Guiding Businesses Through the CEE Digital Tax Landscape
At KGT, Lucia Nezvalova is leading the R&D team that plays a key role in tracking every development within the rapidly evolving landscape of tax digitalization and electronic invoicing across Central and Eastern Europe (CEE). With more than 8 years of experience at KGT, and in her role as Head of Research & Development, she and the R&D team are at the forefront of innovation.
With her roots in Slovakia, Lucia has a natural pulse on what is happening across the CEE region. Together with the R&D team, she continuously monitors regulatory, technical, and market developments in e-invoicing and VAT digitalization, ensuring alignment with broader European initiatives. Lucia's deep expertise bridges both the legal and technical worlds. She supports multinational companies by translating regulatory requirements into practical, scalable solutions within SAP. Within KGT, Lucia leads various research initiatives and contributes to the development of new technology and methodologies that help companies remain compliant and future-proof in this rapidly changing regulatory landscape.
In the following interview, Lucia shares her insights on the evolution of e-invoicing and SAF-T reporting in CEE, the challenges organizations in the region are facing, and why acting now matters.
Let’s start with the context. How has e-invoicing developed in CEE?
Lucia: “Electronic invoicing has been gaining momentum in the EU since 2019, when public sector entities became legally required to receive and process e-invoices. In 2022, responsibility for digital tax initiatives moved under the Digital Europe Programme, which encourages EU Member States to extend e-invoicing requirements to the private (B2B) sector. In the CEE region, this shift has accelerated rapidly, driven by governments aiming for better VAT collection, reduced fraud, and more transparency in cross-border trade.”
What does this mean for companies operating in CEE?
Lucia: “For companies in Central and Eastern Europe, e-invoicing is moving from optional to a mandatory legal requirement. The change is particularly impactful here because CEE supply chains often involve large transaction volumes and multi-country operations. Governments benefit from automated VAT reporting and real-time transaction visibility. Companies benefit from efficiency and automation, but only if they prepare early.
Furthermore, tax digitalization is not limited to e-invoicing. Many countries are also introducing SAF-T (Standard Audit File for Tax) reporting, where transactional data must be submitted to the tax authority in a predefined, structured format. In several CEE countries, SAF-T has evolved into a mandatory periodic report submitted together with VAT returns. This enables tax authorities to reconcile figures more effectively.”
Can you give a few examples of this approach in CEE?
Lucia: “Countries like Poland, Romania, and Lithuania already use SAF-T extensively, and Bulgaria will make SAF-T reporting mandatory as of 1 January 2026. Hungary introduced the voluntary eVAT system which goes beyond the OECD SAF-T structure: information about underlying VAT transactions are sent to the local tax authorities in a structured format with specific VAT coding. Slovakia and Czech Republic have implemented mandatory control statements, also known as the VAT ledger.
This means some companies face a dual obligation: real-time or near-real-time e-invoicing, combined with periodic SAF-T reporting. For organizations operating across multiple CEE countries, both processes impact master data, tax determination, and ERP configuration.”
Let’s move on to implementation. Each country is moving at a different pace. What does this mean for implementation, and can you give an overview?
Lucia: “Yes, CEE is one of the most dynamic regions in Europe when it comes to e-invoicing, and implementation timelines differ significantly across countries. Some jurisdictions already operate mandatory e-invoicing, while others are still in the legislative or preparation phase.
E-invoicing models in CEE are evolving under the EU's focus on interoperability and standardized formats. Key models include the Four-Corner Model, which uses private service providers for invoice exchanges (like the Peppol network), and the Clearance Model, where invoices are pre-approved by tax authorities before reaching buyers. Some countries also use a Centralized Model with the government as a hub, but many are shifting towards a Four-Corner or hybrid approach to improve flexibility and efficiency.
Hungary was one of the earliest adopters with real-time reporting in 2018, followed by Romania making B2B e-invoicing compulsory in 2024. The next wave of CEE implementations is approaching quickly. Croatia, Poland and Moldova are all scheduled to go live in 2026, Slovakia is targeting 2027, and Slovenia has recently postponed its implementation to 2028. The Czech Republic is currently in the final phase of legislative discussions.
