Mandatory E-Invoicing In Poland, Germany, Belgium, And France

The European Union is undergoing a major shift in how it approaches tax compliance, with several member states introducing mandatory e-invoicing. While the shared goal is to reduce fraud, the approaches to implementation differ greatly, reflecting each country’s unique tax system, infrastructure, and policy priorities.

This article explores the forthcoming e-invoicing mandates in Poland, Germany, Belgium, and France. It outlines the timelines, highlights the key aspects of each country’s approach, and provides practical insights to help businesses prepare for these changes.

Poland

Poland’s journey toward mandatory e-invoicing has encountered numerous delays, reflecting the complexity of implementing such a significant shift in tax infrastructure. The country has chosen a centralized e-invoicing model, requiring electronic invoices to be processed through the National e-Invoicing System, known as KSeF (Krajowy System e-Faktur). This government-operated platform serves as a hub for the issuance, receipt, and storage of electronic invoices.

KSeF has been available for voluntary use since January 1, 2022, giving businesses time to familiarize themselves with its functionality. However, the mandatory implementation of the system has been repeatedly postponed due to technical challenges and concerns about its impact on businesses. Originally scheduled to become compulsory by mid-2024, the rollout was delayed after an external audit revealed irregularities in the KSeF’s infrastructure.

Poland revised the implementation timeline in May 2024, establishing a phased approach. Under the updated schedule, KSeF will become mandatory from February 1, 2026 for businesses with a registered office or fixed establishment in Poland that reported sales exceeding PLN 200 million in 2025. For all other businesses, the obligation will take effect on April 1, 2026. This phased implementation is intended to ease the transition and allow businesses of varying sizes to adapt at their own pace.

Under the KSeF system, taxpayers will create structured invoices in XML format according to the e-Faktura FA(2) specifications, using their own ERP systems. These invoices will then be transmitted to KSeF via an API. Upon receipt, each invoice will be assigned a unique identification number and timestamp, ensuring authenticity and traceability. A structured electronic invoice not transmitted to KSeF will be regarded as not issued. The mandatory use of KSeF will apply exclusively to business-to-business (B2B) transactions. For consumer transactions, the use of KSeF will remain voluntary, allowing businesses the flexibility to choose the invoicing approach that best suits their operational needs.

To further support taxpayers during the transition to mandatory e-invoicing, the Ministry proposed several simplification measures in November 2024. One significant update will allow invoices to include attachments, reflecting feedback from key stakeholders, particularly energy, gas, and telecommunications providers. Micro-entrepreneurs—those issuing invoices with a total amount not exceeding PLN 450 per invoice and with total sales under PLN 10,000 in a calendar month—will be permitted to issue invoices outside the KSeF system until September 30, 2026. Additionally, certain specific requirements, such as including the KSeF number in payments for invoices issued via KSeF or through cash register systems, have been postponed to July 31, 2026. Taxpayers will have the option to issue invoices offline until the end of 2026, enabling businesses to create e-invoices even when technical issues prevent immediate submission to KSeF. However, these offline invoices must comply with the structured e-invoice format and be submitted to KSeF by the next business day to ensure compliance. Furthermore, a grace period has been established: no penalties for non-compliance with KSeF obligations will be imposed until the end of July 2026, offering additional reassurance to taxpayers during the adjustment phase.

A significant unresolved issue is the potential misalignment between Poland’s KSeF system and the European Union’s VAT in the Digital Age (ViDA) framework. From 2030, VIDA will require businesses to issue cross-border invoices in a standardized EU format. By 2035, this obligation will extend to domestic transactions in countries that choose to mandate e-invoicing for domestic sales. Poland’s KSeF system uses a more complex e-invoicing format than the EU standard, raising concerns that Polish businesses might need to invest additional time and resources to adapt their systems to comply with VIDA in the future.

Germany

In March 2024, Germany enacted a law requiring the use of electronic invoices for domestic B2B transactions. On October 15, 2024, the Federal Ministry of Finance published detailed guidelines for implementing this e-invoicing mandate, which will be rolled out gradually from 2025 to 2028.

