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Since 1 January 2021, companies doing business in Hungary have been required to comply with the RTIR (Real-Time Invoice Reporting). This does not only include B2B E-Invoicing requirements, but further B2C E-Invoicing regulations, that are imposed by the NAV (Nemzeti Adó és Vámhivatal, National Tax and Customs Administration of Hungary, HU TA). From a technical point of view, an XML version 3.0 needs to be submitted to the NAV Online Számla platform in real time, enabling the tax authority to validate and monitor invoice data immediately upon issuance. In February of 2026, the NAV and the Ministry of National Economy have confirmed that structured B2B domestic E-Invoicing will be introduced in phases, starting from 2028. This will replace the current RTIR. For you as an organization, this means that you need a future-proof SAP solution that can be easily managed and updated to ensure compliance on the long run and to avoid paying severe penalties for non-compliance.
In this article, you can read why we recommend SAP Document & Reporting Compliance for keeping your SAP system and E-Invoicing process compliant on the long run with the latest Hungarian E-Invoicing regulations.
Hungary RTIR: Timeline from 2018 NAV Mandate to Future Updates
As mentioned in our previous blog post, Hungary was one of the early E-Invoice adopters. It started in 2018, as shown in the timeline below, with the first B2B requirements, which included an early machine-readable XML format (version 1.0). The purpose was to electronically transmit accounting documents, which exceed the threshold of 100.000 HUF (€320), in real time. However, invoicing and reporting were two different processes.
On the first of July 2020, the requirements extended to an update which implied a new XML format (version 2.0). It was now obligated to transmit tax-exempt transactions (except intra-community) and domestic transactions subject to reverse charge procedure. From then onwards the reporting threshold of HUF 100.000 VAT amount charged per invoice has been eliminated. Moreover, it became possible to see inbound invoices at NAV portal.
As of the first of January 2021, with a granted “grace period” until 31 March 2021, a new version 3.0 entered into force. The NAV adopted a strategy of quick adjustments, as version 2.0 was only introduced in 2020. Reporting includes invoices issued to individuals (B2C) as well as export and intra-community transactions. From 1st April 2021, when the soft-landing period ended, only the new XSD (XML Schema Definition, version 3.0) could be submitted and version 2.0 was no longer accepted by NAV. In other words, from this date on penalties up to 500.000 HUF (€1.700) per invoice were issued in the case of non-compliance.
While the current RTIR system is still in place, some changes took place. On the 1st of July 2025 the Hungarian B2B E-Invoicing mandate has extended to all business transactions within the electricity and natural gas sector. The wholesale or utility of supply of water is also mandated for Hungarian B2B E-Invoicing since the 1st of January 2026. Under this mandate, the accounting documents are still transmitted in real time using RTIR but certain fields within the XML format are filled in differently or are added. For example, a field indicating that the format is an E-Invoice or a hash that adds encryption to your document.
The framework does not mandate a specific E-Invoicing format or exchange method. Any format accepted by the NAV can be used. If all the necessary fields are present, your customer should be able to find and download the E-Invoice on the platform.
In February 2026, the NAV has announced the phased implementation of structured B2B E-Invoicing from 2028. This will combine E-Invoicing and E-Reporting, meaning it will replace the existing RTIR. It will be mandatory for domestic and cross-border B2B transactions under the European ViDA package. Peppol will be adopted as the primary method of E-Invoice exchange.
SAP DRC as the solution to compliance with the current Hungarian RTIR & B2B E-Invoicing
In order to comply with the existing and new Hungarian RTIR E-Invoicing rules, I recommend a SAP solution, called SAP Document & Reporting Compliance. SAP DRC is a strategic, integrated SAP solution that works with SAP ECC and SAP S/4HANA and that makes your SAP accounting processes 100% legally compliant with the Hungarian rules.
SAP has developed this solution to not only comply with the Hungarian RTIR requirements, but also to ensure compliance with many other country-specific legal requirements all over the world, such as SII in Spain, SDI in Italy, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, DIAN in Colombia, E-Invoicing and E-Archiving in Turkey, MyDATA in Greece, etc. All the implemented country-specific legal requirements can be easily managed with the SAP eDocument Cockpit that takes a central role in SAP Document Compliance. With SAP Document Compliance, you have an end-to-end solution that automatically generates the required XML files based on source information from your SD or FI billing documents and digitally signs the XML file, when required. SAP Document Compliance can be connected with SAP CPI or with 3rd party EDI middleware systems to manage all data transmission with the local tax authority systems.
An additional benefit of using SAP Document Compliance is its flexibility. Several SAP BAdI’s (Business Add-Ins) are available to change the standard XML structure and PDF mapping, to change the e-mail content and the recipients, to partially automate the customer feedback process, etc. We have already adapted SAP Document Compliance to many different customer-specific cases. Please let me know in the Comments section below if you have a specific business requirement that needs to be implemented in your Hungarian SAP accounting process. I am happy to investigate how this can be integrated with SAP Document Compliance.
