Electronic invoice in China

Understand China’s fully digitalised e-fapiao system, STA-controlled issuance, local formats and evolving real-time invoicing requirements.

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Overview

China operates a centralised, state-run system of fully digitalised electronic tax invoices — 全面数字化电子发票, usually shortened to 数电发票 and translated as the digital e-fapiao. It runs on a single national platform operated by the State Taxation Administration (STA).

Two words that look interchangeable in English are not. A fapiao (发票) is the official, state-controlled tax document. A commercial invoice is the ordinary business document the parties exchange, especially in foreign trade. Almost every misunderstanding about Chinese e-invoicing starts with collapsing the two.

There is no general law requiring every B2B, B2G and B2C transaction to be documented by a structured electronic invoice only. Chinese legislation treats paper and electronic VAT invoices as legally equivalent and speaks of promoting electronic invoicing rather than banning paper. The nationwide date is best understood as a deployment date, not a universal electronic-only mandate. Industry-specific exceptions are being introduced, and they are where the real obligations bite.

20-digit number

assigned by the STA itself — the taxpayer never allocates its own invoice numbers

Monthly quota

a dynamic issuance limit set per taxpayer from risk profile and tax credit rating

30 years

the retention period for accounting vouchers — among the longest anywhere

Timeline

A decade of steady expansion, and now a shift from a general platform to sector-specific real-time obligations.

Already in force

1 December 2015

Electronic general VAT invoices go nationwide

The electronic file could be printed, and the printed version carried the same legal force as an ordinary paper VAT invoice.

December 2020 — January 2021

Electronic special VAT invoices

Rolled out to new taxpayers in 11 regions from 21 December 2020 and a further 25 regions from 21 January 2021, with recipients anywhere in China.

1 December 2021

The 数电发票 pilot

Fully digitalised invoices began in Guangdong, Shanghai and Inner Mongolia.

November — December 2024

Nationwide rollout

Fully digital rail ticket-invoices launched on 1 November 2024; on 1 December 2024 the 数电发票 went live nationally, alongside digital itinerary receipts in civil aviation. The aviation transition period, during which paper and electronic receipts ran in parallel, closed on 30 September 2025.

1 January 2026

The new VAT Law takes effect

The VAT Law enacted in 2024 replaced the provisional regulations in force since 1993 and put electronic invoicing inside the statutory framework — while confirming that paper and electronic VAT invoices carry equal legal effect.

Still ahead

1 November 2026

Fuel retail — 交易即开票

Every retail filling station must issue the 数电发票 immediately from the data of each transaction, on the principle that the transaction is the invoice. This is the strictest real-time obligation in the Chinese system — see Direct integration.

B2G, B2B and B2C

One system serves all three. What differs is not the document but the surrounding obligations.

B2GNo separate nationwide B2G mandate and no separate B2G platform. A supplier to a government body issues the same Chinese VAT fapiao as to anyone else. The Ministry of Finance separately promotes electronic handling of accounting documents in administrative and budgetary institutions — which confirms the shared system rather than creating a B2G regime

B2BThe 数电发票 has been available nationwide since December 2024, but there is no general date on which paper became unusable for all companies. The binding obligation is to issue a proper fapiao — not necessarily an XML-only invoice for every transaction

B2CSame system. The invoice can reach the consumer through their tax digital account, a QR code, email, or download and print. Sector rules are stricter: rail tickets, aviation itinerary receipts, and fuel retail from November 2026

A public buyer may impose additional procurement conditions — a contract number, an order number, a project or budget code, a departmental portal or a specified delivery method. These sit on top of the fapiao; they do not create a separate B2G tax model.

One nuance worth knowing for retail: a provincial tax authority may permit a business not to issue a separate invoice for every small retail sale or occasional service. So it is not accurate to say that every transaction in every province always requires its own 数电发票.

The clearance-like model

China runs a centralised tax-authority CTC model that is functionally close to clearance but not identical to European or Latin American clearance systems. Official Chinese documents do not use the word clearance and do not describe a separate step in which the tax authority returns a clearance response that makes the invoice valid.

