Section 1: The Unifying Framework: ViDA and Pan-European Standards

The current transformation of invoicing across the European Union is not a series of isolated national policy decisions but a coordinated, albeit fragmented, movement toward a digital-first value-added tax (VAT) system. This evolution is driven by a central legislative initiative and the adoption of common technical standards designed to enhance fiscal transparency, combat tax fraud, and streamline cross-border trade. Understanding this overarching framework is critical for any organization planning a pan-European compliance strategy. The primary drivers are the EU’s „VAT in the Digital Age“ (ViDA) package, the EN 16931 European Standard for e-invoicing, and the PEPPOL e-delivery network.

1.1. The „VAT in the Digital Age“ (ViDA) Revolution: Timelines and Strategic Impact

The „VAT in the Digital Age“ (ViDA) package represents the most significant modernization of the EU VAT system in decades. Formally adopted by the EU Council on March 11, 2025, and published in the Official Journal on March 25, 2025, ViDA establishes a multi-year roadmap for transitioning the entire bloc to a system of real-time digital reporting and electronic invoicing.¹ The initiative is a direct response to the substantial „VAT Gap“—the difference between expected VAT revenues and the amount actually collected—which was estimated at €99 billion in 2020 alone. A significant portion of this gap, up to €11 billion annually, is attributed to VAT fraud, particularly in intra-EU trade.²

The ViDA package is built upon three foundational pillars, each with a distinct implementation timeline that will progressively reshape business processes through 2035 ¹:

1. Digital Reporting Requirements (DRR) and E-Invoicing: This is the core pillar driving the shift to e-invoicing. Starting July 1, 2030, businesses will be obligated to issue structured electronic invoices for all intra-community B2B supplies. These e-invoices must be issued within 10 days of the supply. Concurrently, businesses must report transactional data from these invoices to their national tax authorities in near real-time. This system of digital reporting will replace the current periodic EC Sales Lists, providing tax administrations with immediate visibility into cross-border transactions to combat carousel fraud.⁴
2. VAT for the Platform Economy: To address the challenges posed by the growth of the digital platform economy, new rules will take effect on July 1, 2028. Under these rules, platforms facilitating short-term accommodation rentals and passenger transport services will become the „deemed supplier.“ This makes them responsible for collecting and remitting VAT on the transactions they facilitate, ensuring a level playing field with traditional service providers and simplifying compliance for individual providers or small businesses using their platforms.¹
3. Single VAT Registration (SVR): Also beginning on July 1, 2028, the scope of the existing One-Stop Shop (OSS) and Import One-Stop Shop (IOSS) systems will be expanded. This will allow more businesses to register for VAT in a single Member State to declare and pay VAT on sales across the entire EU, significantly reducing the administrative burden and cost of multiple VAT registrations.¹

While the 2030 deadline for harmonized intra-community e-invoicing sets the long-term strategic direction, the most immediate and disruptive provision of the ViDA package took effect in April 2025. This provision grants Member States the authority to mandate B2B electronic invoicing for domestic transactions without first needing to obtain a special derogation from the EU Council.⁴ This has effectively opened the floodgates for national governments to accelerate their own e-invoicing timelines.

This dual-timeline structure has created a complex, two-speed transition period. While the final destination is a harmonized EU-wide system by 2030, the journey there is a patchwork of urgent, disparate national mandates. Countries with significant VAT gaps, such as Germany, France, Spain, and Poland, have seized this opportunity to fast-track their domestic B2B mandates, setting deadlines in 2026, 2027, and 2028.⁵ For a multinational business, this means the strategic challenge is not a single, large-scale project for 2030, but rather a continuous, multi-year program of country-by-country implementations, each with its own unique technical and procedural requirements.

1.2. The European Standard (EN 16931): The Semantic Foundation for Interoperability

At the technical heart of the European e-invoicing movement is the European Standard EN 16931. Published by the European Committee for Standardization (CEN), this standard defines a semantic data model for an electronic invoice. It specifies the core business terms and data elements an invoice must contain—such as seller information, buyer information, line items, VAT details, and totals—to be considered compliant.⁹ It serves as a common language, ensuring that an e-invoice generated in one country can be understood and processed by a system in another.

The EN 16931 standard is the foundation upon which nearly all national mandates are built, including those in Germany, France, Italy, Poland, Belgium, and Sweden.⁹ It is typically implemented using one of two standardized XML syntaxes: UBL (Universal Business Language) or UN/CEFACT Cross Industry Invoice (CII).

However, being „EN 16931 compliant“ in a general sense is insufficient for practical implementation. The standard provides a core model, but individual Member States often have specific legal or business requirements that are not covered by the core specification. To address this, many countries have developed a Core Invoice Usage Specification (CIUS). A CIUS is a national version of the EN 16931 standard that includes extensions (additional data fields) or restrictions (limitations on how certain fields can be used) to meet domestic needs.⁹

This proliferation of CIUS is the primary source of technical fragmentation in the European e-invoicing landscape. Examples include:

• Germany: Utilizes XRechnung (a pure XML format primarily for B2G) and ZUGFeRD/Factur-X (a hybrid format combining a PDF with embedded XML).⁶
• France: Mandates one of three core formats: UBL, CII, or Factur-X.¹¹
• Italy: Enforces a single, strict national format, FatturaPA, which is a CIUS based on XML.¹⁷
• Poland: Mandates a national XML schema, e-Faktura, and utilizes Peppol BIS Billing 3.0 as its CIUS for transmission.⁹

The existence of these distinct CIUS means that a single, generic „EN 16931“ export template from an ERP system is not a viable solution for pan-European compliance. The system, or more commonly the middleware connected to it, must be capable of generating multiple, distinct XML files. Each file must be structured and validated according to a different country’s specific rules and schematrons. This multiplies the technical complexity and testing requirements for any multi-country rollout, making format transformation and validation a critical function of any chosen e-invoicing solution.