The SAP DRC process flow for RTIR B2B E-Invoicing requirements in Hungary
SAP Document & Reporting Compliance is a solution to make your SAP system compliant to the RTIR B2B E-Invoicing requirements in Hungary. The following graphic illustrates the different end-to-end process steps that are implemented in SAP Document Compliance to achieve compliance with the RTIR E-Invoicing regulations:
- After an invoice (incl. accounting document) has been posted in SAP SD or SAP FI, the SAP DRC solution automatically generates a corresponding SAP eDocument.
- The RTIR process in the eDocument Cockpit is being used to submit the eDocument to NAV. When submitting the eDocument, it is converted to the correct XML format within SAP ERP (AIF Interface) and forwarded to SAP Cloud Platform Integration (SAP CPI).
- SAP CPI forwards the XML file to the NAV platform. This involves the following sub steps:
- Request a token for authentication from NAV.
- Hungarian tax authority acknowledges the request and provides the needed token.
- Forward the eDocument alongside the token.
- Upon receipt of the eDocument, the NAV platform validates it.
- If the document is valid, a registration ID is provided.
- If the document is invalid, NAV rejects it, and an error message is provided.
- This feedback flows back into S/4HANA (eDocument Cockpit) via SAP CPI and SAP ERP. The status of the eDocument is updated. You can proceed as follows:
- If the eDocument is approved, no further action is required. In a second phase of the project (after conversion from e-Reporting to e-Invoicing), it would become possible for the customer to directly download the approved e-Invoice from the NAV platform.
- If the eDocument is rejected, NAV sends a rejection message in response. Depending on the rejection message you can either choose to cancel the eDocument (after cancelling the source document) or correct the errors and resubmit the eDocument.
Note: At present, the SAP DRC solution only covers real-time invoice reporting (RTIR), where invoice data is submitted to the government’s NAV portal and a feedback (approval/rejection) is returned. From a legal standpoint, businesses could decide on a voluntary basis to extend their RTIR messages with additional fields that will allow customers to receive these NAV submissions electronically as well (RTIR e-reporting to RTIR e-invoicing extension). This optional solution extension is nevertheless not covered or planned at the moment by SAP DRC, which means that aside from RTIR reporting to government, businesses should continue to send invoices to their customers outside of the eDocument Cockpit (e.g. by means of SD PDF or e-mail output or through third-party set-up).
The process-related and technical impact of the Hungarian RTIR E-Invoicing update of 2021 on your SAP system
In order to comply with the Hungarian RTIR regulations for E-Invoicing, you need to consider both the technical and process-related impact on your SAP system. The two biggest changes for organizations due to this regulation are:
- Version 3.0 offers the opportunity to complete invoicing and reporting in one step.
- The new XML scheme (XSD 3.0) can be used as a valid E-Invoice. Therefore, not only financial information will appear on the XML, but also all sales related information must be included. What will change on the XML format is explained in detail in the next paragraph.
As is shown in the figure below, in the current process (version 2.0) invoices are sent to the customers and at the same time reporting to the Hungarian Tax Authority takes place (step 1 + 2). This possibility is still available with the new XML scheme (XSD 3.0), but there is also the chance to simplify the process.
With the new XML scheme (XSD 3.0) the invoicing towards customers and the reporting towards the Hungarian Tax Authority can be done in one step, as is shown in the process below (only step 1). There will not only be more mandatory fields, but it will also become crucial to take in to account your customers’ requirements.
With the update to version 3.0 organizations can use real-time reporting as E-Invoicing between businesses. In other words, XML invoices which have been submitted by companies can be downloaded by their customers. In this case, the supplier must provide the full data content of the invoice instead of only some mandatory fields.
Regarding the new XML schema version 3.0, reporting will include invoices issued to individuals (B2C), export and intra-community transactions as well.
How PIKON Supports your SAP RTIR E-Invoicing Compliance in Hungary
PIKON has developed a Competence Center for Legal Requirements, which researches country-specific legal requirements all over the world and their impact on your SAP system. Because of that, we can ensure that your SAP system and business processes comply with these different country-specific legal requirements. Our team of experts combine SAP expertise and in-depth knowledge of the end-to-end legal processes and technical requirements of the Hungarian RTIR regulations and other legal requirements. Our consultants have gathered this experience thanks to the many SAP Document & Reporting Compliance and local implementation projects we have done all over the world. Examples include SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, E-Invoicing in France, XRechnung and ZUGFeRD in Germany, E-Invoicing and E-Archive in Turkey, DIAN in Colombia, MyDATA in Greece, etc. We have also created our own SAP Compliance Add-Ons for MTD VAT in the UK and the VAT Whitelist in Poland to ensure we offer clients the best suitable solution.
Because we care about our customers and want your company to focus on your daily business, we also follow-up on new and changing legal requirements relevant to your company. If any action in your SAP system is needed, we will inform you and offer our support. That way, you save the time to research this yourself and are ensured that your SAP system remains compliant to necessary regulations.
If you have further questions about the Hungarian RTIR and B2B E-Invoicing updates, or on how we can help you achieve compliance in your SAP system, please ask in the Comment section or request a web-meeting with us.
Schedule a web meeting
If you have any questions on Hungary’s E-Invoicing regulations, or if you are interested in a system demo regarding the E-Invoicing flow, do not hesitate to request a web meeting or leave a comment in the comments section below. We are happy to help and will come back to you as soon as possible.
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