The EY report on ViDA: what it says, what it omits, and what it means

A report with a conclusion — and a story around it

On 10 March 2026, the Dutch Ministry of Finance published a research report on the introduction of e-invoicing and digital reporting in the Netherlands, conducted by EY Tax Advisors. The report, delivered to the client on 23 January 2026, was triggered by the European ViDA directive (VAT in the Digital Age), which from 1 July 2030 will require all EU member states to report cross-border B2B transactions digitally. The report’s core conclusion is clear: the Netherlands should opt for the broader variant — ViDA-B — making e-invoicing mandatory for domestic B2B transactions as well, using Peppol as the prescribed infrastructure, phased in between 2030 and 2032.

That is an important recommendation, substantiated carefully. But anyone who reads the report closely will find several passages that raise more questions than they answer. This article surfaces those passages — not to undermine the report, but because the policy debate that must precede its conclusions is better served by precision.

The Netherlands is behind — and that has consequences for the entire chain

While Belgium has been fully operational with mandatory B2B e-invoicing via Peppol since January 2026, and France, Germany and Poland are rapidly preparing their systems, the Netherlands at the time of this report’s publication is still in the process of forming a position. Not implementing — forming a position. That is a meaningful distinction.

That delay is not purely an administrative problem. It puts pressure on every link in the chain simultaneously. Policymakers must translate legislation into appropriate policy instruments in time — and that requires decision-making that should already be underway. Software vendors and Peppol Service Providers must adapt, certify and scale their products and services — and they need implementation time that begins only once the policy framework is clear. And at the end of the chain stand businesses, government organisations and institutions, all of which must adapt their processes, staff and planning to a new reality.

The deadline of 1 July 2030 looks comfortable on paper. But anyone who traces the chain from back to front — from business to software vendor to policymaker — will see that every month of delay at the beginning multiplies at the end. This report is an important step. But it is a late one.

1. The Netherlands doesn’t really have a free choice

The central question in the report — ViDA-A or ViDA-B — implies that the Netherlands still has an open decision to make. But the report itself reveals something that relativises that framing: every country studied that has introduced or is about to introduce e-invoicing has opted for a domestic mandate. Belgium went live in January 2026. France follows in September 2026. Germany, Italy, Poland — all equivalent to ViDA-B.

The report calls this the waterbed effect: if the Netherlands is the only major EU economy not to introduce a domestic mandate, it becomes more attractive for VAT carousel fraud. Fraudsters migrate to the jurisdiction with the least oversight. In other words, the freedom of choice the research framework implies is more limited in practice than it appears. ViDA-B is the logical outcome — the question is only how and when.

What stands out in the report’s international comparison is which countries are absent. The Scandinavian countries — Norway, Sweden, Denmark and Finland — are referenced only briefly, through a cost savings study by a software vendor. Yet these countries have some of the most mature e-invoicing ecosystems in the world, with decades of experience building interoperable standards, broad adoption and public-private collaboration. Their lessons for the Netherlands go unexamined. The same applies to Latin America: Chile, Brazil, Mexico and others have had mandatory e-invoicing for decades as a VAT enforcement instrument. The report cites their tax revenue gains, but does not analyse what made those systems architecturally successful — and what the Netherlands could learn from them.

2. Almost no one in SMEs knows what ViDA is — and the clock is ticking

One of the most soberly worded findings in the report is also one of the most alarming: awareness of ViDA among small business owners is ‘very low’. Those are EY’s own words. At the same time, the report recommends starting the domestic e-invoicing mandate before 1 January 2030, precisely to prevent businesses from facing a big bang on the European deadline.

Anyone familiar with ERP implementation timelines, supplier selection and internal process adaptation knows that 2030 is closer than it sounds. For large companies, a two to three year horizon is workable. For SMEs — with limited IT budgets and often no dedicated finance team — a migration trajectory of 12 to 24 months is realistic. That means preparation should be starting now. Not after the public consultation. Not after legislation. Now.

Here it is worth drawing a distinction the report does not make. The impact of e-invoicing does not differ primarily according to the size of a business or organisation, but according to the accessibility, flexibility and affordability of the permitted solutions. A freelancer who can send invoices via a simple accounting app or web portal faces a fundamentally different barrier than one whose app is not yet connected to Peppol — and who therefore has to wait for their software vendor to catch up, or switch to a different solution. The policy choice of which solutions are permitted — and how accessible the entry point is for small businesses — is therefore at least as decisive for the transition’s success as the implementation timeline itself.

3. ICV reporting is unworkable — but that is no surprise

One of the less well-known but practically significant components of the ViDA directive is the ICV reporting obligation: the requirement to report invoices received from other EU countries to the Tax Authority within five days. The report is notably direct on this point: implementation in 2030 is not advisable. Invoices are rarely approved within five days in practice, let alone processed. The result would be a flood of ‘false positives’ — reports that later need to be corrected — creating administrative burden for both businesses and the Tax Authority.

That the Tax Authority itself acknowledges this is presented in the report as a relevant observation. But there is a more honest way to frame it: the five-day deadline is not unworkable because it was poorly designed. It is unworkable because the Netherlands never created the infrastructural conditions for it. In countries where e-invoicing has been broadly adopted for years — Belgium, the Scandinavian countries, various Southern European countries — a five-day reporting deadline is a realistic standard, because invoice data already flows through systems in a structured and machine-readable way. In the Netherlands, that is not the case. And that is not a coincidence. It is the result of years of inaction on the e-invoicing file.

