E-invoicing Delays: France, Poland, Belgium, and Spain

Get ready to go digital! E-invoicing mandates are sweeping across Europe, promising efficiency and cost savings. But what if the deadlines aren't quite what they seem? This article explores the recent delays in these mandates using real-world examples from France, Poland, Belgium, and Spain.

Read on to discover insights from industry professionals Ellen Cortvriend (Partner - Leader PwC Center of Excellence on e-invoicing and e-reporting), Rafał Trojanowski (Head of Legal Compliance at Comarch) and Katya Kancheva (Business Solution Manager at Comarch). This article is based on the recent webinar “How to Navigate E-invoicing Postponements”, hosted by Comarch and featuring PwC.

E-invoicing in France: Shifting Deadlines

Initially, France aimed to implement a continuous transaction control invoicing/e-reporting model back in 2023. This ambitious plan offered two options:

• A revolutionary mandate for all taxpayers
• A gradual rollout between 2023 and 2025

The gradual rollout gained traction, but the 2023 deadline quickly proved unrealistic. COVID-related disruptions provided a convenient explanation for the initial delays, considering the significant resources e-invoicing implementation demands from governments and businesses alike.

A revised timeline emerged, pushing the mandate back to July 2024 for some and January 2026 for others, depending on company size. However, even this revised plan faced challenges. Delays in releasing essential documentation forced service providers to rely on simulations and assumptions, creating uncertainty for clients who craved concrete solutions for testing purposes.

Finally, in October 2023, just eight months before the scheduled go-live date, a new amendment arrived. This latest delay pushed the deadlines back further, offering some relief but also highlighting the challenges of planning under such shifting timelines.

France's e-invoicing saga serves as a prime example of the complexities involved in rolling out an electronic invoicing mandate. The current deadline of September 1, 2026 with a phased approach appears more feasible. It is worth noting that clear communication and realistic planning is crucial when implementing such large-scale initiatives.

E-invoicing in Poland: Early Start, Early Flaws, and a Delayed Implementation

Unlike France's initial delays, Poland opted for an early launch with a centralized clearance platform called KSeF. While Poland gets credit for starting the platform in a voluntary phase as early as Q4 of 2021, this move quickly revealed significant flaws in KSeF. Despite receiving an EU exemption allowing a January 2024 mandate, Poland, recognizing the need for further development, pushed back the go-live date to July 2024 – similar to France's initial plan.

However, even July 2024 seemed unrealistic. The voluntary phase exposed the need for extensive adaptations to KSeF, which were planned too close to the launch date. With a change in leadership, the Polish Ministry took a cautious approach, ordering an audit of the project's progress. This resulted in a significant delay, with the mandate now postponed to February 2026. This revised timeline includes a staggered rollout for smaller taxpayers.

KSeF 1.0 vs KSeF 2.0

In the meantime, the work on KSeF continues. This "second voluntary phase" allows companies to test the improved system, reducing the burden of adapting to a completely new system at the mandatory launch. This approach offers several benefits, particularly for multinational companies with limited resources. By implementing the changes in Poland before the official mandate, they can avoid overlapping implementations and potentially streamline the process.

Looking ahead, it's important to understand the differences between the current, limited-use version of KSeF and the upcoming, improved model. While some changes will focus on security and administrative tasks, others will directly benefit taxpayers.

These include:

• Offline Mode: Issuing invoices that are reported to KSeF but distributed separately with a QR code.
• Industry-specific Adjustments: Allowing attachments for specific invoice types requiring additional information.

B2B E-invoicing in Belgium: A Flexible Big-bang Approach

Belgium is taking a bold step towards digitalization with a mandatory e-invoicing mandate for most business-to-business transactions. This new regulation will require established Belgian VAT-registered taxpayers to issue and receive structured electronic invoices starting January 1, 2026.

The Belgian approach prioritizes both interoperability and flexibility. PEPPOL, a widely used standard in Europe and beyond, will be the default format for exchanging electronic invoices. However, businesses can choose alternative methods as long as both parties agree. Importantly, regardless of the chosen method, invoices must be in a structured electronic format, eliminating the use of PDFs or other non-standardized formats.

Big-bang implementation for companies of all sizes

Unlike some other European countries with phased rollouts, Belgium is opting for a "big-bang" approach. The mandate will apply to all company sizes, regardless of revenue or turnover. This simplifies implementation but may require more extensive planning, especially for smaller businesses.

Recognizing the potential challenges for smaller companies, the Belgian government has introduced a fail-safe option. Hermes, a dedicated system, allows suppliers to translate structured electronic invoices into PDFs. These PDFs can then be easily integrated into the accounting software used by many smaller businesses.

While the initial model doesn't require direct exchange of invoice data with the government, this might evolve in the future. As e-invoicing becomes more established, Belgium might introduce additional reporting requirements, potentially integrating with the PEPPOL network.

B2B E-Invoicing in Spain: Mandate Delay for Harmonization

Spain's journey towards mandatory e-invoicing for B2B transactions has taken an interesting turn. While initially planning a clearance model that differed from the European Commission's ViDA harmonization initiative, Spain has revised its approach to align with the broader European vision.

This new model, enforced through the "Ley de Creación y Crecimiento de Empresas" (Law for the Creation and Growth of Companies), will require Spanish VAT payers to issue and receive electronic invoices. The scope primarily covers:

• Spanish businesses
• Spanish professionals
• Businesses with a fixed establishment in Spain (with some potential exceptions)

The heart of the new model lies in the decentralized CTC exchange model championed by ViDA. This system leverages certified service providers (CSPs) to connect with a public electronic invoicing solution, similar to the approach used in France. Businesses can choose between:

• The government-developed Fattura E solution (already familiar from B2G invoicing)
• Certified alternative solutions (must be interoperable and handle approved formats)

Spain's e-invoicing mandate goes beyond just issuing invoices. It also requires capturing:

• Response messages from buyers regarding acceptance or rejection of invoices
• Payment completion information

This ensures a more comprehensive electronic record of transactions.

The exact implementation date remains uncertain. The mandate hinges on the publication of a Royal Decree in the Official Gazette, which is expected sometime in 2024. This could potentially lead to a July 2025 launch at the earliest. Additionally, a staggered rollout is planned, with large taxpayers facing earlier compliance deadlines than their smaller counterparts.

E-invoicing Delays: A Complex Balancing Act

France, Poland, Belgium, and Spain's journeys towards e-invoicing mandates reveal the challenges involved. Complex models, such as those in France and Poland, can lead to delays as unforeseen issues arise. Political shifts can further disrupt timelines, as seen in Poland and Spain where new administrations reassessed plans.

The upcoming ViDA initiative, promoting harmonization across Europe, offers hope for a smoother future. However, its impact on national timelines remains uncertain.

These delays highlight the complexities of e-invoicing mandates. Striking a balance between model complexity, government goals, and political stability will be key to a successful European-wide transition.

In the meantime, businesses can leverage a trusted e-invoicing platform that ensures readiness for the mandates, regardless of the final go date. Comarch e-Invoicing delivers this advantage while being a certified PEPPOL Access Point. Don't wait until deadlines loom – consult with our experts now for early and ongoing compliance support.