Electronic invoice in Lithuania

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Overview

Lithuania has had a mandatory structured B2G regime since 2017 — one of the earliest in the EU — and no B2B mandate at all. What it does have instead is i.SAF, a monthly obligation on every Lithuanian VAT payer to file registers of issued and received invoices. So there is real reporting pressure here; it just sits on tax data rather than on the invoice channel.

The infrastructure changed recently and confusingly. The old E. sąskaita platform was replaced by SABIS, and both 1 July and 1 September 2024 circulate as the switchover date. The Ministry of Finance page gives 1 September 2024 as the point at which SABIS replaced the old system, so that is the date to build against. The mandate itself did not change in 2024 — only the pipes.

0200 and 9937

the legal entity code and the VAT number — 0200 is the natural default

3 routes

into SABIS — the web portal, API or ERP integration, and Peppol

10 years

retention for the data underlying the i.SAF filings

Timeline

Lithuania's obligations arrived early and have been stable since. The recent activity has been infrastructure rather than law.

Already in force

1 October 2016

i.SAF invoice register reporting begins

Lithuanian VAT payers start filing registers of issued and received VAT invoices into the tax administration's system. See i.SAF reporting.

1 July 2017

Structured e-invoicing becomes mandatory in public procurement

Suppliers to Lithuanian contracting authorities and entities must issue electronic invoices — above and below the EU procurement thresholds. This is the mandate, and it has not changed since.

1 September 2024

SABIS replaces E. sąskaita

The national platform changes, driven by alignment with the European infrastructure through Peppol. The European Commission records 1 July 2024 as the transition without a parallel period; the Lithuanian Ministry of Finance page gives 1 September 2024 as the operational replacement.

14 April 2025

ViDA enters into force

Adopted in March 2025, the package sets the cross-border obligations that will reach Lithuania through implementation rather than through a national initiative.

Still ahead

1 July 2030

ViDA digital reporting for intra-EU B2B

Mandatory structured e-invoicing and near-real-time digital reporting for the cross-border B2B transactions in scope, replacing the existing recapitulative statements. See Cross-border and ViDA.

European Commission material for Lithuania has mentioned 1 January 2028 as a target date for a national B2B mandate. No adopted Lithuanian law establishing a general domestic B2B mandate from that date was found in the official national sources. Treat 2028 as an indication of direction, not as a statutory deadline, until a Lithuanian legislative act says otherwise.

Who is in scope

Suppliers in public procurementMust issue structured e-invoices and route them through SABIS. Applies to central, regional and municipal authorities and other contracting entities

Contract type and valueWritten contracts, oral agreements, and long-term oral arrangements alike — and regardless of the amount. There is no de minimis

Foreign suppliers to the public sectorBound by the same obligation where the invoice relates to a Lithuanian public procurement

Domestic B2BNo mandate. Structured invoicing is voluntary and by agreement

B2CNo mandate. Retail receipts and cash register documents follow their own rules

Lithuanian VAT payersi.SAF filing is mandatory, independently of how the invoice was delivered

The absence of a value threshold in B2G is worth flagging to clients. The Ministry of Finance states that all invoices for goods, services and works must go through SABIS — including those under oral and long-term oral agreements, and irrespective of amount. A small recurring invoice to a municipality is in scope exactly as a large tender is.

B2G and SABIS

SABIS — the General Account Administration Information System (Sąskaitų administravimo bendroji informacinė sistema) — is the central government platform for receiving, validating, routing and processing B2G invoices. Every invoice to a contracting organisation goes through it.

Web portalManual creation and submission, including documents composed directly in the SABIS interface

API or ERPDirect integration for volume senders

PeppolSABIS is connected to the Peppol network, so a foreign supplier with an Access Point can reach Lithuanian contracting authorities without a Lithuanian account

SABIS performs technical and business validation, forwards the invoice to the correct public recipient, and exposes processing status back to the sender. Build for that status feedback — rejections and technical acknowledgements are part of the flow, not an exception to it.

The 2024 change is often described as "Lithuania introduced e-invoicing". It did not. The mandate dates from 2017; what happened in 2024 was that the technical infrastructure was replaced and connected to Peppol. For a foreign provider that is good news — the new platform is reachable the way the rest of Europe is reachable.

