due by 20 August 2027.
- No, the first is January 2028 — No. January 2028 is the start for the second wave.
- Does mandatory eVAT mean every business needs an ERP-to-NAV machine connection?
- Yes, M2M becomes compulsory — No. The bill keeps both eVAT channels.
- Only accounting firms need M2M — No. The bill does not tie the channel to the type of business.
- Correct: No, the eVAT web interface remains an option — Correct. Both the web interface and the machine interface (VAT Act Section 184(2) b and c) remain available; the choice depends on volume and data sources.
What does “largest tax performance” mean?
It is a Hungarian taxpayer category defined in Section 101 of Government Decree 465/2017, with annual thresholds published by NAV. For 2026 there are two thresholds, and they serve different purposes:
| Purpose | 2026 threshold | What it covers |
|---|---|---|
| General application of the Tax Procedure Act (except Section 110) | HUF 1,900,000,000 | The general “largest tax performance” category. |
| Section 110 of the Tax Procedure Act only | HUF 400,000,000, plus monthly VAT filing | A separate category for special data reporting by the largest taxpayers. |
The bill does not say which threshold applies. Because proposed Section 383 does not refer to Section 110, the general HUF 1.9 billion category is the sensible starting point for planning. This is our reading, not an official position: whether a company is actually in the first wave depends on its 2026 classification and the law as enacted. Under the bill, NAV would notify the businesses concerned electronically by 15 December 2026.
Tax performance is not turnover
Tax performance is an annualised figure built from several years of filed returns: the sum of the annual averages per tax (Decree Sections 96–99). The 2026 classification uses data held on 15 October 2025. Its VAT component draws on returns for 1 January 2020 to 30 June 2025, taking for each return the higher of output VAT and deductible input VAT, not the net amount paid; output VAT is first reduced by the VAT due on intra-Community acquisitions and imports. The corporate income tax component uses a different window, the 2020–2024 tax years, based on tax before credits. You cannot read the classification off 2026 revenue or tax payments. The similar-sounding “priority taxpayer” category (Section 100) is a different list.
Which return is the first mandatory eVAT return?
The bill ties the new rules to the tax period, not to the filing date. For a first-wave business still filing monthly in 2027, the first mandatory eVAT return is the July 2027 return, due by 20 August 2027. The June 2027 return, filed in July, is not. For the second wave, the first is the period that includes 1 January 2028: January (due by 20 February) for monthly filers, the first quarter for quarterly filers, or the 2028 year for annual filers.
Web interface or machine connection?
Mandatory eVAT does not mean mandatory M2M. The bill keeps both channels under Section 184(2) b) and c) of the VAT Act: NAV’s web interface, where data can also be uploaded as XML, and the machine interface that lets an ERP or a filing platform submit directly. For groups running an international ERP, the machine route usually saves the most work at volume. Either way, the return counts as submitted when the draft is approved (Section 184(3)). Part 2 of our series compares the channels: Web interface, XML upload or M2M?.
Who could keep filing on a form (ÁNYK) instead of eVAT?
Proposed Section 184(2a) keeps two narrow groups on forms: non-taxable persons liable for VAT on an intra-Community acquisition of a new means of transport (Section 143(2)), and individuals who become taxable persons by selling a new means of transport to another Member State (Section 6(4) a)). There is no general exemption for sole traders or individuals.
What changes for self-revisions?
The channel for a self-revision follows the channel of the original return (proposed Sections 184(7)–(8) and 383(4)):
| Original return filed | Self-revision filed |
|---|---|
| On a form (ÁNYK) | On a form only |
| Through eVAT (web or M2M) | Through eVAT |
| Through eVAT, but already self-revised once on a form | On a form from then on |
Keep a record of which period was filed on which channel. The longer a business files on forms, the longer it has to run self-revisions on two channels. Part 8 of the series covers submission and self-revision: When is it really submitted?.
Will the EC Sales List fill itself in?
No. From the period that includes 1 January 2027, businesses filing VAT through eVAT could choose to report EC Sales List (A60) transactions one by one rather than in aggregate (new point I.6/A of Annex 4/A; Section 384). The option would be open only to eVAT filers, from before the mandatory date. The bill does not say NAV will generate the A60 from the VAT return, so the EC Sales List still needs its own process. NAV has published a separate A60 data structure for it.
What else would the bill repeal?
| Provision | Subject | Proposed repeal |
|---|---|---|
| VAT Act 184(2) a) | The general option to file VAT on a form | 1 July 2027, with the Section 383 transition |
| VAT Act 253/H(9), 253/I(9) | OSS treatment of certain energy supplies (inserted by the bill from 2027) | 1 July 2028 |
| VAT Act 12/A, 22(4)–(6), 182–183, 328; Annex 4/A point 1/A | Simplified treatment of call-off stock and related records | 1 July 2029 |
Why move before you have to?
The bill buys time, but readiness is not decided on the deadline day. There are solid reasons not to make the mandatory period your first live eVAT period:
A process that has already run. If the first mandatory return is also the first live one, missing data, tax-code mappings and permissions surface under deadline pressure. A closed-period test in the test environment, followed by a few voluntary live periods, takes most of that risk out.
Surcharge-free corrections from day one. For returns filed through the machine interface, a self-revision within 15 days of submission, and at the latest of the due date, carries no self-revision surcharge (Tax Procedure Act Section 211(3) c)). It applies to every machine-filed return, so it starts when you switch, not when eVAT becomes mandatory.
