EU Invoice Requirements 2026: The Mandatory VAT Field List
An invoice is not a document you send because you feel like it — it is the evidence on which your customer deducts their input VAT. Get one mandatory field wrong and your customer's deduction can be refused, leaving them to chase you for the tax they cannot recover. This guide is the field list, what counts as "mandatory", the special cases, and the timing rules.
- Article 226 is the baseline, not the whole story. Articles 224 (self-billing), 227 (extra customer VAT-ID cases), 229 (no signature), 230 (non-euro currency), 238 (simplified invoices) and 222 (issue deadline) modify it. Most "my invoice was rejected" cases trace to one of those six.
- The invoice number must be unique and sequential with no gaps. Gaps invite questions about unreported supplies, which is a compliance issue in its own right.
- A simplified invoice is an option, not a right. Article 238 lets Member States allow reduced-content invoices above €100 up to €400, or where sector practice makes full invoicing difficult - each country sets its own conditions.
- Reverse charge wording must name the mechanism. "VAT exempt" is not the same thing and will not satisfy a customer's tax authority.
- Timing is a separate legal requirement from content. Article 222 sets the 15th-day deadline for intra-Community and cross-border B2B supplies; other deadlines come from national law. Issuing late is as much a problem as issuing an incomplete document.
- Post-supply price cuts reduce the taxable amount. Article 90 covers retrospective discounts, returns, cancellation and non-payment - under national conditions, via a credit note, not an edited invoice.
1. Why the field list decides everything
The VAT rules come from Council Directive 2006/112/EC. Its core principle is that invoices are mandatory documents, and their content is prescribed by law rather than left to commercial preference. The consequence runs in both directions — you need the invoice to charge VAT correctly, and your customer needs it to deduct correctly.
That second point is where the risk sits. If your invoice does not meet the requirements, the deduction may be disallowed, and the usual outcome is not a friendly phone call. Your customer asks their tax authority, the authority says no, and your customer comes back to you for the VAT they cannot claim. A twenty-second field check before sending avoids all of it.
One structural point to keep in mind: the Directive binds every member state as to result, but each state chooses its own form and methods of transposition. That is why a threshold or a reduced field list can differ between countries, and why the national rules are the last word for your own compliance.
2. The mandatory fields, one by one
Article 226 lists what an invoice must show. Here is each element, with the practical detail that decides whether yours passes:
Two presentation details that are often missed. First, subtotals by VAT rate are not optional when rates are mixed — one blended line fails. Second, if you are not in the euro and a customer pays in another currency, state which rate you used and on what date; leaving it implicit pushes the conversion problem onto your customer.
One more rule lives in section 2 because it changes what the invoice must show. Article 226(8) already requires discounts and rebates to appear unless they are in the unit price. Where the price is reduced after the supply - a retrospective discount, returned goods, cancellation, refusal or total or partial non-payment - Article 90 reduces the taxable amount accordingly, under conditions set by each Member State (which may derogate for non-payment). Practically: issue a credit note referencing the original invoice rather than editing it.
3. The special cases: Articles 224 to 238
Most non-compliant invoices are not missing a core field — they are a standard invoice applied where a special rule governs. These are the five:
| Article | What it covers | The catch |
|---|---|---|
| 224 | Self-billed invoices, where the customer draws up the invoice instead of the supplier | Only with prior agreement and an acceptance procedure; the Member State may require issue in the supplier's name |
| 227 | Extra customer VAT-ID cases | A Member State may require the customer's VAT number beyond the Article 226(4) cases |
| 229 | Signatures | Member States shall not require invoices to be signed |
| 230 | Invoicing in a currency other than the national currency | VAT amount shown in national currency using the Article 91 conversion mechanism |
| 238 | Simplified invoices with reduced Article 226b content | Only above €100 up to €400, or where sector practice makes full invoicing difficult; excluded for intra-Community supplies and non-established suppliers |
| 226b | What a simplified invoice must still show | Date, supplier identity, description, and the VAT amount or the data to compute it - Member States may not demand anything beyond Articles 226, 227 and 230 |
For a small supplier or freelancer, the one that matters most is Article 238. Where your Member State has switched the option on, an invoice in the €100–€400 band - or one where your sector's practice makes full invoicing genuinely difficult - can carry the reduced Article 226b content: date, supplier identity, description, and the VAT amount or the data to compute it. Intra-Community supplies never qualify, nor do supplies where you are not established and the customer is liable. Check whether your country implemented the option before relying on it.