B2B and B2C

There is no general domestic B2B mandate. Companies may exchange Peppol BIS Billing, UBL, CII, EDI or any other agreed format, or continue with PDF and paper. What matters is the agreement between the parties and compliance with the ordinary accounting and VAT rules.

Alongside this sits the i.SAF obligation, and the two are frequently conflated. Keeping them apart is worth the effort:

—The invoice does not pass through the tax administration before reaching the buyer

—No prior approval by the tax authority is required

—Peppol is not obligatory for B2B

—PDF and paper invoices remain usable under the general rules

—What goes to i.SAF is invoice data, not necessarily the legally operative EN 16931 document

B2C

No mandate. An electronic invoice may be provided to a consumer voluntarily or by agreement, but no structured format is required. Cash register receipts and retail documents are governed by separate rules and do not turn B2C into Peppol or EN 16931 territory. Individual B2C invoices can still fall into i.SAF where the document is a VAT invoice subject to registration.

The model

Lithuania combines a centralised B2G gateway with a decentralised Peppol four-corner network, on top of a periodic tax reporting system. Each of those three descriptions matters, and the first one invites a misunderstanding worth heading off.

Is SABIS clearance?

It has the shape of one — the invoice enters a central system, is checked, and is then routed onward to the public buyer. But it is not a national tax clearance model in the manner of the Italian SdI or Polish KSeF:

SABIS serves the B2G and public procurement domain, not general commerce

The tax administration assigns no mandatory fiscal identifier to the invoice

Prior authorisation is not a condition of the validity of any B2B invoice

Ordinary B2B invoices never touch SABIS at all

Nor is there real-time or near-real-time VAT reporting. i.SAF is periodic — monthly filers submit by the 20th of the following month — which places Lithuania firmly outside continuous transaction control in the strict sense.

Formats and PDF

The B2G system conforms to EN 16931, and Lithuania applies no national CIUS and no significant national extensions — which makes it one of the less demanding integrations in the region.

Peppol BIS Billing 3.0Invoice and Credit Note, on UBL 2.1 — the principal structured exchange format

UN/CEFACT CIIAccepted where EN 16931-compliant

SABIS-composed documentsInvoices created directly in the platform's web interface

i.SAF XMLA separate Lithuanian tax reporting schema with its own XSD — not UBL and not CII. See i.SAF reporting

Where the PDF sits

In B2G, a plain PDF is not a structured EN 16931 invoice, and emailing one does not discharge the obligation to submit through SABIS. A PDF may serve as a visualisation, an attachment, an additional human-readable document, or within the buyer's own internal process — but the legally required step is the structured submission.

In B2B and B2C, with no mandate in place, a PDF remains usable where the parties agree and where authenticity of origin, integrity of content, legibility, the mandatory VAT invoice content and the retention requirements are all satisfied. That changes for the intra-EU transactions caught by ViDA from 2030.

Identifiers

Two schemes apply, and choosing the wrong one is a more common cause of failed Lithuanian delivery than any format problem.

0200The Lithuanian legal entity code (juridinio asmens kodas). Written as 0200:123456789. For Lithuanian legal persons this is the natural primary identifier

9937The Lithuania VAT number. Written as 9937:LT123456789. Used where the participant is registered under its VAT ID

For B2G, do not guess. Reconcile the identifier against the recipient's registration in SABIS, the entry in the Peppol SMP, the specific contracting authority's stated requirements, and the contract or procurement documentation. Those four should agree — and when they do not, the SMP is not automatically the winner.

Peppol in Lithuania

Peppol is the officially supported interoperability channel and the obvious route for automated and cross-border exchange — but it is not the only way into SABIS, which also accepts portal submissions and direct API or ERP integration. SABIS remains the central point of receipt for B2G regardless of how the invoice arrives.

No separate national Peppol Authority

Lithuania does not appear in the current OpenPeppol list as a jurisdiction with its own national Peppol Authority, and OpenPeppol performs the role as Peppol Coordinating Authority where none exists. So governance splits cleanly: SABIS is run by Lithuanian institutions; the Peppol framework applying to service providers runs through OpenPeppol. There is no Lithuanian Peppol Authority Agreement and no Lithuanian PA-specific accreditation layer.

i.SAF reporting

i.SAF is a subsystem of i.MAS, the Lithuanian smart tax administration system. VAT payers registered in Lithuania file registers of issued and received VAT invoices. It has been mandatory since October 2016 and is entirely separate from how the invoice itself was delivered.

