July 14th, 2021

Ah, the borders have reopened and international travel from the U.S. to Europe is once again possible. Now that many of us are busy planning our next European vacation, we think it’s a good time to talk about international trade and everything you need to take into account regarding invoicing when engaging in business-to-business (B2B) and/or business-to-government (B2G) transactions overseas.

In the U.S., 25 billion B2B invoices are exchanged annually, and 75% of these invoices still require manual processing. In most countries in Europe, however, public sector organizations are legally required to receive electronic invoices (e-invoices) and this legislation is quickly penetrating the B2B space. And while the EDI market in the U.S. is highly mature thanks to large retail companies, many of which require all of their suppliers to send e-invoices via EDI or some other format in order to do business with them, large-scale e-invoicing adoption lags. After all, there’s no push from the U.S. government to adopt it.

This is important to mention because it explains why U.S. companies tend to be a little lost when they decide to open one or more European locations and are immediately confronted with the realization that no one will accept checks. On the bright side, all it takes is some getting used to. In fact, many companies end up liking the way business transactions are handled abroad once they get into the swing of things. But we know it’s not always easy to find the information you’re looking for, so here’s a list of B2B and B2G e-invoicing requirements in all 27 EU member states (in alphabetical order).

Going along with e-invoicing requirements, we’re going to talk about Peppol a lot in this blog. If you’re unfamiliar with Peppol, you might want to read one of our previous blogs here.

1. Austria

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and all public authority suppliers are required to send their invoices in the specified electronic format (ebInterface, Peppol BIS, UBL). Public authorities and their suppliers may choose their own e-invoicing solution provider given the provider is able to meet Austrian e-invoicing requirements.

Whether B2B or B2G, all companies operating in Austria are subject to a 7-year archiving period for invoices (electronic or not). Archiving outside of Austria is permitted under certain conditions.

You can find more details here.

2. Belgium

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and select public authority suppliers are required to send their invoices in the specified electronic format (Peppol BIS). Currently, B2G e-invoicing is only mandatory for suppliers to public authorities in the Flemish and Brussels regions. The Belgian approach to e-invoicing is platform agnostic, meaning everyone uses a platform that has been set up by the government to enable open exchanges. This system is called Mercurius, and all Belgian public authorities are connected. Likewise, all B2G suppliers can send their invoices through the platform using a web-based portal. In other words, there’s no need to find an e-invoicing service provider; it’s all possible via Mercurius.

Whether B2B or B2G, all companies operating in Belgium are subject to a 7-year archiving period for invoices (electronic or not). Archiving outside of Belgium is permitted under certain conditions.

You can find more details here.

3. Bulgaria

B2B e-invoicing is not mandatory. However, it’s important to note that Bulgarian authorities are thinking about introducing a new law that would make e-invoicing mandatory for private sector organizations. Bulgarian authorities claim a decision will be reached by the end of 2021.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but public authority suppliers are not required to send their invoices in an electronic format (yet). The government has also developed a national platform for electronic public procurement, CAIS EPP, in which all document exchange activities are executed by the organization itself or with the help of an e-invoicing service provider. Although there is no standard e-invoicing format in the country, the most commonly used format is XML and sometimes the ISO 20022 standard for payments.

Whether B2B or B2G, all companies operating in Bulgaria are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of Bulgaria is permitted under certain conditions.

You can find more details here.

4. Croatia

B2B e-invoicing is not mandatory, but it is strongly recommended. Croatia’s state-owned service provider, FINA, has developed a separate e-invoicing platform for B2B exchanges (Peppol BIS, UBL 2.1). Private organizations are not required to use this platform, however, and may choose to enter an agreement with a private e-invoicing service provider.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and all public authority suppliers are required to send their invoices in the specified electronic format (Peppol BIS, UBL 2.1 or CII). Public authorities are required to receive e-invoices via Croatia’s central e-invoicing platform, Servis eRačun za državu, which is operated by a state-owned service provider.

B2G suppliers are also welcome to use the national platform to submit their e-invoices to public authorities, and all it takes is a simple platform registration (no contract). Suppliers may also choose to use their own e-invoicing solution provider given the provider is able to meet Croatian e-invoicing requirements. However, in this case, a digital signature is required on all e-invoices.

Whether B2B or B2G, all companies operating in Croatia are subject to an 11-year archiving period for invoices (electronic or not). Archiving outside of Croatia is permitted under certain conditions.