1.3. The PEPPOL Network: The De Facto Standard for E-Document Exchange

While EN 16931 and its national CIUS define what an e-invoice should contain, the Pan-European Public Procurement OnLine (PEPPOL) network defines how it should be securely and reliably exchanged. PEPPOL is not a centralized platform but rather a set of technical specifications and a governance framework that creates an interoperable e-delivery network.¹⁸

The network operates on a „four-corner model“ ²⁰:

1. Corner 1 (Sender): The invoice issuer creates an invoice in their ERP or accounting system.
2. Corner 2 (Sender’s Access Point): The sender transmits the invoice to their chosen certified PEPPOL Access Point provider. This provider uses the recipient’s unique PEPPOL ID to look up their receiving capabilities and address in a central directory (Service Metadata Publisher – SMP).
3. Corner 3 (Receiver’s Access Point): The sender’s Access Point securely transmits the invoice across the PEPPOL network to the recipient’s designated Access Point.
4. Corner 4 (Receiver): The recipient’s Access Point delivers the invoice directly into their ERP or accounting system for processing.

Initially developed to simplify cross-border public procurement within the EU, PEPPOL has rapidly evolved into the backbone of both B2G and B2B e-document exchange across Europe and globally.¹⁹ Its adoption has been driven by government mandates. It is the required or recommended transport channel for B2G invoicing in numerous countries, including Germany (for federal states), Belgium, Sweden, Norway, Denmark, and the Netherlands.⁶

The strategic importance of PEPPOL is growing as countries transition to B2B mandates. Because many businesses are already connected to the network to serve public sector clients, extending its use for B2B transactions is a logical and efficient step. Belgium’s B2B mandate, for example, establishes PEPPOL as the default exchange network.²² France’s „Y-Model“ also relies on PEPPOL for interoperability between its private PDPs.²⁶

For a multinational business, this trend presents a significant strategic opportunity. Investing in a connection to a single, certified PEPPOL Access Point provides a standardized and reusable technical channel to reach a vast and growing number of trading partners and public bodies across Europe. This approach dramatically simplifies the connectivity challenge, which is often one of the most complex aspects of an e-invoicing implementation. By leveraging PEPPOL, a company can abstract away the complexities of point-to-point connections and focus its resources on the critical task of ensuring the invoice content (the CIUS format) is correct for each jurisdiction.

Section 2: Comparative Cross-Sectional Analysis of EU E-Invoicing Models

The European e-invoicing landscape is characterized by a variety of procedural models and platform architectures, each reflecting a different national strategy for achieving fiscal control and digitalization. For a multinational organization, understanding these models is essential for assessing the compliance risk, technical complexity, and operational impact in each market. The models can be broadly categorized into Clearance, Post-Audit, and Real-Time Reporting systems.

2.1. Decoding the Models: Clearance, Post-Audit, and Real-Time Reporting

The choice of procedural model dictates the level of government intervention in the invoicing process and has profound implications for business workflows.

• Centralized Clearance (Continuous Transaction Controls – CTC): This is the most stringent model, where the tax authority acts as a direct intermediary in the invoicing process. Invoices must be submitted to a central government platform for validation and clearance before or as part of the process of sending them to the buyer. An invoice that has not been cleared by the platform is not considered legally valid. This model provides tax authorities with maximum, real-time control over transactional data.
• Examples: Italy’s Sistema di Interscambio (SdI) is the archetypal centralized clearance system.²⁷ Poland’s Krajowy System e-Faktur (KSeF) and Romania’s RO e-Factura platform follow the same paradigm.⁸
• Decentralized Clearance / Interoperability CTC: This model combines government oversight with a competitive market of private service providers. Businesses exchange invoices through accredited private platforms (known as PDPs in France), which are responsible for validating the invoices, transmitting them to the recipient’s platform, and simultaneously reporting a subset of the invoice data to a central tax authority platform. This creates a „Y“ shaped data flow.
• Example: France’s „Y-Model“ is the primary example of this architecture. It aims to balance the state’s need for data with businesses‘ freedom to choose their technology partners.⁵
• Real-Time Invoice Reporting (RTIR): In this model, the invoice exchange process itself is decoupled from tax authority reporting. Businesses issue and send invoices directly to their customers through any agreed-upon channel (e.g., email, EDI). However, they are simultaneously obligated to report the data from these invoices to the tax authority’s platform in real-time or near real-time. The reporting is of the invoice data, not the invoice document itself.
• Example: Hungary’s Online Számla system, which requires real-time reporting of all invoice data to the National Tax and Customs Administration (NAV), is a pure RTIR model.³¹
• Post-Audit / Interoperability: This is the most traditional and least intrusive model. Invoices are exchanged directly between trading partners without any prior or real-time government intervention. The exchange often occurs over an interoperability network like PEPPOL or through bilateral agreements. Tax authorities ensure compliance retrospectively through periodic audits, often facilitated by standardized audit files like SAF-T.
• Examples: Germany’s upcoming B2B mandate is a post-audit model.⁶ Belgium, Sweden, and the Netherlands also currently operate under this paradigm for their B2G and voluntary B2B exchanges.¹⁴

2.2. Platform Architectures: Centralized Hubs vs. Decentralized Networks

The procedural model is closely linked to the underlying technical architecture. Centralized clearance and RTIR models rely on a single, state-operated platform that acts as a central hub for all transactions (e.g., Italy’s SdI, Poland’s KSeF). This architecture offers tax authorities complete control and a single source of truth for all transactional data. However, it can also represent a single point of failure and may limit innovation and competition among service providers.

In contrast, post-audit and decentralized CTC models are built on the principle of interoperability between multiple actors. Networks like PEPPOL and the French PDP ecosystem are decentralized by design. They do not rely on a single central platform for invoice exchange but rather on a common set of rules and protocols that allow any certified provider to connect with any other. This architecture is more resilient, fosters a competitive market for value-added services, and aligns with the principle of a single digital market.

2.3. The Spectrum of Mandates: From B2G-Only to Universal B2B/B2C Compliance

The scope of e-invoicing mandates across Europe follows a clear evolutionary path. Most countries begin by mandating e-invoicing for Business-to-Government (B2G) transactions, using public procurement as a lever to build national infrastructure and drive adoption among suppliers. This has been the case in Sweden, Denmark, Norway, and many others.¹⁴

Following a successful B2G implementation, the next logical step is to extend the mandate to Business-to-Business (B2B) transactions to address the larger VAT gap in the private sector. This is the transition currently underway in Germany, France, Spain, Poland, and Belgium.⁵

A few of the most advanced jurisdictions have taken the final step of extending mandates to include Business-to-Consumer (B2C) transactions, thereby capturing the entirety of the domestic economy. Italy mandates e-invoicing for B2C transactions, and Romania is doing the same, requiring businesses to report B2C invoice data through the RO e-Factura system even though the invoice must still be delivered separately to the consumer.¹⁷ This progression from B2G to B2B and finally to B2C represents the full spectrum of digital tax compliance.

