E-invoicing in Hungary, NAV Online Számla, real-time invoice reporting (RTIR), NAV Online Invoicing System, XML 3.0 schema, invoice data reporting to the Hungarian tax authority, electronic invoice hash, completenessIndicator, or any question about issuing, transmitting, validating, or archiving…
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Who must comply
All Hungarian VAT-registered taxpayers who issue invoices must report invoice data in real-time to the NAV Online Számla system. This includes: Domestic B2B invoices (all VAT amounts, including zero); Domestic B2C invoices; Invoices issued to other EU member states (intra-community supplies); Export invoices to third countries; Self-billing invoices (buyer issues on behalf of supplier); Modification invoices (credit notes, corrections). The only invoices excluded from RTIR are those issued under the OSS (One-Stop Shop) regime for non-established sellers.
RTIR vs E-Invoicing distinction
Hungary operates a real-time invoice data reporting model, not a clearance model. The reported XML is a copy of the invoice data, not the invoice itself (unless completenessIndicator=true). The legal invoice can be paper, PDF, or (optionally) the XML itself. With XSD 3.0, businesses can opt to declare the XML as the actual electronic invoice by setting completenessIndicator=true. In this case, the XML becomes the legally binding document and is available to the buyer via NAV's system.
XSD version requirement
The NAV Online Számla system uses a proprietary XML schema maintained by NAV. As of 2026, only XSD version 3.0 is accepted.
Buyer access when completenessIndicator=true
When completenessIndicator=true, NAV makes the invoice XML available to the buyer for download, and the XML serves as the legally binding invoice.
API Workflow steps
1. Token Exchange: Call TokenExchangeRequest to obtain a session token (valid for 5 minutes) 2. Prepare Invoice XML: Generate invoiceData XML conforming to XSD 3.0 3. Compress and encode: Base64-encode the invoice data; optionally compress 4. Submit: Call ManageInvoiceRequest with the encoded invoice data, operation type (CREATE, MODIFY, STORNO), and request signature 5. Receive transaction ID: NAV returns a transactionId 6. Query status: Call QueryTransactionStatusRequest to verify processing result (RECEIVED, PROCESSING, DONE, ABORTED)
Request signature composition
Every ManageInvoiceRequest must include a request signature computed from: Request ID; Timestamp; XML signing key; Invoice hash values. The signature algorithm uses SHA-512 and the technical user's signing key.
Batch submission limit
Up to 100 invoice operations can be submitted in a single ManageInvoiceRequest (within the invoiceOperations element). Each operation has its own index, operation type, and invoice data.
Technical user management
Each taxpayer registers an "elsődleges felhasználó" (primary user) on the NAV portal, who then creates technical users for API access. Each technical user has: Login name and password; XML signing key (cserekulcs); XML exchange key (aláírókulcs). If keys are regenerated on the portal, they must be updated in the invoicing software immediately.
NAV-side validation checks
NAV validates every submitted invoice against: 1. XSD schema validation -- must conform to XSD 3.0; earlier versions rejected. 2. Request signature validation -- cryptographic signature must be valid. 3. Technical user validation -- credentials and keys must match. 4. Business rule validation: Tax number format and validity (8-digit taxpayer ID + VAT code + county code); Invoice number uniqueness per supplier; Modification references: original invoice must exist in the system (unless modifyWithoutMaster=true); completenessIndicator restrictions (cannot be true for paper invoices, private person invoices, merged invoices, or pre-2021 invoices); Currency and exchange rate consistency; VAT rate validity against current Hungarian VAT law.
Pre-submission checks
Validate XML against XSD 3.0 locally before API call; Verify request signature computation is correct; Confirm technical user credentials and keys are current (keys must be refreshed if regenerated on the portal); Verify tax number validity using NAV's public tax number query service; Ensure invoice number has not been previously submitted; For modifications: verify original invoice exists and modification index is sequential.
Rounding rules
VAT amounts calculated per line in the invoice currency (HUF or foreign currency). HUF amounts rounded to the nearest whole forint (no decimals). EUR/foreign currency amounts rounded to 2 decimal places. Summary totals are the sum of rounded line-level amounts. NAV validates that line-level amounts sum to the summary totals (with tolerance).
Multi-rate invoice handling
Each VAT rate has a separate summaryByVatRate element in the invoiceSummary. Each element contains: vatRateNetData (taxable base at this rate); vatRateVatData (VAT amount at this rate); vatRateGrossData (gross amount at this rate). Lines with different VAT rates must declare the rate individually.