Other countries moved quickly to drive broad e-invoicing adoption, partly because they understood that European digital reporting obligations were coming. The Netherlands did not take that step. The finding by EY and the Tax Authority that the ICV deadline is unworkable is therefore less an observation about the directive than a quiet acknowledgement of policy failure. The report does not make that conclusion explicit — understandable in the context of an advisory report to the commissioning ministry. But anyone reading it is entitled to say so.

EY recommends as an alternative shortening the VAT filing period from quarterly to monthly. That is a pragmatic way out. But it does not resolve the underlying problem: as long as e-invoicing in the Netherlands has not reached a mature level of adoption, any form of real-time or near-real-time reporting will remain a theoretical obligation with a practical exemption.

4. There is an option the Netherlands is deliberately not taking — and few know it exists

Article 168 of the VAT Directive gives member states the option to link VAT deduction to receipt of a correct e-invoice. In practice, that would mean: no valid e-invoice received, no VAT deduction. A hard compliance incentive, but also a potentially far-reaching measure for businesses encountering technical failures or format errors during the transition period.

The report explicitly recommends against implementing this option. Industry is opposed, and EY endorses that concern. But the fact that this option exists at all — and that a deliberate policy choice is needed not to use it — is unknown territory for most businesses. It illustrates how multifaceted the ViDA implementation space is, and how important it is that businesses understand not just the final outcome, but also the choices being made in the policy process.

5. The main recommendation comes with a legal caveat — and a governance blind spot

The recommendation to mandate Peppol as the digital infrastructure for e-invoicing and reporting enjoys broad support — from software vendors, government bodies and business organisations alike. That support is genuine and the arguments are clear: Peppol is interoperable, scalable, internationally widely adopted, and connects to existing B2G infrastructure in the Netherlands.

But the report also contains a passage that has received little attention in public debate. EY notes that Peppol, as a non-qualified trust service, may not meet the eIDAS requirements that apply if it is designated as mandatory infrastructure. And that NIS2 cybersecurity requirements — not yet even implemented in the Netherlands via the Cybersecurity Act — will bring additional obligations. EY therefore recommends ‘further legal research’. The recommendation to mandate Peppol is already there, but its legal soundness still needs to be established.

This raises a deeper question the report does not sufficiently address: is it wise at all to enshrine the name of a specific network in legislation? As early as 2019, Hooghiemstra & Partners — commissioned by the Ministry of the Interior (BZK) — advised explicitly that the government should move towards a role in which it actively delivers or facilitates the trust structure of the e-invoicing infrastructure, rather than leaving that question to the market. The report introduced the ‘Stuurman’ (Helmsman) model for this: a government that acts proactively and as executor, delivering the trust structure itself. The opposite — a government as ‘Reder’ (Shipowner) that merely sets conditions and only intervenes when the public interest demands it — was explicitly assessed in that advice as insufficient for a system of public interest. The EY report does not reference this advice, and thereby poses the same question seven years later that was already asked — and answered — in 2019.

The parallel with eHerkenning is instructive: that system was not placed in legislation by brand name either, but as a framework of agreements that must meet statutory requirements and on which the RDI exercises oversight. That same approach — the government as active deliverer of trust structure, with admission based on objective criteria and statutorily grounded oversight — gives the government steering capacity that directly mandating the Peppol brand name does not, and keeps legislation future-proof.

The report itself acknowledges that OpenPeppol is a private legal entity based in Belgium, with its own interests that do not automatically align with Dutch policy objectives. And that when Peppol is designated as mandatory infrastructure, its private governance ‘effectively becomes part of a publicly mandated system’ — requiring further legal analysis that has not yet been done. What is also missing is any analysis of how the Dutch government can secure governance influence within OpenPeppol: who sits at the table, which countries have voting rights, and does the Netherlands have comparable positions to those it holds in other international financial and technical organisations? The report does not ask the question.

Finally, the report states that the RDI ‘already has practical experience with oversight’ of Peppol. But formal supervisory authority in the sense of administrative law — the power to verify compliance with statutory requirements — requires a statutory designation. That designation does not currently exist. The report’s framing creates an impression of formal supervisory authority that is not yet in place. This too is a gap that must be addressed before Peppol can be designated as mandatory infrastructure.

6. The Tax Authority will soon have real-time insight — but the legal framework is lagging

The essence of ViDA-B is not just that businesses invoice electronically, but that invoice data is reported to the Tax Authority in near real-time. That is a fundamental shift: where the Tax Authority currently receives periodic returns and audits retrospectively, it will soon have transaction-by-transaction insight into the accounts of businesses.

The report acknowledges the opportunities — less VAT fraud, a partly pre-filled VAT return, more efficient oversight. But it also addresses the risks: prematurely classifying errors as fraud, incorrect fiscal conclusions based on incomplete data, and questions about which analytical methods the Tax Authority may use. What is missing is an answer. The legal frameworks governing how the Tax Authority may use that data have not yet been established. The GDPR assessment has not been completed. The Data Protection Authority has not yet been formally involved. The report rightly recommends this — but the urgency of that step is not always felt in the follow-up process.

7. A note on representativeness — a small one and a large one

An observation that is not a criticism of the report’s quality, but is relevant for the policy formation that follows from it. The interview list contains twenty parties: seven government bodies, nine technology companies — including SAP, Microsoft, IBM and a number of specialist e-invoicing vendors — and two industry associations. In addition, three anonymous SME businesses were consulted.

Those are the only individual businesses represented, in a population of over 2.5 million registered companies in the Netherlands. Industry associations like VNO-NCW and the Platform for Independent Entrepreneurs represent their members at an abstract level, but are not businesses themselves. The technology parties have a legitimate perspective, but also a commercial interest in the outcome: they sell precisely the services businesses will need under a mandate.

