1. Policy Direction
1.1 From receive-only to real time
Malta is shifting from merely accepting standard e-invoices in the public sector to a phased regime of e-invoicing with digital real-time reporting (DRR) to raise transparency and shrink the VAT gap.
1.2 Strategic alignment with ViDA
The roadmap is calibrated to the EU’s VAT in the Digital Age milestones so Malta’s domestic build lands before cross-border rules apply.
2. Where Things Stand in 2025
2.1 No issuance mandate
There is no legal obligation yet for B2B, B2G or B2C e-invoicing.
2.2 Public sector readiness
All contracting authorities must be able to receive EN 16931-compliant e-invoices; suppliers are not compelled to issue them.
3. Standards and Rails
3.1 Peppol first
Malta uses Peppol BIS Billing 3.0 with its CIUS and avoids national extensions to keep interoperability high.
3.2 No central B2G portal
There is no national issuance platform; the transport layer relies on Peppol Access Points.
4. Target Operating Model
4.1 Five-corner exchange
Business documents move over Peppol on EN 16931/UBL semantics, with acknowledgements cycling back to ERPs for status-driven posting.
4.2 DRR capture
Transaction data is expected to be reported close to the event, enabling pre-filled VAT returns, fewer retrospective audits, and faster anomaly detection.
5. Why This Pivot Matters
5.1 VAT gap pressure
A materially higher VAT gap than the EU average makes structured invoicing and DRR a pragmatic lever for revenue protection.
5.2 Compliance by design
Machine-readable payloads, delivery receipts and consistent identifiers create cleaner ledgers and quicker reconciliations.
6. Rollout Logic
6.1 Phasing before 2030
Authorities have signalled a staged introduction (likely large taxpayers and public-facing suppliers first), completing ahead of the EU cross-border go-live.
6.2 Voluntary runway
Until any domestic mandate starts, businesses can adopt Peppol voluntarily to de-risk later cutovers.
7. ViDA Anchors
7.1 National freedom from 2025
Member States can introduce domestic B2B e-invoicing without prior EU approval when limited to established taxpayers.
7.2 EU go-lives
From 1 July 2030, e-invoicing and DRR apply to intra-EU B2B and reverse-charge transactions; by 1 January 2035, national regimes are expected to be harmonised with the EU model.
8. Technical Essentials
8.1 Data model
Map ERP fields to EN 16931 (parties, lines, bases, rates, totals, identifiers) in UBL via Peppol BIS 3.0 CIUS.
8.2 Transport and observability
Use a Peppol Access Point, ensure idempotency keys and correlation IDs, and store acknowledgements alongside the original payload.
9. Business Readiness Checklist
9.1 Governance and controls
- Define ownership for e-invoicing/DRR processes and exception queues.
- Embed pre-submission validations mirroring business rules.
9.2 Integration and data
- Connect to an Access Point and run partner pilots.
- Clean master data (VAT IDs, legal names) and align tax treatments.
- Instrument archives for fast retrieval of originals and receipts.
10. Timeline at a Glance
- 2025: Domestic B2B e-invoicing can be introduced nationally without EU pre-approval (for established taxpayers).
- 2025–2029: Phased Malta rollout of e-invoicing + DRR signalled; pre-filled return capability expected to emerge.
- 1 Jul 2030: EU-level e-invoicing and DRR for intra-EU B2B and reverse-charge flows.
- 1 Jan 2035: Harmonisation horizon for national systems with EU standards.
