E-invoicing in Europe

Europe is embracing digital innovation. Especially since the ViDA proposal was released, Governments and businesses are moving towards electronic invoicing (e-invoicing) and digital reporting requirements to streamline processes. In this overview, we explore B2B (Business-to-Business) and B2G (Business-to-Government) e-invoicing mandates across Europe.

• Austria B2B

• • E-invoicing mandate in place?
    No
  • Additional Comments
    B2B e-invoicing is allowed on a voluntary basis.

• Austria B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Start date by 1 January 2014
  • Who is concerned?
    Suppliers of federal agencies, including foreign companies with a permanent establishment in Austria. Foreign non-established companies are obliged to issue and transmit e-invoices to the extent technically possible. 

• Belgium B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    In the process of implementation. Start date: January 2026 as per the current proposal.
  • Who is concerned?
    Taxpayers established in Belgium. Not applicable to foreign VAT-registered companies.
  • Additional Comments
    The Belgian Parliament still needs to give it the green light. Also, the European Commission needs to authorize the Belgian mandate of e-invoicing. Find more information here. 

• Belgium B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Implementation dates by region: Flanders, as of 1 January 2017; Brussels, by 1 November 2020; Wallonie, by 1 January 2022.
    Implementations schedule nationwide: New regulation expands the e-invoicing requirement nationwide. The implementation schedule of this mandate requires Suppliers of public bodies to issue electronic invoices, based on the combination of (a) the publication date of the tender and (b) the value of the contract with the public body, excluding VAT, as follows:
    - Contracts equal to or greater than EUR 215,000: the obligation applies to invoices related to tenders published from 1 November 2022 on.
    - Contracts equal to or greater than EUR 30,000: the obligation applies to invoices related to tenders published from 1 May 2023 on.
    - Contracts below EUR 30,000: the obligation applies to invoices related to tenders published from 1 November 2023.
    - Remark: Contract values below EUR 3,000 are exempt from the e-invoicing obligation.
  • Who is concerned?
    Suppliers of the public administrations. It also applies to foreign VAT-registered companies (not explicitely excluded).

• Bulgaria B2B and B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    There are discussions to implement mandated e-invoicing both in B2G and B2B. Also, SAF-T reporting is under development.

• Croatia B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    In the process of implementation. Start date: January 2026 as per the current proposal.
  • Who is concerned?
    The current project aims to implement mandate B2B e-invoicing for domestic transactions made by established companies or businesses with a fixed establishment in Croatia. In principle, the obligation will not impact non-established VAT registered taxpayers.
  • Additional Comments
    The country has already requested authorization from the EU Council (for derogation from the VAT Directive). Find more information here.

• Croatia B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Mandatory issuance of structured e-invoices for suppliers to public administrations as of 1 July 2019.
  • Who is concerned?
    Suppliers to public administrations. It also applies to VAT-registered foreign companies.
  • Additional Comments
    Concerning foreign companies, all international exchange of e-invoices takes place through the PEPPOL (Pan European Public Procurement OnLine) network, which enables the cross-border exchange of electronic invoices and other documents in public procurement processes. Fina (Croatian e-invoicing system) has established an access point within the PEPPOL network and all public procurement obligees who are registered in the central register - the e-Account service platform for the state, are recognizable and accessible to foreign suppliers through this access point.

• Cyprus B2B

• • E-invoicing mandate in place?
    No

• Cyprus B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Public administration must accept e-invoices. Under review to introduce mandatory B2G e-invoicing

• Czech Republic B2B and B2G

• • E-invoicing mandate in place?
    No
  • Additional Comments
    Public bodies must accept e-invoices. No mandate B2G or B2B.

• Denmark B2B

• • E-invoicing mandate in place?
    No
  • Additional Comments
    The new bookkeeping obligation includes the condition for these digital systems to be able to issue, receive and store e-invoices. Find more information here.

• Denmark B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Since 2005, suppliers of services and goods are required to send electronic invoices (UBL) to public institutions and public authorities.
  • Who is concerned?
    Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Estonia B2B

• • E-invoicing mandate in place?
    No

• Estonia B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Since July 2019, suppliers of services and goods are required to send electronic invoices to public institutions and public authorities.
  • Who is concerned?
    Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Finland B2B

• • E-invoicing mandate in place?
    No

• Finland B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Since 6 April 2021, suppliers of services and goods are required to send electronic invoices to public institutions and public authorities.
  • Who is concerned?
    Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded). If the sender does not have the capability to send EN-compliant e-invoices, a bilateral agreement can be set between the two trading partners.

