E-Invoicing in Europe: Harmonised standard and national fragmentation
25 March

E-invoicing in Europe: Harmonised standard and national fragmentation

the E-bill is no longer a niche topic in Europe. With Directive 2014/55/EU and the technical standard EN 16931, the EU has created a common framework - but in practice, the picture is much more complex. Companies that operate across borders are faced with a multitude of national platforms, formats and deadlines that differ considerably from one another despite having a common basis. This article provides a structured overview of the current status of the e-invoicing landscape in Europe.

Read more: E-Rechnung in Europa: Harmonisierter Standard und nationale Fragmentierung

EN 16931 as a common denominator - and its limits

The EN 16931 standard defines the semantic data model for e-invoices in Europe. It specifies what information an invoice must contain in order to be machine-readable and legally recognised across borders. It therefore forms the basis for interoperable systems and simplifies cross-border trade considerably - at least in theory.

EN 16931 as a common denominator

In practice, however, the member states supplement this standard with national CIUS specifications (Core Invoice Usage Specifications). Portugal uses the CIUS-PT, Romania the RO_CIUS, Croatia its own national CIUS. Each of these specifications prescribes additional mandatory fields, specific syntaxes or different validation rules. As a result, for ERP systems considerable customisation effort, even if the underlying standard is the same. Technically speaking: EN 16931 harmonises the semantics, but not the operational implementation.

Two models, one goal: centralised platforms vs. decentralised networks

Looking at the implementation models in Europe, two basic approaches can be distinguished: the centralised platform approach and the decentralised network model.

The Italian SDI as a model for interoperability

Italy pursues the most consistent centralised approach. The „Sistema di Interscambio“ (SDI) is the only approved platform for exchanging electronic invoices – mandatory for B2G since 2014, for B2B and B2C since 2019, and since January 2024, also for micro-enterprises without exception. A particular technical feature worth noting is that the SDI acts as a conversion instance, automatically translating European standard formats into the national FatturaPA format. This eliminates the need for manual format adjustments for incoming invoices from abroad. The EU Council extended the authorisation to use the SDI system until the end of 2027, underscoring the strategic importance of this model.
Romania follows a similarly strict approach: The „RO e-Factura“ platform mandates a submission deadline of just five calendar days after invoicing. Significant fines are threatened in case of delay. The B2B mandate has been in force nationwide since January 2024, and for high-risk sectors such as alcohol and construction, it has been in place since July 2022.

Northern Europe and the Baltic States: Peppol as the backbone

Sweden, Finland, Luxembourg and the Baltic states Conversely, they are opting for decentralised models based on the Peppol infrastructure. Peppol uses the so-called „four-corner model“: senders and recipients communicate via certified access points, without a state platform acting as an intermediary.
Finland shows where this path can lead: 99 per cent of invoices to public buyers are already electronic. The state service centre Palkeet processes the invoices centrally, but accepts several formats - Finvoice 3.0, TEAPPSXML 3.0 and Peppol BIS Billing 3.0. Luxembourg has fully completed its B2G mandate since March 2023; the invoice volume increased from less than 100 invoices in 2021 to 1.4 million in 2024.
Sweden in turn deliberately avoids special national approaches and relies consistently on Peppol BIS Billing 3.0 - with the declared aim of minimising the implementation effort for companies.

Country-specific mandates at a glance - what companies need to know now

Already active B2B obligations

Next to Italy and Romania has also Hungary We were an early adopter of digital transaction control. Real-Time Invoice Reporting (RTIR) via the NAV system has been recording all B2B and B2C transactions subject to VAT in real time since 2018. Under certain conditions, XML data from the RTIR can function directly as a legally valid e-invoice.
Estonia is taking a different path from July 2025: The so-called „Buyer's Choice“ principle allows all entities registered in the Commercial Register to request electronic invoices – which is effectively equivalent to a universal B2G and B2B mandate. Furthermore, a general obligation for all VAT-liable B2B transactions is planned by 2027.

Mandates 2025-2028

Croatia A comprehensive B2B mandate will be implemented from 1 January 2026, with a testing phase starting in September 2025. As part of the „Fiskalizacija 2.0„ reform, near real-time reporting will also be introduced. For micro-suppliers with fewer than 250 invoices per year, the state will provide the “MICROeINVOICE" application.
Portugal requires a qualified electronic signature (QES) for PDF invoices from January 2026. The B2G mandate has been mandatory for SMEs since January 2025
Lithuania With the new SABIS platform, its B2G system has been completely converted to a „Four Corner“ model since September 2024. An expansion to B2B is planned by January 2028 – explicitly with the aim of ViDA conformity.

