Germany, Poland, Slovakia and Norway change their invoicing rules on the same date. Spain has stepped out of it. This article sets out what applies in each country, which thresholds decide the obligation and what to settle before January.
2026 was a year of go-lives: Belgium in January, Poland in February and April, Greece in March and October, France in September. The first day of 2027 is different. Four countries change their invoicing rules on the same date, and a company operating in more than one of them meets four sets of consequences in a single weekend.
Spain was part of this date until October. On 5 October 2026 the Ministry of Finance announced that the pending obligations of its invoicing software regulation move to October 2028, so the Spanish strand is no longer part of this calendar. The four that remain have almost nothing in common technically, which is the point worth planning around.
Every German business has had to be able to receive structured e-invoices since January 2025. From 1 January 2027, businesses whose turnover in the previous calendar year exceeded EUR 800,000 must also issue them. Businesses below that figure follow on 1 January 2028.
Note on the small-entrepreneur scheme. Businesses under that scheme do not have to issue structured invoices. They do have to be able to receive them, and that has applied since January 2025.
The National e-Invoicing System has been mandatory since February 2026 for the largest taxpayers and since April 2026 for everyone else established in Poland. On 1 January 2027 the last transitional exclusions end: the exclusion for taxpayers issuing no more than PLN 10,000 gross per month, and the transitional option to issue invoices through cash registers. From that date the system covers every taxpayer established in Poland.
Enforcement moves in the opposite direction. The Council of Ministers has adopted a draft amendment deferring the penalty provisions of Article 106ni of the VAT Act, so that they apply from 1 January 2028. According to the Ministry's announcement the new provisions are to enter into force on 31 December 2026. The same draft extends the reverse charge mechanism for gas, electricity and greenhouse gas emission allowances until 30 June 2030.
The deferral concerns fines, not the duty. Issuing invoices outside the system remains unlawful during 2027. The Ministry states that tax offices will first remind taxpayers of the obligation, and where that produces no result they will examine whether not using the system has led to an unreliable settlement of tax. The exposure during 2027 is therefore a VAT exposure rather than a penalty exposure.
Slovakia requires structured e-invoicing and real-time reporting for domestic transactions between taxable persons established in Slovakia from 1 January 2027. The mandatory semantic format is EN 16931, applied through the Peppol BIS 3 specification. Cross-border reporting for intra-Union transactions follows on 1 July 2030.
Two details are easy to miss. Voluntary use of domestic e-invoices in the Peppol BIS 3.0 format started in June 2026, so the infrastructure can be tested before the obligation applies. And the existing public-sector system IS EFA is replaced by a solution built on Peppol infrastructure on the same date, which means a supplier to Slovak public bodies changes its B2G route in the same week as its B2B route.
Norway separates the two halves of the obligation by three years. From 1 January 2027 entities subject to bookkeeping duties must issue electronic invoices on sales of goods and services to other such entities. The duty to receive electronic invoices, and the requirement to keep the books in an electronic accounting system, apply from 1 January 2030.
Two further Norwegian dates sit in 2028. From 1 January 2028 the buyer's organisation number must be stated in the sales document, and from the same date parties subject to bookkeeping duties may no longer agree that the sales document is not sent to the buyer. The exemption from electronic accessibility for turnover below NOK 5 million is repealed from 1 January 2027.
Technically, very little. Germany is decentralised and format-led. Poland runs a central clearance platform. Slovakia uses Peppol with reporting to the tax administration. Norway uses Peppol with a three-year gap between issuing and receiving.
There is no single build that satisfies all four and no ERP that ships all four natively. What does travel between them is the master data, the discipline of the invoice content and the ability to validate a file before it is sent. That is where the remaining weeks of 2026 are best spent, not in choosing four integrations but in making sure the data going into them passes validation in any of them.
Invoice-Portal is a certified Peppol access point and covers country-specific requirements behind a single ERP integration. For these four mandates that means producing the profile each market expects, routing the document the way each market requires, and keeping the submission records that a reconciliation needs. You can check what your systems currently produce with our free E-Invoice Validator, or see where each market stands in the country overview.
Note: three of these four markets use Peppol and one does not. Poland runs its own clearance platform, and a Peppol connection does not substitute for it. The country requirements should be assessed separately even where the transport layer looks familiar.
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Start free trialThose whose turnover in the previous calendar year exceeded EUR 800,000. The assessment is made on the 2026 figures and per legal entity, so a small company inside a large group may not be obliged in 2027, and it would then follow on 1 January 2028.
No. The draft defers the penalty provisions to 1 January 2028. The obligation to use the system is unchanged, and on 1 January 2027 the last transitional exclusions end. Issuing outside the system remains unlawful during 2027.
Yes. Voluntary use of domestic e-invoices in the Peppol BIS 3.0 format started in June 2026, so documents can be exchanged in the national format before the obligation takes effect on 1 January 2027.
The duty to issue applies from 1 January 2027, but until 1 January 2030 it applies in practice only where the recipient subject to bookkeeping duties can receive electronic invoices, which means the recipient is registered in ELMA or Peppol. A PDF may not be used where the buyer can receive an electronic invoice.
The Spanish invoicing software regime was due to apply to corporate income tax payers from 1 January 2027. On 5 October 2026 the Ministry of Finance announced that the pending obligations move to October 2028, to align with the e-invoicing obligation for businesses whose annual turnover does not exceed 8 million euro. The announcement is not yet enacted, so the current legal dates still stand until the amendment is adopted.
The four mandates use different models, so the country logic differs in each case. What can be shared is the source data and the point at which the invoice leaves the ERP. Three of the four markets use Peppol and Poland uses its own clearance platform, so a Peppol connection alone does not cover Poland.
