EU E-Invoicing: Country Compliance Standards & Mandates

Country

Mandate

Austria

• The Austrian Federal Ministry of Finance oversees the implementation of the national e-invoicing mandate.
• The mandate is being rolled out in phases, starting with Central, Regional, and local authorities and gradually expanding to Economic Operators.
• Austria implements the European standard (UBL, CII) and the national XML standard (ebInterface).
• E-invoices must comply with PEPPOL version 2.2 and be compatible with platforms connected to the Federal Service Portal (USP) services.
• The e-Rechnung.gv.at portal is the central platform for e-invoicing transmission.

Belgium

• The Federal Public Service Policy and Support (BOSA), in collaboration with the federal, regional, and private sectors, is responsible for overseeing the implementation of the national e-invoicing mandate.
• The mandate is being rolled out in phases, starting with Central, regional, and local contracting authorities (receiving) and gradually expanding to Economic operators and suppliers of Flanders and Brussels provincial governments (submitting).
• Belgium implements the European E-Invoicing standard, utilising the PEPPOL model and eDelivery Network, operating the Mercurius eProcurement platform.
• E-invoices must comply with PEPPOL version 2.2 and be compatible with platforms connected to the eDelivery Network.

Germany

• The German government approved and announced a draft act for a nationwide B2B e-invoicing mandate in September 2023.
• This mandate will require all businesses in Germany to submit B2B invoices electronically using the PEPPOL version 2.2 standard beginning in 2025.
• The mandate will be implemented in two phases, with the first phase starting in January 2025 and the second phase commencing in January 2026.
  • Phase 1: Voluntary e-invoicing (January 2025–December 2025) This phase allows businesses to use e-invoicing voluntarily. However, businesses can still submit paper invoices during this phase. This voluntary phase serves as a transition period to allow businesses to familiarise themselves with the e-invoicing requirements and implement the necessary systems and processes.
  • Phase 2: Mandatory e-invoicing (January 2026 — onwards) Starting in January 2026, all businesses will be required to use e-invoicing for B2B transactions. All invoices submitted between businesses must be electronic, and there will no longer be an option to revert to paper invoices. ZUGFeRD, a simplified version of PEPPOL BIS 2.2 specifically designed for the German market, will also be accepted for B2B e-invoicing during this phase.

Finland

• Finland has had a mandatory B2B e-invoicing mandate using the PEPPOL version 2.2 standard since April 2020.
• The State Treasury is responsible for overseeing the mandate’s implementation, which applies to central, regional, and local authorities and economic operators.
• The mandate implements the UBL 2.1, CII, TEAPPSXML 3.0, and Finvoice 3.0 standards for e-invoices.
• The myDATA system facilitates the adoption of e-invoicing and supports both voluntary and mandatory compliance.
• Businesses can require e-invoices regardless of supplier turnover.

France

• France will implement mandatory B2B e-invoicing and e-reporting using the PEPPOL standard for e-invoices, submitting e-reporting data to the French tax authorities, and connecting to the Chorus Pro SII electronic invoicing system through APIs.
• The rollout will be in phases:
  • Phase 1 for medium-sized companies using the PEPPOL version 2.2 standard (January 2025)
  • Phase 2 for all companies using the PEPPOL version 2.2 standard (January 2026) and full rollout by September 2026.

Greece

• Greece has implemented B2G e-invoicing starting in September 2023, using the Artemis system for B2G e-invoicing and the PEPPOL specification for B2B e-invoicing.
• B2B e-invoicing will be based on the MyDATA digital reporting system and will use PEPPOL version 2.2. Full implementation of B2B e-invoicing is expected by January 2025.

Italy

• Italy has adopted mandatory e-invoicing since 2019, utilising the SdI (Sistema di Interscambio) electronic invoicing system and connecting businesses to the platform through the X-Road secure data exchange infrastructure.
• The SdI system uses PEPPOL version 2.2 for e-invoices.
• Micro businesses will join the SdI system in January 2024, and they can receive their e-invoices via PEC (Posta Elettronica Certificata).

Croatia

• Croatia plans to complete its Fiscalisation Project 2.0 by the end of 2024, enabling the introduction of mandatory B2B e-invoicing in 2025.
• Businesses will exchange electronic invoices using the PEPPOL standardised format and the Adria e-Invoice Gateway, a central e-invoicing platform overseen by the Ministry of Finance.
• The Adriatic e-Invoice Gateway will utilise PEPPOL version 2.2 for e-invoices.
• Mandatory B2B e-invoicing is expected to be implemented by 2025.

Latvia

• Latvia plans to implement mandatory B2B e-invoicing based on the PEPPOL standard in January 2025, leveraging the EIS (Elektronisko dokumentu apmaiņas sistēma) central platform overseen by the VID (Valsts ieņēmumu dienests).
• Businesses will exchange electronic invoices using the PEPPOL format through the EIS platform and adhere to PEPPOL version 2.2 for e-invoices.
• To register for the e-invoicing system and access related resources, businesses can visit the e-Factura Portal.

Lithuania

• Lithuania’s government is actively considering implementing an e-invoicing platform, utilising the eSaskaita central platform overseen by the Ministry of Finance.
• The eSaskaita platform is expected to utilise PEPPOL version 2.2 for e-invoices.
• The government plans to implement the e-invoicing platform in phases, starting with medium-sized businesses and gradually expanding to all companies.

Montenegro

• Montenegro is actively considering implementing a mandatory e-invoicing system for B2B transactions.
• The government is evaluating the use of a centralised e-invoicing platform overseen by the Tax Administration Agency. The e-invoicing platform is expected to utilise PEPPOL version 2.2 for e-invoices.
• The government plans to implement the e-invoicing platform in phases, starting with medium-sized businesses and gradually expanding to all companies.

Poland

• Poland will introduce mandatory B2B e-invoicing beginning January 1, 2025, providing businesses with a transition period to prepare for the new requirements.
• Businesses will exchange electronic invoices using the Krajowy System e-Faktur (KSeF) format through the KSeF e-invoicing portal.
• The KSeF platform will utilise PEPPOL version 2.2 for e-invoices.

Portugal

• Portugal has mandated mandatory certified e-invoicing software for non-resident businesses that deal with Portuguese customers, effective January 1, 2024.
• Businesses must utilise PEPPOL-compliant e-invoicing software that adheres to stringent Portuguese government specifications, ensuring data security, authenticity, and traceability.
• Non-resident businesses are obligated to implement the QR code (ATCUD) for invoice authentication, as well as connect to the Sistema de faturação eletrónica (SFE) for electronic invoice exchange.
• Failure to comply with the mandatory e-invoicing requirements may result in penalties imposed by the Portuguese Revenue Agency (Autoridade Tributária e Aduaneira).
• Businesses can seek guidelines and assistance from the Agência para a Modernização Administrativa (AMA) and register for the SFE through the Portal de Factura Eletrónica during the transition period provided.

Spain

• Spain is planning to introduce a Real Decreto-ley (RD-ley) draft for mandatory B2B e-invoicing based on the PEPPOL standard (version 2.2).
• The mandate is proposed to be enforced starting in 2024 through the Sistema de Facturación Electrónica en Red (FACe) platform managed by the AEAT (Agencia Estatal de Administración Tributaria).
• A phased rollout plan will be implemented, starting with large enterprises and gradually expanding to SMEs and micro-enterprises. Businesses must adhere to specific technical and data requirements to ensure their e-invoices comply with the Spanish e-invoicing mandate.

• No mandatory e-invoicing mandate at present