An incorrect invoice costs you more than embarrassment. EU VAT authorities can disallow your client's input VAT reclaim — which means your client gets an unexpected tax bill they weren't budgeting for, they blame the supplier (you), and suddenly payment is delayed while their accountant investigates. In 2023, the Italian Agenzia delle Entrate rejected over 4% of submitted e-invoices due to format and field errors. The fix is simple: know exactly what goes on every invoice before you send it.
The 12 Mandatory Fields on Every EU VAT Invoice
Article 226 of the EU VAT Directive specifies the minimum information required on a VAT invoice. These apply across all 27 member states:
1. Invoice date — The date the invoice is issued. This determines the VAT reporting period for both you and your client.
2. Sequential invoice number — A unique number forming part of an unbroken sequence. You choose the format; the sequence must have no gaps.
3. Your VAT registration number — Prefixed with your country code: DE123456789 (Germany), FR12345678901 (France), GB123456789 (UK — not EU, but same format for cross-border). If you are not VAT-registered, do not include a VAT number.
4. Your client's VAT number — Required for all B2B reverse charge invoices. This is the legal basis for applying zero VAT. If your client cannot provide a valid VAT number, the reverse charge cannot apply — you must charge VAT at your own country's rate instead.
5. Your full name and address — Legal business name and registered address, exactly as registered with your tax authority.
6. Your client's full name and address — Legal business name and registered address of the recipient.
7. Clear description of goods or services — Specific enough to identify what was supplied. "Web development services — project: [name], January 2026" is acceptable. "Consulting" alone is not sufficient for audit purposes.
8. Quantity and unit price — Number of units or hours supplied and the price per unit excluding VAT. For fixed-fee projects, quantity is 1 and the unit price equals the total net amount.
9. Net amount excluding VAT — The total value of the supply before any tax is applied. If multiple VAT rates apply, list them separately.
10. VAT rate applied — The percentage rate. If reverse charge applies, show 0% and state the reason. If multiple rates apply to different line items, each must be shown.
11. VAT amount payable — The actual monetary amount of VAT. For reverse charge invoices: €0.00. For zero-rate supplies, €0.00 with the applicable exemption noted.
12. Gross total including VAT — The final amount the client owes. For reverse charge invoices, this equals the net amount since VAT is €0.
Optional but strongly recommended: Payment due date, bank account details (IBAN + BIC), payment reference, and your applicable tax number (Steuernummer in Germany, alongside the VAT number).
Invoicing Across EU Borders — VAT Treatment by Scenario
Scenario 1: Both parties are VAT-registered, different EU countries (B2B)
This is the most common scenario for freelancers with EU clients. The reverse charge under Article 44 of the EU VAT Directive applies. Your invoice shows:
- Net amount: €5,000
- VAT: €0.00 (Reverse Charge — Article 44 of Directive 2006/112/EC)
- Total: €5,000
Your client's VAT number must appear on the invoice. Verify it via VIES before sending. See our VAT Reverse Charge Guide for the exact wording and filing requirements.
Scenario 2: Your client is a private individual in another EU country (B2C)
No reverse charge. For most services, you charge VAT at your own country's rate. But once your annual B2C cross-border revenue across all EU countries exceeds €10,000, you must apply the VAT rate of each customer's country. The OSS (One Stop Shop) scheme handles this with a single quarterly return.
Scenario 3: You are not VAT-registered
You invoice without VAT — not as a reverse charge, but because you're exempt as a small business. Your invoice must not show a VAT number or VAT line. Add a note: "Gemäß §19 UStG wird keine Umsatzsteuer berechnet" (Germany), "TVA non applicable — art. 293 B du CGI" (France), or the equivalent in your country.
Scenario 4: Both parties in the same EU country
Normal domestic VAT rules apply. You charge your local VAT rate and remit it to your national tax authority via your regular VAT return.
Country-Specific E-Invoicing Mandates (2024–2026)
The EU is moving towards mandatory structured e-invoicing across all member states. If your clients are in any of these countries, PDF invoices may no longer be accepted:
Italy — SDI system has been mandatory for all domestic B2B since January 2019. Invoices must be in FatturaPA XML format and transmitted via the Interchange System (SDI). A PDF sent by email does not satisfy Italian legal requirements. If you are a foreign supplier, the rules are more nuanced — but if your Italian client requests an e-invoice, they need the XML.