Fewer parallel channels. Periods filed on forms must be self-revised on forms. Switching earlier shortens the time you run two self-revision routes.
A new EC Sales List option from 2027. eVAT filers could choose to report A60 transactions one by one. From January 2027 that option would be open only to them.
Avoiding the rush. In NAV’s survey, 55% of responding accountants named lack of preparation time and delayed software updates as obstacles, and 64% of responding developers had not started real testing. The heaviest load is likely to fall on software vendors and advisers close to the mandatory dates.
Moving early does not require an in-house development project: eVAT can be used through NAV’s web interface or through ready-made software. SimplyX is one such solution; our eVAT M2M page explains how it works.
How ready are you for mandatory eVAT?
Choose whether you answer as a company or as an accounting firm, and mark where you stand today. You will get your next steps in order of priority.
- Have you established which wave you (or your clients) fall into?
- Not yet — Document the three conditions and their source. If you may be in the first wave, a NAV notice could arrive by 15 December 2026.
- Roughly — Record the basis of the classification; in borderline cases, the law as enacted and NAV’s notice decide.
- Yes, documented
- Have you chosen between the web interface and a machine connection?
- Not yet — Part 2 of our series sets out the criteria. (Web interface, XML upload or M2M?)
- We have a preferred option — Record the decision and why; permissions and testing build on it.
- Yes, decided
- For companies: Do you know which systems feed your VAT records?
- Not yet — Map data sources and owners; eVAT records are document-level. (Where does the return data come from?)
- The main sources are known — Add the exceptions and out-of-period items.
- Yes, fully mapped
- For accounting firms: Have you grouped your clients by wave and complexity?
- Not yet — Start with clients that may be in the first wave and with high-volume clients.
- Partly — Record wave, channel and test period per client.
- Yes, per client
- Have you run a test return in the test environment, using a closed period?
- Not yet — A closed-period test in the test environment surfaces gaps now, not on your first mandatory return. Do not file a second live return for the same period as a test. (A test return without live risk)
- Planned — Assign a period and an owner, and plan for handling NAV feedback.
- Yes, completed
- Is it clear who approves and submits the return?
- Not yet — Name an approver and a deputy; part 5 of the series covers permissions. (Registration and permissions)
- Partly — Arrange cover so that a holiday does not surface on the deadline day.
- Yes, defined
- For companies: Discovery: Start with your wave and your channel. Several basics are still open. Order matters: wave and channel first, then data, permissions and a test run. The steps below are sorted by your answers. eVAT migration step by step · Request a consultation
- For companies: On track: The foundations are there; the risk is in the detail. Most decisions are made. A full test on a closed period is the fastest way to surface what is still open, before your first mandatory return. A test return without live risk · Request a consultation
- For companies: Ready to test: You are well placed: consider switching before you have to. Your process is in place. If you move ahead of the mandatory date, the benefits of the machine channel apply from the day you switch, such as surcharge-free self-revision within 15 days for each machine-filed return. eVAT M2M in SimplyX · Request an offer
- For accounting firms: Discovery: Map your client base first. Many questions are still open at firm level. Classifying clients shows where preparation is urgent and where 2028 is enough. eVAT migration step by step · Request a consultation
- For accounting firms: On track: Progress is good, but the peak is still a risk. The key decisions are made. Running one or two clients end to end now shows where capacity is tight, before many clients switch at once. A test return without live risk · Request a consultation
- For accounting firms: Ready to test: Your firm is ready: phase your clients in early. Moving clients in planned batches avoids having every switch fall at the end of 2027 and the start of 2028. eVAT M2M in SimplyX · Request an offer
What to prepare now
For companies
In a company, tie the classification, data sources, owners and filing channel together in one document:
Classification: record the 2026 taxpayer category, the September filing frequency and the basis of establishment; for a VAT group, at group level.
NAV notice: name someone to receive and route the electronic notice.
Data and tax codes: map source systems and finish mapping internal VAT codes to NAV tax codes.
Test run: a full test on a closed period, in the test environment, shows where data or permissions are missing.
For accounting firms
In an accounting firm, set the next step per client; one switch date will not describe the whole portfolio:
Client classification: who may be affected from July 2027, who has until 2028, and whose classification is unclear.
Scheduling: spread the switches over time so they do not all land at the end of 2027.
Permissions: agree per client who approves the return; see part 5.
Records: keep track of which period was filed on which channel; it decides where later self-revisions go.
Step-by-step preparation in our series
The eVAT migration in practice series covers each step:
1. NAV asks about eVAT: where do you stand? — situation and self-assessment
2. Web interface, XML upload or M2M? — choosing the channel
3. Where does the return data come from? — data sources and owners
4. From VAT codes to NAV tax codes — tax-code mapping
5. Registration and permissions — technical user and approval
6. A test return without live risk — closed-period comparison
7. Error or warning? — handling NAV feedback
8. When is it really submitted? — approval and self-revision
Sources
All sources are in Hungarian.
Bill T/927 (27 October 2026): Sections 27, 33–37, 124 and Annex 2
NAV: More time proposed for the digital transition (15 October 2026)
Act CXXVII of 2007 on VAT (Sections 184, 254)
Act CL of 2017 on the Rules of Taxation (Sections 110, 211(3) c), 268)
Government Decree 465/2017 (XII. 28.), Sections 96–101
NAV notice on the 2026 tax performance thresholds
NAV developer notice: A60 data structure (#455)
Sources checked on 29 October 2026. This guide analyses the bill as submitted; we will update it if the text changes or the law is enacted.