E-invoicing in Europe in 2026: Peppol, UBL and Factur-X explained
In a growing number of European countries, a PDF attached to an email no longer counts as an invoice. What changed, what the formats mean, and what a small business actually has to do.
What an e-invoice is — and what it isn't
In the new rules, an e-invoice is not a PDF. It is a structured data file, usually XML, that accounting software can read without anyone retyping it: seller, buyer, VAT numbers, invoice lines, amounts, the VAT breakdown and the payment details each sit in a defined field. A PDF, a scan or a Word file sent by email is "electronic" in the everyday sense, but for the mandates it counts the same as paper.
Europe has one common rulebook for that content: the standard EN 16931. It describes the core of an invoice once and lets it be written in two syntaxes, UBL (Universal Business Language) and UN/CEFACT CII (Cross Industry Invoice). Almost every national format you will come across is one of those two, with local rules added on top.
The formats you will meet
- Peppol BIS Billing 3.0 — a UBL invoice that follows EN 16931 and is sent over the Peppol network. The default in Belgium, the Netherlands and the Nordic countries, and for public procurement in much of Europe.
- XRechnung — Germany's national version of EN 16931, in UBL or CII. Required by German public bodies and accepted between businesses.
- Factur-X / ZUGFeRD — a hybrid: an ordinary PDF/A-3 for people to read, with the CII data embedded inside for software. Used in France and Germany; the two names describe the same format.
- FatturaPA (Italy) and KSeF (Poland) — national XML formats that pass through a government platform before the buyer receives them.
Peppol itself is not a file format but a network: rules plus certified access points that deliver business documents, much as email providers deliver mail. You register once through an access point — often your accounting package — and can then exchange invoices with any other Peppol participant.
Where it is mandatory — the situation in October 2026
The EU package "VAT in the Digital Age" (ViDA, Council Directive (EU) 2025/516, in force since 14 April 2025) allows every member state to require domestic e-invoicing without asking Brussels for permission, and makes structured e-invoicing compulsory for intra-EU business-to-business transactions from 1 July 2030. Countries are moving at different speeds:
- Belgium — mandatory for domestic invoices between VAT-registered businesses since 1 January 2026, via Peppol by default. Fines, starting at €1,500 and rising for repeat offences, apply since the tolerance period ended on 31 March 2026. Real-time e-reporting is planned for 2028.
- Germany — every business must be able to receive e-invoices since 1 January 2025. Issuing them becomes compulsory on 1 January 2027 for businesses with a turnover above €800,000, and for all businesses on 1 January 2028. XRechnung and ZUGFeRD from version 2 both qualify.
- France — since 1 September 2026 every business must be able to receive e-invoices and large and mid-sized companies must issue them, through approved platforms. Small and micro businesses follow on 1 September 2027.
- Poland — invoices go through the national KSeF system: for large taxpayers since 1 February 2026, for other businesses since 1 April 2026, and for the smallest businesses from 2027. The Ministry of Finance has extended the relief on penalties until the end of 2027.
- Spain — the business-to-business mandate under the "Crea y Crece" law is phased in, with larger companies first and everyone else a year later; the first phase is expected in the autumn of 2027.
- Italy — has required e-invoices through its SdI platform since 2019, and is the reference everyone else looks at.
- The Netherlands — no obligation between businesses yet; the government has proposed one, on Peppol, around 2030.
Dates move, and details differ per country. Before you change how you invoice, check your own tax authority — FPS Finance in Belgium, the BMF in Germany, impots.gouv.fr in France, the Ministry of Finance for KSeF in Poland, the AEAT in Spain. This guide describes the situation in October 2026.
What a small business actually has to do
For most small businesses the change is smaller than it sounds, because software does the work. In practice:
- Check that your invoicing or accounting software can send and receive the required format — in Belgium, Peppol BIS Billing 3.0. Most current packages can, and many include the Peppol connection in the subscription.
- Register on Peppol (or on your national platform) so customers can find you by VAT or company number. Your software provider normally does this for you.
- Keep your master data clean: correct VAT numbers, addresses and bank details. A structured invoice is checked by machines, and a wrong VAT number that a person would overlook can make it bounce. Our VAT number validator checks a number against the EU's VIES register.
- Decide what happens to incoming invoices: who approves them, where they are stored and for how long. The retention period does not change because the format changes — check the rule in your country, often seven to ten years.
If you send only a handful of invoices a year, a free government portal or a basic online invoicing service is usually enough. What no longer works in a country with a mandate is designing an invoice in a word processor, exporting a PDF and emailing it.
Reading, checking and archiving e-invoices
An XML invoice is not meant for human eyes, and that creates practical problems: the bookkeeper wants to check it, a manager wants to approve it, and the archive wants something readable in ten years. Three things help:
- Make it readable. Our UBL/Peppol invoice to PDF tool turns the XML into a clean PDF with all lines, the VAT breakdown and the payment details — for approval, printing or a quick look.
- Check it before you send it. The UBL/Peppol validator runs a structural check on an invoice file, so a missing or malformed field is caught before your customer's software rejects it.
- Get the data out of a hybrid PDF. A Factur-X or ZUGFeRD invoice looks like any PDF but carries XML inside; the Factur-X XML extractor pulls that file out so your accounting software can import it.
These three tools run on our server for the conversion and delete the file as soon as it is done; nothing is stored. For the archive, keep the structured file itself: that is the legal invoice. A readable copy next to it does no harm, and for long-term storage PDF/A is the safer kind of PDF — see our guide PDF/A explained.
Common mistakes
- Treating a PDF sent by email as an e-invoice. In a country with a mandate it is not one, however official it looks.
- Assuming a hybrid PDF is automatically valid. The embedded XML has to match what the PDF shows, and its profile has to be one the receiver accepts.
- Waiting for the penalty date. The obligation and the fines are separate: in Belgium the duty started on 1 January 2026, months before the first fines.
- Forgetting the receiving side. Even if you send few invoices, you must be able to receive structured invoices from your suppliers.