Continuous reporting and CTC models

Continuous Transaction Controls (CTC) explained: how tax authorities receive invoice data in real time via pre-clearance, post-clearance, and post-audit models.

CTC stands for Continuous Transaction Controls: systems where invoice data is shared with the tax authority in real time or near-real time. Instead of checking retrospectively via quarterly or annual returns, tax authorities monitor every transaction as it happens. ViDA makes this approach the European norm.

The shift towards continuous reporting is the most fundamental change in VAT compliance of recent decades. Where VAT compliance was traditionally an end-of-month or end-of-quarter activity (filing VAT returns, submitting EC Sales Lists), with CTC it becomes a built-in part of the daily invoicing process.

The three CTC models

Three main variants of CTC exist, differing in when and how the tax authority is involved in the invoicing process.

Pre-clearance

With pre-clearance, the invoice is submitted for approval to the tax authority before sending. The invoice only becomes legally valid after the tax authority assigns a reference number.

This is the most far-reaching model. The tax authority sees every invoice before the recipient receives it, making fraud nearly impossible. The downside: the invoicing process depends on the availability of the government platform, and there is an extra step between creating and sending the invoice.

Countries with pre-clearance:

  • Italy via the SdI (Sistema di Interscambio): all invoices (B2B and B2G) are uploaded to the SdI, checked, and only then forwarded to the recipient. Italy was the first EU country to introduce this model (2019) and serves as an example for the rest of Europe.
  • Poland via the KSeF (Krajowy System e-Faktur): comparable to the Italian model. Mandatory from February 2026 for large taxpayers, from April 2026 for all other VAT-registered businesses and from January 2027 for micro-entrepreneurs.
Post-clearance

With post-clearance, the invoice is sent directly to the recipient, while reporting data is simultaneously sent to the tax authority. The invoice does not need prior approval, but the tax authority receives the data in real time.

This is the model that best fits the Peppol 5-corner model and the ViDA DRR architecture. The invoice flow is not delayed, but the tax authority gets the same data as with pre-clearance. For businesses, this is the least disruptive real-time model: the Service Provider handles the reporting without changing the invoicing process.

Countries with post-clearance:

  • France via the PPF/PA system (Plateforme Publique de Facturation / Plateforme Agréée): the PA sends a CDAR message to the PPF. Mandatory from September 2026 for large and medium-sized businesses, from September 2027 for SMEs and micro-enterprises.
  • Slovakia via the Peppol 5-corner model: a TDD (Tax Data Document) is sent to the tax authority as the fifth corner.
  • UAE via the Peppol 5-corner model with TDD AE.
  • Croatia via the Peppol network with real-time fiscalisation at the tax authority. Mandatory since 1 January 2026 for VAT-registered businesses, from January 2027 for non-VAT-registered entities.
  • Oman via the Peppol 5-corner model with TDD OM and the Fawtara Portal. The PASR is in member review (until 20 April 2026).
Post-audit

With post-audit, invoice data is reported periodically, typically via a standardised file such as SAF-T. The tax authority checks retrospectively based on the delivered data.

This is the least disruptive model for businesses. There is no real-time impact on the invoicing process. However, it also provides the tax authority with the least direct insight, making fraud prevention less effective. Many countries using post-audit are therefore moving towards one of the other models.

Countries with post-audit:

  • Norway with SAF-T
  • Portugal with SAF-T PT (Portugal is also a Peppol Authority but has not published a PASR)
  • Poland uses SAF-T in addition to KSeF
Comparison of CTC models
CharacteristicPre-clearancePost-clearancePost-auditWhen reportingBefore invoicingSimultaneously with invoicingPeriodically (month/quarter)Tax authority approvalYes, in advanceNoNoImpact on invoicing processHigh (extra step, dependent on platform)Low (Service Provider handles it)No direct impactFraud preventionVery effectiveEffectiveLimitedExampleItaly (SdI), Poland (KSeF)France (PPF/PA), ViDA DRRNorway (SAF-T)
Which model does ViDA choose?

ViDA's Digital Reporting Requirements (DRR) are based on the post-clearance model: invoice data is reported to the tax authority simultaneously with invoice sending, without requiring prior approval. This is a deliberate choice: it offers the benefits of real-time insight without slowing down the invoicing process.

Member states that already have a pre-clearance system (such as Italy and Poland) may keep it, but must align their systems with the ViDA standard by 1 January 2035 at the latest. These countries will likely combine their pre-clearance model with ViDA DRR compatibility.

The trend: from periodic to real-time

The global trend is clear: tax authorities are moving from post-audit (retrospective checking) to pre- or post-clearance (real-time monitoring). ViDA accelerates this movement in Europe. The figures underline the urgency: the VAT Gap in the EU amounted to EUR 99 billion in 2020, of which an estimated quarter was due to intra-community trade fraud. The total economic benefits of ViDA are estimated at € 172 to € 214 billion over ten years. Member states can expect up to € 18 billion per year in additional VAT revenue, of which approximately € 11 billion specifically through more effective fraud prevention via CTC reporting.

This trend is not limited to Europe. Countries such as Brazil, India, Mexico, and Saudi Arabia already have advanced CTC systems. The EU is behind in this area but catches up significantly with ViDA in one step.

On 28 October 2025, the European Commission organised an Implementation Dialogue with 38 stakeholders from business, industry associations and the tax advisory sector. A key theme was the need for a harmonised DRR transmission model, to prevent member states from each developing their own reporting format. Commissioner Hoekstra characterised ViDA as one of the most significant EU VAT reforms in decades.

For businesses operating internationally, the message is clear: invest now in structured e-invoicing. The question is not whether you will face real-time reporting, but when.

How eConnect supports all CTC models

The PSB of eConnect is designed to work with all CTC models, regardless of the recipient's country:

  • Pre-clearance (Italy, Poland): direct integration with SdI and KSeF. Invoices are automatically submitted for approval.
  • Post-clearance (France, Slovakia, UAE): automatic TDD/CDAR reporting via the 5-corner model. Reporting runs behind the scenes.
  • Netherlands: the EY report on ViDA implementation recommends the post-clearance model via the Peppol 5-corner network. The ongoing 5-corner Peppol pilot with the Dutch Tax Authority is already preparing for this.
  • ViDA DRR: as soon as the obligation takes effect, the PSB handles DRR reporting automatically for all cross-border EU transactions.

As a customer, you do not need to adapt your invoicing process per country. The PSB determines based on the recipient which CTC model applies and automatically selects the correct reporting method.


Want to learn more about the specific requirements per country? See the implementation timeline and country overview.

View the international overview