Sweden has formally opened a government led review to determine how it should implement the EU’s VAT digitalisation reforms and whether it should introduce a domestic mandate for e-invoicing and digital reporting. A special investigator has been appointed under a government directive dated 5 February 2026 (Dir. 2026:9), with findings due by 30 November 2027. The review is significant because it moves the topic from general policy discussion to a structured assessment of scope, legal changes, operational design, and feasibility.
What the Review Covers
The directive from the Swedish Ministry of Finance frames the review around two connected questions:
- EU alignment: How Sweden should transpose upcoming EU requirements that rely on structured e-invoice data to support digital VAT reporting, particularly for cross-border B2B transactions.
- Domestic extension: Whether Sweden should apply similar requirements to domestic transactions and if so, how broadly and under what model.
This dual scope matters: Sweden is not only examining minimum EU compliance, but also the potential value of a national framework that goes beyond cross-border reporting.
The Key Question: Scope and Proportionality
The inquiry is not limited to cross-border alignment. It also requires an evaluation of whether domestic transactions should be brought into an e-invoicing and digital reporting framework and, if so, to what extent.
This is the pivotal policy question for the Swedish market: whether Sweden will remain focused on EU-minimum implementation for cross-border flows, or whether it will adopt a broader national approach that extends into domestic B2B activity. At this stage, the government is establishing an evidence base rather than announcing a final mandate.
What the Investigator Is Required to Deliver
The directive assigns a defined set of tasks to the investigator. These include:
- Legal implementation analysis: Identify the legislative changes needed to introduce digital reporting based on e-invoicing in line with EU requirements for relevant cross-border transactions.
- Domestic feasibility assessment: Evaluate whether e-invoicing and digital reporting should be introduced for domestic transactions, and how far such a system should reach.
- Tax administration usability: Analyse how the Swedish Tax Agency can use the collected data and what conditions are required for effective operation.
- Legislative proposals: Provide concrete proposals for the legal changes considered necessary, consistent with the inquiry’s findings and the intended policy direction.
Issues Already Raised in Sweden’s Policy Discussion
The inquiry builds on questions that have already surfaced in Swedish discussions during 2025–2026. Reported topics include:
- Whether a domestic mandate should be introduced and what the scope would be.
- Whether VAT-exempt transactions should be included.
- What technical requirements should apply to structured e-invoicing.
- What sanctions or penalties would apply in cases of non-compliance.
- Whether the model should be based on an established interoperability framework (for example, approaches already used in public procurement).
These points matter because they indicate the practical design questions Sweden will need to resolve if it chooses to move from assessment into implementation.
Conclusion
Sweden’s 2026 directive establishes a formal pathway to decide how EU-driven VAT digitalisation should be implemented and whether similar controls should be introduced domestically. With a report expected by 30 November 2027, the review will shape the future compliance landscape by defining scope, technical approach, and enforceability. For businesses, the prudent approach is to use this period to strengthen structured invoicing capabilities and invoice-data governance so that any eventual mandate EU-aligned or domestic can be met with controlled cost and minimal disruption.