Table: Master Comparison Matrix of European E-Invoicing Systems

The following table provides a consolidated overview of the e-invoicing landscape across key European countries, serving as a strategic tool for planning and prioritization.

Country	Mandate Scope	Procedural Model	Go-Live Dates (Phased)	Central Platform / Network	Required Formats (CIUS)	Archiving Period
Italy	B2G, B2B, B2C	Centralized Clearance	B2G: 2015; B2B/B2C: 2019 (Universal since 2024)	Sistema di Interscambio (SdI)	FatturaPA XML	10 Years (Conservazione)
France	B2G, B2B	Decentralized CTC	B2G: 2020; B2B: Sept 2026 (Receive All/Issue Large), Sept 2027 (Issue SMEs)	PPF (Hub) + PDPs (Network)	Factur-X, UBL, CII	10 Years (common practice)
Poland	B2G, B2B	Centralized Clearance	B2G: via PEF; B2B: Feb 2026 (Large), April 2026 (All Others)	Krajowy System e-Faktur (KSeF)	e-Faktura (XML)	10 Years (by KSeF)
Germany	B2G, B2B	Post-Audit	B2G: 2020; B2B: Jan 2025 (Receive), Jan 2027 (>€800k), Jan 2028 (All)	Decentralized (PEPPOL recommended)	XRechnung, ZUGFeRD (Factur-X)	10 Years (GoBD)
Spain	B2G, B2B	Interoperability	B2G: 2015; B2B: Pending (est. 2026/27+)	Public/Private Interconnected Platforms	Facturae (B2G); TBD (B2B)	6 Years
Belgium	B2G, B2B	Post-Audit	B2G: Phased 2022-23; B2B: Jan 1, 2026	PEPPOL (Default Network)	Peppol BIS 3.0	7 Years
Romania	B2G, B2B, B2C	Centralized Clearance	B2G: 2022; B2B: Jan 2024; B2C: Jan 2025	RO e-Factura (via ANAF SPV)	RO_CIUS (UBL/CII)	10 Years
Hungary	B2G (Partial), B2B, B2C	Real-Time Reporting	RTIR since 2018 (Universal since 2021)	Online Számla (NAV)	XML (for reporting)	8 Years
Sweden	B2G	Post-Audit	B2G: April 2019	PEPPOL (via ELMA registry)	Peppol BIS Billing 3.0	7 Years
Denmark	B2G	Post-Audit	B2G: 2019; B2B (Capability): Jan 2026 via Bookkeeping Act	NemHandel, PEPPOL	OIOUBL, Peppol BIS 3.0	5 Years
Netherlands	B2G (Central Govt)	Post-Audit	B2G: 2017	Digipoort, PEPPOL	Peppol BIS 3.0, SI-UBL	7 Years
Croatia	B2G, B2B	Clearance	B2G: 2019; B2B: Jan 1, 2026	eRačun (via FINA), PEPPOL	UBL 2.1, CII	11 Years
UK	B2G (NHS England)	Post-Audit	NHS: Mandatory; Other Public Bodies: Must be able to receive	PEPPOL (for NHS)	Peppol BIS 3.0	6 Years

Section 3: Country-by-Country E-Invoicing Compendium

This section provides a detailed, standardized analysis of the e-invoicing regulations and technical requirements for key European markets. Each profile serves as a self-contained guide for compliance in that specific jurisdiction.

3.1. Germany

Legal Framework: The primary legislation for the upcoming B2B mandate is the Wachstumschancengesetz („Growth Opportunities Act“), which was passed by the Bundesrat on March 22, 2024.⁶ Detailed guidance is provided in a letter from the Federal Ministry of Finance (BMF) published on October 15, 2024.³⁵ E-invoicing with the public sector (B2G) is governed by the federal E-Rechnungsverordnung (E-RechV) and corresponding state-level regulations.³⁷

Mandate Status & Timeline:

• B2G: Mandatory for suppliers to federal authorities since November 27, 2020.³⁵ The implementation for Germany’s 16 federal states (Bundesländer) is decentralized. While each state has its own decree, all are required to accept EN 16931-compliant e-invoices, and the use of the PEPPOL network is a common requirement.⁶
• B2B: A phased mandatory rollout is in effect:

• January 1, 2025: All businesses established in Germany must have the technical capability to receive structured electronic invoices that comply with the EN 16931 standard. Issuers no longer require recipient consent to send an e-invoice.⁶
• January 1, 2027: Mandatory issuance of e-invoices for all domestic B2B transactions for businesses with a prior year’s turnover exceeding €800,000.⁶
• January 1, 2028: The mandatory issuance obligation extends to all remaining businesses, regardless of turnover.⁶

Procedural Model: Germany has adopted a Post-Audit model for B2B e-invoicing. There is no central government platform for invoice submission or clearance, and the legislation does not currently mandate any real-time reporting of invoice data to the tax authority. The exchange occurs directly between trading partners.⁶ The BMF is, however, considering the future possibility of a national portal for reporting certain invoice data.⁶

Technical Standards & Formats: An e-invoice is strictly defined as one that complies with the European Standard EN 16931. Other formats, like a simple PDF, are considered „other invoices“ and require recipient consent.⁶

• Accepted CIUS: The primary national formats are XRechnung (a pure XML structure, preferred for B2G) and ZUGFeRD (a hybrid format embedding XML within a PDF/A-3 file, identical to France’s Factur-X) from version 2.0 onwards.⁶
• Transitional Provisions: Invoices in traditional Electronic Data Interchange (EDI) formats remain permissible until December 31, 2027, provided there is a bilateral agreement between the trading partners.³⁴

Platforms & Channels:

• B2B: No central platform is mandated. Invoices can be exchanged via any channel agreed upon by the parties, including email, direct API connections, or through service providers. The PEPPOL network is increasingly becoming the recommended standard for interoperable exchange.¹⁹
• B2G: The federal administration uses several portals, primarily the Zentrale Rechnungseingangsplattform des Bundes (ZRE) and the OZG-konforme Rechnungseingangsplattform (OZG-RE). A unified routing system based on a specific identifier, the Leitweg-ID, ensures invoices reach the correct public entity regardless of the entry point.¹⁵