That does not make the conclusions wrong. But it underscores why the public consultation recommended by EY itself is so important — and why that consultation needs to be broad and accessible. The experience of the installer, the bookkeeper and the freelancer is different information from the strategy of an ERP vendor.

Then the larger observation. The report was commissioned by the Ministry of Finance, and that is visible in its scope. E-invoicing is treated as a fiscal question: VAT enforcement, digital reporting to the Tax Authority, fraud prevention. That perspective is legitimate and forms the core of the ViDA directive. But e-invoicing is simultaneously an infrastructure question — and for that, a different ministry bears policy responsibility.

The Ministry of the Interior and Kingdom Relations (BZK) is, within the framework of the Generic Digital Infrastructure (GDI) and the Digital Government Act, the ministry responsible for e-invoicing as part of the government’s digital infrastructure. BZK is the principal of Logius — the implementation organisation that manages the Peppol network for central government. BZK is the principal of the national digital infrastructure inspectorate (RDI) — the supervisory body repeatedly cited in the report as the authority overseeing Peppol. And BZK is the body that established the Dutch Peppol Authority (NPa).

BZK does appear in the steering committee — this emerges from a single subordinate clause in the research methodology section. It is the only time the ministry is mentioned by name in the entire report. In the main text, the analysis, the recommendations and the conclusions: no mention. Yet three of the five government bodies on the interview list — Logius, RDI and the NPa — fall directly under BZK’s policy responsibility. The implementation organisations were consulted; the policy principal of those implementation organisations was not.

The questions this raises are fundamental: how does the fiscal policy of Finance relate to the infrastructure policy of BZK? Who bears ultimate responsibility for the choices recommended in this report? And how will the governance structures of the NPa, Logius and RDI be embedded in a statutory framework drafted by Finance, while the implementation rests with BZK bodies? The report provides no answer. The question is whether it was ever asked.

8. The real opportunities of e-invoicing are being underestimated

The report presents cost savings as the primary benefit of e-invoicing. International studies are cited: 55 to 70 percent savings per invoice compared to paper-based processes, a Scandinavian business case of 19 billion euros per year, a Dutch potential of 10 to 12 billion euros with full adoption. These are impressive figures. But they deserve two caveats the report does not make.

The first: cost savings only materialise once e-invoicing is the only permitted method and the entire chain participates. As long as paper invoices, PDF emails and portal solutions continue alongside e-invoicing, it is an additional cost for most businesses — not a replacement. And even after a full mandate, savings are only realisable if every element is structurally in place: identification and authentication, digital signing, timestamps, secure connections, standardised messages, authorisation management and Know Your Business processes. That is a systemic change, not a software update.

The second caveat is more fundamental: cost savings are probably not the most interesting benefit of e-invoicing. Implementing the European invoice standard EN 16931 enables the exchange of structured financial data — data that is machine-readable and analysable for both parties in a transaction. That opens the door to a new generation of fintech applications. Consider factoring that no longer depends on manual assessment, but on continuous insight into the financial cycle of a business. Consider supply chain finance where a supplier’s reliability can be inferred from their invoicing history. Consider automated credit assessments based on real transaction data rather than annual accounts. These are not speculative scenarios — in countries with mature e-invoicing infrastructure, these business models already exist. The report does not mention them. That is a missed opportunity in a study that is meant to help the Dutch government make a strategic decision.

What now?

The EY report provides a solid basis for policy decisions. The conclusion that the Netherlands should opt for ViDA-B — broad implementation, Peppol as infrastructure, phased timeline — is well-founded and aligned with what other EU countries are doing. The urgency is real.

But the report also reveals how much still needs to be worked out: the legal basis for Peppol as mandatory infrastructure, the GDPR assessment of data fields, the legal position of businesses when data is analysed by the Tax Authority, and the concrete design of exemptions for small businesses and specific sectors. That work requires time, broad consultation — and a deliberate choice to include the voice of individual businesses.

The pressure on the chain is real. Policymakers who decide now give software vendors the space to build. Software vendors who build in time give businesses the space to implement. And businesses that implement on time will not find themselves under pressure at the 2030 deadline. That chain only works if the first link — policy — starts moving. That is the real urgency behind this report.

Sources

• EY Tax Advisors, ‘ViDA e-invoicing and digital reporting’, commissioned by the Dutch Ministry of Finance, delivered 23 January 2026, published 10 March 2026.

• Hooghiemstra & Partners, ‘Advies publiek belang SI — Definitieve rapportage versie 1.0’ [Advisory report on public interest in SI], commissioned by the Dutch Ministry of the Interior and Kingdom Relations (BZK), 16 September 2019.

At Peppol.now, we follow ViDA policy developments closely. Want to know which reliable Peppol Service Providers are available for your organisation? Browse the overview at Peppol.now.

Belgian E-invoicing obligation: What does this mean for international business partners?

Over recent months, we at Peppol.now have been receiving the same question more and more frequently: “What does the Belgian e-invoicing obligation mean for our business?” What’s striking is that this question doesn’t only come from Belgian entrepreneurs themselves, but increasingly — and in growing numbers — from companies in the Netherlands, the United Kingdom, and other countries that do business with Belgian partners.

A Dutch IT supplier delivering software to Belgian companies, a British consultant advising a Belgian group, a German logistics company regularly delivering goods in Belgium — they all face the same question: does the Belgian e-invoicing obligation apply to us too? And if so, what do we need to do?

The Facts at a Glance

From 1 January 2026, Belgium introduces a mandatory structured electronic invoicing requirement for all business-to-business (B2B) transactions between VAT-liable companies. This obligation applies to all Belgian VAT-liable businesses conducting B2B transactions, regardless of their sector or size.

But what does this mean exactly for foreign businesses? This is where it gets interesting, because the legislation makes a clear distinction between different situations.