It is clearance-like because the number, the tax signature, the quota and the digital tax document itself are all generated inside the STA infrastructure. The tax authority does not receive the data through a later report — it receives it in the act of issuing.

What the STA does

—Operates the single national Electronic Invoice Service Platform

—Assigns each 数电发票 a unique 20-digit number

—Sets a monthly issuance limit for each taxpayer

—Authenticates the authorised person

—Receives the invoice data directly at the moment of issue

—Delivers the invoice automatically into the buyer's tax digital account

—Controls confirmation of the invoice's intended use — VAT deduction, export refund or another declared tax purpose

Issuance quotas

This is the feature with no European equivalent. The STA assigns each taxpayer a dynamic monthly ceiling on the total value it may invoice, derived from tax risk, tax credit rating, actual activity and issuance history. Changing the limit can require approval from the competent tax authority. A platform serving Chinese clients has to treat the quota as a first-class operational concern, not an edge case.

What the model is not: not Peppol four-corner, not Peppol five-corner, not a decentralised network of private access points, and not a classic post-audit system in which the invoice travels freely to the buyer and is reported later. For an ordinary 数电发票 no separate parallel real-time report is needed — the data is already inside the STA.

Direct integration — 乐企

乐企 (lèqǐ) is the official mechanism for connecting a company's own systems directly to the tax platform. It is where China's e-invoicing is actually heading — not toward Peppol, but toward deeper ERP and retail-system integration with the STA.

The clearest illustration is fuel retail. From 1 November 2026 filling-station point-of-sale and retail systems must transmit transaction data through 乐企, after which the electronic invoice is generated immediately on completion of the transaction. The requirement covers payment by card, internet platform, third-party payment system, fuel card, cash and bank transfer alike. For a private individual buying fuel an invoice must be issued for each separate transaction; a special VAT invoice is not issued to an individual.

Operating 乐企联用 for others

A company may also connect on behalf of other businesses. Shanghai's tax administration defines such an operator as an organisation located in China with independent legal personality that owns or controls the connected platform. The trial conditions published in Shanghai in January 2026 are demanding:

—Paid-up registered capital of at least CNY 10 million

—Aggregate transaction revenue through the system of at least CNY 100 million over the preceding twelve months

—Tax rating A or B for the last three years, with at least one year at A

—No serious tax violations in the last three years

—Professional IT, security, operations and support capability, and rights to the software used

—Tax authority review and connection testing, plus a security and tax risk-control scheme

—Registration of network addresses and confirmation of a dedicated fixed IP

—A time-limited approval — two years under the published Shanghai procedure

These are Shanghai trial rules and thresholds may differ elsewhere. But the underlying principles — national tax infrastructure, controlled direct connection and local tax supervision — are characteristic of the Chinese model as a whole.

Formats and standards

The Chinese system does not conform to EN 16931 in any regulatory sense. Chinese official documents do not require the EN 16931 semantic model and do not establish UBL 2.1 or UN/CEFACT CII as the syntax of the 数电发票. National standards apply instead.

GB/T 42965.1-2023Electronic invoice business data specification, Part 1: Basic elements — in force since 6 August 2023, developed and administered by the STA

GB/T 42965.2-2023Part 2: Specific elements

GB/T 44554 seriesStandards for electronic accounting documents and the various types of fully digital invoice

The three file formats

XMLThe structured data file — and, with the tax authority's digital signature, the electronic original for a fully digital accounting process. It can be retrieved from the tax digital account and needs no invoice stamp

OFDOpen Fixed-layout Document, China's national fixed-layout format — comparable in purpose to PDF

PDFVisual representation for viewing, transmission, printing and internal workflow

Moving to the 数电发票 removed the dependence on one fixed visual form: the STA added XML as the structured format while keeping PDF and OFD for viewing and transfer. Some documents also use OFD with XBRL, or PDF with embedded XML. A company that treats a printed PDF or OFD as its accounting evidence should also retain the underlying electronic document.

A detail that catches foreign systems out: invoices in China must be issued in Chinese. In autonomous regions a local language may additionally be used. Alongside the standard tax fields — seller and buyer, date, description of goods or services, quantity, price, rate and tax amount — this is a hard requirement, not a preference.

