Electronic invoice in Switzerland

Legal Requirements, Standards and Best Practices

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Overview

Switzerland is the outlier in this part of Europe. There is no clearance, no continuous transaction control, no real-time reporting and no B2B mandate — and none announced. The only compulsory e-invoicing is towards the federal administration, and even there a PDF by email remains acceptable. Swiss VAT law is deliberately technology-neutral: it defines an invoice by function, not by file format.

What Switzerland does have is a distinctive payment layer that foreigners consistently mistake for an invoicing regime — the QR-bill, which is in the middle of a transition with a deadline in September 2026. Getting that distinction right matters more here than any question about XML.

CHF 5,000

the federal threshold — on contract value excluding VAT, not on the invoice

0183 and 9927

the UID and the VAT identifier — the UID is normally the primary one

10 years

the usual retention period for Swiss accounting documents

Timeline

Switzerland's dates are about payment infrastructure and federal procurement, not about tax control. There is no mandate roadmap to track.

Already in force

1 January 2016

E-invoicing becomes mandatory for federal suppliers

Suppliers to the central federal administration must invoice electronically where the contract value exceeds CHF 5,000 excluding VAT. See Federal B2G.

1 October 2022

The QR-bill fully replaces payment slips

The old inpayment slips are withdrawn and the QR-bill becomes the Swiss payment standard.

30 June 2023

PDF leaves the federal service-provider channel

PDFs are no longer forwarded to the federal administration through the ordinary e-invoicing service provider channel — but they continue to be accepted by email.

21 November 2025

New QR-bill requirements take effect

Only structured addresses may be used in the Swiss QR code, and additional special characters are introduced. See The QR-bill.

Still ahead

30 September 2026

The QR-bill transition period ends

QR-bills carrying unstructured addresses have been accepted during a transition period ending on this date, after which the risk of payment rejections rises. This is the nearest real deadline Switzerland has.

1 July 2030

ViDA digital reporting — in the EU, not in Switzerland

Relevant to Swiss groups only through EU establishments or EU VAT registrations. See Cross-border and ViDA.

No Swiss B2B mandate exists and none has been announced. No law, no draft with a confirmed commencement date, no phased schedule by company size or turnover, and no obligation to transmit B2B invoices to the tax administration. The Federal Council has treated e-invoicing as a possible consequence of deeper future integration with European VAT mechanisms — not as a decision already taken.

Who is in scope

Federal administration suppliersMust invoice electronically where the contract value exceeds CHF 5,000 excluding VAT. Below the threshold, paper can still be accepted

Cantons and municipalitiesNo uniform federal mandate. Requirements come from the individual buyer's tender documents, contract and instructions — the federal threshold cannot be assumed to apply

Domestic B2BVoluntary. No published mandate date

B2CVoluntary. Paper, PDF, customer portals and eBill are all in use

Foreign suppliers to the ConfederationThe federal terms create no exemption by country of registration — the obligation attaches to the contract. Check the specific procurement for the delivery routes available

The threshold is the detail most often implemented incorrectly. It is measured on the value of the contract, not on the amount of the individual invoice, and it is calculated excluding VAT. A framework contract worth CHF 40,000 invoiced in monthly instalments of CHF 3,300 is in scope for every one of those invoices.

Federal B2G

The federal administration supports several ways in, and this is where Peppol capability alone can quietly fail to be enough.

Service providerStructured invoice data transmitted through an e-invoicing service provider

ERP integrationDirect from the ERP through a connected provider

Federal web portalInvoice created online, for suppliers without a system

PDF by emailStill accepted at a dedicated email address — so the federal mandate does not mean EN 16931 XML is the only permissible invoice

Federal recipients work primarily through the infrastructure of PostFinance and Swisscom. Other service providers reach those recipients through interconnect agreements. A Peppol certificate does not by itself guarantee that a given federal buyer is registered in a Peppol SMP and reachable over Peppol BIS Billing — check the route, not the certification.