Scenario 1: The Dutch Supplier Without a Fixed Establishment

Suppose: TechSolutions BV from Amsterdam delivers software to Belgica Industries NV in Brussels. TechSolutions has no fixed establishment in Belgium, but does have a Belgian VAT number for these supplies.

The reality: Foreign businesses that are not established in Belgium are not required to issue structured electronic invoices, even when they are identified in Belgium for VAT purposes. TechSolutions BV therefore does not need to send an e-invoice under Belgian rules.

However: Belgica Industries NV is, from 2026, obliged to receive e-invoices from all its Belgian suppliers. This means it must maintain two different invoicing channels: traditional invoices from foreign suppliers like TechSolutions, and e-invoices from Belgian suppliers.

Scenario 2: The German Company With a Fixed Establishment

LogistikPartner GmbH from Cologne has a branch in Antwerp with its own staff and warehouse facilities. From this Belgian establishment, they provide transport services to Belgian businesses.

The reality: Foreign businesses that have a fixed establishment in Belgium are treated the same as a VAT-liable business established in Belgium and must therefore issue structured electronic invoices. LogistikPartner GmbH is therefore obliged to send e-invoices via the Peppol network.

This is a crucial distinction: it is not the nationality of the company that is decisive, but whether there is a fixed establishment in Belgium.

Scenario 3: The British Consultant Post-Brexit

Advisory Services Ltd from London provides consultancy services to Belgian companies. Since Brexit, the UK is no longer an EU member state, but the company does have a Belgian VAT number for certain assignments.

The reality: The same applies here: no fixed establishment in Belgium means no e-invoicing obligation. Advisory Services Ltd can simply continue invoicing as it always has.

The practical consequence: Their Belgian clients must again maintain two separate invoicing channels.

The Double Administration Problem

This is precisely the core of the problem Belgian companies face. From 1 January 2026, all Belgian VAT-liable businesses must use structured electronic invoices among themselves, but their foreign suppliers (without a fixed establishment) continue to invoice traditionally.

The result? Belgian companies must maintain two parallel systems:

• E-invoices via Peppol for Belgian suppliers
• Traditional invoices (PDF, paper) for foreign suppliers

This means double the work, double the costs, and an increased risk of errors in the administration.

When Does the Obligation Apply?

The obligation for structured electronic invoicing will almost always apply to transactions between a Belgian VAT-liable supplier and a Belgian VAT-liable customer.

For foreign businesses, the obligation applies when:

• They have a fixed establishment in Belgium (own staff, office, warehouse)
• They have a Belgian VAT number and a fixed establishment

Exceptions to the obligation:

• VAT-liable businesses not established in Belgium without a fixed establishment
• Transactions exempt under Article 44 of the VAT Code
• B2C transactions (invoices to private customers)
• Certain flat-rate VAT taxpayers

What Is a Fixed Establishment?

A foreign company will in principle have a fixed establishment in Belgium when it has a place where management tasks are carried out, a branch, factory, workshop, agency, warehouse, office or laboratory. Key criteria are:

• Sufficient permanence of presence
• Appropriate structure in terms of human and technical resources
• Regular supply of goods or services from this establishment

A temporary project or incidental presence does not generally constitute a fixed establishment.

The Peppol Network: The Technical Solution

Structured electronic invoices are sent via a decentralised network called Peppol. Peppol is a standardised network that facilitates secure and efficient exchange of electronic documents between businesses.

For companies that are required to send e-invoices, connecting to the Peppol network via a certified service provider is necessary.

Practical Advice for Belgian Businesses

As a Belgian company, you can avoid the double administration problem by proactively communicating with your international suppliers. Even if they are not required to send e-invoices, it is in everyone’s interest to do so.

The benefits of uniform e-invoicing:

• One invoicing channel instead of two
• Automatic processing of all invoices
• Faster payments through streamlined processes
• Fewer errors through standardised formats
• Better cash flow management

Communicating With International Partners

Explain the following to your foreign suppliers:

“From 2026, as a Belgian company we are required to receive e-invoices from our Belgian suppliers. Although you as a foreign supplier are not obliged to send e-invoices, it would greatly help our collaboration if you were to do so. This prevents us from having to maintain two different invoice processing systems and ensures faster handling of your invoices.”

Immediately offer a path forward: Refer your suppliers directly to practical help. By mentioning websites such as Peppol.now, you not only make a request but also immediately offer a solution. This lowers the threshold and shows that you are thinking along with the practical implementation. Your supplier can find information there about suitable Peppol providers and the steps required for connection.

International Developments

It is important to realise that Belgium is not the only country making e-invoicing mandatory. From 2030, this obligation will also apply to invoicing between EU member states. Companies that invest in Peppol connectivity now are ahead of this European development.

Ensure Clear Communication

For Belgian businesses, our advice is: engage proactively with your international suppliers. Explain why it is beneficial for both parties to switch to e-invoicing, even if they are not required to do so.

For foreign suppliers of Belgian businesses: Seriously consider connecting to the Peppol network. This prevents administrative burden for your Belgian clients and positions you well for the further European digitalisation of invoicing.

Do you have questions about Peppol connection or want to know which service provider best suits your situation?

Visit Peppol.now for more information and check our overview of Peppol providers to find the provider that best meets your needs.

By taking action now, you ensure that your international trade relationships continue to run smoothly after 1 January 2026 — without double administration and with maximum efficiency.

Would you like to stay informed about the latest developments in e-invoicing across Europe? Follow Peppol.now for up-to-date information and practical tips for your business.

