NAV Digital Reporting in 2026: What a Foreign-Owned Kft. Actually Has to Send
Hungary does not ask your company for a periodic sales listing at year end. It watches the invoices as you issue them. A Hungarian Kft. must transmit every invoice to NAV in real time through the Online Számla system, from 1 September 2026 must also report the data of receipts, and files a VAT return on top of both. Nothing here is optional, and none of it depends on turnover. Here is the whole picture in one place, with the one change that was announced and then cancelled this summer.
The three layers, and how they fit together
| Layer | What it covers | Since / from | Who is affected |
|---|---|---|---|
| Online Számla | data of every issued invoice, in real time | 4 January 2021 (no threshold) | every VAT-registered business |
| Receipt data reporting (eNYUGTA) | data of every issued receipt, within 3 calendar days | 1 September 2026 | businesses issuing receipts without an online cash register |
| VAT return (eVAT / ÁFA) | the periodic return itself | ongoing, 20th of the month | every VAT-registered business |
The invoice layer and the receipt layer are not alternatives — they cover two different documents. A Hungarian business issues an invoice (számla) to a named buyer, and a receipt (nyugta) when the buyer is an anonymous consumer who does not need an invoice. Most foreign-owned Kft.s doing B2B work only ever issue invoices, so the September change passes them by. A Kft. running a shop, a café or a walk-in service does need to look at it.
Layer 1: Online Számla, the part nobody can opt out of
Every invoice your Hungarian company issues must reach NAV immediately after issue, through a machine interface. There is no value threshold, no exemption for small companies, and no exemption for invoices issued to foreign customers. Even a company under the small-business VAT exemption reports its invoices.
This is where foreign owners most often get it wrong. The obligation is not on you personally — it is on your invoicing software. And the invoicing tools most founders arrive with do not speak to NAV:
- A generic international billing tool, a spreadsheet template or a PDF you produce by hand will not transmit anything.
- The obligation to register your invoicing software with NAV (the old SZAMLAZO form) was abolished on 4 January 2021 — so the absence of a registration step is not a sign that you are outside the system. It was removed precisely because every invoice is now reported anyway.
- What you need is invoicing software connected to the Online Számla API, set up with a technical user created in your company’s Online Számla account. NAV also publishes a free online invoicing tool that reports automatically.
Practical consequence: decide the invoicing tool before the first sale, not after. Re-issuing early invoices through a compliant system later is possible but ugly, and it leaves a visible gap in the data NAV holds.
Layer 2: receipts, mandatory from 1 September 2026
From 1 September 2026, businesses that issue receipts without an online cash register must report receipt data too. That includes handwritten receipt books and computer- or app-generated receipts.
- Deadline: within 3 calendar days of issue.
- Format: aggregated per day, broken down by VAT rate (27% / 18% / 5% / exempt) — not receipt by receipt.
- Channels: NAV’s free e-cash-register mobile application, manual entry on NAV’s portal, or a machine (M2M) connection from your own software.
NAV granted a four-month transition period: the obligation applies from 1 September 2026, but default penalties for failing or misreporting receipt data can only be imposed from 1 January 2027. Note carefully what the grace period does not cover — failing to give the customer a receipt at all is sanctioned exactly as before, throughout 2026.
If your company already uses an online cash register, nothing changes in September. The separate migration to hardware e-cash registers runs to 1 July 2028.
Layer 3: the VAT return — and the change that was cancelled
Your Kft. files a VAT return by the 20th of the month following the period. A newly registered company files monthly in its first two calendar years; afterwards the frequency depends on the VAT payable in the reference period. Rates and thresholds are in our guide to VAT in Hungary.
In the return, the M-sheets report, invoice by invoice, the purchase invoices on which you claim input VAT — the counterpart of the seller’s Online Számla data.
A 2025 amendment would have gone further from 1 July 2026: it required reporting the VAT you actually deducted, split by rate and by pro-rata apportionment, per invoice. Software vendors and accountants pushed back, and the government reversed course. Act XXXV of 2026, promulgated on 30 July 2026, repealed the tightening, retroactively for the period that includes 1 July 2026. In plain terms: M-sheets keep the familiar data content, and the development work many companies were quoted for is not needed.
Keep this on your radar rather than in your budget. The direction of travel — NAV pre-filling returns from data it already holds — has not changed; only this particular step did.
What this costs you in practice
Nothing on this list has a government fee. The cost is software and discipline:
| Item | Typical reality for a small Kft. |
|---|---|
| Online Számla reporting | included in Hungarian invoicing software; NAV’s own tool is free |
| Technical user set-up | one-off, done once at company set-up |
| Receipt reporting (if applicable) | NAV mobile app is free; own-software integration is vendor-dependent |
| Penalty exposure | up to HUF 1,000,000 in general for a company; up to HUF 2,000,000 for failure to issue an invoice or receipt |
Those are ceilings, not automatic charges — NAV weighs severity, repetition and cooperation, and often issues a notice first. The realistic risk for a well-run company is not a fine but a mismatch: your reported invoice data and your VAT return telling two different stories. NAV cross-checks them automatically.
Who is responsible for what
Ownership of these obligations gets blurry in a foreign-owned company, and that is where gaps appear.
| Task | Normally sits with |
|---|---|
| Creating the Online Számla account and technical user | the accountant, at incorporation |
| Choosing and configuring invoicing software | the owner / managing director |
| Issuing invoices correctly and on time | whoever sells — often the owner |
| Filing the VAT return from the same data | the accountant |
| Watching that the reporting actually runs | nobody, unless you assign it |
That last line is the one worth fixing. Reporting failures are usually silent: the software stops transmitting after a credential change or a version update, and the first sign is a NAV query months later. Ask your accountant to reconcile invoices issued against invoices reported once a month — it takes minutes and it is the only control that catches a silent break.
A short set-up sequence for a new Kft.
- Register the company’s Online Számla account and create a technical user. Your accountant normally does this at incorporation.
- Choose Hungarian-compliant invoicing software and enter the technical user’s credentials. Test with a live invoice.
- Decide whether you will ever issue receipts. If yes, pick a channel before 1 September logic applies to you; if no, document that all sales are invoiced.
- Align the invoicing tool with the bookkeeping. The VAT return is built from the same data — see our accounting requirements guide for what the accountant needs monthly.
- Diarise the 20th. Late filing is cheap; a pattern of late filing is not.
FAQ
Does Online Számla apply if my customers are all abroad? Yes. The obligation attaches to invoices issued by a Hungarian taxable person, not to the customer’s location.
We are VAT-exempt under the small-business threshold — are we out? No. Exempt taxable persons report their invoices too.
Can I keep using my existing foreign invoicing tool? Only if it has a working Online Számla integration. Most do not. Check before you rely on it.
Does the September 2026 receipt rule affect a B2B consultancy? Generally no — if you issue invoices to named clients, you are not issuing receipts.
Is there still a July 2026 M-sheet tightening to prepare for? No. It was repealed on 30 July 2026 and the previous data content applies.
Who is liable if the software fails to report? The taxpayer. Software failure is not a defence, which is why the set-up should be tested rather than assumed.
Updated: 2026-09-09 · Tax year 2026. Based on NAV guidance, Decree 8/2025. (III. 31.) NGM and Act XXXV of 2026. General information for foreign owners, not tax advice — obligations differ by activity, and cash-register-obliged sectors have their own rules.
Setting up a Hungarian company and want the reporting stack right from invoice one? See how we handle it as part of company formation in Hungary, or tell us what you sell and we will map the obligations to your model.