You can find more details here.

5. Cyprus

B2B e-invoicing is not mandatory, but it is likely that Cyprus will pursue B2B e-invoicing in the future.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but public authority suppliers are not required to send their invoices in an electronic format unless required by the customer. This is likely to change in the near future, though, as the government in Cyprus is leaning towards making B2G e-invoicing mandatory for suppliers as well.

All exchanges take place via the Peppol network (Peppol BIS 3.0), and all public authorities need a service provider that serves as a Peppol Access Point. The same goes for suppliers who may voluntarily send their invoices in an electronic format via the Peppol network. The government is currently developing a centralized e-invoicing platform that’s set to go live in 2022.

Whether B2B or B2G, all companies operating in Cyprus are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of Cyprus is permitted under certain conditions.

You can find more details here.

6. Czech Republic

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the country’s central platform, NEN. In fact, they are obligated to use NEN for the entire e-procurement lifecycle unless they have authorization to use a private service provider. Public authority suppliers are required to send their invoices in an electronic format as well. Accepted formats are ISODOC, EDIFACT, and UBL. However, law states that public authorities cannot reject e-invoices from their suppliers if they are in a format compatible with the European standard on e-invoicing.

Whether B2B or B2G, all companies operating in the Czech Republic are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of the Czech Republic is only permitted within EU member countries.  

You can find more details here.

7. Denmark

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the country’s central platform, NemHandel. They can do this by either establishing their own access point or through a contract with a value-added network (VAN) services provider. Public authority suppliers are required to send their invoices in an electronic format as well (UBL 2.1, OIOUBL, Peppol BIS). While domestic suppliers are required to submit their invoices via the NemHandel platform and need a service provider that can connect them, non-domestic suppliers may use the Peppol network.

Whether B2B or B2G, all companies operating in Denmark are subject to a 5-year archiving period for invoices (electronic or not). Archiving outside of Denmark is permitted under certain conditions.  

You can find more details here.

8. Estonia

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices directly, and public authority suppliers are required to send their invoices in an electronic format (UBL, UN/CEFACT, CII, Peppol). Both public authorities and their suppliers are free to choose their own service provider.  

Whether B2B or B2G, all companies operating in Estonia are subject to a 7-year archiving period for invoices (electronic or not). Archiving outside of Estonia is permitted under certain conditions.  

You can find more details here.

9. Finland

To summarize, B2B e-invoicing is not mandatory, and B2G e-invoicing is mandatory. You can read all about e-invoicing requirements in Finland here.

10. France

B2B e-invoicing in France is expected to become mandatory in 2023. We’ve covered the topic extensively in another blog. You can read the details of the upcoming B2B e-invoicing obligation in France here.

B2G e-invoicing in France is mandatory. All public authorities must be able to receive e-invoices via the country’s national e-invoicing platform, Chorus Pro. Likewise, all public authority suppliers are required to send their invoices via Chorus Pro. You can read this blog for more information. 

11. Germany

To summarize, B2B e-invoicing is not mandatory, but it very well could be in the near future based on the recent developments of Order X. On the other hand, B2G e-invoicing is mandatory. All public authorities are required to receive e-invoices, and the obligation for suppliers to send e-invoices varies per state. You can read all about e-invoicing requirements in Germany at the national and state level here.

12. Greece

B2B e-invoicing is not mandatory. However, all businesses operating in the country are legally required to submit e-books (which contain accounting data) via the national myDATA platform. The purpose of this is so that Greek authorities can maintain individual taxpayer records and cross check the data submitted via the platform with filed tax returns. E-book submissions require an overview of issued invoices, as well as the classification of invoices received. This is required regardless of how the invoice was sent, for example, via an ERP system or through an e-invoicing service provider. E-book reporting became mandatory on July 1st, 2021.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but public authority suppliers are not required to submit their invoices electronically (even though many still do). Both public authorities and their suppliers may choose their own service provider given the provider is able to meet Greek e-invoicing requirements.

Whether B2B or B2G, all companies operating in Greece are subject to a 5-year archiving period for invoices (electronic or not). Archiving outside of Greece is permitted under certain conditions.  

You can find more details here.