Who filesPersons registered as VAT payers in Lithuania

DeadlineMonthly filers by the 20th day of the following month; other periods follow the equivalent rule after the period ends

HowXML in the prescribed local structure, a web service, manual entry, or by creating and receiving individual invoices through certain i.SAF functions

ContentA header, taxpayer details, customer and supplier data, the issued and received invoice registers, tax codes, and payment information where required

ScopeNot only domestic invoices — certain invoices from foreign counterparties and transactions creating a Lithuanian VAT liability are included

The i.SAF XML is a tax reporting format, not an EN 16931 syntax. It is neither UBL 2.1 nor UN/CEFACT CII, and no amount of Peppol capability produces it. Delivering invoices and filing i.SAF are two distinct pieces of work — a distinction that decides how a provider scopes a Lithuanian engagement.

Requirements for providers

No Lithuanian accreditation regime comparable to the Slovak digitálny poštár or the French PDP was found in the available official material. Since Lithuania has no Peppol Authority of its own, there is also no set of Lithuanian PA-specific requirements to satisfy. What applies is the ordinary OpenPeppol layer: membership, valid Access Point certification, the Transport Infrastructure Agreement, AS4, SMP and SML, the applicable BIS profiles, and support for the required document and process identifiers.

A certified Access Point from another EU country can register Lithuanian clients, address them on a supported scheme, and deliver B2G invoices into SABIS through Peppol

No requirement was found for a Lithuanian entity, local office, local representative, national electronic mailbox, local data centre, or a licence from the tax administration or Ministry of Finance

Companies may use any service provider, provided the invoice complies with the European standard

What actually needs attention

Endpoint registrationConfirm whether 0200, 9937 or another permitted scheme is in use for the specific participant

Profile supportPeppol BIS Billing 3.0 including Invoice, Credit Note, business rules and EN 16931 validation

Correct identifiersProcess and document type identifiers must let SABIS recognise the document as a supported B2G invoice

Response handlingTechnical acknowledgements, rejections and processing statuses from SABIS

Procurement referencesContract number, order, procurement reference or other buyer reference where the authority requires it

The client itself, or its authorised person, may still need SABIS access — to manage the account, view statuses, work through rejections, confirm authority or configure direct API integration. That is a client-side requirement, not a local presence requirement on the provider.

Consequences and VAT deduction

No single fixed penalty applied automatically to every invoice not sent through SABIS was identified in the official sources. The Ministry of Finance characterises SABIS use as a legal obligation rather than a recommendation — but the consequences of ignoring it are operational and contractual rather than a fixed fine.

—The invoice never enters the government workflow, so the buyer may not take it into its accounts

—It can be returned or rejected, and the payment term may not begin to run until a proper invoice arrives

—The supplier may be in breach of the contract and of the public procurement rules, with the usual contractual consequences

i.SAF breaches

Failing to file, filing late or filing incorrect data can lead to correction demands from the tax administration, tax control, administrative liability and fines under the general tax and administrative rules — and, where the breach involves incorrect VAT, to additional assessment, interest and penalties. The applicable amount depends on the characterisation of the offence, whether it is repeated, who is held liable, whether it was intentional or negligent, whether it was corrected and whether tax was lost. A single universal figure for any i.SAF breach cannot honestly be stated.

VAT deduction

A structured EN 16931 or Peppol invoice is not the only lawful basis for deducting input VAT in ordinary B2B. The right to deduct turns on the transaction actually having taken place, the acquisition being used for taxable activity, holding a proper VAT invoice or other permissible document with the mandatory content, absence of fraud or abuse, and the substantive conditions being met. An unstructured invoice, including a PDF or a paper document, can still be valid in domestic B2B.

Four things are separate and should stay separate: the validity and content of the VAT invoice; the buyer's right to deduct; the supplier's duty to route a B2G invoice through SABIS; and the duty to register data in i.SAF. A format or reporting error does not automatically destroy a substantive deduction right — though the tax administration may require a corrected invoice, an explanation and a correction to the filings.

