Saf T Realtime Ereporting Matrix

SAF-T and Real-Time E-Reporting Matrix v0.1

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

What this file is

This file is a content skill that loads on top of cross-border-workflow-base. It maps the global landscape of digital invoice and ledger reporting mandates as of mid-2025.

Tax year coverage. Current for calendar 2025, reflecting:

• The EU's VAT in the Digital Age (ViDA) package as politically agreed and published in Council Directive (EU) 2025/516 (with key Digital Reporting Requirements taking effect 1 July 2030 — earlier optional date 1 January 2027 for member states that wish to mandate)
• Germany e-invoicing mandatory receipt phase from 1 January 2025 (B2B receipt) and outbound phase from 1 January 2027 / 2028 (size-based)
• France e-invoicing reform rescheduled to begin September 2026 (receipt) / September 2027 (issue for SMEs)
• Belgium e-invoicing mandatory B2B from 1 January 2026
• Poland KSeF delayed; latest schedule has voluntary continuation through 2025 and mandatory 1 February 2026 for large taxpayers, 1 April 2026 for others
• Spain Veri*Factu / Verifactu for non-SII taxpayers in force from 1 January 2026
• Romania e-Factura B2B mandatory since 1 July 2024
• Greece myDATA B2B fully effective since 2024
• Saudi Arabia ZATCA Fatoorah Phase 2 waves continuing rolling enrolment
• Israel "Form Mandate" for invoice clearance > ILS 5,000 in force since 5 May 2024 (threshold lowering 2025)

The reviewer is the customer of this output. E-reporting mandates carry steep penalties and ERP-blocking consequences. Every output must be reviewed by a credentialed e-invoicing / VAT specialist before any go-live decision.

Section 1 — Scope statement

This skill covers:

• SAF-T mandates (Standard Audit File for Tax — OECD-aligned XML extract on demand or periodic)
• Real-time / near-real-time invoice transmission — clearance models (Italy SDI), pre-clearance models (Hungary RTIR), reporting models (Spain SII), centralised platform models (Poland KSeF, France PPF, Belgium PEPPOL)
• CTC (Continuous Transaction Controls) taxonomies — clearance, reporting, hybrid, decentralised
• EU ViDA alignment: by 2030 all intra-EU B2B invoices must be structured EN 16931 and digital reporting requirements (DRR) replace recapitulative statements

This skill does NOT cover:

• VAT rate determination (see country *-vat-return.md skills)
• B2C e-receipt mandates (Greek myDATA B2C, Italian corrispettivi telematici) unless overlapping with the B2B system
• Software accreditation procedures with national tax authorities
• Detailed XSD schema field-level mapping beyond format and core blocks
• E-archiving retention beyond the minimum

Section 2 — SAF-T matrix

SAF-T is an XML standard published by the OECD for fiscal audit data exchange. Countries adopting it generally specify required modules (master data, GL, AR, AP, inventory, payments, source documents).

Section 3 — Real-time / clearance e-invoice matrix

Asia, Middle East, Latin America

Section 4 — EU ViDA — Digital Reporting Requirements

[T1] Council Directive (EU) 2025/516 amending Directive 2006/112/EC and Regulation (EU) 282/2011:

[T2] Member States must align national e-invoicing systems with EN 16931 by 1 July 2030. Pre-clearance models that block invoice transmission are NOT permitted under ViDA (post-clearance reporting only). Italy's SDI and France's PPF have explicit transition paths.

Section 5 — Decision flow

Step 1 — Determine taxpayer status in each jurisdiction

For each country where the taxpayer issues invoices to local customers OR receives invoices from local suppliers OR has VAT registration:

1. VAT-registered? → check the country's e-invoicing scope
2. Threshold-based exemption? → check turnover thresholds
3. Sector-specific carve-out? → check (e.g., Italian SDI exempts certain micro-businesses under EUR 65k revenue with forfettario regime; Spanish SII exempts < EUR 6m turnover)

Step 2 — Select format

• Cross-border within EU → Peppol BIS billing 3.0 or EN 16931-aligned XML
• Italy → FatturaPA
• France → Factur-X (hybrid PDF/A-3 + UBL or CII) OR Peppol BIS
• Germany → XRechnung (B2G) / ZUGFeRD or Factur-X / EN 16931 (B2B)
• Spain → Verifactu XML for SII / Verifactu
• Poland → KSeF FA(2) XML
• Saudi Arabia → ZATCA XML or PDF/A-3 with embedded XML
• LATAM → country-specific (CFDI Mexico, DTE Chile, etc.)

Step 3 — Select transmission channel

• Centralised → Italy SDI, Poland KSeF, France PPF, Romania SPV, Spain Verifactu/SII web service
• Decentralised via Peppol → Belgium, Norway, Denmark, Sweden, EU intra-Community by 2030
• Direct B2B without clearance → Germany B2B
• LATAM PAC/PSE intermediaries → Mexico, Brazil, Peru, Chile

Step 4 — Plot deadlines and penalties

Section 6 — Output specification

The reviewer brief must include:

1. Jurisdiction inventory — every country with mandate exposure for the entity.
2. Mandate status per country — in-force / pending / proposed; effective date for the entity.
3. Format and transmission selection per country.
4. Implementation roadmap — ERP changes, intermediary selection (PAC / PDP), accreditation status, go-live dates.
5. Data residency and archiving — required retention period per country (commonly 10 years), location restrictions.
6. Penalty exposure if go-live missed.
7. EU ViDA alignment — for EU-registered taxpayers, the 1 July 2030 DRR transition plan.
8. Reviewer questions — open items flagged as [T2] or [T3].

Section 7 — Self-checks

• Every country of registration / supply / receipt mapped to a mandate status.
• Threshold tests applied (turnover, sector) before assuming in-scope.
• Format selected per country, not assumed by analogy.
• Transmission channel matches model (centralised / decentralised / PAC).
• Pre-clearance model identified where invoice transmission is blocking.
• ViDA DRR transition plotted for 1 July 2030 deadline.
• Italy SDI cross-border replacement of Esterometro reflected.
• Mexico Pólizas + CFDI 4.0 + Catálogo de Cuentas integration documented.
• Penalty schedule per country in the brief.
• Output flags every [T2]/[T3] item for reviewer judgement.

Section 8 — Prohibitions

• Do not assume Peppol BIS is universally accepted — Italy SDI, Mexico CFDI, Brazil NF-e use proprietary formats and Peppol is NOT the local mandate.
• Do not treat a "B2G mandate" as equivalent to a "B2B mandate" — Norway, Sweden, Denmark have B2G mandates but B2B is still voluntary in 2025.
• Do not rely on the EU ViDA 2030 dates as locked — Member State adoption pace varies and derogations may persist.
• Do not propose a centralised-clearance go-live for ViDA-compliant intra-Community invoicing — post-clearance only is permitted under ViDA.
• Do not advise on circumventing mandates (e.g., issuing PDF invoices in a clearance regime) — penalties and VAT recovery loss apply.

Section 9 — Disclaimer

This skill and its outputs are provided for informational and computational purposes only and do not constitute tax or implementation advice. E-invoicing and SAF-T mandates change frequently with national budget cycles and EU directives. Every output must be reviewed and signed off by a credentialed e-invoicing / VAT specialist before any go-live decision.

The most up-to-date, verified version of this skill is maintained at openaccountants.com.

Source: OpenAccountants — open tax Guides for AI, reviewed by named CPAs/CAs/EAs. Quality: source-cited draft. For always-current figures and named-accountant backing, connect the OpenAccountants MCP server (openaccountants-mcp).