4. When you must issue it (Article 222)
Timing is a separate requirement from content, and getting it wrong is just as damaging. The Directive sets one hard deadline itself; everything else is national law:
- The 15th day of the month following the chargeable event for Article 138 intra-Community supplies of goods and Article 196 cross-border B2B services. This is the Directive’s own deadline and it covers only those two cases.
- National time limits for everything else. Article 222 expressly leaves other supplies to the Member States, so a domestic deadline - days, weeks, or aligned to the return period - comes from the country’s own law.
There is no EU-wide default for domestic supplies, so do not assume the 15th-day rule travels. Cross-border supplies take the Article 138/196 deadline above; everything else follows the law of the Member State where the VAT is due.
5. Reverse charge wording
Where the reverse charge mechanism applies, the invoice must make three things unambiguous: that no VAT is charged, that the reason is the reverse charge mechanism - using the literal mention ‘Reverse charge’ required by Article 226(11a) - and, for an intra-Community supply, the Article 138 exemption. Both VAT identification numbers must appear. Wording such as "VAT exempt" is actively harmful, because it describes an exempt supply rather than a taxable one accounted for by the recipient — and it gives your customer's auditor a reason to pause.
If the reverse charge is the most common thing you invoice, the mechanism itself is worth reading properly: EU Reverse Charge Mechanism guide. You can also confirm a counterparty's VAT number through the VIES VAT validator before you commit to the treatment.
6. The pre-send checklist
- Both VAT numbers present — yours always, the customer's for cross-border B2B.
- Number is unique and sequential, with no gaps in the series.
- Both dates — issue date and supply date where they differ.
- One line per VAT rate, with rate, net and tax subtotals per rate, then a gross total.
- Currency and conversion - VAT amount shown in the national currency via the Article 91 conversion mechanism if not billing in it.
- Special wording correct — reverse charge names the mechanism, not "exempt".
- Total in words and figures where your jurisdiction or contract requires it, and not contradicting each other.
- Bank details correct — validate the IBAN before sending, since a wrong account is a 30–60 day recovery problem rather than a five-day one.
Steps 1 to 7 are compliance requirements. Step 8 is not, but it protects the payment as reliably as the compliance does. The free Invoice Generator builds a compliant document in about 30 seconds and runs entirely in your browser — no account, no data uploaded.
Frequently asked questions
What are the mandatory fields on an EU VAT invoice?
Article 226 requires the supplier's identity and VAT number, the customer's identity and VAT number where relevant, a unique sequential invoice number, the date of issue and the date of supply where they differ, a description of the goods or services with quantities, the unit price excluding tax, the applicable VAT rate, the net amount per rate, the VAT amount per rate, and the total payable including tax. Non-euro currencies are permitted provided the exchange rate is shown.
Can I issue a simplified invoice in the EU?
Yes, under Article 238, where your Member State allows it: invoices above €100 up to €400, or where sector practice or technical conditions make full Article 226 compliance particularly difficult. The reduced Article 226b content - date, supplier identity, description, VAT amount or calculation data - is still mandatory, and intra-Community supplies plus non-established suppliers are excluded. Check your country’s conditions before relying on it.
How long do I have to issue an EU invoice?
Article 222 sets one EU deadline: no later than the 15th day of the month following the chargeable event, for Article 138 intra-Community supplies and Article 196 cross-border B2B services. All other deadlines are set by the Member States under national law.
What wording is required for a reverse charge invoice?
The invoice must state that no VAT is charged because the supply is subject to the reverse charge mechanism, carry the mention ‘Reverse charge’ required by Article 226(11a), show both VAT identification numbers, and for intra-Community supplies reference the Article 138 exemption. "VAT exempt" is not sufficient and is actively misleading, because it describes an exempt supply rather than a taxable one accounted for by the recipient.
Does a missing field make an EU invoice invalid?
For deduction purposes, an invoice that fails the Article 226 requirements cannot be relied on, and the customer's input VAT deduction risks refusal. Several member states accept errors that are immaterial to the tax treatment, so the safe move is to issue a corrected or replacement invoice rather than defend the original.
Sources
- Council Directive 2006/112/EC (consolidated) — invoicing rules as amended by Directive 2010/45/EU — EUR-Lex
- Articles 226, 226b, 224, 227, 229, 230, 238, 222 and 90 — article texts verified September 2026
- VAT Directive — European Commission taxation pages
Verification status: the article-by-article citations here (Articles 90, 222, 224, 226, 226b, 227, 229, 230 and 238) were verified against the Directive text on 27 September 2026; Articles 228 and 231 were deleted by Directive 2010/45/EU and are no longer cited. The content remains an explanatory summary for general readers, not a substitute for the legal text — check the Directive and your national transposition before making a compliance decision. Corrections are logged in the changelog.