Compliance Requirements:

• Archiving: Invoices must be archived for a period of 10 years. Crucially, the structured electronic invoice must be stored in its original, unalterable format (e.g., the XML file), in compliance with the German principles of data access and auditability of digital records (Grundsätze zur ordnungsmäßigen Führung und Aufbewahrung von Büchern, Aufzeichnungen und Unterlagen in elektronischer Form sowie zum Datenzugriff – GoBD).⁶
• Sanctions: While the Wachstumschancengesetz does not specify new penalties, non-compliance with general invoicing rules under the VAT Act can lead to administrative fines. More significantly, failure to issue a compliant invoice could jeopardize the recipient’s right to deduct input VAT. Penalties of up to €5,000 per offense have been cited.³⁸

3.2. France

Legal Framework: The B2B e-invoicing mandate is established by Finance Law for 2024 (Law no. 2023-1322) and defined by Ordinance No. 2021-1190. This framework received the necessary derogation from the EU Council to deviate from the standard VAT Directive.⁵

Mandate Status & Timeline:

• B2G: Mandatory since January 1, 2020, for all suppliers to the public sector, with invoices exchanged via the central Chorus Pro platform.⁴⁰
• B2B: A phased mandate is scheduled after an initial postponement:

• September 1, 2026: All companies must be technically capable of receiving electronic invoices. Large and medium-sized enterprises (ETIs) must begin issuing e-invoices and submitting e-reports.⁵
• September 1, 2027: The obligation to issue e-invoices and submit e-reports extends to all small and medium-sized enterprises (SMEs) and micro-enterprises.⁵

Procedural Model: France has implemented a Decentralized Continuous Transaction Controls (CTC) model, known as the „Y-Model“.⁵

• In this model, businesses cannot send invoices directly to each other. They must use an accredited private service provider, a Partner Dematerialization Platform (PDP – Plateforme de Dématérialisation Partenaire).
• The sender’s PDP validates the invoice, extracts required data for tax reporting, and sends this data to the central government platform, the Portail Public de Facturation (PPF).
• Simultaneously, the sender’s PDP transmits the full invoice to the recipient’s chosen PDP. The PPF maintains a central directory to route invoices between the different PDPs.⁵

Technical Standards & Formats: The mandate specifies a „minimum base“ of three accepted structured formats that all platforms must support:

• Factur-X: A hybrid format (PDF with embedded XML), which is the Franco-German standard identical to ZUGFeRD.¹¹
• UBL (Universal Business Language)
• CII (UN/CEFACT Cross Industry Invoice).¹¹

Platforms & Channels:

• PDPs: All businesses must contract with a government-accredited PDP to issue and receive e-invoices. These platforms are the mandatory intermediaries.⁴³
• PPF: The Portail Public de Facturation, an evolution of the B2G Chorus Pro platform, acts as the central data concentrator for the tax authority (DGFiP) and manages the directory of all registered companies to ensure interoperability between PDPs.⁵

Compliance Requirements:

• E-Reporting: In parallel with the e-invoicing mandate for domestic B2B transactions, there is a mandatory e-reporting obligation. Businesses must periodically report data on transactions not covered by e-invoicing, which includes B2C sales and cross-border B2B transactions (both sales and purchases).⁴¹
• Archiving: While the legal minimum for archiving documents is 6 years, common practice for tax-relevant documents like invoices is 10 years.³⁹
• Sanctions: Penalties for non-compliance are clearly defined: €15 per non-compliant e-invoice (capped at €15,000 per year) and €250 per non-compliant e-reporting transmission.⁴⁴

3.3. Italy

Legal Framework: The mandate for B2B e-invoicing was introduced by Law no. 205/2018 and has been progressively expanded. As Italy was the first EU member state to mandate B2B e-invoicing, it required a specific derogation from the EU Council (Implementing Decision (EU) 2018/593) to bypass the then-standard requirement of recipient consent.²⁸

Mandate Status & Timeline:

• B2G: Mandatory since March 2015.⁴⁶
• B2B and B2C: Italy has the most comprehensive mandate in Europe. It has been mandatory for nearly all domestic B2B and B2C transactions since January 1, 2019. A phased rollout for smaller taxpayers and specific regimes was completed on January 1, 2024, at which point the obligation became universal for all VAT-registered businesses in Italy, regardless of size or turnover.²⁷

Procedural Model: Italy operates a strict Centralized Clearance (CTC) model. Every invoice must pass through the government’s central platform to be considered legally issued.²⁷

Technical Standards & Formats: The system enforces a single, mandatory national format: FatturaPA. This is a specific XML schema defined by the Italian Revenue Agency (Agenzia delle Entrate). The technical specifications are periodically updated, with version 1.9 set to take effect on April 1, 2025.²⁷

Platforms & Channels: All invoices without exception must be transmitted through the central government platform, the Sistema di Interscambio (SdI). The process is as follows:

1. The supplier generates the invoice in the FatturaPA XML format.
2. The invoice is sent to the SdI.
3. The SdI performs technical validation checks, applies a timestamp, and either accepts or rejects the invoice.
4. If accepted, the SdI delivers the invoice to the buyer’s designated address (a PEC email or an intermediary’s Codice Destinatario).¹⁷

Compliance Requirements:

• Cross-Border Transactions: The previous system for reporting foreign invoices, the Esterometro, was abolished in July 2022. Now, data from cross-border sales and purchases must also be reported to the SdI in the FatturaPA format, typically by the 15th day of the month following the transaction.¹⁷
• Archiving (Conservazione Sostitutiva): Italy has highly specific and stringent e-archiving requirements. Invoices must be stored for 10 years following a process known as Conservazione Sostitutiva. This process requires grouping invoices into archival packages, applying a qualified electronic signature and a timestamp to each package, and maintaining a detailed process manual (Manuale della Conservazione). This ensures the legal authenticity, integrity, and legibility of the documents over time. This can be done via accredited third-party providers or a free service offered by the government.²⁷
• Sanctions: Penalties for non-compliance are among the most severe in Europe, with fines ranging from 90% to 180% of the VAT amount associated with the non-compliant invoice.²⁷

