An Overview of E-invoicing Mandates in 2024: European Union

Numerous countries are currently in the midst of the complex process of implementing e-invoicing and e-reporting mandates, progressing from initial drafting phases, undergoing public consultations, and executing those mandates for diverse business sectors. The adoption of electronic invoicing plays a big role in global digitization initiatives and in combating the VAT gap and tax fraud. How are EU countries approaching these changes in tax legislation?

E-invoicing in Romania

The implementation of the e-invoicing mandate in Romania commenced on January 1, 2024. Since this date, all business-to-business (B2B) invoices issued by companies established in Romania have been required to be reported via the RO-eFactura system, a live reporting platform. The grace period for non-compliance with invoice reporting ends on March 31, 2024. From July 1, 2024, the obligation to issue invoices through the RO-eFactura system will be fully enforced.

To utilize the RO-eFactura system, it is advisable to do so via a third-party solution provided by a reliable provider capable of generating compliant invoices in the XML format required by the Romanian tax administration. Each invoice submitted to the RO-eFactura system undergoes validation and returns an assigned XML invoice, which is considered validated and suitable for accounting purposes.

The Romanian e-invoicing mandate was swiftly established and understood by businesses utilizing service providers. It applies to taxpayers established in Romania and those registered in Romania, as well as non-resident businesses holding a Romanian VAT number.

Additionally, regarding the e-reporting requirements, businesses operating from the US, EU, or UK with a Romanian VAT number should seek advice regarding the implications of this mandate. Failure to adhere to these regulations will incur penalties, the severity of which may vary based on the size of the company.

There’s more you should know about e-invoicing in Romania – learn more about the new and upcoming regulations.

E-invoicing in Poland

Poland’s National e-Invoicing System, KSeF, initially operated as a voluntary solution, with plans for full implementation of the e-invoicing mandate scheduled for July 1, 2024. However, the Polish Minister of Finance has raised concerns about this timeline. The original KSeF system was plagued by critical errors that rendered it incapable of supporting all business-to-business (B2B) and business-to-government (B2G) e-invoicing requirements. Once the Ministry of Finance ensures the portal's functionality and conducts an audit, a new implementation date will be announced, most likely for 2025.

The postponement of the 2024 deadline grants companies additional time to prepare for forthcoming changes. Regarding the scope of the B2B invoicing mandate, it will apply to companies established in Poland. Therefore, it is essential to ascertain the type of companies operating in Poland to determine if the invoicing mandate is applicable.

The use of the FA(2) structure and XML format is obligatory. Additionally, once an invoice is submitted to KSeF, it undergoes validation and receives an ID number to confirm official validation before transmission to the recipient. It's noteworthy that KSeF does not permit attachments, necessitating the establishment of external systems or procedures in cases requiring attachments.

Furthermore, the Polish Ministry of Finance has established protocols for sending invoices in the event of KSeF failure. 

As a new mandatory e-invoicing implementation date for Poland has yet to be determined, and it is important to stay informed about current developments.

There’s more you should know about e-invoicing in Poland – learn more about the new and upcoming regulations.

E-invoicing in France

The e-invoicing mandate in France was originally scheduled for implementation on July 1, 2024, similar to Poland, but has been postponed until September 2026.

France has introduced two main obligations:

• Mandatory B2B invoicing, applicable for domestic transactions. Companies are required to issue invoices using one of 3 formats: UBL, CII, or Factur-X. Factur-X is a PDF format that incorporates XML data
• E-reporting, applicable for non-domestic B2B invoicing data, B2C transactions, and payment data. These data must be transmitted to the French tax administration in a new XML format defined by the authorities

Companies have two options for sending and receiving invoices:

• Using a third-party or platform dematerialization partner (PDP)
• Utilizing the public invoicing portal (PPF)

All VAT group members, including small companies within the group, are required to issue electronic invoices. Mandatory invoicing also extends to inbound invoices, regardless of the company's size.

Medium-sized and small companies are mandated to commence e-invoicing processes by September 2027.

In January 2024, the French tax administration published the list of registered candidates for PDP status, and Comarch is one of them. Now, registered companies will undergo external audits to ensure compliance with the mandated solutions.

It’s worth noting that the success of the mandate relies on every PDP being interoperable with each other. This interoperability ensures seamless transactions between trading partners across different service providers.

The extended timeline is essential, as it allows the French tax authorities to examine specific use cases, refine guidance and technical information, develop core infrastructure, and enable service providers to design, test, and implement solutions. Additionally, it provides businesses with ample time to plan and implement e-invoicing processes effectively.

There’s more you should know about e-invoicing in France – learn more about the new and upcoming regulations.

E-invoicing in Belgium

Belgium introduced a B2G e-invoicing mandate using PEPPOL, which has been in effect since 2023. However, there's an update regarding a broader B2B invoicing mandate in the country.

In February 2024, the Belgian parliament approved the adoption of the obligatory B2B e-invoicing. Companies will be obliged to issue and receive e-invoices starting from January 2026. Notably, this project specifies that e-invoicing will not be mandatory for B2C transactions, aligning with Belgian VAT regulations. Belgium submitted a derogation request to the European Commission in October 2023, awaiting approval to proceed with this invoicing initiative.

To help businesses comply with the invoicing mandate, Belgium is announcing various measures. These include anticipated tax deductions for investments related to invoicing projects and temporary tax support available for SMEs.

This invoicing mandate will apply to most taxpayers registered for VAT in Belgium. The draft law outlines certain exclusions for taxpayers and transaction types exempt from mandatory invoicing. Belgium plans to introduce structured invoicing, promoting the PEPPOL UBL format as the preferred format for exchange alongside any other EU-standard compliant formats. As of January 2026, using PDF invoices or non-structured formats will no longer be permissible.

