Estonia KMD INF Guide: Scope, Threshold and Filing

Estonia's KMD INF is a monthly invoice-data annex filed with the KMD VAT return. Part A reports qualifying invoices issued, while Part B reports qualifying invoices received. The mandatory threshold is EUR 1,000 excluding VAT per transaction partner and taxation period, calculated separately for sales and purchases. Both the KMD and its annex are normally due by the twentieth day of the following month.

This Estonia KMD INF guide starts with the decision that controls the rest of the form: determine whether the counterparty and invoice are within scope, then total eligible sales and purchases in separate populations. Reaching EUR 1,000 on the sales side does not make purchases from the same partner reportable, or vice versa. KMD INF supplies invoice-level detail; it does not perform the VAT calculation reported on KMD.

The annex is often described as domestic invoice reporting, but that shorthand can misclassify cross-border counterparties. The form looks to the partner's Estonian register code. A non-resident assigned a code in Estonia's register of taxable persons can fall within KMD INF, whereas invoice data for a non-resident without an Estonian register code is excluded.

The controlling reference is EMTA's current English KMD INF form and instructions. It identifies the applicable invoice categories, threshold calculation, exclusions, fields, VAT rates and special codes. Use the version applicable to the taxation period rather than carrying forward the fields or rates from an older form.

How the EUR 1,000 threshold is calculated

Build four totals for each transaction partner in the taxation period: ordinary sales invoices, sales credit invoices, ordinary purchase invoices and purchase credit invoices. Use amounts excluding VAT. Do not net sales against purchases, and do not combine ordinary invoices with credit invoices for the threshold test.

Suppose an Estonian VAT-registered business issues two ordinary invoices to the same customer in one month, for EUR 400 and EUR 650 excluding VAT. The ordinary sales total is EUR 1,050, so both invoices belong in Part A. If that business also receives EUR 700 of qualifying invoices from the customer, the purchase total remains below the mandatory threshold and does not enter Part B solely because the sales test was met. RIK's KMD INF threshold explanation likewise confirms that the limit is based on VAT-exclusive totals per buyer or supplier and that all relevant invoices are included when several invoices together cross it.

Ordinary invoices and credit invoices have separate EUR 1,000 tests. If the ordinary-invoice total reaches the limit, all invoices in that direction for the partner and period are reported, including credit invoices. The same result follows if the credit-invoice total itself reaches EUR 1,000: report the full set for that direction, not only the credit documents that triggered the test.

Each invoice counts toward the limit once, in the first taxation period in which it is required to appear in Part A or Part B. Members of a VAT group calculate the limit separately rather than pooling invoices across the group. Reporting below EUR 1,000 is permitted voluntarily, but that option does not lower the statutory threshold or combine the separate sales and purchase tests.

Included transaction partners and genuine exclusions

The standard population covers qualifying invoices issued to and received from legal persons, self-employed persons, and state or local-government authorities. The invoice must also contain a component taxed at a rate recognized by the current form and satisfy the relevant threshold test unless it is being reported voluntarily.

Registration matters more than geography. For a non-resident transaction partner, use the register code assigned in Estonia's register of taxable persons. If no Estonian register code has been assigned, the invoice data is not declared in KMD INF. A foreign legal entity with such a code can therefore be in scope even though calling the annex “domestic invoice reporting” might suggest otherwise.

The principal exclusions are specific:

• an invoice issued to a natural person, unless that person is self-employed;
• an invoice containing no supply taxed at 24%, 13% or 9%, or at one of the limited transitional rates recognized by the form;
• an invoice issued solely under the VAT special procedure for travel services;
• a sales invoice for a transaction protected by professional secrecy; and
• for Part B, an invoice whose stated VAT is not deductible as input VAT.

Professional-secrecy treatment is asymmetric: the issuer omits the protected sales transaction, while the recipient may report the invoice data where the form's conditions are met.

Mixed invoices need a second look. If an invoice contains a qualifying taxable-rate component alongside zero-rated supply, exempt supply, contractual penalties or other amounts not treated as supply, the total invoice amount excluding VAT is used in the threshold calculation. An invoice made up only of zero-rated, exempt or non-supply items has no qualifying-rate component and does not count. The same distinction prevents a mixed invoice from being excluded merely because one line would be outside KMD INF on its own.

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Part A versus Part B: fields to report

Both parts identify the transaction partner and invoice, but their amount fields reconcile to different sides of KMD.