13. Hungary

B2B e-invoicing is mandatory for all Hungarian registered VAT companies in compliance with the country’s real-time invoice reporting (RTIR) model. The RTIR model also applies to B2C transactions, including transactions issued by non-residents. The RTIR model requires that all companies are connected to the national tax platform, NAV. A service provider that supports this model—as well as Hungary’s newly established e-invoicing format, XML 3.0 XSD—is necessary.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the country’s central platform, NAV. Public authority suppliers are required to send their invoices in an electronic format via the NAV platform as well (XML). Together, public authorities and their suppliers must decide on the solution they will use to exchange e-invoices.

Whether B2B or B2G, all companies operating in Hungary are subject to a 5-year archiving period for invoices (electronic or not). Archiving outside of Hungary is permitted under certain conditions.  

You can find more details here.

14. Ireland

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the Peppol network. Public authority suppliers are not required to send their invoices electronically, but depending on the sector, they may be required by the customer (Peppol BIS 3.0). Both public authorities and their suppliers may choose their preferred e-invoicing service provider given the provider is able to meet EU e-invoicing requirements and (preferably) serves as a Peppol Access Point.

Whether B2B or B2G, all companies operating in Ireland are subject to a 6-year archiving period for invoices (electronic or not). It is possible to archive invoices abroad.    

You can find more details here.

15. Italy

B2B, B2C, and B2G e-invoicing are mandatory in Italy. All exchanges must be done through the country’s national exchange system, Sistema di Interscambio, and all invoices must be submitted in the FatturaPA format. All public and private organizations may choose their own service provider given the provider is able to meet all Italian e-invoicing requirements.

Whether B2B or B2G, all companies operating in Italy are subject to a 10-year archiving period for invoices. Archiving outside of Italy is permitted under certain conditions.  

You can find more details here.

16. Latvia

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the Latvian e-invoicing platform, eAddress, or via email using a solution from a private service provider. However, use of the eAddress platform will become mandatory in 2023.

Public authority suppliers are not required to send their invoices in an electronic format, but they are free to submit e-invoices on their own accord via the municipality portal. If they choose to do this, suppliers can view their submissions via the Latvija.lv platform once they have been authenticated to do so.  

Whether B2B or B2G, all companies operating in Latvia are subject to a 5-year archiving period for invoices (electronic or not). Archiving outside of Latvia is permitted under certain conditions.  

You can find more details here.

17. Lithuania

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and public authority suppliers must submit their invoices electronically according to the specified format (UBL 2.1, Peppol BIS 3.0). All exchanges take place via Lithuania’s central e-invoicing platform, eSaskaita. Suppliers may choose to submit their invoices directly through the platform following a simple registration or establish an interface between eSaskaita and their back-end financial system (ERP or other). The latter is recommended for suppliers that send a large number of invoices to public authorities. The eSaskaita platform is connected to the Peppol network to easily facilitate cross-border trade.

Whether B2B or B2G, all companies operating in Lithuania are subject to a 10-year archiving period for invoices (electronic or not). Archiving outside of Lithuania is permitted under certain conditions.  

You can find more details here.

18. Luxembourg

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but public authority suppliers are not required to send their invoices electronically. Public authorities access e-invoices via Luxembourg’s central Peppol Access Point, while suppliers that choose to submit their invoices electronically do so via the Peppol network (Peppol BIS, UBL 2.1), in which case they need a service provider that serves as an official Peppol Access Point since they cannot connect directly to the central Access Point.

Whether B2B or B2G, all companies operating in Luxembourg are subject to a 10-year archiving period for invoices (electronic or not). Archiving outside of Luxembourg is permitted under certain conditions.  

You can find more details here.

19. Malta

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and all public authority suppliers must be able to submit their invoices electronically in the specified format (Peppol BIS). Malta is in the process of developing an e-invoicing platform, but for the time being, suppliers may use their preferred service provider given the provider is able to meet EU e-invoicing requirements.

Whether B2B or B2G, all companies operating in Malta are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of Malta is permitted under certain conditions.  

You can find more details here.

20. Netherlands

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the Peppol network and may be connected directly or indirectly via a service provider (TIE Kinetix is a preferred service provider for Dutch public authorities, including, but not limited to, the Municipalities of Amsterdam and Rotterdam).

Suppliers to central public authorities are required to submit their invoices electronically. They have four options for this. First, they can submit invoices via the Peppol network. To do so, they need a service provider (like TIE Kinetix) that serves as an official Peppol Access Point. Second, for suppliers that send very low volumes of invoices, they can choose to do manual submission via the Logius e-invoicing portal at no cost. Third, for large volumes, a direct connection with Digipoort (the ICT center where message traffic for the government is handled) is possible. Fourth, suppliers can submit invoices manually via a web-based portal solution offered by a supplier that has a direct connection with Digipoort.

