EU electronic invoicing requirements now operate on two tracks: any business selling to a public sector body in the EU must already send structured, machine-readable invoices that meet the European Standard EN 16931, and mandatory business-to-business (B2B) e-invoicing is being switched on country by country through 2028, ahead of EU-wide cross-border digital reporting that starts on July 1, 2030 under the VAT in the Digital Age (ViDA) package adopted on March 11, 2025.1European Commission. Adoption of the VAT in the Digital Age Package What you have to do depends on who you invoice and where they are.
What Counts as a Compliant E-Invoice
A PDF attached to an email is not an electronic invoice under EU rules. Directive 2014/55/EU is explicit that only machine-readable invoices capable of fully automated processing qualify.2legislation.gov.uk. Directive 2014/55/EU – On Electronic Invoicing in Public Procurement
The technical rules come from EN 16931, a European Standard developed by CEN. It has two parts. The first is a semantic data model that lists the core elements every invoice must contain: supplier and buyer identification, invoice number and date, line item descriptions, tax breakdowns, and totals. The second is a short list of approved syntaxes for encoding that data. EN 16931 recognizes exactly two: UBL (Universal Business Language) version 2.1 and UN/CEFACT CII (Cross Industry Invoice), both XML-based.3European Commission Digital. Obtaining a Copy of the European Standard on eInvoicing Public bodies within the directive’s scope must be able to receive invoices in either syntax.4European Commission Digital. Navigating the eInvoicing Standard Documentation
Directive 2014/55/EU covers central, regional, and local government bodies. The formal duty is on the public entity to accept a compliant e-invoice, but in practice any supplier that wants to sell to a public buyer has to be able to produce one.2legislation.gov.uk. Directive 2014/55/EU – On Electronic Invoicing in Public Procurement The directive itself does not require e-invoicing between private businesses. National mandates and ViDA are what extend the reach into B2B.
How E-Invoices Get Delivered
Producing the file is only half of compliance. It also has to reach the recipient through an approved channel, and the channel depends on the country.
For cross-border B2G transactions and for several national B2B systems, the primary infrastructure is PEPPOL (Pan-European Public Procurement Online). PEPPOL uses a four-corner model.5OpenPeppol. For End Users The sender transmits the invoice to their certified Access Point, which validates the document and routes it through the network to the recipient’s Access Point, which then delivers it to the buyer.6E-Rechnung in der Bundesverwaltung. Peppol’s Technical Solution: The Four-Corner Model Sender and recipient do not need the same software or provider; they just both need certified Access Points. Access Points handle validation, transport integrity, and participant registration in the PEPPOL directory.
Not every country uses PEPPOL for domestic B2B. Belgium built its national mandate around it. Italy and Poland route everything through centralized government platforms instead. France is using a decentralized model based on certified service providers with government oversight. If you invoice across multiple Member States, you will likely need connections to more than one system, either directly or through a provider that consolidates them.
National B2B Mandates and Deadlines
The country-level rules are where most businesses will feel the change first. Dates and technical models differ, so the practical calendar matters.
Italy
Italy has run the EU’s most mature mandatory e-invoicing system since January 2019. All B2B and B2C invoices between Italian VAT-registered businesses pass through the Sistema di Interscambio (SdI), a centralized platform managed by the Agenzia delle Entrate, using the FatturaPA XML format. The EU Council authorized Italy to continue operating the system through December 31, 2027.7European Commission Digital. eInvoicing in Italy If a file fails SdI validation, it is not delivered. There is no email or PDF fallback.
Germany
Germany’s mandate is phased under the Growth Opportunities Act. Since January 1, 2025, all German businesses have had to be able to receive structured electronic invoices in EN 16931-compliant formats. Sending obligations follow annual turnover:
- January 1, 2027: businesses with annual turnover above €800,000 must issue structured e-invoices.
- January 1, 2028: the obligation extends to all businesses, ending paper and unstructured PDF for B2B.
Accepted formats include XRechnung, EN 16931-compliant versions of ZUGFeRD, and other EN 16931-compliant formats such as UBL or CII. Standard PDFs do not qualify. Invoices under €250 and passenger transport tickets are exempt.
France
France’s mandate covers domestic B2B e-invoicing and e-reporting for B2C and cross-border transactions. All businesses must be able to receive electronic invoices from September 1, 2026. Issuing obligations phase in by size:
- September 1, 2026: large and medium-sized companies must issue e-invoices.