3.4. Spain

Legal Framework: Spain’s e-invoicing landscape is shaped by two key pieces of legislation:

1. The „Crea y Crece“ Law (Law 18/2022), which establishes the future mandate for B2B electronic invoicing.⁷
2. The „Anti-Fraud Law“ (Law 11/2021), which mandates the use of certified invoicing software systems known as Veri*factu systems to ensure the integrity and traceability of invoice records.⁵¹

Mandate Status & Timeline:

• B2G: Mandatory since 2015. Invoices must be submitted in the Facturae format to the central platform, FACe (Punto General de Entrada de Facturas Electrónicas).⁵⁰
• B2B E-Invoicing: The mandate has been approved in principle, but the go-live date is contingent on the final approval and publication of the technical regulations. The timeline is defined as:

• 1 year after regulation approval for companies with an annual turnover exceeding €8 million.
• 2 years after regulation approval for all other businesses and professionals.
  Given the current status, implementation is not expected before 2026 at the earliest.7
• Veri*factu (Certified Software): This is a separate, but related, obligation with a firm timeline. It requires that all invoicing software used by businesses meets certain technical standards for traceability.

• July 29, 2025: Deadline for software producers to be compliant.
• January 1, 2026: Deadline for corporate taxpayers to use compliant systems.
• July 1, 2026: Deadline for all other taxpayers to comply.⁵¹

Procedural Model: The proposed B2B model is a decentralized interoperability system. Businesses will be able to exchange e-invoices through either private, certified platforms or a public e-invoicing solution run by the Spanish Tax Agency (AEAT). A key feature is that all private platforms must be interconnected with each other and with the public solution. The system will also require the reporting of invoice statuses, specifically commercial acceptance/rejection and full payment, to combat late payments.⁴⁹

Technical Standards & Formats: The final technical specifications for B2B e-invoices have not yet been published. The B2G format is Facturae. It is anticipated that the B2B format will be based on either Facturae or a UBL-based standard to ensure alignment with EN 16931 and the upcoming ViDA requirements.⁵⁰

Platforms & Channels: The system will consist of a network of interconnected private platforms and a central public solution provided by the AEAT. The public solution will also serve as a repository, allowing recipients to check their invoices and enabling the tax authority to monitor transactions.⁴⁹

Compliance Requirements:

• Archiving: The standard archiving period for tax-relevant documents in Spain is 6 years.⁵¹
• Sanctions: Specific penalties for the B2B e-invoicing mandate are yet to be defined. However, for the Verifactu* requirement, failure to use certified software can result in significant fines, potentially up to €50,000 per year.⁵²

3.5. Poland

Legal Framework: The mandatory B2B e-invoicing system is governed by the Act on the National e-Invoicing System (Krajowy System e-Faktur – KSeF), which amends the Polish VAT Act.⁸

Mandate Status & Timeline:

• B2G: Currently, B2G invoicing is handled through a separate platform, PEF (Platforma Elektronicznego Fakturowania), which is set to be integrated with the new KSeF system.⁹
• B2B: After several postponements to ensure system stability, a new phased mandatory timeline has been signed into law:

• February 1, 2026: Mandatory for large taxpayers with a sales value in 2024 exceeding PLN 200 million.⁸
• April 1, 2026: Mandatory for all other VAT-registered taxpayers.⁸

Procedural Model: Poland has chosen a Centralized Clearance (CTC) model, similar to Italy’s. All B2B invoices must be processed through the central government platform to be considered legally valid.⁹

Technical Standards & Formats: The mandate requires a single, structured XML format known as e-Faktura. The technical schema is defined by the Ministry of Finance.⁸

Platforms & Channels: All in-scope invoices must be issued, validated, and received via the central state platform, the Krajowy System e-Faktur (KSeF). The process is as follows:

1. The seller’s ERP system prepares the invoice in the e-Faktura XML format.
2. The XML file is sent to the KSeF platform via its API.
3. KSeF validates the invoice structure and content.
4. If valid, KSeF assigns a unique identification number (KSeF ID) and a timestamp. At this point, the invoice is considered legally issued and delivered.
5. The buyer can then retrieve the invoice from the KSeF platform using the KSeF ID or other search criteria.⁸

Compliance Requirements:

• Scope: The mandate applies to all taxpayers established in Poland for their domestic transactions. The application to foreign entities with only a fixed establishment in Poland is a point of legal discussion, though the Ministry of Finance’s position is that they are included.⁸
• Archiving: A significant benefit of the system is that the KSeF platform will automatically archive all cleared invoices for a period of 10 years, relieving businesses of this specific obligation.⁸
• Sanctions: After an initial grace period, penalties for non-compliance will be severe. Failure to issue an invoice via KSeF can result in a penalty of up to 100% of the VAT amount on the invoice. Other penalties apply for system failures or incorrect data.⁸

3.6. Belgium

Legal Framework: The law implementing mandatory B2B e-invoicing from January 1, 2026, was published in the Belgian Official Journal on February 20, 2024. A Royal Decree in July 2025 provided further technical clarifications.²²

Mandate Status & Timeline:

• B2G: Mandatory for suppliers to public sector entities, phased in between 2022 and 2023 based on contract value.⁵⁵
• B2B: A „big bang“ approach will be used, with e-invoicing becoming mandatory for all B2B transactions between VAT-liable entities established in Belgium on January 1, 2026.¹³

Procedural Model: Belgium has opted for a Post-Audit model based on the PEPPOL network. There is no central clearance platform; invoices are exchanged directly between trading partners via the network.²²

Technical Standards & Formats: The mandate requires the use of structured electronic invoices compliant with the EN 16931 standard. The default format is Peppol BIS 3.0.²²

Platforms & Channels: The PEPPOL network is the default channel for transmitting e-invoices. While parties can agree to use another channel, all taxpayers must have the technical capability to issue and receive invoices via PEPPOL.²²

Compliance Requirements:

• VAT Deduction: A critical aspect of the Belgian mandate is that the right to deduct input VAT will be linked to the receipt of a compliant structured e-invoice. Receiving a non-compliant invoice (e.g., a simple PDF) may jeopardize VAT recovery.¹³
• Archiving: Invoices must be archived for 7 years.
• Sanctions: Fines are specified for technical non-compliance (failure to issue/receive correctly), starting at €1,500 for a first offense and rising to €5,000 for subsequent violations.²²
• Future E-Reporting: Belgium plans to introduce a near real-time e-reporting system, potentially based on a 5-corner PEPPOL model, in January 2028.¹³

3.7. Other Country Profiles

(This section would continue with detailed profiles for all other EU/EEA countries and the UK, following the same standardized structure. Below are summary highlights for a selection of countries based on the provided research.)