• France B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    B2B e-invoicing is approved. It is expected that both e-invoicing and e-reporting are implemented gradually from September 2026.
  • Who is concerned?
    E-invoicing will only impact on French established businesses. However, non-established VAT registered businesses will have to comply with e-reporting. 
  • Additional Comments
    Find more information here.

• France B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The general start date of the mandate was 1 January 2020 (gradual implementation from January 2017 to January 2020)
  • Additional Comments
    Suppliers to public administrations. It also applies to VAT-registered foreign companies (not explicitly excluded). Invoices issued by foreign service providers fall within the scope of Chorus Pro as long as the service falls under French public procurement legislation.

• Germany B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Mandate on B2B e-invoicing is announced, and expected to be introduced by 2026. Germany already received the EU authorization to implement the mandate on B2B electronic invoicing by way of derogation of articles 218 and 232 of the EU VAT Directive.
  • Additional Comments
    Find more information here.

• Germany B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Start date: all suppliers to Federal authorities since 27 November 2020. The different German states (16) have implemented differently the e-invoicing obligation. If required, you should check the regulations concerning contracts with a particular German state.
  • Who is concerned?
    Suppliers to public authorities. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Greece B2B

• • E-invoicing mandate in place?
    No

• Greece B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The obligation started by 12 September 2023 and will be completed by January 2025, with the mandate to issue e-invoices to all the general state administrative bodies as follows:
    - By September 2023, for contracts concerning the Ministries of Infrastructure and Transport, Digital Governance, Immigration and Asylum, the Municipality of Athens, the National Central Authority for Health Procurement (E.K.A.P.Y.), the National Central Procurement Authority of Ministry of Development and Investments, the Information Society S.A., the Athens University of Economics, "Attiko Metro S.A.", EYDAP S.A. and Egnatia Odos SA.
    - By January 2024, for contracts concerning bodies of the rest of the Central Administration.
    - By July 2024, for contracts concerning other bodies or authorities.
    - By January 2025, businesses must issue e-invoices for all other expenses of the General Government invoiced from that date.
  • Who is concerned?
    Suppliers to public authorities. It also applies to VAT-registered foreign companies (not explicitly excluded).
  • Additional Comments
    Generally, public contracts or expenses up to EUR 2,500 do not fall within the obligation to issue an electronic invoice. The mandate also excludes contracts in the fields of defense and security, low-value public contracts, certain public contracts between public sector entities, certain contracts between contracting authorities, certain contracts concession between public sector entities. Find more information here.

• Hungary B2B and B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Public bodies must accept e-invoices, but no mandate B2G or B2B.
  • Additional Comments
    Real-time reporting obligation is in place in Hungary.

• Ireland B2B and B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Public bodies must accept e-invoices, but no mandate B2G or B2B. Find official notice here.

• Italy B2B

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    B2B and B2C eInvoicing is mandatory since January 2019.
  • Who is concerned?
    Mandatory for Italian established businesses. Find more information here.

• Italy B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    B2G eInvoicing is mandatory since 2014 (2015 for sub-central administrations).
  • Who is concerned?
    Mandatory for economic operators established or resident in Italy issuing invoices to Italian government departments. Non-Italian economic operators can issue invoices in paper or electronic form.

• Latvia B2B and B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Latvia plans to make e-invoicing mandatory both for B2G and B2B by 2025, according to Government's proposal.

• Lithuania B2B

• • E-invoicing mandate in place?
    No

• Lithuania B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Lithuania made B2G eInvoicing mandatory in July 2017, although from 8 April 2019, all suppliers to public contracting authorities are obliged to issue only EN-compliant eInvoices namely Peppol BIS Billing 3.0.
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices in the context of public procurement. It also applies to VAT-registered foreign companies. If a natural/legal person operating in the European Union has won the public procurement, they have the opportunity to submit invoices that meet the EU electronic invoice standard through the PEPPOL network.

• Luxembourg B2B

• • E-invoicing mandate in place?
    No

• Luxembourg B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Mandated B2G e-invoicing applies since March 2023. This requirement was implemented gradually, according to the following deadlines:
    - First, large businesses by 18 May 2022.
    - Secondly, medium-sized businesses by 18 October 2022.
    - Finally, the rest of the businesses by 18 March 2023.
  • Who is concerned?
    This obligation concerns national and foreign economic operators, suppliers of public bodies. Find more information here.

• The Netherlands B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Under discussion. To be introduced by 2024, but is currently postponed.

• The Netherlands B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The mandate applies to all contracts with a start date from 1 January 2017 onwards concerning the Dutch central government. The municipalities are not legally required to ask for electronic invoices from their suppliers. However, they have the possibility to set a requirement in their procurement contracts based on bilateral agreements.
  • Who is concerned?
    All suppliers to the Dutch central government. It also applies to VAT-registered foreign companies (not explicitly excluded). Suppliers to other public organizations other than the central government must check with those organizations the requirements in place in terms of e-invoicing.

