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Starting from July 1, 2025, electricity and gas providers in Hungary will be required to issue electronic invoices exclusively to their non-residential customers. Consequently, the acceptance and archiving of electronic invoices (e-invoices) will become mandatory for all businesses that have a direct contractual relationship with electricity and gas providers.
Electronic invoices must meet three fundamental criteria:
Both the invoice issuer and the recipient must ensure compliance with these three requirements throughout the entire legally mandated retention period.
The regulation applies only to energy providers and non-residential customers. Residential customers are not obligated to accept e-invoices. If a utility provider chooses to invoice residential customers electronically, this can only be done with the customer’s explicit consent.
While the method of invoicing can be agreed upon between the provider and the non-residential customer, e-invoicing is mandatory even in the absence of an agreement, as it is required by law.
However, it may be worthwhile to include the conditions of sending and receiving e-invoices in a mutual agreement to ensure that the customer can verify the authenticity of the invoice upon receipt.
Extra caution should be exercised if, for example, the invoice is received through an unfamiliar channel (such as a different email address than previously agreed), in a different format, or if the previously agreed authentication tool (like an electronic signature or hash code) is missing. In such cases, it is advisable to contact the issuer before accepting the invoice, as input VAT can only be deducted based on a valid and authentic invoice.
In Hungary, electronic invoices must be preserved exclusively in electronic form—with a suitable IT system and together with the electronic signature on the invoice or the hash code provided as an attachment.
Businesses are advised to rethink their entire invoice processing workflow, not just focus on archiving.
The archiving process can be integrated into the invoice reception process, or it can be handled via a standalone manual method.
The most important requirement is that the invoice must not only be accessible but also readable and interpretable during the entire retention period required by law.
Furthermore, steps must be taken to ensure that the e-invoice cannot be lost or destroyed during archiving.
It’s important to emphasize that appropriate archiving must comply with the VAT Act and relevant archiving regulations, but the technical solution must be adapted to the invoice type. These solutions should also be tailored to the size and operations of the business. Options include outsourcing to an archiving service provider, developing an in-house server, or choosing a cloud-based solution.
Avoid storage methods not suited for long-term data retention (e.g., keeping invoices in an email inbox). Similarly, it’s not secure to simply save invoices on a local computer, Google Drive, or OneDrive, as these do not provide adequate protection against deletion or data loss.
The most serious consequence is the loss of an already issued e-invoice by either the issuer or the recipient. The legal consequences are the same as in the case of losing a paper invoice.
Here’s a brief checklist to ask internally to see if your company is prepared:
If you need any assistance with the new obligation, do not hesitate to get in touch with us, or learn more about our advisory and outsourcing services in Hungary.