While most discussions around ViDA today still focus on e-invoicing, Peppol connectivity, and XML formats, something potentially even more significant happened in March 2026 — and remarkably quietly: OpenPeppol published the first official version of the ViDA Tax Data Document semantic model. At first glance, this may seem like merely a technical document describing how future ViDA e-reporting will be structured semantically (through business terms, identifiers, and standardized data structures). However, its content also clearly demonstrates the enormous impact of the Digital Reporting Requirements under ViDA (and national e-reporting obligations).
- VAT IDs of buyer and seller
- Countries
As of 1 July 2030, the EC Sales List will disappear and be replaced by near real-time reporting of transactional data originating from Peppol e-invoices (or at least e-invoices compliant with the European standard). By then, such e-invoices will become mandatory for transactions currently reported through the EC Sales List. In addition, from July 2028 onwards, the listing obligation will already be extended to certain domestically reverse-charged transactions.
Several Member States are also exploring how they can introduce additional e-reporting obligations based on the same model.
Several Member States are also exploring how they can introduce additional e-reporting obligations based on the same model.
The role of Peppol in this evolution cannot be underestimated. Belgium, for example, has already chosen Peppol as the central network for sending and receiving e-invoices. Peppol is expected to become the de facto dominant interoperability layer for intra-EU invoicing within the EU. This explains the importance of the “ViDA Tax Data Document,” developed within the Peppol ViDA Pilot. The document effectively shows what future e-reporting will look like.
Substantively, the ViDA Tax Data Document tells a much larger story than one of purely technical architecture. The document reveals which transactional invoice data businesses will in future transmit to tax authorities in near real time. And this represents a fundamental paradigm shift. More importantly, it now becomes truly clear that the new e-reporting obligations raise a number of fundamental questions.
From VAT returns to transaction-level visibility
Today, VAT reporting still largely operates according to a relatively traditional model. An invoice is generated, recorded in the accounting system, and subsequently included in a VAT return periodically submitted to the tax authorities. The data communicated in that process remains relatively general.
The ViDA Tax Data Document demonstrates that this will fundamentally change in the future. Invoice data will be transmitted to the tax authorities almost in real time.
That may seem like a subtle difference, but it is anything but. We are moving from periodic reporting of aggregated information to continuous transactional reporting.
What exactly will tax authorities see?
Perhaps the most striking aspect of the semantic model is not what it contains, but rather how broad the dataset actually is.
The future reporting layer includes, among others:
- Identification data
- VAT IDs of buyer and seller
- Countries
- Tax representatives
- Endpoints or digital addresses
- UUIDs and unique identifiers
- Transaction data
- Descriptions of goods and services
- Quantities
- Delivery dates
- Invoice periods
- Line-level amounts
- VAT logic
- VAT categories
- Exemptions
- Rates
- Taxable amounts
- Payment information
- IBANs
- Payment references
- Payment methods
Based on the ViDA legislation, it was already clear which information would need to be transmitted, but it is nevertheless quite striking to see approximately 135 tax data fields listed (some of which are optional).
Keep in mind that all of this will be machine-readable, and it becomes obvious that tax authorities will suddenly have access to far more information than they do today. This is no longer about PDFs being manually reviewed, but about semantic data that can automatically be validated, linked, analyzed, and profiled.
Where are the fundamental questions?
When tax administrations gain near real-time access to client relationships, supply chains, payment information, line-level descriptions, transactional metadata, and cross-border flows, they effectively obtain a comprehensive view of commercial transactions and relationships.
ViDA and e-reporting in general therefore go far beyond traditional VAT reporting. As a result, tax authorities will be able to verify, match, and analyze transactions much faster — particularly to detect carousel fraud and VAT leakages.
These objectives are legitimate.
These objectives are legitimate.
At the same time, however, fundamental questions regarding proportionality, privacy, GDPR, confidentiality, and professional secrecy remain underexplored. Once invoice data becomes machine-readable and available in near real time, this creates not only greater fiscal transparency but also a much broader and deeper insight into economic relationships and business activities.
From a legal perspective, the debate will likely focus less on whether tax administrations may process such data, and more on the proportionality, granularity, and retention periods of these data flows. The core question will be how to preserve the balance between legitimate anti-fraud objectives on the one hand and fundamental legal principles such as confidentiality and professional secrecy on the other. Consider sectors such as legal services, tax advisory, consultancy, or healthcare. The metadata continuously transmitted to tax authorities may reveal highly sensitive information.
The debate on this issue does not yet appear to have truly started, but it clearly deserves attention.
The challenge for businesses: data governance
Many businesses still primarily view ViDA as an IT project. But that is probably not the essence of the challenge. The real challenge will be data governance, because in a near real-time reporting model, inconsistencies become visible much faster. And that creates a completely new type of compliance exposure.
Under traditional periodic VAT returns, businesses could still create a certain “buffer” between operational data and fiscal reporting. Accounting corrections, consolidations, and manual interventions still provided a degree of filtering. In a near real-time semantic model, however, that buffer largely disappears.
The quality of ERP master data, VAT engines, product classifications, customer data, and invoicing logic becomes critical. Taxation thereby penetrates much deeper into the operational systems of businesses.
The underestimated impact of free-text fields
Today, many invoices contain highly specific descriptions. In a semantic real-time reporting model, the question of who can access that information suddenly becomes far more relevant.
This raises an interesting question: will businesses adapt their invoice language? It is entirely conceivable that companies will evolve towards far more neutral invoice descriptions. Instead of detailed descriptions of services rendered, businesses may shift towards generic wording such as “consultancy services,” “tax advisory services,” “professional services,” and so on.
Another interesting dynamic is the potential shift of sensitive information towards attachments, contractual documentation, portals, and separate reports. The semantic model currently proposed appears to focus primarily on semantic invoice data and not necessarily on attachments or other supporting documents.
But we should not forget that even without attachments, a semantic invoice already contains a significant amount of contextual information.
The tax authority as a real-time data platform
Perhaps the most striking substantive observation is how closely the ViDA model resembles modern data and network environments. This makes real-time matching, anomaly detection, fraud scoring, and supply chain analysis far more powerful than was ever possible under traditional VAT returns. VAT administrations are gradually evolving into transactional data platforms — fundamentally changing the relationship between businesses and tax authorities.
And that is precisely why it is remarkable how quietly the publication of the ViDA Tax Data Document has passed so far. Because behind what appears to be a purely technical semantic model lies a much broader transformation.