Mandatory e-invoicing: what applies to you?

Whether you must send or receive e-invoices depends on where you are established, who you do business with and what role you play. Use this checklist to determine which types of obligations apply to your organisation.

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A question organisations frequently ask is whether they are required to send or receive e-invoices. The answer does not depend on a single rule, but on a combination of factors: where your organisation is established, who you do business with and what role you play yourself. On this page you can read which types of obligations exist and how to determine, step by step, what applies to your organisation.

This page is deliberately kept general, because obligations differ by country and change regularly. You will find the latest developments per country in our news overview and on the blog. New to e-invoicing? Start by reading What is e-invoicing?.

What types of obligations exist?

Public sector bodies receive e-invoices (B2G receipt)

In the European Union, public sector bodies must be able to receive and process e-invoices that comply with the European standard EN 16931 (Directive 2014/55/EU). Outside the EU, this varies by country. For suppliers, an e-invoice is therefore an accepted, and often the preferred, way to invoice a government.

Suppliers send e-invoices to the government (B2G sending)

Some countries and public sector bodies go further and only accept e-invoices. A PDF or paper invoice will then no longer be processed. Sometimes this applies only above a certain contract value, to certain legal forms, or via a prescribed channel.

E-invoicing between businesses (B2B), and sometimes to consumers (B2C)

Businesses must also send and receive e-invoices among themselves. Often an obligation to receive applies first, followed by an obligation to send, or the obligation is phased in by company size. A few countries, such as Italy, also route invoices to consumers through the government platform.

Clearance and e-reporting

With clearance, the invoice must first pass through a government platform before it is valid or reaches the customer. Examples are SdI in Italy and KSeF in Poland. With e-reporting, the invoice simply goes to the customer, and you or your service provider send the transaction data separately, in real time or periodically, to the tax authority. Both concern VAT control, but they do determine how your invoicing process must be set up.

European digital reporting (ViDA)

From 1 July 2030, digital reporting based on e-invoicing applies in the EU to cross-border B2B transactions. In addition, member states may make domestic e-invoicing mandatory under certain conditions. Read more about this in ViDA explained.

What does the obligation require?

Once you know that an obligation applies, look at three things:

  • The format: the European standard EN 16931, a national format, or a specific implementation such as Peppol BIS.
  • The channel: free choice, the Peppol network, or a mandatory government platform.
  • The start date and phasing: for receiving and for sending, and by company size.

Together, these three determine which solution you need. Read more about formats and channels in E-invoice formats and Types of e-invoicing.

What this means for you as a business: how to determine what applies

These forms occur separately, but also in combination. A country may, for example, mandate B2G sending and at the same time have an e-reporting obligation for all VAT-taxable transactions. Always look at the full set of rules that applies to your situation. Answer the following questions: together they give a clear picture of the obligations that are relevant to your organisation.

In which country or countries is your organisation established?

The rules of your country of establishment are the starting point. If you have establishments in several countries, a different obligation may apply to each establishment.

In which countries are your customers established?

Some obligations apply based on where the transaction is taxed or where the customer is located. Even if your own country has no obligation, a customer in another country may ask for an e-invoice in a particular format. Large customers also often set their own requirements for channel and format, even where the law does not.

Do you supply to public sector bodies?

Then you are likely to deal with B2G rules. Check whether the public sector body merely accepts e-invoices or requires them, and via which channel.

Are you a public sector body yourself?

Then, as a rule, an obligation to receive applies. See below for what this means for your own process.

What is your VAT registration status in the relevant countries?

Many obligations are linked to a VAT registration. If you are registered for VAT in another country, that country's rules may also apply to you, including any e-reporting obligations.

Do you engage in cross-border B2B trade?

With cross-border transactions, the rules of several countries can apply at the same time. An open network such as Peppol helps to exchange e-invoices across borders, but in some countries a national platform is mandatory.

Still unsure after answering these questions? Discuss your situation with your tax adviser or accountant. They can assess exactly which rules apply to your organisation.

Preparation: these steps always apply, regardless of the country

1
Map where you operate and what applies there
Make an overview of the countries where you are established, where you sell and where you are registered for VAT. Follow the latest obligations per country through the news overview and the blog on Peppol.now.
2
Ask your customers what they expect
Ask your main customers through which channel and in which format they want to receive e-invoices. Large customers and governments often set their own requirements, even where the law does not.
3
Check your current software
Check whether your accounting or ERP package can send and receive e-invoices, in which formats and through which channels. Ask your software vendor about the options.
4
Choose a suitable solution or service provider
Select a service provider or e-invoicing solution that meets the requirements that apply to you: the right formats, countries, channels and any reporting obligations. In the comparison tool, you can filter by coverage area and by public networks, such as Peppol, SdI, KSeF and Chorus Pro. You will find guidance in Choosing an e-invoicing solution.
5
Test well before any start date
Send and receive test invoices with a few regular customers or suppliers. This allows you to detect errors in master data, formats or routing before an obligation takes effect.
6
Document what you have done
Record which obligations you have assessed, which choices you have made and how your process is set up. This documentation is valuable for your own compliance records and when an accountant or tax authority has questions.

Do you know which obligations apply to you? Then use the comparison tool to find a solution that meets them.

Compare e-invoicing solutions

What does this mean for public sector bodies?

For public sector bodies, the focus is first and foremost on their own receiving process. Make sure e-invoices arrive through the common channels, are validated automatically and reach the financial administration without manual intermediate steps. Also consider the information you provide to suppliers: make clear how you receive e-invoices, which details must be included on the invoice (such as an order number or reference) and what happens to invoices that do not meet the requirements. Clear communication prevents rejected invoices and delayed payments.

In addition, look at your outgoing invoices. Organisations that also send e-invoices themselves, for example for rent, fees or recharges, increase support among suppliers and customers. Your organisation will also be ready for European digital reporting from 2030.

What does this mean for software vendors?

For software vendors, obligations determine the product requirements. Customers expect their software to create, send, receive and process e-invoices in the required formats, and to connect to the Peppol network, either directly or through a Peppol service provider. Where e-reporting or CTC applies, integrations with tax authority platforms are added to this. Because obligations differ by country and can change, a flexible architecture that can accommodate new formats and reporting rules is an important selling point. Also keep an eye on developments in digital reporting via the Peppol network. In a ViDA pilot, OpenPeppol is testing an extension of the Peppol architecture in which tax authorities are connected to the network as a fifth corner.

From obligation to solution

The route can be summarised in three steps: determine which obligation applies to you, prepare your organisation and systems, and then choose a solution that fits your situation. In the comparison tool on Peppol.now, you can compare Peppol service providers and e-invoicing solutions side by side, so you can make a targeted choice for a solution that meets your obligations.

Ready to meet the requirements?

Compare Peppol service providers and e-invoicing solutions that match your obligations.

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