Currency handling
For invoices in foreign currency: currencyCode must be a valid ISO 4217 code; exchangeRate is the MNB (Magyar Nemzeti Bank) rate on the tax point date or a contractual rate; HUF equivalents are required in the summary for tax reporting purposes; If the invoice is in HUF, exchangeRate must be 1.
Reverse charge reporting
Domestic reverse charge (fordított adózás) invoices must be reported with: vatExemption or vatOutOfScope indicator on relevant lines; Specific VAT rate type VAT_RATE_EXEMPT with the appropriate exemption reason.
Rendered from the canonical facts model. General reference only — confirm with a qualified professional before acting.
Section 1 -- Quick Reference
| Field | Value |
|---|---|
| Country | Hungary (Magyarország) |
| Currency | HUF (domestic); EUR/USD accepted for cross-border with HUF conversion |
| E-invoicing system name | NAV Online Számla Rendszer (Online Invoicing System) |
| Governing body | Nemzeti Adó- és Vámhivatal (NAV -- National Tax and Customs Administration) |
| Key legislation | Act CXXVII of 2007 on VAT (Áfa tv.); Act LXXXIII of 2018 (Online Invoicing System); Government Decree 23/2014 on technical requirements |
| Implementation timeline | Jul 2018 (B2B, VAT ≥ 100k HUF); Jul 2020 (all B2B invoices); Jan 2021 (B2C included); Jun 2021 (XSD 3.0 mandatory); May 2025 (XSD 2.0 end of life) |
| Current status (2026) | Fully operational RTIR covering 100% of invoices issued by VAT-registered persons; XSD 3.0 only; optional e-invoice (XML as legal invoice) available; preparing for ViDA alignment |
| Skill version | 1.0 |
Timeline Phases
| Date | Milestone |
|---|---|
| 1 July 2018 | RTIR launched for B2B invoices with VAT ≥ HUF 100,000 |
| 1 July 2020 | RTIR extended to all B2B invoices regardless of VAT amount (XSD 2.0 mandatory) |
| 4 January 2021 | B2C invoices included in RTIR; all invoices now reportable |
| 1 June 2021 | XSD 3.0 mandatory for all submissions; optional e-invoice feature activated |
| 1 April 2021 | XSD 2.0 and earlier rejected; 3.0 exclusively accepted |
| 15 May 2025 | NAV officially ends all support for XSD 2.0 |
| 2026--2028 | ViDA alignment: transition from RTIR (data reporting) to full structured e-invoicing (EN 16931 XML as the legally binding invoice) |
XML Schema (XSD 3.0)
| Schema | Namespace | Purpose |
|---|---|---|
invoiceData.xsd | http://schemas.nav.gov.hu/OSA/3.0/data | Invoice data content |
invoiceApi.xsd | http://schemas.nav.gov.hu/OSA/3.0/api | API request/response envelopes |
base.xsd | http://schemas.nav.gov.hu/OSA/3.0/base | Common base types |
common.xsd | http://schemas.nav.gov.hu/NTCA/1.0/common | NTCA common types |
Key Schema Structures
| Structure | Description |
|---|---|
InvoiceData | Root element for invoice data XML |
InvoiceMain | Contains Invoice (for normal invoices) or BatchInvoice (for summary invoices) |
InvoiceHead | Supplier data, customer data, fiscal representative |
InvoiceDetail | Invoice-level detail: category, appearance, currency, exchange rate, payment method, dates |
InvoiceLines | Line-level data: descriptions, quantities, amounts, VAT rates, product codes |
InvoiceSummary | Summary totals per VAT rate, global totals |
API Request Types
| Request | XML Root | Purpose |
|---|---|---|
ManageInvoiceRequest | invoiceApi:ManageInvoiceRequest | Submit new invoices or modifications |
TokenExchangeRequest | invoiceApi:TokenExchangeRequest | Obtain session token |
QueryInvoiceDataRequest | invoiceApi:QueryInvoiceDataRequest | Query submitted invoice data |
QueryTransactionStatusRequest | invoiceApi:QueryTransactionStatusRequest | Check processing status |
ManageAnnulmentRequest | invoiceApi:ManageAnnulmentRequest | Technical annulment of erroneous data |
Invoice Data Fields (XSD 3.0)
| Field | XPath (within InvoiceData) | Notes |
|---|---|---|
| Invoice number | invoiceHead/invoiceDetail/invoiceNumber | Unique identifier |
| Invoice category | invoiceHead/invoiceDetail/invoiceCategory | NORMAL, SIMPLIFIED, AGGREGATE |
| Invoice issue date | invoiceHead/invoiceDetail/invoiceIssueDate | ISO 8601 |
| Invoice appearance | invoiceHead/invoiceDetail/invoiceAppearance | PAPER, ELECTRONIC, EDI, UNKNOWN |