Bronnen

• FOD Financiën – Voor wie wordt e-facturatie verplicht?
• BOSA – Elektronische facturatie
• SBB België – Vaste inrichting in België
• Belgisch btw-wetboek – ejustice.just.fgov.be
• Europese richtlijn EN-16931 – Europese Commissie
• CEN-CENELEC – Europese standaardisatieorganisatie

Denmark scraps OIOUBL 3.0 and chooses Peppol as its sole e-invoicing standard

On January 14, 2026, the Erhvervsstyrelsen (the Danish Business Authority) confirmed a decision that ends years of uncertainty for the Danish e-invoicing landscape: OIOUBL 3.0 has been definitively cancelled. The planned successor to the national e-invoicing format will not be released. Instead, Denmark is charting a fundamentally different course: the country is moving toward a single document standard, aligned with the international Peppol ecosystem. For businesses trading with Danish partners, service providers operating in the Scandinavian market, and organisations shaping their European e-invoicing strategy, this is a decision with immediate consequences.

Denmark’s choice to make Peppol its core e-invoicing standard is not a sudden pivot. It is the result of a consultation process that began in March 2025 with the postponement of OIOUBL 3.0, followed by stakeholder meetings through the NemHandelsforum in June and October 2025. Service providers consistently delivered the same message: maintaining two parallel standards — OIOUBL and Peppol BIS 3.0 — leads to disproportionate implementation costs and technical complexity. The Danish government has now translated that feedback into policy.

The facts at a glance

Denmark has operated a national e-invoicing system since 2005, making it one of the world’s earliest adopters of mandatory B2G e-invoicing. The NemHandel platform — the national infrastructure for secure document exchange — supports over 100 certified solutions and more than 30 service providers. In 2017, NemHandel was connected to the international Peppol network, enabling Danish businesses to exchange electronic documents across borders.

Until January 2026, Denmark operated with two parallel e-invoicing standards. On one hand, OIOUBL (Offentlig Information Online Universal Business Language), the national format based on UBL 2.0 and later UBL 2.1, with specific Danish extensions for climate data and VAT reporting among others. On the other hand, Peppol BIS 3.0, the international format based on the European standard EN 16931. Both formats were accepted on the NemHandel platform and through the Peppol network.

The development of OIOUBL 3.0 was intended to bring the national format into closer alignment with the European standard EN 16931, with enhanced specifications for invoices, credit notes, and invoice response messages. The release candidate was published in November 2024, with mandatory adoption originally targeted for November 2025 — later postponed to May 2026 following the first delay in March 2025.

Now that this trajectory has been definitively abandoned, the Erhvervsstyrelsen is focusing on a unified document standard covering both national and international requirements. Industry experts anticipate this will take one of two forms: Peppol PINT (Peppol INTernational), the flexible international specification being adopted by an increasing number of countries, or a Danish CIUS (Core Invoice Usage Specification), a localised version of the standard Peppol format. Further details will be presented at the Nemhandelsforum on February 24, 2026.

What changes concretely?

The cancellation of OIOUBL 3.0 has three direct consequences.

First: OIOUBL 2.1 remains active for the time being. The existing national format is not being phased out immediately. The Erhvervsstyrelsen has even published new validation rules — schematron version 1.17, with mandatory implementation by May 15, 2026 — to safeguard data quality within the existing system. This includes stricter VAT consistency checks and mandatory currency validation on amount fields.

Second: the Digital Bookkeeping Act proceeds on schedule. Since January 1, 2026, approximately 118,000 additional businesses — including sole traders and foreign entities with a permanent establishment in Denmark — are required to use certified digital bookkeeping systems. These systems must be capable of sending and receiving structured e-invoices via NemHandel or the Peppol network. Businesses developing their own bookkeeping software have a transition period until July 1, 2026.

Third: the direction is clear, even though the exact specifications are not yet finalised. Denmark is moving away from a proprietary national format toward full alignment with internationally recognised standards. This follows a pattern visible across multiple European countries: national standards are being replaced by or integrated with the Peppol ecosystem.

Why this decision matters for international trading partners

Denmark is an open economy with strong trade relationships both within and outside the EU. Its key trading partners include Germany, Sweden, the Netherlands, the United Kingdom, and Norway. For businesses in these countries that regularly exchange invoices with Danish partners, the shift to a single Peppol-based standard has concrete implications.

For businesses already using Peppol: The transition to a single Peppol-based format in Denmark simplifies technical integration. Where service providers previously had to support two formats — with associated conversion, validation, and error handling — a single standard will suffice. This reduces both implementation costs and the risk of processing errors in cross-border transactions.

For businesses not yet using Peppol: The Danish decision strengthens the business case for Peppol connectivity. With Belgium mandating B2B e-invoicing via Peppol since January 2026, France launching in September 2026, Poland rolling out KSeF, and now Denmark consolidating its national standard toward Peppol, the network becomes increasingly difficult to ignore. An investment in Peppol connectivity covers an ever-growing number of markets.

For service providers active in Scandinavia: This is potentially the most direct impact. Parties supporting both OIOUBL and Peppol BIS 3.0 can simplify their technical stack after the transition. However, the transition period demands attention: OIOUBL 2.1 with the new schematron 1.17 validation rules must be supported by May 15, 2026, while simultaneously preparing for migration to the yet-to-be-specified new format.

The Danish approach in European perspective

Denmark is not the only country grappling with the tension between national e-invoicing standards and international interoperability. Across Europe, the same dynamic is playing out: countries that spent years developing proprietary standards are confronting the question of whether continuing on a national path remains viable in an increasingly integrated European trading landscape.

