Since 1 January 2026, a Belgian VAT-registered business that invoices another one has to issue a structured e-invoice. A PDF by email no longer counts. If your customers are also in Germany or France, you meet two more sets of rules, and they are built differently.
Below are the rules as of 8 October 2026. Enacted law and proposals are labelled separately. We built Peppol support for Belgium, the Netherlands, Luxembourg and the Nordics and researched France for our Qonto integration, so those rows are first-hand. The other countries come from published sources, listed at the end.
Four models
A decentralised network (Peppol). You send a structured invoice through an access point, and the recipient's access point delivers it. The tax authority is not in the middle. Belgium, the Netherlands, Luxembourg, Sweden and Norway work this way, and the UK is expected to.
Clearance or reporting through the tax authority. A state system validates the invoice, or receives a report of it, before or as it reaches the buyer. Italy (SdI), Poland (KSeF), Romania (RO e-Factura) and Greece (myDATA) work this way. You cannot withdraw a cleared invoice, so a correction is always a new document.
Certified private platforms. France routes invoices through Plateformes Agréées, platforms approved by the tax administration, and not through Peppol.
Format only. Germany mandates the format (EN 16931) and leaves transport to you. Email is fine if the attachment is XRechnung or ZUGFeRD and not a plain PDF.
Where each country stands
| Country | Model | Status on 8 October 2026 |
|---|---|---|
| Belgium | Peppol | B2B mandatory since 1 January 2026 |
| France | Certified platforms | Receiving mandatory for everyone, and issuing for large and mid-size companies, since 1 September 2026. SMEs and micro-enterprises from 1 September 2027 |
| Germany | Format only | Receiving mandatory since 1 January 2025. Issuing from 1 January 2027 if the previous year's turnover was above €800,000, from 1 January 2028 for everyone |
| Italy | Clearance (SdI) | B2B mandatory since 2019 |
| Poland | Clearance (KSeF) | Mandatory since 1 February 2026 for the largest companies and 1 April 2026 for most others. Smallest taxpayers from 1 January 2027 |
| Spain | Platform and format | Royal Decree 238/2026 published 31 March 2026. Deadlines start from a ministerial order that is not final |
| Romania | Clearance (RO e-Factura) | B2B mandatory. Penalty-free window for small businesses ended 1 July 2026 |
| Greece | Clearance (myDATA) | Large companies since 2 March 2026. Everyone else moved from 1 October to 2 November 2026 |
| Netherlands | Peppol | No B2B mandate. B2G over Peppol since 2017. A domestic B2B mandate is only recommended |
| Luxembourg | Peppol | B2G universal since March 2023. B2B bill no. 8815 proposed: receiving 1 January 2028, issuing 1 July 2028 (large and medium) and 1 January 2029 (rest). Not enacted |
| Sweden | Peppol | B2G since 2019. B2B undecided, inquiry reports by 30 November 2027 |
| Norway | Peppol | B2B issuing from 1 January 2027 and receiving from 1 January 2030, in a bill before parliament |
| Denmark | NemHandel and Peppol | Bookkeeping systems must be able to send and receive structured invoices. Format moves from OIOUBL to a Peppol BIS 4 based one by about 2029 |
| Finland | Operator networks and Peppol | A buyer with turnover above €10,000 can demand a structured invoice. No general mandate |
| United Kingdom | Peppol expected | B2B and B2G mandate announced for April 2029, details pending |
ViDA is the EU-wide rule: e-invoicing and digital reporting become mandatory for cross-border B2B from 1 July 2030, and domestic systems have to align by 1 January 2035.
If you invoice across borders
The national mandates above bind businesses established in that country. What a Belgian seller owes a German or French customer before 2030 is a question we have not verified for each case, so ask your accountant for the transaction in front of you.
What we can say: a Peppol BIS Billing 3.0 invoice follows EN 16931, the standard behind Germany's definition of an e-invoice, so it is the format a German customer's software is most likely to accept. Whether it actually does is a question for that customer. France's mandate runs through certified platforms and not Peppol, although some French companies are reachable on both, so ask a French customer which address they receive on.
Penalties and exceptions
Belgium. Peppol BIS Billing 3.0 is the default format, and other formats are allowed only if both parties agree. A three-month tolerance period for businesses that could show reasonable efforts to comply ended on 31 March 2026. Fines are €1,500, €3,000 and €5,000 for successive infringements.
France. The reform has two parts. E-invoicing covers domestic B2B, in Factur-X, UBL or CII. E-reporting covers everything else: consumer sales, cross-border B2B, and payment data for services. The Finance Act for 2026 sets the fine at €50 per non-compliant invoice and €500 per missed e-reporting transmission, each capped at €15,000 a year. A company with no platform to receive invoices gets a formal notice first.
Germany. Until the end of 2026 you can still issue paper or PDF invoices with the recipient's consent. If your turnover in 2026 was under €800,000, that extends through 2027. XRechnung and ZUGFeRD are accepted, except the ZUGFeRD MINIMUM and BASIC-WL profiles. Invoices under €250 are exempt. The fine is up to €5,000 under section 26a UStG and requires intent or recklessness. The more practical risk is the recipient losing the input VAT deduction. Financica reads Factur-X and ZUGFeRD invoices without OCR.
Italy. A rejected invoice counts as not issued. Since 1 September 2024 the general penalty for an undocumented transaction is 70% of the VAT, down from 90% to 180%. If the VAT still went into the periodic settlement, the fine is a flat €250 to €2,000 instead, which is the usual outcome for a late invoice.
Poland. Penalties for KSeF failures are scheduled to start on 1 January 2027. A draft bill published in September 2026 would move that to 1 January 2028, and it is not law. The ceiling is 100% of the VAT on an invoice issued outside KSeF, or 18.7% of the amount due when no VAT is shown.
Spain. The decree covers B2B between businesses established in Spain, and recipients must report each invoice's status back, including payment. The deadline is 12 months after the ministerial order for companies above €8 million turnover and 24 months for the rest. The tax agency's calendar is reported to put the first deadline in October 2027. The Verifactu rules for invoicing software are a separate regime.
Romania. Late-submission fines run from RON 1,000 to RON 10,000 depending on the size of the taxpayer. An invoice issued outside the system can cost 15% of its value. Since Law 88/2026, invoices to private individuals identified only by a personal number generally no longer have to go through the system.
Greece. The second phase was postponed on 30 September 2026. From 2 November 2026 to 31 January 2027 you may keep your existing systems, and from 1 February 2027 invoices must go through a certified provider or the tax authority's free apps. Failing to transmit a transaction with VAT can cost 50% of the VAT.
What Financica covers today
Peppol sending and receiving is available in Belgium, the Netherlands, Luxembourg, Sweden, Norway, Denmark and Finland. In Denmark and Finland, confirm that your counterparty is reachable over Peppol first, because some recipients only receive over NemHandel or Finvoice. France is in progress through Qonto's certified platform. We do not yet support SdI, KSeF, RO e-Factura or myDATA.
Sources
- Belgium: KPMG on the tolerance period, BDO
- France: Service-Public
- Romania: KPMG on Law 88/2026
- Greece: VATupdate, Comarch
- Poland: Sovos on the penalty relief
- United Kingdom: ACCA
Poland, Spain and Greece have each moved a date in the past year. Check the tax authority's own page before you act on any date here.