Starting January 1, 2025, businesses involved in domestic B2B transactions must be capable of receiving electronic invoices. Germany defines an electronic invoice as one issued in a structured electronic format compliant with EN 16931 or in a format agreed upon by the issuer and recipient, provided it enables the correct and complete extraction of required information in line with EN 16931 or is interoperable with it. Germany’s widely used invoicing formats, ZUGFeRD and XRechnung, comply with the criteria for electronic invoices. The obligation to receive electronic invoices also extends to foreign e-invoicing formats such as the French Factur-X and Peppol-BIS Billing, which are compatible with EN 16931. The Finance Ministry emphasizes that the choice of format is a civil law matter that must be agreed upon by the contracting parties. The Ministry has also clarified that the requirement to receive electronic invoices can be met by providing an email inbox; it does not need to be a dedicated inbox solely for receiving e-invoices. However, contracting parties may agree on alternative permissible transmission methods.

The rollout of mandatory e-invoicing obligations in Germany will be implemented in phases. In 2025 and 2026, businesses may continue issuing paper invoices or electronic formats that do not comply with EN 16931 standards, as long as they have the recipient’s consent. Starting in 2027, companies with an annual turnover exceeding €800,000 in the previous year will be required to issue electronic invoices. These businesses can still use Electronic Data Interchange (EDI) systems instead of fully adhering to EN 16931 standards, provided the recipient agrees. From 2028 onward, all businesses in Germany will be required to issue electronic invoices, marking a complete transition to digital invoicing nationwide.

The e-invoicing obligation will apply exclusively to domestic B2B transactions. Businesses based in Germany will be required to issue electronic invoices for supplies taxable in Germany if the recipient is also located in the country. The mandate will not extend to business-to-consumer (B2C) transactions, certain exempt B2B transactions, invoices for amounts below €250, or tickets.

The guidelines do not mandate a specific method for transmitting e-invoices, leaving the decision to the contracting parties. Acceptable transmission methods include email, electronic interfaces, or download portals. While supplementary information may be included in an unstructured PDF attachment, all mandatory details must be contained within the structured data of the invoice. Contracts can also be attached, and for recurring obligations, a new e-invoice is necessary only when there are changes to mandatory invoice details.

The German e-invoicing mandate aligns with the European Union’s VAT in the Digital Age (ViDA) initiative, particularly the adoption of the EN 16931 standard. However, unlike some other European countries, Germany will not require e-invoice data to be reported directly to the tax authorities. Such a reporting obligation is expected to be implemented at a later stage.

Belgium

Belgium is preparing to implement a mandatory e-invoicing system for B2B transactions, starting January 1, 2026. This requirement will apply to all VAT-registered businesses that are established or have a fixed establishment in Belgium. Unlike other countries that adopt a phased approach based on company size or specific conditions, Belgium’s mandate will apply universally from the outset. E-invoices must be issued for all taxable transactions that are not exempt and are deemed to take place in Belgium.

Belgium distinguishes between structured electronic invoices and ordinary electronic invoices. An ordinary invoice includes all mandatory data and is issued and received in electronic form, such as a PDF. Starting January 1, 2026, ordinary electronic invoicing will no longer be allowed for transactions between VAT-registered Belgian businesses. Instead, businesses will be required to issue structured electronic invoices that comply with the EN 16931 standard. These invoices must use the PEPPOL BIS format or another EN 16931-compliant format agreed upon by the parties.

Belgium has adopted the PEPPOL network as the standard for exchanging structured electronic invoices. To connect to the PEPPOL network, businesses need to register with a certified access point provider. Structured electronic invoices must always be sent and received via the PEPPOL network unless both parties explicitly agree to use an alternative method.

To support businesses in the transition to mandatory e-invocing, the government has introduced several measures aimed particularly at small and medium-sized enterprises (SMEs) and self-employed individuals. Starting January 1, 2025, the investment allowance for digital infrastructure improvements will increase to 20%, encouraging businesses to upgrade their invoicing systems. Additionally, for taxable periods from 2024 to 2027, SMEs and self-employed individuals using subscription-based invoicing software can benefit from an increased expense deduction of 120%.

Belgium’s e-invoicing mandate aligns with the European Union’s ViDA initiative, particularly the adoption of the EN 16931 standard. Belgium has not yet proposed mandatory digital reporting requirements. Such a reporting obligation is expected to be implemented at a later stage.