• Croatia: B2G mandatory since 2019 via the eRačun platform. A B2B mandate („Fiscalization 2.0“) is confirmed for January 1, 2026, for all VAT-registered businesses. The model will be clearance-based, using the FINA agency and the PEPPOL network. The required format is UBL 2.1 or CII, and archiving is for 11 years.⁵⁶
• Denmark: B2G is mandatory via the NemHandel platform. The 2022 Bookkeeping Act requires all businesses to have systems capable of sending and receiving e-invoices via PEPPOL and NemHandel by January 2026. This is not a direct issuance mandate but a technical capability requirement. Formats are OIOUBL and Peppol BIS 3.0.²⁴
• Finland: B2G is mandatory. B2B is voluntary, but businesses have the right to request an e-invoice from their suppliers. The system is decentralized, using an operator model including PEPPOL. National formats (Finvoice, TEAPPSXML) are used alongside Peppol BIS 3.0.⁵⁹
• Greece: B2G is mandatory. A phased B2B mandate begins February 2, 2026, for large companies and extends to all others on October 1, 2026. The model is a clearance system via the myDATA platform, which already handles real-time reporting. Exchange is via certified providers.⁶²
• Ireland: B2G is mandatory for public bodies to be able to receive EN 16931-compliant invoices via PEPPOL, but it is not mandatory for suppliers to send them. B2B is entirely voluntary. The model is Post-Audit.⁶⁴
• Luxembourg: B2G is mandatory, phased in from 2022 to 2023. The required channel is the PEPPOL network. B2B remains voluntary.⁶⁶
• Netherlands: B2G is mandatory for suppliers to central government bodies, using the Digipoort gateway or PEPPOL. B2B is voluntary. Formats include Peppol BIS 3.0 and the national SI-UBL.²³
• Norway (EEA): B2G is mandatory for all suppliers to the public sector via the PEPPOL network. The national registry is ELMA. Formats are EHF and Peppol BIS. B2B is voluntary but has high adoption rates due to the B2G mandate.²⁵
• Portugal: B2G is mandatory via the FE-AP platform, with the deadline for SMEs postponed to January 1, 2026. B2B is voluntary, but from 2026, PDF invoices will only be considered valid if they have a Qualified Electronic Signature. All invoices must include a QR code and an ATCUD code and be generated by certified software.⁷¹
• Slovakia: A B2B mandate is proposed for January 1, 2027. The model is expected to be a decentralized, PEPPOL-based system (5-corner model) with near real-time reporting via the IS EFA platform.⁷³
• Slovenia: B2G is mandatory via the UJP eRačun platform. A B2B mandate with real-time reporting is proposed for January 1, 2027.⁷⁵
• United Kingdom (Non-EU): There is no general e-invoicing mandate. The primary digital tax initiative is Making Tax Digital (MTD) for VAT, which is a real-time reporting system, not an e-invoicing system. It requires businesses to keep digital records and submit VAT returns via API. A specific B2G mandate exists for suppliers to NHS England, which requires PEPPOL.⁷⁷

Section 4: Forward-Looking Roadmap: Upcoming Changes (2026-2028)

The e-invoicing landscape in Europe is in a state of rapid and continuous evolution. The period between 2026 and 2028 will be particularly transformative, as a critical mass of major economies implements B2B mandates. This section provides a consolidated roadmap of these changes to aid in strategic, medium-term planning and resource allocation.

4.1. Timeline of Key Deadlines and Legislative Milestones

The following timeline details the most significant confirmed and proposed deadlines for mandatory B2B e-invoicing across Europe. This serves as a critical planning tool for prioritizing country-specific implementation projects.

Date	Country	Milestone	Affected Businesses	Requirement
Feb 1, 2026	Poland	B2B Mandate (Wave 1)	Large taxpayers (>PLN 200M turnover)	Mandatory issuance via KSeF platform.
Apr 1, 2026	Poland	B2B Mandate (Wave 2)	All other VAT-registered taxpayers	Mandatory issuance via KSeF platform.
Sept 1, 2026	France	B2B Mandate (Wave 1)	All businesses Large & Medium Enterprises	Mandatory reception of e-invoices. Mandatory issuance of e-invoices & e-reporting
Jan 1, 2026	Belgium	B2B Mandate	All VAT-liable businesses	Mandatory issuance & reception via PEPPOL.
Jan 1, 2026	Croatia	B2B Mandate	All VAT-registered businesses	Mandatory issuance via eRačun/PEPPOL.
Jan 1, 2026	Spain	Veri*factu Deadline	Corporate taxpayers	Use of certified invoicing software mandatory.
Feb 2, 2026	Greece	B2B Mandate (Wave 1)	Large companies (>€1M revenue)	Mandatory issuance via myDATA providers.
Oct 1, 2026	Greece	B2B Mandate (Wave 2)	All other businesses	Mandatory issuance via myDATA providers.
Jan 1, 2027	Germany	B2B Mandate (Wave 1)	Businesses >€800k turnover	Mandatory issuance of EN 16931 e-invoices.
Sept 1, 2027	France	B2B Mandate (Wave 2)	SMEs & Micro-enterprises	Mandatory issuance of e-invoices & e-reporting.
Jan 1, 2027	Slovakia	B2B Mandate (Proposed)	All VAT-registered businesses	Proposed mandate for issuance via PEPPOL model.
Jan 1, 2027	Slovenia	B2B Mandate (Proposed)	All taxable businesses	Proposed mandate with real-time reporting.
Jan 1, 2028	Germany	B2B Mandate (Wave 2)	All businesses	Universal mandatory issuance of e-invoices.
Jan 1, 2028	Latvia	B2B Mandate	All VAT-registered businesses	Mandatory issuance and reporting to VID.
Jan 1, 2028	Belgium	E-Reporting (Planned)	All VAT-liable businesses	Planned start of near real-time reporting system.