| Supplier tax number | invoiceHead/supplierInfo/supplierTaxNumber/taxpayerId | 8-digit Hungarian tax ID |
| Supplier name | invoiceHead/supplierInfo/supplierName | |
| Supplier address | invoiceHead/supplierInfo/supplierAddress | Structured address |
| Customer status | invoiceHead/customerInfo/customerVatStatus | DOMESTIC, OTHER, PRIVATE_PERSON |
| Customer tax number | invoiceHead/customerInfo/customerVatData/customerTaxNumber/taxpayerId | Required for DOMESTIC; optional for PRIVATE_PERSON |
| Customer name | invoiceHead/customerInfo/customerName | Required for B2B |
| Customer address | invoiceHead/customerInfo/customerAddress | Required for B2B |
| Currency | invoiceHead/invoiceDetail/currencyCode | ISO 4217 |
| Exchange rate | invoiceHead/invoiceDetail/exchangeRate | Required if currency ≠ HUF |
| Supply date | invoiceHead/invoiceDetail/invoiceDeliveryDate | Teljesítés dátuma |
| Payment method | invoiceHead/invoiceDetail/paymentMethod | TRANSFER, CASH, CARD, VOUCHER, OTHER |
| Payment date | invoiceHead/invoiceDetail/paymentDate | Due date |
| Line description | invoiceLines/line/lineDescription | Description of goods/services |
| Line quantity | invoiceLines/line/quantity | |
| Line unit of measure | invoiceLines/line/unitOfMeasure | |
| Line unit price | invoiceLines/line/unitPrice | |
| Line net amount | invoiceLines/line/lineAmountsNormal/lineNetAmountData/lineNetAmount | |
| Line VAT rate | invoiceLines/line/lineAmountsNormal/lineNetAmountData/lineVatRate/vatPercentage | |
| Line VAT amount | invoiceLines/line/lineAmountsNormal/lineVatAmountData/lineVatAmount | |
| Summary per VAT rate | invoiceSummary/summaryByVatRate | Net, VAT, gross per rate |
| Invoice grand total | invoiceSummary/summaryGrossData/invoiceGrossAmount |
Modification Invoice Fields
| Field | Notes |
|---|---|
modificationReferenceNumber | Original invoice number being modified |
modificationTimestamp | When the modification was initiated |
modifyWithoutMaster | true if original invoice was issued before RTIR or not in the system |
modificationIndex | Sequential number of modifications to the same original |
Electronic Invoice (completenessIndicator=true)
| Field | Location | Notes |
|---|---|---|
completenessIndicator | ManageInvoiceRequest/invoiceOperations/compressedContent (attribute) | Set to true to declare XML as the legal invoice |
electronicInvoiceHash | ManageInvoiceRequest/invoiceOperations/invoiceOperation/electronicInvoiceHash | SHA3-512 or SHA-256 hash of the invoice XML |
cryptoType | Attribute of electronicInvoiceHash | SHA3-512 or SHA-256 |
NAV Online Számla API
| Component | Detail |
|---|---|
| API type | RESTful XML-based API |
| Production URL | https://api.onlineszamla.nav.gov.hu/invoiceService/v3/ |
| Test URL | https://api-test.onlineszamla.nav.gov.hu/invoiceService/v3/ |
| Web portal | https://onlineszamla.nav.gov.hu (manual queries and management) |
| Authentication | Technical user credentials (login + password) + XML signing key + XML exchange key |
| Submission deadline | Immediately upon invoice issuance; technically within 5 minutes |
Common Rejection Reasons
| Reason | Detail |
|---|---|
| XSD version mismatch | Submission uses XSD 1.x or 2.0 (rejected since April 2021) |
| Invalid request signature | Signing key mismatch or computation error |
| Invalid tax number | Supplier or customer tax number format invalid or not registered |
| Duplicate invoice number | Same invoice number already submitted by the same supplier |
| Modification reference error | Referenced original invoice not found and modifyWithoutMaster=false |
| CompletionIndicator conflict | completenessIndicator=true with non-electronic appearance or private person |
| Missing mandatory field | Required XSD element absent or empty |
| Rate validation failure | VAT percentage does not match known Hungarian rates |
Hungarian VAT Rates (2026)
| Rate | Percentage | Application |
|---|---|---|
| Standard | 27% | Most goods and services (one of the highest in the EU) |
| Reduced 1 | 18% | Dairy products, bakery products, commercial accommodation |