Italy preceded Denmark with the SdI system, a centralised clearance model operating independently of Peppol but where international interoperability remains a growing challenge. Belgium chose Peppol explicitly as the backbone of its 2026 B2B mandate. France is building a hybrid model with both Peppol and national Plateformes de Dématérialisation Partenaires (PDPs), having established its own Peppol Authority since July 2025. Croatia integrates Peppol-compatible infrastructure into its ambitious Fiskalizacija 2.0, combining B2B, B2G, and B2C with real-time reporting.

Denmark’s decision fits the broader European trend toward standardisation. The EU’s ViDA directive (VAT in the Digital Age), which mandates e-invoicing for intra-EU transactions from 2030, is based on the European standard EN 16931 — the same standard underpinning Peppol. Countries converging toward Peppol-based standards now are better prepared for the European harmonisation ahead.

What makes the Danish case unique is the explicit choice to abandon a national standard — with more than twenty years of history — in favour of an international framework. That is a signal that reaches well beyond Denmark alone.

Practical scenarios for international businesses

Scenario 1: The Dutch exporter to Danish retailers

A Dutch company supplying consumer products to Danish retail chains currently sends invoices via Peppol BIS 3.0 or in OIOUBL format through NemHandel. After the transition to a single Peppol-based format, this company only needs to support the Peppol format. When the same exporter also supplies Belgium (mandatory via Peppol since January 2026), a single Peppol connection now covers both markets without format conversion.

Scenario 2: The German engineering firm with a Danish subsidiary

A German company with a permanent establishment in Denmark falls under the Digital Bookkeeping Act and must use a certified digital bookkeeping system from January 1, 2026. The shift to a Peppol-based standard means this company — which may also use the German XRechnung format — can converge to a single Peppol solution covering both the German and Danish markets. With Germany itself increasingly investing in Peppol compatibility through its XRechnung CIUS, the synergy continues to grow.

Scenario 3: The Norwegian logistics provider with Scandinavian clients

For Scandinavian businesses trading across multiple Nordic markets, the Danish decision is particularly relevant. Norway has announced plans to introduce mandatory digital bookkeeping and e-invoicing toward 2030. Sweden is evaluating until December 2027 whether to adopt domestic e-invoicing or strictly adhere to intra-EU ViDA requirements. Denmark’s choice of Peppol as its sole standard could set the direction for the entire region.

Strategic advice

For businesses that regularly trade with Denmark:

Monitor the outcomes of the Nemhandelsforum on February 24, 2026, for the definitive specifications. Evaluate whether your current service provider can support both OIOUBL 2.1 (transition period) and the future Peppol format. Consider using the Danish transition as a catalyst for broader Peppol connectivity covering other European markets as well.

For service providers and software vendors:

Prepare for a dual challenge: supporting OIOUBL 2.1 with the new schematron 1.17 validation rules by May 15, 2026, while simultaneously preparing for migration to the new unified format. The transition period will require careful planning, but the end result — supporting just one standard — structurally reduces operational complexity.

For businesses that have not yet implemented e-invoicing:

The Danish decision underscores a broader European trend: Peppol is becoming the de facto standard for B2B e-invoicing in Europe. With Belgium (January 2026), France (September 2026), Poland (KSeF), and now Denmark explicitly choosing Peppol, the question is no longer whether but when Peppol connectivity becomes unavoidable for your business operations.

Simplicity as strategy

Denmark’s decision to scrap OIOUBL 3.0 is more than a technical course correction. It is a strategic acknowledgment that in an increasingly integrated European trading landscape, national standards must give way to international interoperability. A country that has been at the forefront of e-invoicing since 2005 is now deliberately choosing simplification over national specificity.

For international businesses, the message is clear: investing in Peppol connectivity means investing in a network that gains value with every new European mandate. Denmark confirms that pattern.

Sources:

• Erhvervsstyrelsen (Danish Business Authority) — Confirmation of OIOUBL 3.0 cancellation, January 14, 2026

• Thomson Reuters / Pagero — Denmark Compliance Regulatory Updates

• Comarch — Denmark Cancels OIOUBL 3 Standard

• Meridian Global Services — Denmark cancels OIOUBL 3.0

• European Commission — eInvoicing in Denmark, Digital Building Blocks

• OpenPeppol — Denmark Country Profile

• Fiscal Solutions — Denmark Pushes Back OIOUBL 3.0 Launch

Looking for a reliable e-invoicing solution ready for the Danish mandate and other European requirements? On Peppol.now you can compare service providers that support Peppol connectivity, EN 16931 compliance and multi-country e-invoicing. View the overview of Peppol service providers and make an informed choice.

Croatia’s Fiscalization 2.0: Europe’s Most Ambitious E-Invoicing Mandate

Since 1 January 2026, Croatia has operated the most comprehensive e-invoicing mandate Europe has seen to date. While Belgium limits its scope to B2B- and B2G transactions via the Peppol network and Poland builds a centralised clearance model focused on B2B, Croatia goes fundamentally further. The country mandates electronic invoicing for all transaction types – B2B, B2G and B2C – combined with real-time reporting to the tax authority. This makes Croatia e-invoicing Peppol 2026 a unique case within the European landscape.

For businesses trading with Croatian partners, this is far from abstract policy news. Croatia’s largest trading partners are Italy, Germany, Slovenia, Bosnia-Herzegovina, Hungary and Austria – countries each with their own e-invoicing trajectories. Croatia’s decision to build a fully integrated system around Peppol-compatible infrastructure, combined with fiscal control, creates both operational challenges and strategic opportunities for international trading partners.

The facts: Fiscalization 2.0 at a glance

The Croatian Parliament approved the new Fiscalization Act on 11 June 2025, replacing the existing Act on Fiscalization of Cash Sales. The law entered into force on 1 September 2025, after which a testing environment was made available. From 1 January 2026, the mandate is fully effective for all VAT-registered businesses.

