NAV Proposes a Phased Exit from ÁNYK — Largest Companies on eÁFA for VAT Returns in 2027, Most Other VAT Filers from 1 January 2028
On 15 October 2026 the Hungarian National Tax and Customs Administration (Nemzeti Adó- és Vámhivatal, NAV) published a press release titled "Több időt adna a NAV a digitális átállásra" (NAV would give more time for the digital transition). After consulting the tax profession, NAV proposes to replace the full phase-out of its ÁNYK form-filling program on 31 December 2026 with a gradual exit, applied return by return and form by form. The largest companies would be the first required to file VAT returns through eÁFA, during the following year; most other VAT filers, including SMEs, would have until 1 January 2028. The release describes a proposal and cites no legislation.
Background
NAV had announced on 5 December 2025 that ÁNYK, its general form-filling framework since 2008, would be switched off on 31 December 2026 and that from 1 January 2027 data could be submitted only through modern, data-based solutions: ONYA (online form filling, for individuals and small businesses), NAV M2M (machine-to-machine API connection, for accountants, advisers and large businesses) and eÁFA (the recommended VAT return tool). On 15 July 2026 NAV published an ÁNYK-átállás knowledge base and stated that, under the legislation then in force, ÁNYK would be replaced from 2027. On 3 August 2026 the eÁFA-M2M production interface began to accept only XSD version 2.0.
NAV also reports the consultation behind the change: about 2,000 bookkeepers, tax professionals and developers completed an eÁFA questionnaire. 55% of bookkeepers cited insufficient preparation time and delayed development of accounting software; 64% of software developers had not yet started actual testing.
The Legislative Change
This is not a legislative change in the sense of an enacted act. The NAV release is a proposal; it cites no legal basis and does not say which instrument, if any, would be needed to implement a phased schedule. It operates, for now, within the existing framework, under which NAV itself had announced the 31 December 2026 shutdown.
It is nonetheless relevant in practice for two reasons. First, until the proposal is adopted, the 2026 timetable remains NAV’s last formally announced position. Second, the technical channels that every route depends on (the eÁFA web interface and the M2M interface, on XSD 2.0) continue on NAV’s existing schedule, so only the date on which users must stop using ÁNYK is proposed to move.
Scope
The proposal covers all taxpayers that file through ÁNYK, with VAT returns as the lead item. The largest companies would be the first required to use eÁFA for VAT returns. The NAV release does not define "largest" (turnover, tax liability or invoice volume) and does not say whether the date would be fixed for companies above a size threshold. Widely used returns such as the personal income tax and corporate tax returns could still be filed in the old system in 2027.
Existing channel rules inside eÁFA are unchanged by the release. NAV’s eÁFA information of 13 February 2024 states that taxpayers handling fewer than 100,000 invoices in a tax period may use the web interface, while those handling 100,000 or more must use the M2M connection. That is a channel rule and should not be read as the definition of "largest companies".
Timeline
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5 December 2025 — NAV: ÁNYK to be switched off on 31 December 2026; from 1 January 2027 data only through data-based solutions.
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1 January 2026 — versions 1.0 of VAT return form 2665 and recapitulative statement 26A60 dated 1 January 2026 on the NAV forms pages; later versions: 26A60 v2.0 (29 April 2026) and v3.0 (2 September 2026); 2665 v2.0 (26 August 2026).
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15 July 2026 — NAV ÁNYK-átállás knowledge base; M2M data structure 4.0 (BizonylatAPI) expected 31 July 2026.
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3 August 2026 — eÁFA-M2M production accepts only XSD 2.0.
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15 October 2026 — NAV proposes the phased exit.
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2027 (date not published) — proposed: largest companies required to use eÁFA for VAT returns.
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1 January 2028 — proposed: most VAT filers, including SMEs, required to use eÁFA.
Businesses Affected
All Hungarian VAT filers, and groups with Hungarian entities, are affected in principle. The most exposed are high-volume entities that may fall within the "largest companies" group, and software houses and SAP-integrated reporting solutions that file through M2M. Entities expecting to remain on ÁNYK through 2027 will file on the 2026 form versions, which NAV has already updated during the year.
Required Actions
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Do not treat the proposal as law. Plan for the date NAV eventually adopts, and keep the 1 January 2027 date as a contingency for high-volume entities until NAV names the first group.
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Keep eÁFA-M2M development on XSD 2.0 and follow the M2M data structure releases NAV publishes (BizonylatAPI 4.0 was announced in July 2026).
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Confirm which NAV form versions (2665 and 26A60) were used for each 2026 period and re-test any templates built on January 2026 versions.
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Ask NAV or your adviser which channel (ONYA, M2M or eÁFA) each Hungarian entity should use, and track the M-sheet position (below).
Practical Implications
The release moves a deadline, not the destination. NAV states that only the schedule would change and that the aim remains to replace ÁNYK with simpler digital services. For SAP-integrated reporting the practical effect is time for testing, not a pause in the build, because the first group to be switched is still undefined.
A separate item remains open. Act LXXXIII of 2025 tightened the rules on invoice-recipient data in the VAT return (the M sheet) from 1 July 2026. On 25 June 2026 the Ministry of Finance announced that the government planned to submit a proposal so that the stricter rules would never apply to a reporting period. KGT could not confirm on an official source whether that proposal has been enacted; the NAV page for form 2665 shows no M-sheet change in its 2026 versions. Statements that returns on old form versions are automatically rejected by ÁNYK were also not found on the NAV forms pages.
Expected Next Steps
NAV says it will keep consulting professionals and developers on the schedule and will provide information, professional forums, educational material and direct assistance. KGT will monitor the NAV news and eÁFA information pages for the definition of the largest companies, a dated 2027 start, the legal instrument, and the outcome of the M-sheet amendment.
How Can KGT Support You?
KGT delivers SAP-integrated e-invoicing and statutory reporting add-ons, including Hungary, and supports SAP Document and Reporting Compliance (SAP DRC) scoping, configuration and country activation. We can help you assess which Hungarian entities may fall in the first eÁFA group, keep the M2M interface aligned with NAV’s XSD and data-structure releases, and plan the cut-over from ÁNYK-based filing.
This update is for information only and is not tax or legal advice. Please consult your tax adviser before acting on it.
