Compliance
Country-by-country e-invoicing mandates: a 2026 compliance map
Country-by-country e-invoicing mandates: a 2026 compliance map
If you sell across Europe, you will have to send structured e-invoices. The part that varies by country is the format, the delivery channel, and the deadline. This map covers the e-invoicing mandates that matter for 2026, the format each country requires, and where the rules come from.
The shared baseline: the EU e-invoicing directive
The starting point for every EU member state is the same. Directive 2014/55/EU requires public-sector buyers across the EU to accept structured electronic invoices. The directive names EN 16931 as the reference semantic standard, so every national public-sector format built to comply with the directive is a customization of the same data model.
That is why the country formats look different on the surface but share the same business terms underneath. XRechnung in Germany, Factur-X in France, and Peppol BIS Billing 3.0 across the Peppol network all carry the EN 16931 content. The differences are the CIUS customizations each country layers on top, the delivery channel, and the enforcement timeline.
The directive only covers business-to-government (B2G) invoicing. The wave of mandates now rolling out across Europe goes further, into business-to-business (B2B), and those rules are set nationally.
Germany: XRechnung and the B2B mandate
Germany is the country most readers of this blog will care about first, and it has the most active mandate timeline for 2026.
Public sector (B2G)
German federal authorities have been required to accept XRechnung XML since November 2020. The mandate extended to state and municipal authorities in stages, with the final tranche covered by the end of 2025. If you invoice any level of German government, XRechnung is the format your recipient's system expects. The Leitweg-ID buyer reference routes the invoice to the right recipient, enforced by the BR-DE-15 Schematron rule.
Business-to-business (B2B)
Germany's B2B e-invoicing mandate comes from the Wachstumschancengesetz (Growth Opportunities Act). It is phased:
- From January 2025, businesses with a turnover above EUR 800,000 must accept structured e-invoices.
- From January 2027, those businesses must also send structured e-invoices.
- From January 2028, the sending obligation extends to all businesses subject to VAT.
The mandate is format-agnostic at the legal level but built on the EN 16931 data model. In practice, the formats that satisfy it are XRechnung XML and ZUGFeRD PDF, both of which InvoiceSpec generates from a single API call.
France: Factur-X and the 2026 B2B rollout
France's e-invoicing mandate uses Factur-X, which is the French name for ZUGFeRD. The specification is identical. A Factur-X file and a ZUGFeRD file are structurally compatible, so the same InvoiceSpec ZUGFeRD output satisfies French recipients.
The French B2B mandate was restructured in 2024 and is now phased from 2026 onward, with larger businesses first and the platform-based reporting (e-reporting) running in parallel. The exact entry dates depend on company size, so check the current schedule on the French tax authority's portal before you rely on a specific date. The format itself is settled: Factur-X, built on EN 16931, delivered as a PDF/A-3 with embedded CII XML.
Italy: the early mover
Italy mandated B2B e-invoicing in 2019 through the SDI (Sistema di Interscambio) platform. Italian businesses send FatturaPA, an XML format that predates EN 16931 but has been aligned with it. Italy is the example other EU countries watched when designing their own B2B mandates, and it is the reason the 2026 wave of mandates looks the way it does.
If you invoice Italian recipients, you deliver through SDI rather than peer-to-peer. The format and the delivery channel are both prescribed.
Spain: B2B verification and the regional layer
Spain is rolling out mandatory B2B e-invoicing through the Ley Antifraude (Anti-Fraud Law) and the associated Veri*Factu verification regime. The mandate applies to businesses and professionals operating in Spain, with a platform-based verification step. The Basque Country and Navarra operate their own tax systems, so the exact platform depends on where your recipient is registered.
Spain's mandate is still settling into its final shape in 2026. The format direction is XML based on EN 16931, delivered through the tax authority's verification platform.
The Peppol network: cross-border delivery
Several countries accept or require delivery over the Peppol network. Peppol BIS Billing 3.0 is based on EN 16931 and is commonly delivered as UBL XML. Countries connected to Peppol include Belgium, Denmark, Finland, Norway, and Sweden, among others.
Peppol is a delivery network, not a new format. The invoice payload is still EN 16931 content, serialized as UBL or CII. If your recipient is on Peppol, the question is whether you can reach them on the network, not whether your invoice data is compliant.
A side-by-side view
| Country | B2G format | B2B mandate | Built on | Delivery |
|---|---|---|---|---|
| Germany | XRechnung | Phased 2025 to 2028 | EN 16931 | Direct / portal |
| France | Factur-X | Phased from 2026 | EN 16931 | Platform |
| Italy | FatturaPA | Since 2019 | EN 16931 aligned | SDI platform |
| Spain | EN 16931 XML | Rolling out 2026 | EN 16931 | Verification platform |
| Peppol states | Peppol BIS 3.0 | Varies by country | EN 16931 | Peppol network |
How to prepare
The mandates differ in detail but share one thing: they all rest on the EN 16931 data model. If your invoicing system produces EN 16931-compliant content, you can deliver it in the format each country requires without rebuilding your data layer.
A practical path:
- Get your invoice data into the EN 16931 model now. If you generate XRechnung or ZUGFeRD today, your data is already there.
- Confirm the format your recipient expects. German public sector wants XRechnung XML. German B2B often wants ZUGFeRD PDF. French recipients want Factur-X. Peppol recipients want UBL.
- Validate before you send. A document that fails the recipient's validation is rejected, and the rejection costs you a payment cycle. Run the same Schematron checks the recipient will run.
Frequently asked questions
Do I need a different invoice for every country?
Not a different data model. The EN 16931 content is shared. You need the right serialization and delivery channel for each recipient. XRechnung XML, ZUGFeRD PDF, and Peppol UBL all carry the same underlying data.
When does the German B2B sending obligation start?
For businesses with a turnover above EUR 800,000, the sending obligation begins in January 2027. The receiving obligation has been in place since January 2025. The sending obligation extends to all VAT-registered businesses in January 2028.
Is Factur-X the same as ZUGFeRD?
Yes. Factur-X is the French name and ZUGFeRD is the German name for the same specification. A file generated as ZUGFeRD satisfies a French recipient who expects Factur-X.
Stay ahead of the mandates
The country-by-country detail changes as each government publishes its final schedules. The data model does not. InvoiceSpec generates XRechnung, ZUGFeRD, and EN 16931 documents from one JSON request and validates them against the official rule sets before delivery, so you adapt to each country's format without maintaining the compliance logic yourself.
Start a free trial to generate your first compliant e-invoice, or read the API reference to see how one payload produces the format each country requires.
Mohamed Waleed
Founder, InvoiceSpec
Mohamed is the founder of InvoiceSpec, where he builds the e-invoicing infrastructure software companies use to ship compliant XRechnung, ZUGFeRD, and EN 16931 documents without maintaining the logic in-house. He writes about German e-invoicing compliance in plain terms for the finance and ops teams who have to meet it.
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