Cross-Jurisdictional Compliance with an OECD International Standard: the Standard Audit File for Tax (SAF-T)

The Standard Audit File for Tax (SAF-T) is a global standard developed by the Organisation for Economic Co-operation and Development (OECD) to streamline the exchange of tax-relevant data between businesses and tax authorities. The format, typically XML, enables the electronic exchange of structured, consistent, and comprehensive reports including accounting information, including general ledger entries, transactional data, payments, inventory, and fixed assets.

Countries across Europe and beyond have adopted SAF-T file format in varying capacities: some require periodic submissions while others mandate on-demand availability during audits. This article provides an overview of the implementation of SAF-T standards in key jurisdictions, with an emphasis on those enforcing periodic filings, along with the legal instruments that underpin each country’s SAF-T obligations.

Portugal SAF-T System

Portugal was a pioneer in SAF-T implementation, mandating it through multiple legal instruments. The VAT Code (Código do IVA) outlines the legal foundation, while Portaria No. 321-A/2007 defines the original SAF-T standardized format. Decreto-Lei No. 198/2012 introduced the obligation to submit monthly data through SAF-T, with Portaria No. 302/2016 and Portaria No. 31/2019 setting specific formats for invoicing, and tax and accounting information.

Monthly SAF-T files must be submitted by the 5th day of the following month. The obligation to submit the annual SAF-T accounting file in Portugal applies to accounting periods from 2025 onwards, with the first submissions due in 2026. The requirement is established from December 31, 2025, per Article 182.º-A and Ministerial Order No. 31/2019. Certified invoicing software is obligatory for taxpayers with a turnover of more than EUR50,000, and non-compliance can incur fines ranging from EUR300 to EUR7,500.

Standard Audit File for Tax in Poland

Poland has one of the most mature SAF-T ecosystems, known as JPK (Jednolity Plik Kontrolny). The Tax Ordinance Act, specifically Article 193a and Article 82 §1b, mandates that all businesses submit SAF-T reports. Monthly JPK_V7M or JPK_V7K files, combining VAT return data and accounts payable and accounts receivable listings, are required from all VAT-registered businesses. Other SAF-T formats (JPK_KR, JPK_FA, etc.) are provided on demand. From 1 January 2025, Poland will introduce new SAF-T structures for corporate income tax, including JPK_KR_PD and JPK_ST_KR, with the first submissions due by 31 March 2026, for the 2025 fiscal year.

Penalties include PLN 500 per file error if not corrected within 14 days, highlighting the importance of accuracy and timely compliance.

Romania SAF-T

SAF-T reporting was gradually implemented through Law No. 207/2015 (Fiscal Procedure Code), operationalized via ANAF Order No. 1783/2021. The SAF-T file (Form D406) has monthly or quarterly reporting requirements, depending on the taxpayer's VAT status. It includes the general ledger, customer/supplier data, and tax information. Separate modules exist for fixed assets (filed annually) and inventory (filed on request).

Large taxpayers have been filing since 2022, medium-sized ones since 2023, and small and non-resident VAT payers will begin in 2025. Penalties for late or missing filings can reach RON 5,000, with grace periods for initial implementation now expired.

Norway SAF-T VAT Compliance

Norway’s SAF-T obligations are governed by Section 7-8 of the Bookkeeping Regulations. A Ministerial Decision in 2017 and SAF-T schema approval in 2018 led to mandatory on-demand submission from 2020. While Norway has made significant changes to its digital VAT reporting, the standard VAT return is not fully replaced by SAF-T. Rather, SAF-T is required on demand, and a new version (SAF-T Financial 1.3) will be mandatory from 1 January 2025, for accounting periods from that date.

The law requires companies with digital accounts and revenue above NOK 5 million to generate SAF-T files on request. Penalties apply under the Regulations relating to Bookkeeping for non-compliance or failure to provide the file.