ViDA: The next development step at EU level

Behind many of these national e-invoicing plans in Europe is an overarching EU project: the „package"VAT in the Digital Age (ViDA). ViDA will establish e-invoicing as the mandatory standard for cross-border transactions within the EU and simultaneously harmonise digital reporting obligations. This fundamentally shifts the nature of e-invoicing compliance: instead of reactive adaptation to individual national requirements, companies must build a strategic digital infrastructure that can seamlessly serve both centralised clearinghouse models and decentralised Peppol networks.

VAT in the Digital Age (ViDA) Timeline

For companies that are active in several EU countries, this results in a clear priority for action: the question is no longer, whether e-invoicing obligations, but How fast provide its own ERP systems and processes with the necessary flexibility for a fragmented but increasingly networked European compliance landscape.

Comparison of e-invoicing regulations in EU member states

Status: 2024/2025 - All information without guarantee

Country Competent authority B2G mandate B2B mandate B2C mandate Standard & Formats Platform / operating model Real-time VAT reporting Source
Italy Ministry of Economy and Finance, Tax Authority Yes
since 2014/2015
Yes
since 2019
Yes
since 2019
EN 16931, FatturaPA (XML) Sistema di Interscambio (SDI) Yes 1, 2
Romania Ministry of Transport and Communications Yes
since 2020
Yes
since Jan 2024
Yes
since Jan 2025
EN 16931, RO_CIUS (UBL 2.1, CII) RO e-Factura Yes
Notification within 5 days
3
France Ministry of Finance, AIFE, DGFiP Yes
since 2020
Planned
Phase-in from Sept 2026
No EN 16931, UBL 2.1, CII, Factur-X Chorus Pro Planned
from Sept 2026
2, 4
Germany Federal Ministry of Finance Yes Partially
Obligation to receive from Jan 2025, issue gradually from 2027
No EN 16931, XRechnung, ZUGFeRD 2.x Decentralised (ZRE, OZG-RE, route ID) No 2, 5
Belgium Federal Public Service Policy and Support (BOSA) Yes Planned
from 01.01.2026 for VAT payers
No EN 16931, Peppol BIS Billing 3.0 Mercurius, Peppol network Planned
for 2028
2, 6
Poland Ministry of Finance Yes Planned
Mandatory from 2026
No EN 16931, Peppol BIS Billing 3.0 PEF, KSeF (integrated from 2026) Planned
from 2026 via KSeF
7
Croatia Ministry of Economic Affairs Yes
since July 2019
Planned
expected from Jan 2026
No EN 16931, UBL 2.1, CII Servis eRačun za državu (FINA) Planned
Fiscalisation 2.0 from 2026
2, 8
Portugal Ministry of Finance, Autoridade Tributária Yes
since 2021 for large companies, from 2025 for SMEs
In development / ViDA No EN 16931, CIUS-PT (UBL 2.1, CII) Portal BASE, FE-AP (eSPap) Yes
since 2013
2, 9
Greece Ministry of Finance, IAPR Partially
gradually from 2024/2025
Planned
Legislation expected
No EN 16931, Peppol BIS Billing 3.0 KE.D (National Interoperability Centre), myDATA Yes
About myDATA
2, 10
Spain Ministry of Economy, Ministry of Finance, AEAT Yes
since Jan 2015
Planned
Mandate on Law 18/2022 in preparation
No EN 16931, Facturae (XML, XAdES) FACe, FACeB2B Yes
SII system
11
Denmark Danish Business Authority Yes Planned
Digital accounting obligation from 2026
No EN 16931, OIOUBL, Peppol BIS 3.0 NemTrade Yes
via certified accounting systems
2, 12
Hungary National Tax and Customs Administration (NAV) Partially
Obligation for authorities to receive since Nov 2019
Partially
except energy supply from July 2025
No EN 16931, XML NAV Online Invoicing System Yes
RTIR system
2, 13
Estonia Ministry of Finance Yes
Buyer's choice principle since July 2025
Yes
Buyer's choice principle since July 2025
No EN 16931, Estonian XML standard Decentralised model (via private service providers) No 2, 14
Finland State Treasury Yes Partially
Right to e-invoice from €10,000 turnover
No EN 16931, Finvoice 3.0, TEAPPSXML 3.0, Peppol BIS 3.0 Centralised (via service provider and Handi-Service) No 2, 15
Latvia Ministry of Finance Yes
since Jan 2025
Planned
Mandatory from Jan 2028
No EN 16931 eAddress (VDAA) Planned
from 2026/2028
16
Austria Federal Ministry of Finance Yes
since April 2020 for federal authorities
In development / ViDA No EN 16931, ebInterface, UBL 2.1, CII Company service portal (USP), e-Rechnung.gv.at No 2, 17
Slovakia Ministry of Finance Yes
since Aug 2019
Planned
from Jan 2027
No EN 16931, UBL 2.1, CII IS EFA (will be replaced by Peppol solution) Planned
from Jan 2027
18
Iceland Ministry of Finance and Economy Partially
Obligation for authorities to receive since Jan 2020
Yes Yes EN 16931, Peppol BIS Billing 3.0, TS-236 Peppol eDelivery Network No 19
Sweden Digital Administration Agency (Digg), Tax Authority Yes
since April 2019
No No EN 16931, Peppol BIS Billing 3.0 None (decentralised access points) No 20
Luxembourg Ministry for Digitalisation Yes
since March 2023
No No EN 16931, Peppol BIS Billing 3.0, UBL 2.1, CII Peppol network, guichet.lu No 21
Lithuania Ministry of Economic Affairs Yes
since July 2017
Planned
from 2028
No EN 16931, Peppol BIS 3.0, CII SABIS (formerly eSąskaita) No 22
Norway Ministry for Digitalisation, DFØ Yes No No EN 16931, EHF (Elektronisk Handelsformat), Peppol BIS 3.0 Peppol eDelivery Network, ELMA register No 23
Netherlands Ministry of the Interior, Logius, RVO Partially
Mandate for central government
No No EN 16931, NLCIUS, Peppol BIS 3.0, UBL-OHNL, SETU Digipoort, Peppol network No 24
Czech Republic Ministry of Finance, Ministry of the Interior Partially
Obligation for authorities to receive since Oct 2016
In development / ViDA No EN 16931, ISDOC, UBL 2.1, EDIFACT Národní elektronický nástroj (NEN) No 2, 25
Bulgaria Ministry of Transport, Information Technology and Communications Partially
Obligation for authorities to receive since Nov 2019
In development / ViDA No EN 16931, UBL 2.1, CII CAIS EPP No 2, 26
Cyprus Ministry of Finance Partially
Obligation for authorities to receive since April 2019/2020
In development / ViDA No EN 16931, Peppol BIS Billing 3.0 Cyprus Government Gateway Portal (gov.cy) No 2, 27
Ireland OGP, Office of the Revenue Commissioners Partially
Obligation for authorities to receive since June 2019
No No EN 16931, Peppol BIS Billing 3.0 Peppol eDelivery Network No 28
Malta Ministry of Finance, Tax Administration Partially
Obligation for authorities to receive since Nov 2018
No No EN 16931, Peppol BIS Billing 3.0 None (use of the Peppol network) No 29
Liechtenstein Ministry of Presidential Affairs and Finance Partially
Obligation to receive for authorities
No No EN 16931, XML None (submission by e-mail) No 30