4.2. Anticipating the Next Wave: Countries Poised to Announce B2B Mandates

Beyond the confirmed deadlines, a second wave of countries is actively preparing to introduce B2B mandates. These are typically nations that have already successfully implemented B2G e-invoicing and are now looking to expand the benefits of digitalization to the broader economy. Organizations should monitor developments in these jurisdictions closely:

• Sweden: The Swedish Tax Agency (Skatteverket) and the Agency for Digital Government (Digg) have formally requested the government to evaluate a B2B mandate, citing alignment with ViDA as a key driver. Given Sweden’s mature B2G PEPPOL infrastructure, a transition to B2B would be technically straightforward.¹⁴
• Finland: While B2B remains voluntary, the legal framework already grants businesses the right to demand e-invoices. The government is actively considering a full B2B mandate and real-time reporting, making it a strong candidate for a future mandate.⁵⁹
• Austria: With a robust B2G system in place (e-Rechnung.gv.at), Austria is well-positioned to consider a B2B mandate, although no formal plans have been announced. The widespread use of the national ebInterface standard provides a solid foundation.⁸⁰
• Lithuania: Having mandated B2G e-invoicing since 2017, Lithuania has indicated plans to align with ViDA and is expected to introduce a B2B mandate, with a potential start date around 2028.⁸¹

4.3. The Convergence Trajectory: From National Systems to a ViDA-Harmonized Future

The current period of fragmentation, characterized by a mosaic of different national models, formats, and platforms, is a temporary phase. The overarching goal of the ViDA initiative is to achieve a harmonized digital VAT system across the single market. The 2030 deadline for mandatory intra-community e-invoicing and digital reporting is the key milestone that will force these disparate national systems to converge.

This convergence will have significant long-term implications. National clearance platforms like Italy’s SdI and Poland’s KSeF, while currently operating as closed ecosystems for domestic transactions, will need to become interoperable with the pan-EU system to handle intra-community transactions post-2030. This will likely necessitate the adoption of common interoperability standards, with the PEPPOL network being the most probable candidate to bridge these national hubs.

For businesses making technology decisions today, this future convergence is a critical strategic consideration. Investing in solutions that are built on proprietary, country-specific protocols or formats carries a significant risk of obsolescence. The most sustainable and future-proof strategy is to prioritize solutions built on open, interoperable standards. An architecture centered around the EN 16931 data model and the PEPPOL network for connectivity will not only address the immediate compliance needs of many post-audit countries but will also provide a scalable and adaptable foundation for the ViDA-harmonized era. Such an approach minimizes the risk of needing to re-engineer core systems as national and EU-level regulations continue to evolve toward their final, unified state.

Part III: Practical Implementation Guide for SAP Business One

This section translates the complex regulatory landscape into a practical, actionable guide for organizations using SAP Business One as their core ERP system. It outlines a strategic approach to architecting a compliant, scalable, and future-proof e-invoicing solution.

Section 5: Architecting a Compliant Solution in SAP Business One

Achieving pan-European e-invoicing compliance within SAP Business One requires a clear understanding of the system’s native capabilities and, more importantly, its limitations. A successful strategy will inevitably involve a hybrid approach, combining the core ERP with specialized external solutions.

5.1. Assessing Native Capabilities vs. The Need for External Solutions

SAP Business One provides a foundational framework for handling electronic documents. This includes an „electronic document monitor“ for tracking status and an „electronic document import wizard“ designed to facilitate the processing of incoming documents.²¹ Critically, SAP offers a native connection to the PEPPOL network through its own access point, allowing for the import and export of certain electronic documents.²¹

However, these native capabilities are insufficient for meeting the diverse and specific requirements of a multi-country European rollout. The primary limitations are:

• Format Generation: SAP Business One does not natively generate the specific XML formats required by each country’s CIUS (e.g., Italy’s FatturaPA, Poland’s e-Faktura, Germany’s XRechnung). The system can produce the core data, but not the final, validated XML file.¹⁹
• Platform Connectivity: While a PEPPOL connection is available, the system lacks native, pre-built API integrations for the numerous national clearance platforms that do not use PEPPOL, such as Italy’s SdI, Poland’s KSeF, or Hungary’s NAV system.
• Process Automation: The native framework requires significant manual intervention and lacks the sophisticated validation, error handling, and status monitoring workflows required by clearance and CTC models.

Therefore, a purely native SAP Business One solution is not a feasible or scalable option. An external solution is required to bridge the gap between the ERP’s data generation capabilities and the complex compliance requirements of each country.

5.2. The Role of Third-Party Add-ons and Certified Service Providers

The market offers a wide range of third-party solutions, often delivered as SAP-certified add-ons or cloud-based middleware, that are specifically designed to manage e-invoicing compliance. These providers act as a crucial intermediary, handling the complex tasks that fall outside SAP Business One’s core functionality.¹⁶

The standard solution architecture for a compliant system is as follows:

SAP Business One -> Third-Party Add-on/Connector -> National Platform or PEPPOL Network

The key functions performed by the third-party provider include:

1. Data Extraction: Securely pulling invoice data from SAP Business One, typically via a pre-built connector or API.
2. Format Transformation & Validation: Converting the raw data into the specific XML format required by the destination country (e.g., FatturaPA, XRechnung) and validating it against the official rules (schematrons) to prevent rejections.
3. Communication Management: Handling the secure API or AS4 (PEPPOL) communication with the relevant national platform or Access Point.
4. Status Monitoring: Receiving and processing status updates from the platforms (e.g., „Accepted,“ „Rejected,“ „Delivered“) and feeding this information back into SAP Business One for visibility in the electronic document monitor.⁸²
5. Archiving: Providing a legally compliant digital archive for the structured invoices, especially for countries with specific requirements like Italy’s Conservazione Sostitutiva.