Peppol in China

Peppol is not an official channel of the Chinese national e-invoicing system. The official channel is the STA's Electronic Invoice Service Platform, with delivery through tax digital accounts, direct system connection, email, QR code, download and print, and the 乐企 integration mechanism.

OpenPeppol's published country profiles contain no national profile for China and name no Chinese Peppol Authority

No national EAS has been established for Chinese e-invoicing

Two things are easily misread here. First, the OpenPeppol directory does list commercial companies domiciled in China certified as Peppol Access Points and SMPs — which means Chinese companies can provide international Peppol services, not that Peppol is integrated with the 数电发票. Second, the general Peppol ISO 6523 ICD list contains code 0131, for the China National Organization Code Registration Authority. That code exists, but China has not established it as a national EAS for e-invoicing and it is not used as a mandatory taxpayer address in the 数电发票.

The near-term direction of travel in China has nothing to do with Peppol. It is the expansion of 乐企, direct ERP and retail-platform integration with the STA, and the sector-by-sector spread of the principle that the transaction is the invoice.

Export and import

There is no cross-border structured e-invoicing mandate in either direction. That is the short answer, and it holds for exports, imports and EU trade alike.

Exporting from China

The Electronic Invoice Service Platform can produce invoices for export transactions. For export VAT refund, the rules applying from 2026 require — depending on the transaction — an export or ordinary invoice, the export customs declaration, evidence of purchase, suppliers' special VAT invoices, customs documents and tax payment documents. For cross-border services and intangibles an export or ordinary invoice is likewise among the required documents.

Chinese customs does not impose a single mandatory format for the international commercial invoice; a commercial invoice consistent with international trade practice is acceptable provided it is genuine and valid. In practice a Chinese exporter issues the Chinese tax fapiao for the STA, separately sends the buyer a PDF, EDI, ERP or other agreed commercial invoice, and — if the buyer needs it — may produce a Peppol document as an additional document. It never replaces the fapiao.

Importing into China

A foreign supplier does not issue a Chinese 数电发票. The Chinese importer relies on the foreign commercial invoice, the contract, proof of payment, the customs import VAT payment certificate and, for services or intangibles acquired from a non-resident, the tax payment document. Where the tax authority doubts a foreign invoice or document it may require confirmation from a foreign notary or registered auditor. For VAT deduction on services or intangibles bought from a foreign entity the taxpayer must hold the tax payment document, a written contract, proof of payment and the foreign counterparty's statement or invoice.

ViDA does not apply

A transaction between China and an EU member state is not an intra-EU transaction. ViDA obligations may arise for the EU-established party, but they do not turn a Chinese export invoice into a Chinese Peppol or ViDA invoice, and they create no Chinese implementation date.

Requirements for providers

The short version: OpenPeppol certification alone is not sufficient, and there is no route by which a foreign Peppol Access Point can serve Chinese domestic clients on the strength of its Peppol credentials.

What a foreign Peppol AP cannot do

Assign Chinese invoice numbers, or substitute for the Electronic Invoice Service Platform

Route domestic Chinese invoices through Peppol instead of the STA

Act as a 乐企联用 operator without meeting the Chinese conditions

Local presence

China imposes no separate requirement to hold a national official electronic mailbox of the kind some European countries operate. But for the direct-connection operator role, local presence is required in substance: a Chinese legal entity, a competent local tax authority, Chinese tax history and rating, controlled infrastructure, registered network addresses and a fixed IP. Appointing a local representative without establishing a suitable organisation does not substitute for any of this.

Data protection and security

An operator must comply with the Cybersecurity Law, the Data Security Law and the Personal Information Protection Law, with the network security classification protection requirements, and with the rules on storing and using tax data. The source transaction data must be generated in the operator's own system, be traceable and be available for inspection — and the operator is obliged to report suspicious client transactions to the tax authority.

Archiving

China has one of the longest retention regimes in the world. Under the Administrative Measures on Accounting Archives — the joint decree of the Ministry of Finance and the National Archives Administration — original accounting vouchers, bookkeeping vouchers, ledgers and journals must be kept for 30 years, raised from 15 years in 2016. A fapiao is an original accounting voucher and falls under that period.