Form area	Part A: invoices issued	Part B: invoices received
Reporting trigger	Supply is declared in the relevant KMD output fields	Input VAT is deducted in KMD field 5
Invoice total	Total excluding VAT	Total including VAT
VAT detail	Applicable tax rate	VAT amount stated on the invoice, completed by cash-accounting users
Period amount	Taxable value for cash-accounting users and taxable supply reported in KMD for the period	Input VAT amount reported in KMD field 5 for the period; the form permits the full stated VAT amount in specified partial-deduction cases
Special code column	Codes 01, 02 and 03	Codes 11 and 12

The shared columns are the line sequence number, the partner's Estonian register code or relevant personal ID code, partner name, invoice number and invoice date. The date is entered in day.month.year format. These identifiers should come from the invoice and the applicable Estonian register record, not from a loosely matched supplier or customer name in a ledger.

Part A follows the period in which the supply represented by the issued invoice is declared in KMD. Part B follows the period in which the right to deduct the received invoice's input VAT is exercised in KMD field 5. If the supply or deduction is recognized across several periods, the same invoice data may appear again with the amount attributable to each relevant period. This does not mean counting the invoice again when testing the EUR 1,000 threshold.

KMD INF is completed invoice by invoice. A Part A invoice can require up to four rows when it includes different tax-rate or special-procedure categories. Every column must be completed on each of those rows. Keep the full invoice total distinct from the taxable supply or input VAT recognized in the current KMD period; substituting one for the other breaks the reconciliation between the annex and the return.

Tax rates, special codes, credit notes and cash accounting

The July 2025 form uses Estonia's current 24%, 13% and 9% VAT rates. It also retains 22%, 20% and 5% for transactions that qualify under transitional provisions, with the exceptional 5% treatment available only through 31 December 2026. Those older rates are not alternatives a preparer can choose for a current supply; they belong only where the underlying transaction and transition rule support them.

Part A has three special codes:

• 01 identifies supply taxed under the special procedures in sections 41 and 42 of the Value-Added Tax Act.
• 02 identifies the section 41¹ procedure under which the acquirer, rather than the transferor, accounts for the VAT shown on the invoice as VAT payable.
• 03 applies when an invoice also contains zero-rated, exempt or non-supply amounts, or when it contains two or more tax rates or negative supply.

Enter every applicable code if one invoice meets more than one condition. The rate and special-procedure combinations can require separate Part A rows, which is why the form allows up to four lines for one invoice.

Part B uses 11 when input VAT is only partly deductible and 12 for an acquisition under the section 41¹ procedure where the acquirer accounts for VAT. Both codes can be entered when both conditions apply. The Part B amount fields still need to distinguish VAT stated on the invoice from the input VAT actually presented in KMD field 5.

Credit notes and other qualifying reductions are entered with a minus sign. Under cash accounting, timing follows the taxable supply or the right to deduct rather than the invoice date alone. A partly settled invoice can therefore appear in more than one taxation period: Part A reports the taxable value and supply attributable to the period, while Part B reports the input VAT deduction attributable to that period. EMTA's VAT return and KMD INF filing guidance provides the detailed statutory treatment and correction instructions.

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KMD INF, KMD, VD and e-invoicing are different obligations

KMD is the VAT return on which taxable supply, VAT payable and deductible input VAT are reported. KMD INF accompanies it with qualifying invoice-level data. VD serves a different tax-reporting purpose: it covers intra-Community supplies rather than the invoice population governed by KMD INF. E-invoicing concerns the exchange and processing of invoice data between parties, not whether a transaction belongs in this VAT return annex.

The distinction matters when comparing Estonia with neighbouring reporting regimes. Lithuania's i.SAF invoice-register requirements concern a broader invoice-register submission, while Hungary's Online Szamla real-time reporting rules follow a real-time model. Neither cadence or data model should be projected onto Estonia's monthly KMD INF.

A defensible month-end process follows the form's decision order:

1. Close the period's issued-invoice and received-invoice ledgers.
2. Validate each transaction partner's Estonian register code and separate sales from purchases.
3. Remove excluded invoices, then apply the ordinary-invoice and credit-invoice threshold tests per partner.
4. Map qualifying sales to Part A and qualifying purchases to Part B, reconciling period amounts to the corresponding KMD fields.
5. Check invoice dates, rates, special codes, negative signs and cash-accounting treatment.
6. File KMD and KMD INF by the twentieth day of the following month, including the relevant no-invoices declaration when a part has no reportable invoices.

EMTA has published technical information for data-based KMD reporting from 1 April 2027. That technical transition does not by itself establish a change to the EUR 1,000 KMD INF threshold. Preparers should apply the law and form in force for the taxation period and verify future threshold claims against a current primary source.