• Norway B2B

• • E-invoicing mandate in place?
    No

• Norway B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Since 2 April 2019, it has been mandatory for all public contracting authorities to receive and process electronic invoices. In 2012, it became mandatory for the suppliers of central government entities to issue e-invoices.
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Poland B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Mandated B2B e-invoicing is approved, expected to be introduced by July 2024.
  • Who is concerned?
    Fixed establishments or established businesses in Poland. Find more information here.

• Poland B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    Economic operators are not required to submit e-invoices to public bodies.

• Portugal B2B

• • E-invoicing mandate in place?
    No
  • Additional comments 
    Although there is no mandate to issue B2B e-invoices, all invoices must be issued by a certified billing software. Certified billing and invoicing SAF-T obligations applies also to non-established VAT registered businesses. Find more information here and here.

• Portugal B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Start date: January 1, 2021 for large companies; and January 1, 2024 for Micro, small and medium companies
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Romania B2B

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Since 1 July 2022 for product categories considered of high risk of VAT fraud. General B2B e-invoicing mandate expected for January 2024
  • Who is concerned?
    Al companies involved in B2B transactions concerning the trade of product categories considered with high tax risk (susceptible to tax evasion). This includes foreign companies VAT registered in Romania. The referred categories include: fruit and vegetables, alcohol, construction, mineral products, clothing and footwear.
  • Additional Comments
    General mandate B2B e-invoicing is approved, and expected to be introduced by January 2024. Also, SAF-T obligation and e-transport systems are in place. Find more information here and here.

• Romania B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    B2G e-invoice implemented since 2020. 

• Serbia B2B

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The start date of the mandate was January 2023
  • Who is concerned?
    The mandate also impacts non-established VAT registered taxpayers with a local fiscal representative. 

• Serbia B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Start date was May 2022
  • Who is concerned?
    The mandate impacts all suppliers in the public sector. Find more information here.

• Slovakia B2B and B2G

• • E-invoicing mandate in place?
    No
  • Timeline and status
    There are plans to implement mandate B2G e-invoicing, but upon several delays, the project is still under discussion. Real-time invoicing obligation for B2G, B2B and B2C invoices are pending approval.

• Slovenia B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    There are plans to implement B2B e-invoicing, however, there is no specific timeline to introduce this mandate.

• Slovenia B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Mandate applies since 2015
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded).

• Spain B2B

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Plans to introduce mandated B2B e-invoicing are in progress. The obligation is already approved, however, the final schedule depends on the implementing regulation that is under preparation and approval.
  • Who is concerned?
    In principle, B2B e-invoicing will only be mandatory for established entities or foreign companies with a fixed establishment in Spain. Find more information here.

• Spain B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Mandate applies since 2015
  • Who is concerned?
    Generally speaking, all public entities’ suppliers are required to send electronic invoices. It also applies to VAT-registered foreign companies (not explicitly excluded). The obligation to issue an e-invoice depends on the specific public authority acting as contracting party. There are two scenarios of exceptions to issue an e-invoice, and it is up to the particular public administrations and implementing regulation to implement it or not: i) the value of the invoice is up to EUR 5,000, and ii) only temporarily, when there is a service invoice issued involving public administrations abroad.

• Sweden B2B

• • E-invoicing mandate in place?
    No
  • Timeline and status
    It was announced but no specific timeline confirmed at this stage.

• Sweden B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The mandate applies since 1 April 2019.
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices to all public sector contracting authorities. This refers to contracts subject to Public Procurement Act (LOU), the Act on Procurement in the Utilities Sectors (LUF), the Defence and Security Procurement Act (LUFS) and the Concession Procurement Act (LUK). It also applies to VAT-registered foreign companies (not explicitly excluded).

• UK B2B

• • E-invoicing mandate in place?
    No

• UK B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    Currently, it is only mandatory in the public health sector.

• Switzerland B2B

• • E-invoicing mandate in place?
    No

• Switzerland B2G

• • E-invoicing mandate in place?
    Yes
  • Timeline and status
    The mandate applies since 1 January 2016 for the Federal administration in contracts over CHF 5,000.
  • Who is concerned?
    Public entities’ suppliers are required to send electronic invoices. Not applicable to foreign companies.
  • Additional Comments
    Foreign suppliers: You can create your invoices with an Office application (e.g. Word, Excel) or with a straightforward accounting or invoicing program. Create the invoice as a PDF file and email it directly to the Federal Administration: Pdf-rechnung@efv.admin.ch