Compliance · Article 6.5
EU invoice compliance — Art. 226 mandatory fields, sequence numbering, retention
Every invoice Clozo issues complies with EU VAT Directive Art. 226: 15 mandatory fields, sequential numbering with no gaps, immutability after issue, and 10-year retention.
EU VAT Directive 2006/112/EC, Articles 220–240, defines what makes an invoice valid. Art. 226 specifically lists the mandatory content. Member states have implemented these into national law (e.g., §14 UStG in Germany, Art. 35a Wet OB in the Netherlands), with minor local additions but the core 15 fields are universal across the EU. Clozo's invoice templates are built to pass Art. 226 inspection in any EU member state, and the local additions are layered in via locale templates.
Why this works this way
The 15 mandatory fields under Art. 226 (per EU VAT Directive 2006/112/EC, Article 226):
1. Date of issue — the date the invoice document was issued (not the project completion date). 2. Sequential number — uniquely identifies the invoice. No gaps in sequence permitted (Art. 226(2)). 3. VAT identification number of the supplier under which the goods or services were supplied. (For non-VAT-registered suppliers under a small-business regime, replaced by the regime note — see below.) 4. VAT identification number of the customer if the customer is liable for the VAT on the supply (i.e., reverse charge B2B intra-EU). 5. Full name and address of the supplier (your business name and address). 6. Full name and address of the customer. 7. Description of the goods or services supplied (sufficient to identify the supply). 8. Date of supply or completion of the services, if different from the issue date. 9. Taxable amount per rate or exemption. 10. VAT rate applied. 11. VAT amount payable, except where a special arrangement applies (e.g., margin scheme). 12. Reference to the applicable provision triggering an exemption or zero rating (e.g., for reverse charge: "Reverse charge — VAT to be accounted for by the recipient (Art. 196)"). 13. Where the invoice is issued by the customer (self-billing arrangement) — "Self-billing" mention. Not applicable to standard Clozo flows. 14. Where a margin scheme is applied — appropriate mention. Not applicable to standard Clozo flows; freelancers using the margin scheme would use the manual override.
National additions to watch for:
- Germany (§14 UStG): tax number (Steuernummer) or VAT ID (USt-IdNr.) — both acceptable. Service description must be specific enough to identify the supply (case law: "consulting services" is too vague; "software architecture consulting for project Phoenix, May 2026" is fine).
- Netherlands (BTW Art. 35a): BTW-nummer required; format NL{9 digits}B{2 digits}. Date format DD-MM-YYYY strongly preferred.
- France (CGI Art. 242 nonies A): SIRET number on top of VAT number; "TVA non applicable, art. 293 B du CGI" for franchise-en-base regime.
- Italy (DPR 633/1972 Art. 21): requires e-invoicing via SDI (FatturaPA) for B2B and B2G — Clozo handles this via the e-invoicing channel (see article 6.6).
- Spain (Ley 37/1992 + RD 1619/2012): NIF required; for B2B and B2G, e-invoicing via FacturaE may be required.
- Poland (Ustawa o VAT): NIP required; for B2B, e-invoicing via KSeF mandatory from July 2026.
Sequential numbering (Art. 226(2)). Numbers must be unique and sequential. Clozo enforces this via an atomic counter (DocumentCounter, see article 6.9). No gaps. If you start your year at INV-2026-0001 and reach INV-2026-0042, you cannot then issue INV-2026-0050 — you'd have to issue 43 through 49 first. The counter design prevents this by always returning the next number.
Immutability after issue. Once an invoice is issued (PDF rendered, uploaded to R2, attached to email), it cannot be edited. The only legitimate ways to change an invoiced amount are:
1. Storno (STR-): voids the invoice. The original remains in your records (with legal_hold) but is marked superseded or cancelled.
2. Credit note (CRN-): records a partial reduction (e.g., refund, discount).
3. Correction invoice (Berichtigungsrechnung): a follow-up invoice that adjusts a specific issue on the original — used in Germany for typo or address fixes.
Clozo's amendment flow (Section 7) generates the right combination automatically based on the delta direction.
Retention: 10 years (GoBD §147 AO Germany; Wet OB Art. 52 Netherlands; CGI Art. L102 B France; Codice Civile Art. 2220 Italy; Ley General Tributaria Art. 70 Spain; Ordynacja Podatkowa Art. 86 Poland — all implementing the 10-year minimum in EU VAT Directive Art. 247(2)). Clozo stores all invoices on Cloudflare R2 with the legal_hold flag; they cannot be deleted within the retention window, even by an admin. If your account is closed, your invoices remain accessible for export through the legal-hold period.
Small-business regime invoices. For Kleinunternehmer (DE), KOR (NL), franquicia (ES), forfettario (IT), and similar regimes, the VAT lines are replaced with a regime note (in the local language) — e.g., "Gemäß § 19 UStG wird keine Umsatzsteuer berechnet (Kleinunternehmerregelung)" for German Kleinunternehmer. Field 3 (your VAT ID) is then optional but Clozo includes your tax number (Steuernummer) where available because some German tax inspectors expect to see something identifying the supplier.
Troubleshooting
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Proposals & Invoices
The deposit invoice (DEP-) — Anzahlungsrechnung, facture d'acompte
The deposit invoice is the legal artefact that records VAT liability on an advance payment. Under EU VAT Directive Art. 65, the deposit becomes chargeable the moment the client pays — the deposit invoice is what the law requires you issue.
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The final invoice (INV-) — Schlussrechnung, facture de solde
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Invoice numbering — sequential per year per type, atomic, no gaps
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Proposals & Invoices
E-invoicing formats: which one for which country, and why
EU member states are migrating to mandatory structured e-invoicing on different timelines. Clozo supports the six major formats — Peppol UBL, Factur-X, ZUGFeRD, FacturaE, KSeF, FatturaPA — with the right one auto-selected by the client's country.