France — Mandatory B2B e-invoicing is being phased in from September 2026 for large businesses, extending to SMEs by 2027. The Portail Public de Facturation (PPF) or approved private platforms will handle transmission.
Poland — KSeF (Krajowy System e-Faktur) becomes mandatory from February 2026 for large taxpayers. All B2B invoices must be submitted through the national e-invoicing platform.
Germany — XRechnung format has been mandatory for B2G (business to government) invoices since 2020. For B2B, Germany introduced a requirement from January 2025 for businesses to be capable of receiving structured e-invoices; full mandatory issuance follows later.
Spain — Verifactu and Factura electrónica mandates are in rollout. The exact timeline has shifted; check the current status for your client's company size.
Practical advice for freelancers: For most cross-border freelance invoices to EU businesses, a well-structured PDF remains acceptable in 2026. But if you regularly invoice enterprise clients in Italy, France, or Poland, ask your client's procurement team whether they need an XML e-invoice — failure to comply can delay payment by weeks.
How to Issue a Credit Note (Corrective Invoice)
When you need to correct an invoice — wrong amount, wrong VAT rate, cancelled service after invoicing — you issue a credit note (also called a corrective invoice). The rules:
- The credit note must reference the original invoice number explicitly
- It must contain all the same mandatory fields as the original invoice
- A credit note is typically a negative-value document (e.g. "Credit Note against Invoice INV-2026-042: −€1,200.00")
- Issue a new corrected invoice with a new sequential number if the service amount changes
- Both the credit note and new invoice must be included in the same VAT return period where possible
Never simply edit and re-send an original invoice with a different amount. That destroys the audit trail and can constitute a VAT compliance violation in several member states.
Late Payment Terms — What EU Law Requires
Under EU Directive 2011/7/EU (Late Payment Directive), B2B payment terms default to 30 days unless you explicitly agree to different terms. To enforce statutory interest on late payments, you must state your payment terms on the invoice.
Minimum recommended wording: "Payment due within 30 days of invoice date. Late payments accrue statutory interest at the ECB reference rate plus 8 percentage points per annum under EU Directive 2011/7/EU."
Without stated payment terms, late payment interest claims become difficult to enforce. For contracts where payment protection matters, our Freelance Contract Generator includes legally sound late payment clauses aligned with the EU directive.
5 Invoice Mistakes That Trigger VAT Reclaim Rejection
These are the specific errors that cause EU tax authorities to disallow your client's input VAT:
1. Missing or invalid client VAT number on reverse charge invoices. This is the single most common error. No valid VAT number = no legal basis for reverse charge = your client cannot reclaim. Always verify via VIES before issuing.
2. Wrong VAT rate for the type of supply. Applying 0% when 20% should apply (or vice versa) forces an amendment. For cross-border supplies, determine whether reverse charge or domestic rules apply before issuing.
3. Non-sequential invoice number. Gaps in numbering (jumping from INV-045 to INV-047) signal missing invoices to auditors and can trigger a full VAT audit request.
4. Missing supply date when different from invoice date. If you completed the work on 28 January but issued the invoice on 5 February, both dates must appear. The supply date determines the VAT period, not the invoice date.
5. Description too vague. "Services" or "Consulting" without specifics is flagged by automated invoice validation systems in Italy, France, and Germany. Describe what was delivered, when, and ideally reference a project or contract number.
Quick Compliance Checklist Before Every Send
- [ ] Invoice number is sequential (no gaps from last invoice)
- [ ] Both parties' full legal names, addresses, and VAT numbers are correct
- [ ] Services described specifically with quantities and unit prices
- [ ] Net amount, applicable VAT rate, VAT amount, and gross total all shown
- [ ] Reverse charge wording included if client is VAT-registered in another EU country
- [ ] Supply date shown if different from invoice date
- [ ] Payment terms stated (e.g. "Net 30 days")
- [ ] Bank details included (IBAN + BIC for EUR payments)
- [ ] Currency conversion note added if invoicing in non-EUR currency
Use our free Invoice Generator to produce fully compliant EU invoices with all mandatory fields pre-filled. Every reverse charge invoice includes the correct Article 44 wording automatically.