France

France is preparing to introduce mandatory e-invoicing and e-reporting obligations, with a phased implementation starting in 2026. The reform is based on Law No. 2022-1157, which defines an electronic invoice as one that is issued, transmitted, and received in a fully digital format containing a minimum set of structured data.

The e-invoicing mandate will apply to domestic transactions between businesses established and registered for VAT in France. Certain transactions, such as those related to education, healthcare, and financial services, which are exempt from VAT and do not require invoices, are excluded. While foreign businesses without an establishment in France are not subject to the e-invoicing requirement, they may still need to comply with e-reporting obligations if they conduct taxable transactions in France.

Originally scheduled to begin on July 1, 2024, the rollout of the mandatory e-invocing was postponed. Under the revised timeline confirmed in Law No. 2023-1322, all businesses must be able to receive electronic invoices by September 1, 2026. On this date, large and intermediate-sized enterprises (known as Entreprises de Taille Intermédiaire or ETIs) will also be required to issue electronic invoices. Small and medium-sized enterprises will follow suit, with the obligation to issue electronic invoices taking effect on September 1, 2027.

The French government initially intended to provide a public invoicing portal, the Portail Public de Facturation (PPF), to manage the exchange of electronic invoices. However, in October 2024, it was announced that the PPF would not function as a free tool for issuing or receiving invoices. Instead, its role will be limited to maintaining a directory of recipients and serving as a tax data hub. Businesses will therefore need to use certified private Partner Dematerialization Platforms (PDPs) to handle their invoicing processes.

PDPs are certified service providers authorized by the French tax authorities to facilitate the issuance, transmission, and receipt of e-invoices. Businesses can choose a PDP from an official list of approved providers. These platforms validate invoices to ensure they comply with regulatory and technical standards, checking for any errors or missing information. After validation, the PDP transmits the e-invoice to the recipient’s platform and submits the required data to the public tax data hub. France allows e-invoices to be issued in three approved formats: Cross Industry Invoice (CII), Universal Business Language (UBL), and Factur-X. PDPs enhance seamless communication and interoperability by converting invoices into a format compatible with the recipient’s system.

In addition to e-invoicing, France is introducing e-reporting obligations for transactions not covered by the e-invoicing mandate. These include B2C sales and cross-border transactions, such as imports, exports, and intra-Community supplies and acquisitions. Foreign businesses that conduct taxable transactions in France and are required to charge French VAT will also need to comply with the e-reporting requirements. These obligations will follow the same phased timeline as the e-invoicing rollout.

The e-invoicing and e-reporting obligations also extend to businesses in French overseas departments such as Martinique, Guadeloupe, and Réunion, where VAT is applicable. However, businesses located in the French overseas collectivities, including French Guiana, Mayotte, New Caledonia, and French Polynesia, where VAT does not apply, are exempt from e-invoicing. These businesses may still be required to comply with e-reporting obligations for taxable transactions conducted in France.

Concluding remarks

Poland, Germany, Belgium, and France demonstrate diverse approaches to implementing mandatory e-invoicing. The most notable difference lies in their choice of data transmission models. Poland has adopted a centralized system, requiring businesses to exchange invoices through its National e-Invoicing System. In contrast, France plans to use private platforms to handle both invoice data reporting and exchange. Belgium has designated the PEPPOL network as the default standard for e-invoice exchange, whereas Germany will grant businesses complete freedom in choosing their invoice transmission methods. Neither Belgium nor Germany has introduced invoice reporting requirements yet.

The rollout timelines also vary significantly. Belgium has opted for a universal implementation, requiring all VAT-registered businesses to issue structured electronic invoices from the outset, without a phased approach. Meanwhile, the other countries have chosen gradual rollouts, with Germany’s particularly intricate transition rules standing out for their complexity.

There are additional differences regarding the impact of these measures on non-resident businesses. Companies holding local VAT registrations but without physical establishments in Poland, Belgium, or Germany will not be affected by these upcoming mandates. However, such businesses may be subject to France’s e-reporting requirements.

The opinions expressed in this article are those of the author and do not necessarily reflect the views of any organizations with which the author is affiliated.