Belgium intends to leverage the PEPPOL network for invoice exchange and provide the existing Hermes system if the recipient is unknown in the PEPPOL network.

Regarding e-reporting, the Belgian Tax Administration may await further information from the VAT in the Digital Age (ViDA) initiative before introducing an e-reporting obligation for non-domestic invoices.

Thanks to the already high adoption of PEPPOL, businesses can easily comply with the government mandate by connecting to an accredited PEPPOL service provider and obtaining a PEPPOL ID number. With approximately 750,000 businesses already on the network, wider mandates incorporating PEPPOL will naturally expand its reach. Notably, PEPPOL, initially introduced for public procurement, is now widely used for B2B invoice exchange, with the PEPPOL UBL format compliant with the European invoicing standard EN 16931. The international adoption of the PEPPOL invoice format is expected to increase in the future.

There’s more you should know about e-invoicing in Belgium – learn more about the new and upcoming regulations.

E-invoicing in Germany

In Germany, a country boasting a vast economy and high GDP, numerous companies will be affected by an e-invoicing mandate. Germany already exhibits a significant voluntary adoption of e-invoicing, particularly leveraging legacy EDI technologies and formats.

From January 2025, all companies must be prepared to receive invoices, with no specific requirements regarding the format of these invoices provided by suppliers.

Additionally, there's a planned obligation to issue invoices implemented in two stages:

• The first stage, commencing from January 2027, will apply to companies with a turnover exceeding €800,000
• The second stage, encompassing other entities, will be enforced from January 2028

Regarding EDI exchanges, the initial draft of the law suggested discontinuing EDI exchanges in Germany. However, it appears that EDI exchanges will remain possible until the end of 2027 concerning formats and networks for invoice exchange. Germany, like other EU countries, intends to utilize formats that are compliant with EU standards, including EDIFACT.

Germany does not plan to introduce a clearance model or a national portal, leaving it to companies to find methods for invoice exchange. This approach may pose challenges for achieving interoperability if companies opt for different formats and channels for invoice exchange.

When Germany submitted its application for a derogation to mandate broader B2B invoicing, it was done shortly before the draft feeder directives were published. This indicates a decentralized approach compliant with the European invoicing standard, leveraging existing German formats and standards, such as XRechnung supported on the PEPPOL network, and ZUGFeRD, a hybrid PDF with embedded XML, akin to the Factur-X invoice in France. These formats facilitate human readability while enabling systems to automate processing.

However, the new timeline presented here does not align with the current derogation. Consequently, Germany may need to seek a new derogation or amend the existing one.

There’s more you should know about e-invoicing in Germany – learn more about the new and upcoming regulations.

E-invoicing in Spain

In Spain, the e-invoicing mandate necessitates the verification of software for compliant issuance of invoices. The obligation concerning the adoption of ERP or software for invoice creation, VeriFact, will be effective from July 2025 for taxpayers established in Spain. It's important to note that this obligation will only apply to taxpayers not utilizing SII (Immediate Supply of Information) in Spain. Therefore, entities already adhering to SII requirements are exempt from it.

Taxpayers will have two options to issue compliant invoices using certified or compliant software:

• Continue using their ERP or other software, provided it meets compliance standards
• Utilize a computer application potentially developed by the tax administration to aid compliance

Several technical requirements are expected from the system or ERP, including:

• Ensuring the integrity and authenticity of invoices
• Archiving
• Event logging
• Creating hash or fingerprint security measures
• Incorporating QR codes on invoices

Moreover, private service providers intending to issue invoices in Spain must offer interoperability, ISO 27001 certification, electronic signature, support provision, and ensure near real-time availability. Compliance with these requirements is essential to avoid penalties. This requirement doesn't solely concern invoicing but mandates the use of certified or accredited software, akin to Portugal's regulations, where certified software is obligatory for all invoicing.

Portugal’s regulations apply universally to all invoicing, electronic or not, with minimum standards ensuring authenticity, integrity, and traceability. Many elements observed here are already being incorporated into individual tax authorities' mandates. For instance, requirements around hashes, QR codes, and data integrity are present in the legislation of the Kingdom of Saudi Arabia.

In Spain, the implementation of broader B2B invoicing was expected in 2024, following a timeline similar to France's with possible delays. However, there isn't a singular set of requirements; businesses must assess the situation holistically. Currently, Spain already has a B2G mandate and networks such as the FACe network for exchanging invoices with government entities. Additionally, the FACeB2B network, initially intended for subcontractors within public procurement, is also used by businesses for voluntary e-invoice exchange. The general e-invoicing mandate will likely extend to interactions with the tax authority. The final timeline for this mandate awaits publication in the official gazette, expected in Q2 2024.

Four formats are acceptable for issuing invoices, but only “Facturae” will be permitted for use on public or national portals. Notably, taxpayers will be obliged to manage various invoice lifecycle stages, including acceptance, rejection, and payment submission, within a specified timeframe. As plans in Spain are still in the draft stage, businesses should closely monitor updates, guidance from tax authorities, and forthcoming legislation.

There’s more you should know about e-invoicing in Spain – learn more about the new and upcoming regulations.

E-Invoicing mandate preparation with Comarch

Not without their own set of challenges, many countries are progressing in their move towards mandatory e-invoicing. If you're seeking a system to facilitate compliance with evolving tax legislation, consider Comarch e-Invoicing. Explore our solution, enabling compliant data exchange in over 60 countries, by visiting our website or scheduling a discovery call with our specialists today.