Implementing e-invoice compliance in SAP Business One

SAP Business One offers several tools that build on each other for the variety of e-billing requirements in Europe described above - but with varying scope depending on the target country.

ZUGFeRD and EN 16931: the native basis

SAP Business One can process e-invoices in ZUGFeRD-format. The ZUGFeRD 2.4 EN 16931 profile corresponds directly to the European standard and therefore fulfils the basic technical requirements for the B2G area as well as for countries that do not prescribe any national specifications that go beyond this. This profile is therefore the sensible starting point for many Central European applications.

Peppol integration via the Versino Financial Suite

For decentralised networks and cross-border transactions – particularly for countries like Sweden, Finland, Luxembourg, or the Baltic states – Peppol integration in SAP Business One covers the „Four-Corner Model“. The Versino Financial Suite connects SAP Business One to the Peppol network, supporting both inbound and outbound invoices, credit notes, and debit notes. The integrated „Electronic Document Monitor“ allows for central management and status tracking of all transferred documents.

National CIUS specifications: Add-ons and SDK

For countries with their own platforms and formats - such as FatturaPA in Italy or RO e-Factura in Romania - the native standard alone is not sufficient. SAP Business One offers the necessary flexibility via its SDK and partner solutions to transform the standardised SAP1 documents into the respective national format. However, this step usually requires country-specific add-ons or integration scenarios that go beyond the standard scope of delivery.

Master data as a foundation

Regardless of the target country, an e-invoicing implementation stands and falls with the quality of the master data. Correct tax numbers and tax codes in the business partner master data, consistent article data and properly configured account determination and VAT groups are the prerequisites for ensuring that incoming and outgoing e-invoices are processed automatically and without errors. Subsequent corrections due to inconsistent master data cause the very manual effort that e-invoicing is supposed to eliminate.

Archiving and reconciliation

In addition, audit-proof archiving of all transmitted and received e-invoice files is recommended - ideally with direct document reference in the respective SAP B1 document. In addition, the VAT-relevant transactions posted in SAP Business One should be regularly compared with the data reported via the e-invoicing platforms. This ensures consistency and compliance in the long term and considerably simplifies external audits.

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