Legal invoice requirements for e-invoices

Mandatory fields on an invoice according to Dutch tax law and how the European standard EN 16931 aligns.

Every invoice, whether paper, PDF or e-invoice, must comply with legal requirements. For e-invoices, the technical requirements of EN 16931 are added on top. This article covers both.

The Dutch Tax Authority prescribes which data must appear on an invoice. These requirements apply regardless of the format:

Data elementExplanationName and address of supplierFull legal name; trade name is allowed if registered with the Chamber of CommerceName and address of buyerFull name and address of the recipientVAT identification numberOf the supplier, including country code "NL"Chamber of Commerce numberIf registered with the Chamber of CommerceInvoice dateDate the invoice was issuedInvoice numberSequential, unique numberDescriptionType and quantity/scope of goods or services deliveredDelivery or advance payment dateWhen the delivery took placeAmount excluding VATListed separately per VAT rateVAT rate and VAT amountWith multiple rates: listed separately per rate

For invoices up to 100 euros (including VAT), simplified rules apply. For international deliveries, additional data may be required, such as the buyer's VAT number for intra-Community supplies.

EN 16931: the European semantic model

The European standard EN 16931 defines the semantic model for e-invoices. It describes which information elements an e-invoice must contain and how they relate to each other. The standard distinguishes mandatory, conditionally mandatory and optional elements.

The core of EN 16931 closely aligns with the Dutch legal requirements, but adds structure. Where the Tax Authority requires "name and address of supplier", EN 16931 specifies exactly in which separate fields (legal name, trade name, address lines, postal code, city, country) this information must be entered.

More about how EN 16931 relates to UBL, BIS Billing and NLCIUS can be found in From semantics to syntax.

VAT category codes

EN 16931 uses standardised codes for VAT categories (UNCL5305):

CodeMeaningWhen to useSStandard VAT rateRegular domestic invoiceKIntra-Community supplyVAT reverse charged for goods within the EUAEDomestic reverse chargeFor example subcontracting in constructionGExport outside EU0% rate for exportsZZero rate0% VAT (not exempt)EExemptVAT-exempt supplies

More about the difference between K and AE can be found in Reverse charge VAT.


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