Updates on e-invoicing in Europe

The European Union is currently at a pivotal phase in the evolution of e-invoicing. The transition towards e-invoicing has been gradual but persistent, commencing with the publication of Directive 2014/55/EU.

Subsequently, a considerable number of European countries have enacted legislation and regulations that facilitate the adoption of e-invoicing in Europe, particularly in B2G and B2B transactions.

In light of the recommendations set forth by the ViDA project and the increasing adoption of PEPPOL, the European Commission, in collaboration with member countries, is working to make B2B e-invoicing a reality in most of the continent.

The following article will examine the challenges and changes occurring in Germany, Belgium, France, UK, Poland, Greece and Italy.

B2B e-invoicing in Germany

Germany is approaching the final stage of the mandatory introduction of e-invoicing. From January 2025, the use of B2B e-invoices will become official. However, a voluntary period will be initiated for those taxpayers who express a desire to adopt this new procedure.

During this phase, it has been determined that all companies must be capable of receiving electronic invoices that comply with the standards set forth in EN 16931.

In January 2027, the obligation will be extended to companies with a turnover of more than €800,000, and just one year later to all other German companies, including small businesses.

During the adoption of the obligation, formats such as ZUGFeRD and Factur-X will be used, and invoices below €250 will be exempt from all requirements. Conversely, the German government has announced that email will serve as an alternative for receiving electronic invoices due to the lack of advanced systems for receiving invoices.

B2B e-invoicing in Belgium

In recent months, the FPS (Federal Public Service for Finance) has published a guide for taxpayers on B2B e-invoicing in Belgium and a set of recommendations for accounting software for businesses to adopt from 1 January 2026. This is the same date that e-invoicing for B2B transactions becomes official.

The Belgian government's objective is to replace the existing four-corner model with a five-corner PEPPOL model. The implementation of B2B e-invoicing has yet to be scheduled, but it is conceivable that it will be divided into groups, comprising large taxpayers, medium-sized taxpayers, and small taxpayers.

B2B e-invoicing in France

In order to enhance the competitiveness of businesses and streamline payment procedures, the French government is set to implement a generalisation of electronic invoicing.

Concurrently, the DGFiP has issued a press release in which it has declared its intention to adopt B2B e-invoicing in accordance with a five-corner model. Consequently, a PDP (Plateforme de Dématérialisation Partenaires) will be required for the issuance and reception of e-invoices, while the PPF (Portail Public de Facturation) will be tasked with the management of a directory and the collection of data from the aforementioned PDPs.

In accordance with the stipulations set forth in the finance law, the implementation of B2B e-invoicing in France is scheduled to become mandatory as of 1 September 2026. This entails that all companies must be equipped with the capability to receive e-invoices, while large and medium-sized companies are obliged to possess the capacity to issue them.

B2B e-invoicing in United Kingdom

The latest developments in the UK with regard to the aforementioned situation pertain to the commencement of a public consultation on e-invoicing.

Nevertheless, the official inauguration of B2B e-invoicing in the UK is not anticipated until 2029 at the earliest. It will be introduced in stages and may adopt a two-stage model similar to that of Belgium.

At present, UK taxpayers are permitted, at their own discretion, to utilise e-invoices in B2B transactions, provided that an agreement exists between the two parties.

B2B e-invoicing in Poland

The Polish government has presented new legal solutions with the objective of facilitating the implementation of the KSeF for taxpayers. It is anticipated that this draft will be published by the end of 2024.

The proposals include the extension of the KSeF number to encompass electronic invoice payments until 31 July 2026, the utilisation of an offline mode for all taxpayers until the conclusion of 2026, the issuance of traditional invoices for taxpayers with minimal invoice volumes until 30 September 2026, and the guarantee of a secure environment for the utilisation of the KSeF.

The introduction of B2B e-invoicing in Poland is scheduled to commence in February 2026, with the initial implementation affecting companies with a turnover exceeding €46 million in 2025. For all other companies, the deadline for compliance is 1 April 2026.

B2B e-invoicing in Greece

In accordance with the stipulations set forth in Law 4308/2014, Greece will initiate the implementation of its electronic delivery notification system in two distinct phases at a later point in the current calendar year.

In the initial phase, commencing on 1 December 2024, users will be obliged to provide data including the sender, recipient, delivery document, Quick Response (QR) codes, date of dispatch and loading and unloading particulars.

The second phase is scheduled to commence on 1 April 2025 and will require the inclusion of additional details, namely the exact time, means of transport and carrier details.

In the event of non-compliance, penalties will be levied at a rate of €100 per document not sent, with a maximum penalty of €20,000 per year.

B2B e-invoicing in Italy

The Italian government has formally requested an extension to the derogation of articles 218 and 232 of the VAT Directive, with the aim of maintaining the mandatory implementation of B2B e-invoicing until 31 December 2025, or until such time as member states deem it necessary to implement decisions following the adoption of the VAT proposals in the digital era.

Italy can be considered the European country that has made the most significant commitment to e-invoicing. The process of massification commenced with considerable success, with the electronic invoicing platform, Sistema di Interscambio (SdI), established by the government, facilitating the exchange of over two billion invoices in the inaugural year.

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