Submitting e-invoices to sub-central government agencies is also mandatory, but there are fewer options. In either case, submitting e-invoices via the Peppol network by choosing a service provider that serves as an Access Point is most common.

Whether B2B or B2G, all companies operating in the Netherlands are subject to a 7-year archiving period for invoices (electronic or not). Archiving outside of the Netherlands is permitted under certain conditions.  

You can find more details here.

21. Poland

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the country’s central platform, PEF. Public authority suppliers are not required to submit their invoices electronically, but many suppliers opt to do this voluntarily by choosing a service provider that serves as a Peppol Access Point.

Whether B2B or B2G, all companies operating in Poland are subject to a 5-year archiving period for invoices (electronic or not). Archiving outside of Poland is permitted under certain conditions.  

You can find more details here.

22. Portugal

To summarize, B2B e-invoicing in Portugal is not mandatory, and B2G e-invoicing is mandatory. Public authorities are required to receive e-invoices, and some public authority suppliers are required to submit their invoices electronically. Portugal has chosen to implement this obligation in phases. We’ve written all about it here.

23. Romania

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but there’s no central receiving platform in place just yet. Public authority suppliers are not required to submit their invoices electronically, but if they choose to do so voluntarily, there’s no standard e-invoicing format, either, so they’re free to use any service provider they’d like.

Whether B2B or B2G, all companies operating in Romania are subject to a 10-year archiving period for invoices (electronic or not). Archiving outside of Romania is permitted under certain conditions.  

You can find more details here.

24. Slovakia

B2B e-invoicing is not mandatory. However, the plan is to develop a real-time invoice reporting model that will eventually include B2B transactions. But no need to stress on this one, it’ll still be years before this can happen.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, but there’s no central platform in place just yet. However, Slovakian authorities are in the process of developing a central platform in line with the European e-invoicing standard (estimation: July 2022). This development comes alongside the initiative to launch a real-time invoice reporting model that’s expected to go live in 2023.

Public authority suppliers are not required to send their invoices electronically.

Whether B2B or B2G, all companies operating in Slovakia are subject to a 10-year archiving period for invoices (electronic or not). Archiving outside of Slovakia is permitted under certain conditions.  

You can find more details here.

25. Slovenia

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to send and receive e-invoices through the country’s PPA e-invoicing system. Public authority suppliers are also required to submit their invoices electronically via PPA in the specified format (eSlog 2.0, Peppol BIS). They can do this manually via the PPA web portal, with the help of a service provider that offers a direct link with PPA, or automatically through an e-invoicing solution provided by a participating bank. PPA is also connected to the Peppol network.

Whether B2B or B2G, all companies operating in Slovenia are subject to a 10-year archiving period for invoices (electronic or not). Archiving outside of Slovenia is permitted under certain conditions.  

You can find more details here.

26. Spain

B2B e-invoicing is not mandatory. However, Spain has developed a relatively new platform for B2B e-invoicing that’s open to the public free of charge. It’s called FACeB2B, and it’s based on the FACe platform for B2G e-invoicing mentioned below.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices via the country’s central platform, FACe, and all public authority suppliers are required to submit their invoices electronically through the same platform if the total exceeds €5,000. Additionally, all invoices must be submitted in the national standard format, Facturae. Suppliers are free to choose any service provider they’d like given the provider is able to connect to the FACe platform.

Whether B2B or B2G, all companies operating in Spain are subject to a 6-year archiving period for invoices (electronic or not). Archiving outside of Spain is permitted under certain conditions.  

You can find more details here.

27. Sweden

B2B e-invoicing is not mandatory.

B2G e-invoicing is mandatory. All public authorities must be able to receive e-invoices, and all public authority suppliers must be able to send their invoices electronically in the specified format (Peppol BIS). Peppol is the recommended method for exchanging e-invoices, and all public authorities are connected. Supplier are free to choose their preferred service provider given the provider is able to meet EU e-invoicing requirements and (preferably) serves as a Peppol Access Point. Though Peppol is preferred, e-invoices sent according to the EDIFACT standard are still accepted in most cases.

Whether B2B or B2G, all companies operating in Sweden are subject to a 7-year archiving period for invoices (electronic or not). Archiving outside of Sweden is permitted under certain conditions.  

You can find more details here.