The key message is clear: companies operating across CEE must be prepared for different models, platforms and timelines. There is no single, unified approach in the region.”
Can you explain what some of these terms mean? Many people assume that digital invoices and e-invoices are the same. What is the difference?
Lucia: “They are not the same, especially from a regulatory perspective. A digital invoice, such as a PDF or scanned invoice, is digital but still unstructured. An electronic invoice, is a structured data file, usually in XML, exchanged system-to-system. In CEE countries that are EU Member States, e-invoices must follow Directive 2014/55/EU and the European data standard EN 16931. To put it simple: Every e-invoice is digital, but not every digital invoice is an e-invoice.”
Are formats standardized across the EU?
Lucia: “Yes, but only at a semantic level. The EU defines what information must be included, ensuring the same core elements. However, each country can choose their own technical infrastructure. In CEE, the dominant trend is the use of government-controlled platforms with real-time or near-real-time reporting. Examples include Poland’s KSeF and Romania’s RO e-Factura - both mandatory and fully centralized systems.
In parallel, SAF-T focuses on reporting full datasets, such as ledgers, VAT and accounting records - whereas e-invoicing focuses on individual invoice transactions. So, companies may need to manage real-time e-invoicing and periodic SAF-T reporting. Both are structured and data-driven, but they serve different purposes.”
Does Peppol play a role in the CEE region?
Lucia: : “Yes, but usually not as the primary B2B e-invoicing channel. Instead, Peppol is mainly used in public procurement (B2G) or by multinational companies seeking a harmonized approach across multiple regions. Peppol typically uses UBL formats, which allow interoperability between different systems. Regardless of the approach, a Peppol network or a local governmental portal, the core requirement remains the same: the invoice must be structured, machine-readable, and automatically processed by the receiving system.”
Which details must an e-invoice contain?
Lucia: “Broadly, the data in an e-invoice can be divided into two categories. First, the mandatory data elements, which include key business and tax data such as the invoice number and issue date, supplier and customer details, VAT numbers, delivery date, and a description of the goods or services including quantity and price. Second, there are optional data elements, which may include additional data such as delivery details, references to purchase or sales orders, payment references, and other contextual data that support the transaction.
In CEE jurisdictions that use a clearance model, such as Poland (KSeF) and Romania (RO e-Factura), the central platform applies technical and business-rule checks and may reject the invoice if core data are incorrect. In reporting/post-audit models, such as Hungary (real-time reporting/RTIR), poor master data still leads to failed submissions, corrections or non-compliance. Either way, high-quality master data are critical and “fix it later” approaches no longer work.”
Let’s dive into the impact on businesses. What are the key benefits of e-invoicing for businesses?
Lucia: “The benefits of e-invoicing go far beyond compliance. Once invoicing processes are digitized and automated, administrative effort drops dramatically; no more printing, scanning or manually entering data. Payment cycles shorten, errors decrease, and audit trails become more transparent. The risk of fraud is reduced and digital workflows lower environmental impact.”
Where do organizations struggle the most?
Lucia: “The biggest challenge is fragmentation. Each country is moving at its own pace and choosing its own model and system. Some countries introduce fully centralized national government platforms, others adopt different exchange models or formats. As a result, integration into ERP systems such as SAP cannot be solved with a single, uniform approach. Many companies underestimate this complexity and still assume that e-invoicing is simply the digital sending of a PDF. In reality, e-invoicing is data-driven, structured, automated, and controlled by the tax authority. When organizations treat it as a formatting exercise instead of a fundamental process transformation, they inevitably face delays, rejected invoices, and compliance risks. Successful e-invoice implementation relies on understanding data structures, required information, official coding linkages, the impact on the system, and the overall billing process, including internal awareness and personnel training.
The challenge becomes even greater when e-invoicing and SAF-T requirements coexist, which is increasingly common across CEE. Each country sets its own e-invoicing deadlines and defines its own SAF-T file structure, meaning that companies must manage multiple reporting layers in parallel. SAF-T is often mistakenly seen as “just another report,” and e-invoicing as a simple layout change. In reality, both require deep changes to master data, tax determination and end-to-end processes.”