Implementation follows two phases. From 1 January 2026, all VAT-registered businesses in Croatia must issue and receive electronic invoices for domestic B2B and B2G transactions. At the same time, non-VAT-registered businesses must be capable of receiving e-invoices. In the second phase, from 1 January 2027, the obligation extends to non-VAT-registered businesses, micro-enterprises and public bodies, which must then also be able to issue e-invoices.

What distinguishes Croatia e-invoicing Peppol 2026 from other European mandates is the integration of three elements into one system. First: mandatory electronic invoicing for B2B and B2G with structured invoices conforming to EU standard EN 16931 in UBL 2.1 format. Second: Continuous Transaction Controls (CTC) with real-time reporting of fiscal data upon both sending and receiving invoices. Third: extended fiscalisation of all B2C transactions, including online payments via bank transfer, Google Pay, PayPal and similar payment methods – whereas B2C transactions previously only needed to be reported for cash and card payments.

How the system works technically

Croatia implements a decentralised e-invoicing model combined with centralised reporting. This means e-invoices are exchanged directly between parties, while invoice data is separately reported to the tax authority by both sender and receiver.

The infrastructure

The system revolves around four core components. The Adresar metadata sustava (AMS) serves as the central address directory maintained by the tax authority, comparable to the Peppol Service Metadata Publisher. It contains the identification data and metadata of all taxpayers, enabling the system to determine where to send an e-invoice. The FiskAplikacija is the government application for fiscalisation and e-reporting, where businesses can review fiscalised data, manage authorisations, check invoice statuses, and consult pre-filled VAT returns. Certified information intermediaries are service providers authorised by the Croatian tax authority to facilitate the entire e-invoicing process, from transmission to receipt, fiscal reporting and archiving. Finally, the government provides MIKROeRAČUN: a free invoicing application for small businesses not registered for VAT.

Invoice format and exchange

Croatian e-invoices must comply with the HR-CIUS (Croatian Core Invoice Usage Specification), based on the European standard EN 16931. The recommended format is UBL 2.1, supplemented by the Peppol BIS 3.0 standard. The Cross-Industry Invoice (CII) format is also supported, but UBL is most common due to broader adoption and simpler implementation.

Invoice exchange runs preferably through access points and certified intermediaries using the AS4 protocol. Croatia’s system uses components with similar functions to Peppol – access points, metadata services and the AS4 protocol – but operates under its own certification processes. The Peppol network may be used as an alternative exchange method, provided the integrity and authenticity of the e-invoice are maintained.

Each invoice must be digitally signed with a certificate linked to the sender’s tax identification number. Every invoice also contains a QR code that allows the recipient to verify its submission to the tax authority.

The reporting obligation

Here lies the core of Croatia’s ambition. The CTC system requires real-time reporting of fiscal data for outbound invoices at the moment of sending, and a five-business-day reporting window for inbound invoices. On top of this comes additional e-reporting of payment information, invoice rejections by recipients, and situations where an invoice could not be issued because the buyer was not registered in the AMS directory.

The result is a system that gives the tax authority a near-complete picture of all economic transactions in real-time – not just the invoice itself, but also payment status, potential disputes and administrative processing on both sides.

Early results: 2.55 million invoices in two weeks

Initial indicators are remarkably positive. In the first two weeks of Fiscalization 2.0 – from 1 to 15 January 2026 – more than 2.55 million e-invoices were successfully fiscalised. The Croatian tax authority published clear guidelines covering the correct handling of self-billing, the structure of XML data in MIKROeRAČUN, and the policy regarding technical errors. An important signal for businesses: technical errors such as incorrect dates do not trigger penalties or tax liabilities during the implementation period.

This smooth rollout is no accident. Croatia has methodically built its e-invoicing infrastructure over the past decade – from cash transaction fiscalisation in 2013, to mandatory B2G acceptance from December 2018, to full B2G e-invoicing via the national platform Servis eRačun za državu since July 2019, managed by financial agency FINA. This platform is integrated with the Peppol network, with FINA operating as a certified Peppol access point.

What makes Croatia different from the rest of Europe

To understand the position of Croatia e-invoicing Peppol 2026 within the European landscape, a comparison with other mandates is instructive.

België: puur gedecentraliseerd Peppol

België kiest sinds januari 2026 voor een volledig gedecentraliseerd Peppol-model voor B2B- en B2G facturatie, zonder centrale clearing of real-time rapportage aan de overheid. Facturen worden rechtstreeks uitgewisseld tussen accesspoints. Dit is het eenvoudigste model voor bedrijven, maar geeft de overheid minder direct zicht op transacties.

Belgium: purely decentralised Peppol

Belgium has opted since January 2026 for a fully decentralised Peppol model for B2B invoicing, without central clearing or real-time reporting to the government. Invoices are exchanged directly between access points. This is the simplest model for businesses but gives the government less direct visibility into transactions.

Poland: centralised clearance via KSeF

Poland is implementing the KSeF system from February 2026 – a centralised clearance model where every invoice must pass through a government platform before reaching the recipient. Poland also uses its own invoice format (FA(3)) that is not compatible with EN 16931, limiting interoperability with other European systems.

Croatia: the hybrid model

Croatia combines decentralised invoice exchange with centralised reporting. Invoices are exchanged directly between parties via access points, but the data is simultaneously reported to the tax authority. The country uses the European EN 16931 standard in UBL format and builds on Peppol-compatible infrastructure. Moreover, Croatia is the only EU country that brings B2B, B2G and B2C together in one integrated mandate with real-time CTC reporting.

