EU E-Invoicing Mandates: Country-by-Country Guide for 2026–2028

Why EU E-Invoicing Mandates Matter Right Now

Across the European Union, tax authorities are moving from voluntary e-invoicing recommendations to legally binding mandates. The goal is twofold: reduce VAT fraud (estimated at €93 billion annually across the EU) and streamline cross-border B2B trade by standardising machine-readable invoice formats. For businesses selling into Germany, France, Poland, Italy, or Spain, compliance is no longer optional — it is a legal requirement with defined phased deadlines.

The EU-wide ViDA (VAT in the Digital Age) initiative underpins many of these national mandates. While each country implements its own rules and timelines, they share a common technical foundation: the EN 16931 semantic data model, which specifies what data an e-invoice must carry. The permitted syntax formats — UBL 2.1 and CII (UN/CEFACT Cross Industry Invoice) — are both expressions of EN 16931. Peppol BIS 3.0 is a business interoperability specification built on UBL 2.1, widely accepted as an exchange channel.

Invotify Pro and Lifetime plans include structured e-invoice export in UBL 2.1, CII (which covers XRechnung and Factur-X), and Peppol BIS 3.0. These three formats collectively satisfy the electronic delivery requirements in every country covered below. Always verify the current mandate deadlines directly with the relevant national authority, as implementation timelines have shifted more than once across all five countries.

Germany (E-Rechnung): Phased Mandate 2025–2028

Germany's e-invoicing mandate stems from the Growth Opportunities Act (Wachstumschancengesetz) enacted in March 2024. The implementation is phased by company size for B2B domestic transactions.

• January 2025 — All German B2B recipients must be able to RECEIVE structured e-invoices (no threshold).
• January 2027 — All companies with annual turnover above €800,000 must SEND structured e-invoices.
• January 2028 — All German B2B companies regardless of size must send structured e-invoices.

Which formats does Germany accept?

Germany accepts XRechnung (a pure XML German CIUS of EN 16931), ZUGFeRD/Factur-X (a hybrid PDF+XML format using CII syntax), and Peppol BIS 3.0. Invotify's CII export covers both XRechnung-compatible content and ZUGFeRD/Factur-X; the Peppol BIS 3.0 export provides a third compliant option.

Is there a mandated submission platform in Germany?

No. Unlike France and Poland, Germany does not mandate a single central submission platform for B2B invoices. Businesses can deliver e-invoices directly by email (with the structured XML attached), via a service provider, or over the Peppol network. B2G (business-to-government) invoices use the ZRE or OZG-RE portals.

France (Facture électronique): Large Companies from September 2026

France's B2B e-invoicing reform, managed by the DGFiP tax authority, rolls out in stages through 2027 and covers all VAT-registered French companies.

September 2026: All companies must be able to RECEIVE e-invoices. Large companies (>5,000 employees or >€1.5bn turnover) and mid-sized companies (>250 employees or >€50m turnover) must also SEND e-invoices. September 2027: All remaining companies (SMBs and micro-businesses) must SEND e-invoices.

France operates a dual-platform model. Chorus Pro remains the B2G portal (already mandatory for all public-sector invoices since 2020). For B2B, companies must route invoices through an accredited Plateforme de Dématérialisation Partenaire (PDP). Invotify exports Factur-X (CII), UBL 2.1, and Peppol BIS 3.0 — all three are accepted formats in the French framework. However, the actual transmission into the French B2B network requires a registered PDP; Invotify generates the compliant file, which you then submit via your chosen PDP provider.

Because France's mandate uses an approved-platform model rather than direct peer-to-peer delivery, the workflow is: generate the e-invoice file in Invotify → upload or transmit it via your PDP. Many accounting software providers and EDI service providers are seeking or have obtained PDP accreditation. Confirm with the DGFiP or your PDP provider for the latest accreditation list.

Poland (KSeF / e-Faktura): Mandatory Since 2026 for Large Taxpayers

Poland's National e-Invoicing System (KSeF — Krajowy System e-Faktur) is now mandatory for large taxpayers (annual turnover above PLN 200 million) from February 2026, with the mandate extending to all other companies from April 2026, and to small taxpayers and those with VAT exemptions from January 2027. Confirm these dates against the Ministerstwo Finansów / KAS portal, as Polish implementation timelines have been revised multiple times.