Authenticity of origin, integrity of content and legibility must be guaranteed throughout the whole period

Archived invoices must be producible for the tax authorities on request at any point in it

The STA platform holds the data, but the taxpayer remains responsible for its own archive

Practically this means retaining the signed XML, not merely a printed or downloaded PDF or OFD. Thirty years is longer than most archive platforms have existed — format migration and readability over decades belong in the design of the solution, not in a later remediation project.

Penalties

Failure to issue or defective issue

The tax authority may order correction, impose a fine of up to CNY 10,000 and confiscate any unlawfully obtained income where an invoice was not issued although it should have been; the timing or sequence rules were broken; mandatory fields are missing; required invoice data was not transmitted; another document was improperly used in place of a fapiao; or the rules on storing and using invoices were breached.

Fictitious invoices

Up to CNY 10,000Unlawful income confiscated and a fine of up to CNY 50,000

Above CNY 10,000A fine of CNY 50,000 to CNY 500,000, with criminal prosecution possible

Invoice data offences

Stealing, intercepting, altering, selling or disclosing invoice data carries CNY 10,000 to CNY 50,000, rising to CNY 50,000 to CNY 500,000 for a serious breach, with possible criminal liability. Where the breach enabled someone else to avoid, underpay or unlawfully reclaim tax, an additional fine up to the amount of that tax may apply.

Fuel retail from November 2026

Failure to meet the immediate-issue requirement will bring a correction order and the general tax sanctions. Using someone else's payment QR code to evade the controls can bring a fine of up to CNY 10,000, confiscation of income and — where tax evasion is established — recovery of the tax with interest and a penalty of 50% to 500% of the underpaid amount.

VAT deduction

Is the electronic invoice the only possible basis for input VAT deduction? No — and this is a point where China genuinely differs from the clearance countries of Latin America.

Since 1 January 2026 Chinese VAT legislation expressly recognises paper and electronic VAT invoices as legally equivalent. The list of documents supporting deduction extends well beyond invoices:

—Special VAT invoices

—The customs document evidencing payment of import VAT

—The tax payment document

—Agricultural purchase and agricultural sales invoices

—Other documents to which the input VAT deduction function has been granted

So a paper special VAT invoice can still be valid; not every ordinary electronic invoice automatically confers deduction; imported goods rely primarily on the customs VAT document; and services from a non-resident rely on the tax payment document plus supporting material.

One active step is easy to miss and expensive to forget. Where a 数电发票 is to be used for input VAT deduction, an export refund or another prescribed purpose, the buyer must confirm its intended use through the tax digital account. Receiving the invoice is not enough.

How we help

China's domestic process runs on state infrastructure that no foreign provider substitutes for. Where a European platform earns its place is on the trade between China and Europe, and in the accounting layer around the fapiao:

The European side of China–EU trade — EN 16931, Peppol BIS Billing, XRechnung, Factur-X and the national CIUS the EU buyer requires

Commercial invoices for Chinese exporters in whatever format the foreign buyer has agreed, alongside the fapiao

Handling of documentation for import into the EU, where the Chinese invoice is a source document rather than the compliant one

Long-term archiving of the electronic originals with integrity and legibility preserved

Connection by API, SFTP and CSV, with ERP and IDoc source data

Frequently asked questions

Is e-invoicing mandatory in China?

Not as a universal electronic-only rule. The 数电发票 has run nationwide since 1 December 2024, but Chinese law treats paper and electronic VAT invoices as legally equivalent and speaks of promoting electronic invoicing rather than banning paper. What is mandatory is issuing a proper fapiao. Sector rules are where genuine electronic obligations exist — rail tickets, aviation itinerary receipts, and fuel retail from 1 November 2026.

Can I use my European Peppol Access Point in China?

Not for domestic Chinese invoicing. A Peppol certificate does not let you register a Chinese taxpayer in the 数电发票 system, assign Chinese invoice numbers, substitute for the Electronic Invoice Service Platform, route domestic invoices through Peppol, or act as a 乐企联用 operator. The operator role in substance requires a Chinese legal entity, local tax registration and rating, STA approval, technical integration and financial and security thresholds.