- September 1, 2027: SMEs and micro-enterprises must comply.
Both dates can be postponed by decree by up to three months, to December 1 of the respective year.
Poland
Poland’s Krajowy System e-Faktur (KSeF) is a centralized platform on the Italian pattern. KSeF 2.0 goes live on February 1, 2026 for large businesses (turnover above PLN 200 million) and for invoice recipients. All remaining businesses must comply by April 1, 2026.
Belgium
Belgium’s mandatory B2B e-invoicing took effect on January 1, 2026. All Belgian VAT-registered businesses must exchange structured electronic invoices for domestic B2B transactions, built around PEPPOL and EN 16931-compliant formats. Belgian tax authorities allowed a three-month tolerance in Q1 2026 for businesses that could show reasonable steps toward compliance.
Spain
Spain’s B2B mandate under the Crea y Crece law phases in by size. Large businesses (annual turnover above €8 million) must comply roughly 12 months after adoption of the implementing Royal Decree, with SMEs following 12 months later. Spain is using a decentralized model.
What ViDA Changes at EU Level
ViDA reaches beyond the B2G scope of Directive 2014/55/EU and pulls cross-border B2B into a common framework.1European Commission. Adoption of the VAT in the Digital Age Package Three milestones matter:
- Immediate effect: Member States can introduce mandatory domestic e-invoicing without first requesting a special EU derogation.
- July 1, 2030: Digital Reporting Requirements apply to cross-border B2B transactions, with structured invoice data submitted to tax authorities.
- January 1, 2035: Member States with existing domestic digital reporting systems must align them with the EU-wide ViDA standard.1European Commission. Adoption of the VAT in the Digital Age Package
The direction is clear: B2B e-invoicing will become as unavoidable as B2G already is. Infrastructure built now for a single national mandate should be designed to extend to cross-border reporting later.
Building a Compliant Process
Three things need to be in place before an invoice can go out.
First, data mapping. Your ERP or accounting system stores invoice data in its own internal structure, and that structure rarely lines up cleanly with EN 16931’s required fields. Every mandatory element, from buyer tax identification to payment terms to line-level tax calculations, has to be mapped to the standard’s semantic model. Fields that look equivalent often differ in how they treat tax rates or unit codes, and this is where most implementations run into trouble.
Second, a delivery connection. For B2G and PEPPOL-based countries, that means contracting with a certified Access Point provider. For centralized systems like Italy’s SdI and Poland’s KSeF, you need a connection to the national platform, either directly or through a service provider. Businesses invoicing across several Member States often use providers that consolidate multiple national connections into a single integration.
Third, testing. Run your invoice files through validation against EN 16931 rules and any country-specific requirements before going live. An invoice that fails SdI validation never reaches the buyer. An invoice rejected by KSeF does not exist for the tax authority. Fixing validation problems after launch is far more expensive than catching them in testing.
Consequences of Non-Compliance
Fines are only part of the picture. In clearance-model countries like Italy and Poland, a non-compliant file is simply rejected by the government platform and never reaches the customer, so the payment cycle never starts. That is a cash flow problem, not just a regulatory one.
France imposes a penalty per non-compliant invoice, with annual caps that escalate. Non-compliant invoices can also create VAT deductibility problems for the buyer, meaning customers may refuse to accept invoices that fall short of the technical requirements. Tax authorities increasingly cross-reference reported invoice data, and gaps caused by non-compliant invoices can flag returns for audit and delay VAT refunds. Belgium’s Q1 2026 tolerance window has closed; businesses without a working PEPPOL connection now face both sending and receiving failures.
Invoice Retention
Sending the invoice does not end your obligations. Retention rules are set by each Member State and are not harmonized. Periods across the EU range from 5 years to 11 years or more. Germany and France both require 10-year retention. Belgium requires 7 years, and 15 years for certain real estate-related transactions. Croatia requires 11 years. Several countries require that invoices remain accessible in their original electronic format for the full period, with the ability to search, display, and reproduce them for audit.
The archive has to guarantee integrity: content cannot be altered after storage. Some Member States also require that any data used to verify the invoice’s authenticity and content integrity be archived with it. If you store invoices outside the country where the transaction occurred, some jurisdictions require you to notify the tax authority. Building retention into your e-invoicing setup from the beginning is far easier than retrofitting it once years of data have accumulated.