KSeF uses a proprietary Polish XML schema (FA(2)) based on EN 16931. This is a country-specific format that is NOT the same as UBL 2.1 or CII. Invotify's UBL 2.1 export is the closest EN 16931-aligned standard for cross-border Polish transactions, but domestic Polish B2B invoices submitted to KSeF require conversion to FA(2) format — typically via a dedicated KSeF submission service or accounting integration. Frame Invotify as generating a standards-based source file that a KSeF-registered submission provider can convert and submit on your behalf.

Italy (Fattura elettronica via SDI): Already Mandatory

Italy was the first major EU economy to mandate B2B e-invoicing at scale. Since January 2024, electronic invoicing via the SDI (Sistema di Interscambio) is mandatory for all domestic B2B and B2C transactions, with no turnover threshold. The SDI acts as the central exchange hub: every Italian invoice must pass through it before it is legally considered delivered.

Italy's native format is FatturaPA — a proprietary Italian XML schema. Invotify's UBL 2.1 and CII exports conform to the EN 16931 data model that FatturaPA is also aligned with, making them suitable for cross-border EU invoicing involving Italian counterparties. However, purely domestic Italian B2B invoices submitted via SDI must be in FatturaPA XML format, which requires either a dedicated SDI accreditation or a registered intermediary. Use Invotify's structured export as the source data, then route through an SDI-accredited intermediary for domestic Italian submission.

Spain (Factura electrónica): Receive-Ready from October 2026

Spain's e-invoicing mandate under the Crea y Crece law and Royal Decree 238/2026 follows a phased B2B timeline.

October 2026: All companies must be able to RECEIVE e-invoices. Approximately October 2027: Companies with turnover above €8 million must SEND e-invoices. Approximately October 2028: All other companies must send e-invoices.

Spain accepts UBL 2.1, CII, and Peppol BIS 3.0 under its mandate — all three are formats Invotify exports natively. The B2G submission portal (FACe) has been operational for years; the B2B platform network (the Plateforme equivalent under Crea y Crece) is still being finalised as of June 2026. Spain also has a separate anti-fraud software reporting obligation called Verifactu/TicketBAI in certain regions — this is a distinct compliance stream from the B2B e-invoice mandate and is not covered by invoice export formats.

Confirm the exact implementation dates and platform requirements with the AEAT (Agencia Tributaria) before your relevant deadline, as the B2B platform specifications were still being published at the time this guide was written.

How to Export Structured E-Invoices from Invotify

E-invoice export is available on Invotify Pro and Lifetime plans. Open any sent or paid invoice from the dashboard, click the Actions menu, and select "Export e-invoice". Choose your format — UBL 2.1, CII, or Peppol BIS 3.0 — and download the structured XML file. The exported file includes all EN 16931 mandatory fields: supplier and buyer identification, VAT numbers, line-item data, tax breakdown by rate, and payment details.

For VIES-validated B2B cross-border transactions, Invotify automatically includes the customer's verified EU VAT number in the structured file when it is on record. This is important for zero-rate reverse charge treatment — the VAT number on the e-invoice is the documentary evidence that justifies the zero rate.

If your mandate requires submission through a national platform or accredited intermediary (France, Poland, Italy, Spain for domestic invoices), your workflow is: create and send the invoice as normal in Invotify → export the e-invoice XML → upload to your national platform or submission provider. Invotify generates the compliant file; the submission step to a country-specific platform is handled by that platform or a registered service provider in your country.

Does Invotify submit e-invoices directly to KSeF, SDI, or Chorus Pro?

Not currently. Invotify generates standards-based e-invoice files (UBL 2.1, CII, Peppol BIS 3.0) that you download and submit via the appropriate national platform or an accredited submission service. Direct API integration with national platforms is a platform-specific integration that varies by country.

What about the EN 16931 standard — does Invotify comply?

Yes. Invotify's UBL 2.1 and CII exports are both syntax bindings of the EN 16931 semantic data model — the European standard that underpins all major national e-invoicing mandates. Peppol BIS 3.0 is a business specification built on UBL 2.1 with additional Peppol-specific rules. All three are accepted under the ViDA framework and by every country covered in this guide.