5.3. Key Integration Points: Master Data, Transactional Data, and Status Monitoring

A successful implementation is fundamentally dependent on the quality and completeness of data within SAP Business One. Inaccurate master data is the most common cause of invoice validation failures and rejections. Key areas to focus on during a pre-implementation data cleansing project include:

• Business Partner Master Data: Ensuring that customer and vendor records contain accurate and complete VAT registration numbers, company names, and addresses. For countries with specific routing requirements, additional fields may be necessary (e.g., Germany’s Leitweg-ID for B2G invoices, Italy’s Codice Destinatario).
• Tax Information: Verifying that VAT codes and rates are correctly configured for all relevant jurisdictions and transaction types.
• Item Master Data: Ensuring that product and service descriptions are clear and meet any industry-specific requirements.

The integration must also provide a closed loop for status monitoring. The ability for the third-party solution to update the status of an electronic document directly within SAP Business One is critical for Accounts Receivable teams to track invoice delivery and acceptance, manage exceptions, and ensure a clear audit trail.

5.4. A Step-by-Step Implementation Framework

A structured approach is essential for a successful multi-country rollout. The following framework outlines a high-level project plan:

1. Phase 1: Strategy & Selection

• Country Prioritization: Use the forward-looking roadmap (Section 4) to identify and prioritize countries based on mandatory deadlines.
• Vendor Selection: Conduct a Request for Proposal (RFP) process to select a third-party e-invoicing provider. Key criteria should include SAP Business One integration experience, country coverage, PEPPOL certification, and support for specific models like the French PDP system or Italian archiving.

2. Phase 2: Preparation & Design

• Master Data Cleansing: Initiate a project to validate and update all relevant master data in SAP Business One.
• Process Design: Map existing Accounts Payable (AP) and Accounts Receivable (AR) processes and design the future-state workflows incorporating the new e-invoicing solution.

3. Phase 3: Implementation & Testing

• Technical Integration: Install and configure the third-party add-on or connector within the SAP Business One environment.
• User Acceptance Testing (UAT): Conduct thorough end-to-end testing for each prioritized country, covering invoice creation, transmission, status feedback, and error handling.

4. Phase 4: Rollout & Support

• Go-Live: Execute a phased go-live, starting with the highest-priority country.
• User Training: Train AR, AP, and finance teams on the new processes and tools.
• Hypercare & Support: Establish a support model for managing post-go-live issues and ongoing maintenance.

Section 6: Country-Specific Configuration Blueprints for SAP Business One

The generic architecture must be adapted to the specific requirements of each key market. The following blueprints outline the solution design for the most pressing mandates.

6.1. Germany

• Objective: Generate EN 16931-compliant invoices and transmit them to business partners.
• Solution Blueprint:

1. The third-party add-on extracts invoice data from SAP Business One.
2. The solution transforms the data into either XRechnung or ZUGFeRD XML format, as required by the trading partner.
3. The invoice is transmitted to the partner’s receiving system via a PEPPOL Access Point. The provider must be a certified PEPPOL AP.¹⁶
4. For incoming invoices, the provider’s PEPPOL AP receives the invoice and the add-on pushes it into SAP Business One for processing.

• Key Focus: Format generation (XRechnung/ZUGFeRD) and robust PEPPOL connectivity.

6.2. France

• Objective: Comply with the „Y-Model“ for invoice exchange and e-reporting.
• Solution Blueprint:

1. Select a service provider that is an officially accredited PDP in France.⁴¹
2. The SAP Business One add-on integrates with the chosen PDP’s API.
3. For B2B invoices, the add-on sends the core invoice data to the PDP. The PDP generates the final format (Factur-X, UBL, or CII), sends the required data to the PPF, and transmits the invoice to the recipient’s PDP.⁴²
4. For e-reporting (B2C, cross-border), the add-on sends transactional data to the PDP, which then formats and submits the report to the PPF.

• Key Focus: Deep API integration with a certified PDP. The project is less about format generation and more about seamless data exchange with the chosen intermediary.

6.3. Italy

• Objective: Comply with the SdI centralized clearance model and Conservazione Sostitutiva archiving.
• Solution Blueprint:

1. The add-on extracts invoice data from SAP Business One.
2. The solution converts the data into the mandatory FatturaPA XML format and applies a digital signature.
3. The XML file is transmitted to the SdI via a secure channel (Web Service or SFTP) managed by an accredited intermediary.⁸²
4. The solution must be able to receive and interpret the status notifications (receipts, rejections) from the SdI and update the invoice status in SAP Business One.
5. The provider must offer a fully compliant Conservazione Sostitutiva archiving service that meets all legal requirements for timestamps, signatures, and process documentation.²⁷

• Key Focus: Strict FatturaPA format compliance, reliable SdI connectivity, and a legally compliant long-term archiving solution.

6.4. Poland

• Objective: Comply with the KSeF centralized clearance model.
• Solution Blueprint:

1. The add-on extracts invoice data from SAP Business One.
2. The solution converts the data into the mandatory e-Faktura XML format.
3. The add-on integrates directly with the KSeF platform’s API to submit the XML file.⁸³
4. The solution must receive the KSeF ID and validation status in real-time from the API and store this information against the invoice record in SAP Business One.
5. For incoming invoices, the solution must use the KSeF API to retrieve cleared invoices from the platform.

• Key Focus: Direct, real-time API integration with the KSeF platform and management of the KSeF ID lifecycle.

6.5. A Universal PEPPOL Connector Approach

A significant opportunity for efficiency exists for countries that have adopted a post-audit model based on the PEPPOL network. This includes Belgium, Sweden, Norway, Denmark, the Netherlands, and is a viable option for Germany.

• Objective: Use a single technical solution to achieve compliance across multiple countries.
• Solution Blueprint:

1. Implement a single, robust third-party add-on for SAP Business One that provides certified PEPPOL Access Point functionality.²⁰
2. For each country, configure the add-on to generate the correct CIUS required for that jurisdiction (typically Peppol BIS Billing 3.0, but may have minor national variations).
3. The add-on uses the same PEPPOL channel to transmit invoices to any recipient registered on the network, regardless of their country.

• Key Focus: This approach consolidates the technical challenge of connectivity into a single, reusable component. The primary task for each country rollout becomes a matter of configuration (ensuring the correct format and master data) rather than a new technical integration, dramatically reducing the cost and time to achieve compliance across this group of nations.

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80. eInvoicing in Austria – European Commission – Europa.eu, Zugriff am Oktober 18, 2025, https://ec.europa.eu/digital-building-blocks/sites/display/DIGITAL/eInvoicing+in+Austria
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