Archiving

The data underlying the i.SAF filings must be retained for ten years, with authenticity, integrity and legibility preserved throughout. Confirm the applicable period for other document categories with a Lithuanian adviser — ten years is the figure that governs the invoice and reporting data, not a universal ceiling for everything a business holds.

Where the invoice was structured, retain the XML and not merely the rendered visualisation

Keep the SABIS evidence as well as the invoice — submission, validation outcome and processing status are what demonstrate the B2G obligation was met

The i.SAF submissions and the commercial invoices are different records. Holding one does not evidence the other

Neither SABIS nor the tax administration is your archive. A platform that routed the document and an authority that received a register are not substitutes for being able to produce the original invoice a decade later.

Cross-border and ViDA

Foreign supplier → Lithuanian authorityThe B2G obligation applies. Peppol is the practical channel, and no Lithuanian company is needed merely to send the invoice. i.SAF duties depend on whether there is a Lithuanian VAT registration

Intra-EU B2B before 2030No general obligation to use Peppol or EN 16931. Format is agreed between the parties; ordinary intra-Community VAT rules apply, and the Lithuanian VAT payer reflects the transactions in i.SAF and its VAT reporting

Intra-EU B2B from 2030Structured e-invoicing becomes mandatory, PDF will not suffice, a harmonised data set is required and data goes to the tax authorities in near-real time

Export outside the EUNo universal Lithuanian requirement. The buyer's country rules, contract terms, customs documents and Lithuanian VAT and i.SAF obligations govern

The export case deserves a caveat that Lithuanian-focused guidance often omits: if the destination country operates a clearance platform or requires a local format, a Lithuanian supplier must comply with those rules. The absence of a Lithuanian B2B mandate is irrelevant to what a Brazilian or Saudi buyer's tax administration requires.

What happens to i.SAF under ViDA is genuinely open. The existing system will have to coexist with the EU model, be amended, or be integrated into it — and the network choice for national reporting, whether Peppol, a state platform or other compatible infrastructure, still requires national specification.

How we help

Lithuania needs no licence and no local entity. The risks here are identifiers and business rules, not permission:

Peppol BIS Billing 3.0 and EN 16931 in both syntaxes — UBL 2.1 and UN/CEFACT CII

Onboarding on 0200 and 9937, reconciled against the recipient's SABIS registration rather than assumed

Delivery into SABIS over Peppol, with correct process and document type identifiers

Buyer references and procurement identifiers carried in the invoice where the authority requires them

Handling of SABIS acknowledgements, rejections and statuses rather than fire-and-forget sending

Structured invoice data clean enough to feed the i.SAF registers, with the scoping distinction made explicit

PDF visualisation alongside the XML for partners who still work on paper

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

Frequently asked questions

Is e-invoicing mandatory in Lithuania?

In public procurement, yes — since 1 July 2017, for contracts above and below the EU thresholds, and regardless of amount. In domestic B2B and B2C, no. Separately, every Lithuanian VAT payer must file i.SAF registers of issued and received invoices, which is a reporting obligation rather than an invoicing one.

What is SABIS and when did it replace E. sąskaita?

SABIS is the central government platform for receiving, validating, routing and processing B2G invoices. Two dates circulate: the European Commission records 1 July 2024 as the transition without a parallel period, while the Lithuanian Ministry of Finance page gives 1 September 2024 as the operational replacement. Build against 1 September 2024. The change did not create the mandate — that has existed since 2017.

Is there a Lithuanian B2B mandate coming in 2028?

European Commission material has mentioned 1 January 2028 as a target date, but no adopted Lithuanian law establishing a general domestic B2B mandate from that date was found in the official national sources. Treat 2028 as direction rather than a statutory deadline until a Lithuanian legislative act confirms it. The date that is legally fixed is 1 July 2030, and it comes from ViDA.

Is SABIS a clearance system?

It has the shape of a central gateway — the invoice enters, is validated, then routed — but it is not a tax clearance model like the Italian SdI or Polish KSeF. SABIS serves public procurement rather than general commerce, the tax administration assigns no mandatory fiscal identifier, prior authorisation is not a condition of validity for any B2B invoice, and ordinary B2B invoices never pass through it at all.