This approach positions Croatia as the most ViDA-ready country in Europe. The EU’s VAT in the Digital Age directive, which becomes mandatory for intra-Community transactions from 2030, requires exactly this type of digital real-time reporting based on e-invoicing. Croatia is already building the infrastructure that other EU countries will not need to implement for another four years.

Practical implications for international trading partners

Scope: who is and isn’t covered?

The obligation to issue and receive e-invoices applies to all VAT-registered businesses established in Croatia or maintaining a fixed establishment in the country. Foreign businesses that only hold a Croatian VAT registration without a physical presence are likely not subject to the mandatory issuance requirement – although final clarification on this point has not been fully published.

Importantly, the mandate applies only to domestic transactions. Cross-border transactions may still use paper invoices. However, this creates an operational tension that directly affects international trading partners.

Scenario 1: The Italian furniture supplier to a Croatian hotel

Albergo Forniture S.r.l. from Milan supplies furniture and interior products to hotel chains on the Dalmatian coast. The company has no establishment in Croatia.

As a foreign supplier without a fixed establishment in Croatia, Albergo Forniture is not subject to the direct e-invoicing obligation. They can continue sending invoices the traditional way. However, their Croatian customers are required to process all domestic invoices electronically through the new system. This means Croatian hotels must maintain two separate processing systems: one for domestic e-invoices with automatic fiscalisation, and one for international invoices processed manually.

In practice, Croatian businesses will increasingly prefer suppliers who can send electronic invoices – not because it is legally required, but because it significantly reduces administrative burden. An Italian supplier already using Peppol for its Italian SdI obligations can relatively easily serve Croatian customers electronically as well.

Scenario 2: The Slovenian manufacturer with a Croatian subsidiary

Industrijska Rešitev d.o.o. from Ljubljana has a production facility in Rijeka supplying parts to Croatian automotive manufacturers.

Because the Croatian facility constitutes a fixed establishment with its own staff and production resources, it falls fully under the Fiscalization 2.0 mandate. All invoices issued from Rijeka to Croatian buyers must be issued electronically, fiscalised and reported in real-time. The Slovenian parent company must integrate its ERP system with Croatian fiscalisation infrastructure, engage certified intermediaries, and implement digital signatures linked to the Croatian tax identification number of the establishment.

Slovenia is itself working towards an e-invoicing mandate from January 2027, also with Peppol as the underlying standard. The Slovenian company can therefore strategically choose a Peppol-based solution that covers both Croatian and future Slovenian requirements – an investment that delivers double returns.

Scenario 3: The German machinery manufacturer with occasional Croatian clients

Werkzeugmaschinen GmbH from Stuttgart delivers a few machines annually to industrial buyers in Zagreb and Osijek, but has no establishment or VAT registration in Croatia.

This company falls entirely outside the scope of the Croatian mandate. Yet it deserves attention. As the Croatian market digitalises, even occasional trade relationships will be influenced by the expectations of Croatian buyers. A German supplier holding a Peppol ID for Belgian or future German obligations can relatively easily extend this to Croatian business partners.

Strategic advice for international businesses

For businesses that regularly trade with Croatia

Assess whether you have a fixed establishment in Croatia or plan to establish one. The presence of a fixed establishment determines whether you fall directly under the mandate. Evaluate your current Peppol connectivity. If you already use Peppol for other markets such as Belgium, France or Scandinavian countries, expanding to Croatia is a relatively small step, as the country builds on the same EN 16931 standard and Peppol-compatible infrastructure.

Consider proactive adoption, even if you are not legally required to do so. The administrative benefits for your Croatian trading partners – automatic fiscalisation, pre-filled VAT returns, streamlined processing – strengthen the trade relationship and may lead to faster payments.

For businesses that have not yet implemented e-invoicing

Croatia’s mandate underscores a broader European trend. With Belgium mandatory since January 2026, France from September 2026, Poland from February 2026, and the EU-wide ViDA framework from 2030, the question is not if but when e-invoicing will affect your business. A comparison of e-invoicing service providers on Peppol.now can help select the right solution – preferably a provider that can support multiple European mandates from a single platform.

For ERP and software vendors

Croatia’s Fiscalization 2.0 sets high standards for technical integration: digital signatures, real-time CTC reporting, AMS registration, and support for the HR-CIUS invoice format. Software vendors looking to serve clients in the Croatian market must invest in certified connectivity with Croatian fiscalisation infrastructure.

Croatia as a blueprint for Europe’s future

Croatia e-invoicing Peppol 2026 is more than a local compliance matter. It is a preview of what the rest of Europe can expect. The country demonstrates that it is possible to bring B2B, B2G and B2C together in one integrated system with real-time fiscal control, built on European standards and Peppol-compatible technology.

The successful launch – with more than 2.55 million fiscalised invoices in the first two weeks – proves that an ambitious mandate is manageable when infrastructure is methodically built up. Croatia’s decade of experience with gradual digitalisation, from cash fiscalisation in 2013 to B2G in 2019 and now the full B2B+B2C mandate, offers lessons for every European country considering similar steps.

For international businesses, the message is clear: Peppol connectivity is not a luxury but a strategic necessity that gains value with every new European mandate.

Sources

• Croatian Fiscalization Act (NN 89/25), published 11 June 2025

• European Commission – eInvoicing in Croatia, Digital Building Blocks

• Croatian Tax Administration (Porezna uprava) – Fiscalization 2.0 guidelines

• FINA – Servis eRačun za državu (national B2G e-invoicing platform)

• OpenPeppol – Peppol Authority and Access Point information

Looking for a reliable e-invoicing solution ready for the Croatian mandate and other European requirements? On Peppol.now you can compare service providers that support Peppol connectivity, EN 16931 compliance and multi-country e-invoicing. View the overview at peppol.now and make an informed choice.