SAF-T in Angola

Angola introduced SAF-T as part of its VAT reform in 2019. Presidential Decree No. 312/18 and No. 292/18 established the legal regime for invoicing and electronic data submission, supported by Executive Decree No. 74/19 for technical specifications.

Businesses with annual turnover above AOA 50 million must submit SAF-T reports monthly by the 20th of the following month. This includes invoicing, accounting, and inventory data. Certified systems with unique hash codes are required. Penalties range from fines to potential invalid documents for tax and payment purposes.

France SAF-T Implementation

France's SAF-T equivalent is the Fichier des Écritures Comptables (FEC), mandated by Article L47 A I of the Livre des Procédures Fiscales (LPF) and specified in Article A47 A-1. All businesses with electronic accounts must produce the FEC during tax audits.

Though not periodically filed, the FEC must be readily available and compliant in format. Penalties include fines of €5,000 and potential rejection of records.

SAF-T in Lithuania

Lithuania adopted SAF-T through changes to the Law on Tax Administration and ministerial decrees under its i.MAS system. Large businesses had to comply from 2017, and since 2020, all VAT payers must be SAF-T capable.

While full SAF-T accounting data (i.SAF-T) is submitted on demand, invoice data (i.SAF) is reported monthly. Failure to comply may lead to fines and disqualification of accounting records during analysis.

Austria Standard File File for Tax

Austria mandated on-demand SAF-T through the 2009 BMF Decree (BMF-010102/0002-IV/2/2009), underpinned by Section 131 of the Federal Fiscal Code (BAO). No periodic filing is required, but businesses using electronic accounts must submit SAF-T files during audits.

The SAF-T schema is based on OECD standards, and failure to provide the file can lead to administrative penalties and extended audits.

SAF-T in Luxembourg 

Luxembourg’s FAIA system, established by the Grand-Ducal Regulation of 1 December 2010, requires businesses with turnover above €112,000 to submit SAF-T reports during VAT audits. Legal backing is found in Article 73 of the VAT Law and Article 61 of the Luxembourg General Tax Law.

FAIA filings include a full year of accounting and transaction data. While not routinely filed, the files must be provided on request, with penalties for failure to comply.

Bulgaria (Introduction of SAF-T from 2026 Onward)

Bulgaria is rolling out SAF-T requirements through amendments to the Tax and Social Security Procedures Code (TSSPC), introduced in the 2025 State Budget Act. A phased implementation begins in 2026 for large businesses and will extend to nearly all taxpayers by 2030.

Monthly SAF-T filings and annual asset reports will be mandatory. Non-compliance penalties are included in the updated TSSPC.

Denmark SAF-T Reports

Denmark's Bookkeeping Act (Act No. 700 of 2022) mandates the use of digital bookkeeping systems that support SAF-T export. From 2025, all companies must be able to generate SAF-T reports on request.

Though not a filing obligation, the inability to generate SAF-T could result in fines up to DKK 1.5 million. The law also lays groundwork for future integration with electronic invoicing and audit automation.

Ukraine (SAF-T from 2025 Onward)

Ukraine's Law No. 1914-IX and Draft Law No. 6255 amend the Tax Code to require SAF-T (SAF-T UA). From 2025, large taxpayers must submit annual SAF-T filings, and from 2027, all VAT-registered businesses will be included.

The Ministry of Finance approved the SAF-T UA format, covering full financial and tax data. Taxpayers must submit the file within two days of request during audits, with penalties for late or inaccurate submission.

Conclusion

SAF-T adoption reflects a global move toward digital tax compliance. Jurisdictions like Portugal, Poland, Romania, and Angola mandate periodic SAF-T submissions, while others like France, Austria, and Lithuania require files on demand. Upcoming frameworks in Bulgaria and Ukraine demonstrate the expanding influence of SAF-T compliance.

Understanding each country's legislative basis is essential for maintaining tax compliance and ensuring that financial systems can generate compliant SAF-T files. As governments modernize their tax infrastructures, SAF-T is becoming an indispensable part of international tax reporting.