Does Peppol capability cover i.SAF?

No. The i.SAF XML is a tax reporting format with its own XSD — neither UBL 2.1 nor UN/CEFACT CII — and it is filed to the tax administration separately from however the invoice was delivered. Delivering invoices and filing i.SAF are distinct pieces of work, and scoping a Lithuanian engagement without saying which one you are doing causes trouble later.

Which identifier should I register for a Lithuanian participant?

EAS 0200 is the Lithuanian legal entity code and the natural primary identifier for a Lithuanian legal person; EAS 9937 is the Lithuania VAT number, used where the participant is registered under its VAT ID. For B2G, reconcile the choice against the recipient's SABIS registration, its Peppol SMP entry, the specific authority's stated requirements and the contract or procurement documentation.

Can a foreign Peppol Access Point serve Lithuanian clients?

Yes. No Lithuanian accreditation regime comparable to the Slovak digitálny poštár or the French PDP was found, and since Lithuania has no national Peppol Authority there are no Lithuanian PA-specific requirements either. No Lithuanian entity, office, representative, mailbox, local data centre or national licence is required. The client itself may still need SABIS access for account management, statuses and rejections — but that is a client-side matter.

Can I still send PDF invoices?

In B2B and B2C, yes, where the parties agree and the requirements on authenticity of origin, integrity, legibility, mandatory VAT invoice content and retention are met. In B2G, no: a plain PDF is not a structured EN 16931 invoice and emailing one does not replace submission through SABIS. A PDF may still accompany the structured invoice as a visualisation. From 2030, PDF will not suffice for the intra-EU B2B transactions caught by ViDA.

What are the penalties?

No single fixed amount applied automatically per invoice not sent through SABIS was identified. The practical consequences are that the invoice never enters the government workflow, can be returned or rejected, may not start the payment term running, and may put the supplier in breach of contract and procurement rules. For i.SAF, failing to file, late filing or incorrect data can bring correction demands, tax control, administrative liability and fines under the general rules, plus assessment and interest where VAT was affected — with the amount depending on the characterisation of the offence, repetition, intent and whether it was corrected.

How long must records be kept?

The data underlying the i.SAF filings must be retained for ten years with authenticity, integrity and legibility preserved. Retain the XML where the invoice was structured, and keep the SABIS submission and status evidence alongside it — that is what demonstrates the B2G obligation was met. Neither SABIS nor the tax administration serves as your archive.

Summary

Lithuania is an early B2G mandate country with no B2B mandate and a long-standing periodic reporting obligation. Public procurement invoicing has been structured and compulsory since 2017, routed through SABIS since 2024, and reachable over Peppol. Domestic B2B remains voluntary, and i.SAF collects the tax data monthly regardless.

Technically the country is undemanding: EN 16931 with no national CIUS, Peppol BIS Billing 3.0 in practice, and two clear identifier schemes. There is no national accreditation, no local entity requirement and no Lithuanian Peppol Authority.

Which leaves the real risks where they actually are: the identifier, the SABIS business rules, the procurement references the authority expects — and the fact that Peppol delivery and i.SAF filing are two jobs, not one.

Resources

Ministry of Finance of the Republic of Lithuania The authority behind SABIS and the source for the scope of the B2G obligation, including oral agreements and the absence of a value threshold State Tax Inspectorate (VMI) The tax administration behind i.MAS and i.SAF, and the place where reporting obligations and deadlines are published European Commission — eInvoicing in Lithuania The country profile: the B2G mandate, the SABIS transition and the absence of a national CIUS Peppol BIS Billing 3.0 The profile used for structured delivery into SABIS and for cross-border exchange Peppol Electronic Address Scheme code list Where 0200 for the legal entity code and 9937 for the VAT number sit OpenPeppol — Peppol Authorities Confirm that Lithuania has no national authority and that OpenPeppol fills the coordinating role European Commission — VAT in the Digital Age (ViDA) The 1 July 2030 obligations — the only firmly fixed future date on this page Peppol Directory Check that a Lithuanian recipient is reachable, and on which identifier scheme

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