Does China have a Peppol Authority or a national EAS?

Neither. OpenPeppol's country profiles contain no Chinese national profile and name no Chinese Peppol Authority. Two things cause confusion: the OpenPeppol directory does list Chinese-domiciled companies certified as Access Points and SMPs — they provide international Peppol services, which is not integration with the 数电发票 — and the general ISO 6523 ICD list contains code 0131 for the China National Organization Code Registration Authority, which China has not established as a national e-invoicing EAS.

What format is the Chinese e-invoice?

A Chinese national XML under STA standards — principally GB/T 42965.1-2023 and 42965.2-2023, with the GB/T 44554 series for electronic accounting documents. EN 16931, UBL 2.1 and UN/CEFACT CII are not required or accepted as the national syntax. The platform also supports OFD, China's national fixed-layout format, and PDF for viewing and printing; for a fully digital accounting process the XML with the tax authority's digital signature is the electronic original. Invoices must be in Chinese.

Do I get an invoice number, or does the tax authority?

The STA does. Each 数电发票 receives a unique 20-digit number from the tax platform, along with the tax signature — the taxpayer never allocates its own numbering. The STA also sets a dynamic monthly ceiling on the total value a taxpayer may invoice, based on tax risk, tax credit rating, actual activity and issuance history; changing it can require approval from the competent tax authority.

How does the buyer receive the invoice?

Automatically, in their tax digital account — the platform delivers it. The seller may additionally send an email, QR code, PDF or link. For consumers, delivery must not be limited to email: the published 乐企联用 rules require a QR code and the possibility of free printing. Where the invoice is to be used for VAT deduction or an export refund, the buyer must then confirm its intended use through the tax digital account.

How long must invoices be archived?

Thirty years. Under the Administrative Measures on Accounting Archives, original accounting vouchers — which includes the fapiao — must be retained for 30 years, raised from 15 in 2016. Authenticity of origin, integrity of content and legibility must hold throughout, and the documents must be producible for the tax authorities on request. The STA platform holds the data, but the taxpayer is responsible for its own archive, so retain the signed XML rather than only a printed PDF or OFD.

Is the e-invoice the only basis for VAT deduction?

No. Since 1 January 2026 the legislation expressly treats paper and electronic VAT invoices as equivalent, and the supporting documents extend beyond invoices to the customs import VAT document, the tax payment document, agricultural purchase and sales invoices and others granted the deduction function. A paper special VAT invoice can still be valid; not every ordinary electronic invoice confers deduction; imports rely primarily on the customs document; and non-resident services rely on the tax payment document with supporting material.

Summary

China is a centralised, clearance-like CTC country in which the tax authority generates the invoice number, the tax signature and the issuance quota, receives the data in the act of issuing, and delivers the document into the buyer's tax digital account. But it is not a universal electronic-only mandate: paper and electronic VAT invoices are legally equivalent, and the obligation is to issue a proper fapiao rather than an XML file.

The pressure is arriving by sector rather than by general rule. Rail and aviation are already electronic-only in their own documents, and from 1 November 2026 fuel retail must issue immediately from each transaction through the 乐企 direct-integration channel. That principle — the transaction is the invoice — is the one to watch as it spreads.

For a European provider China is the clearest closed door of the countries on this site. There is no Peppol Authority, no national EAS, no EN 16931, and no route by which Peppol certification opens the domestic market. The direct-connection role requires a Chinese legal entity with capital, revenue and tax-rating thresholds and STA approval. What remains open — and is substantial — is the European side of China–EU trade, and the long-term archive.

Resources

State Taxation Administration The authority that operates the Electronic Invoice Service Platform and publishes the announcements behind every sector deadline Electronic Tax Bureau Where the tax digital account lives — invoices are issued, received and confirmed for their intended use here Ministry of Finance The accounting-archive rules and the electronic accounting document standards that govern how the fapiao is booked and retained General Administration of Customs Export declarations and the import VAT payment certificate that underpins deduction on imported goods Peppol Directory Useful for the European leg of China–EU trade — and for checking that a Chinese-domiciled Peppol provider is exactly that, not a domestic channel

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