| Reduced 2 | 5% | Basic foodstuffs (meat, eggs, milk), books, newspapers, medicines, district heating, internet access, new residential property (conditions apply), live performances |
| Exempt | 0% | Intra-community supplies, exports, certain financial and insurance services |
Section 8 -- Archiving Requirements
| Requirement | Detail |
|---|---|
| Retention period | 8 years from the end of the year in which the invoice was issued (Számviteli törvény) |
| Format (paper invoice) | Paper original must be retained; RTIR XML is a data report, not the legal document |
| Format (PDF invoice) | Digitally signed PDF with timestamp is the legal document; must be archived with signature intact |
| Format (XML e-invoice, completenessIndicator=true) | The XML submitted to NAV is the legal document; buyer downloads from NAV; both parties must retain the XML |
| Integrity | No modification permitted to the archived document; audit trail required |
| Accessibility | Must be available for NAV audit within the territory of Hungary (or EU with immediate electronic access) |
| NAV portal | NAV retains all submitted RTIR data; businesses can query via the web portal or API; however, NAV data is a report, not an archive -- businesses must maintain their own records |
| Buyer obligation (XML e-invoice) | If completenessIndicator=true, the buyer retrieves the XML from NAV and archives it as the original invoice |
RTIR-Specific Penalties
| Violation | Penalty (HUF) |
|---|---|
| Failure to report invoice data to NAV | Up to HUF 500,000 per invoice (approx. EUR 1,300) |
| Late reporting (beyond the real-time deadline) | Graduated fines based on delay duration |
| Incorrect data in RTIR submission | Up to HUF 500,000 per invoice |
| Use of non-compliant invoicing software | Fines per NAV decree; software must be registered with NAV |
| Systematic non-compliance | Triggers risk classification; increased audit probability |
General VAT Penalties
| Violation | Penalty |
|---|---|
| Failure to issue invoice | Up to HUF 500,000 per instance |
| Incorrect invoice content | Tax reassessment + penalty (50% of tax shortfall as default penalty; 200% if fraud) |
| Late VAT return filing | Late payment interest + administrative fine |
| VAT fraud | Criminal penalties under Hungarian Penal Code |
NAV uses RTIR data for automated risk analysis; persistent errors trigger compliance audits. The planned e-ÁFA (pre-filled VAT return) system relies on correct RTIR data; incorrect submissions lead to discrepancies in the pre-filled return. Buyers increasingly verify supplier RTIR compliance before accepting invoices.
NAV uses RTIR data to construct the e-ÁFA (electronic VAT) pre-filled return. From 2024, NAV offers taxpayers a draft VAT return based on: Supplier-reported outbound invoices; Buyer-received inbound invoices; Customs declarations. Taxpayers review, adjust, and submit the pre-filled return. Discrepancies between RTIR data and the filed return trigger automated queries.
The e-ÁFA system pre-populates: Output VAT from the taxpayer's submitted invoices; Input VAT from suppliers' reported invoices where the taxpayer is the buyer; Adjustments for credit notes and modifications. This significantly reduces manual data entry for small and medium businesses.
When a supplier sets completenessIndicator=true, the buyer can retrieve the structured XML invoice from NAV's system. This enables automated accounts payable processing, booking, and reconciliation.
NAV cross-references RTIR data against corporate tax returns. Revenue and cost data from invoices feeds into NAV's risk-analysis algorithms for corporate tax audits.
Hungary's RTIR is expected to evolve into a full structured e-invoicing system aligned with EU ViDA requirements by 2028--2030. The transition will shift from data reporting (XML as a copy) to clearance or exchange (XML as the legally binding invoice, EN 16931 format). Hungary's advanced RTIR infrastructure positions it well for this transition.
NAV is developing the e-nyugta system for electronic receipts, which will eventually replace traditional cash registers for retail B2C transactions. This system will integrate with the existing Online Számla infrastructure.
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