B2B and B2C

Domestic B2B invoicing is entirely a matter of agreement. Paper, PDF, EDI, SwissDIGIN, Peppol — whatever the parties choose. There is no obligation to transmit anything to the Federal Tax Administration (Eidgenössische Steuerverwaltung, ESTV) beyond the periodic VAT return.

B2C and eBill

Consumers may be invoiced on paper, by PDF, through a customer portal, or through eBill — the Swiss banking channel in which the consumer registers the biller in online banking and receives the invoice directly in the banking interface.

eBill is worth understanding for what it is not. It is not Peppol and not a tax CTC system — it is a voluntary bank-operated delivery channel. Nothing about using eBill discharges or alters a VAT obligation, and nothing about it makes an invoice "structured" in the EN 16931 sense.

The QR-bill

The QR-bill replaced the old Swiss payment slips completely on 1 October 2022. It is a payment instrument, not an invoice format: a paper or PDF invoice carrying a standardised QR code that holds the payment information. Confusing it with e-invoicing is the most common foreign misreading of the Swiss market.

It is also the one part of Swiss invoicing with a live deadline. New requirements took effect on 21 November 2025, replacing version 2.2 of the Swiss Implementation Guidelines with version 2.3. The two substantive changes: only structured addresses may be used in the Swiss QR code, and additional special characters are supported.

Structured (type S)Street, house number, postal code and town as separate fields — the only form now permitted in the QR code, for both creditor and debtor addresses

Unstructured (type K)Free-text address lines — withdrawn, but tolerated during the transition

Transition ends30 September 2026, after which the risk of payment rejections rises

If a system still emits free-text addresses into the QR code, this is the item to fix first. The consequence is not a fine — it is payments failing, which is a slower and more expensive problem to diagnose. And because addresses often arrive from master data rather than from the invoicing layer, the fix is usually upstream of wherever the QR-bill is generated.

The model

Switzerland uses no national invoice-clearance model. The invoice is created by the supplier, delivered to the buyer directly or through a service provider, retained by both parties, and produced to the tax authority if an audit calls for it. The ESTV assigns no state identifier, does not confirm the invoice before it is sent, and is not a mandatory intermediate node.

What applies, and what does not

Centralised clearance through the tax authorityNo

Mandatory real-time transmission of invoice dataNo

A tax five-corner modelNo

Mandatory Peppol four-cornerNo

Voluntary Peppol four-cornerYes

B2G through commercial providers and interconnectYes

PDF by email to the federal administrationYes

VAT is declared in aggregate — usually quarterly, half-yearly under the net tax rate method, monthly in particular cases, and annually for eligible small businesses with permission. The return is filed and the tax paid within sixty days of the end of the period. Since 1 January 2025 returns are submitted through the ESTV portal, but that is electronic filing of a tax return, not transmission of individual invoices.

Formats and PDF

Swiss VAT law defines an invoice broadly — as the document by which consideration for a supply is settled with a third party. It does not provide that only an XML document can be legally valid. The ESTV accepts electronic documents without a qualified electronic signature, and what matters instead is:

—Verifiable origin and unaltered content

—A comprehensible audit trail

—The document can be read and produced on request

—The underlying transaction can be shown actually to have taken place

Structured machine-readable formats are recommended, but other formats are admissible provided they permit verification and contain no changeable dynamic elements.

The format landscape

swissDIGIN / eCH-0069The national recommended content standard, current version 4.2.0 approved on 30 January 2024, maintained by GS1 Switzerland through the swissDIGIN expert group. eCH standards are recommendations — not federal law imposing a mandatory B2B syntax

SwissDIGIN UBL 2.1The published local XML implementation, with a document generator and validator

Peppol BIS Billing 3.0Voluntary, and EN 16931-compliant since Peppol BIS Billing is a CIUS of the European standard

UN/CEFACT CIINot established as a mandatory national syntax

ZUGFeRD / Factur-XUsable by agreement between the parties, but not a Swiss mandatory format

PDF and paperPermitted, outside the cases covered by the federal B2G obligation

EN 16931 is not a mandatory universal standard for Swiss B2G, B2B or B2C invoices. Compliance with it arises chiefly as a side-effect of choosing Peppol BIS Billing 3.0 voluntarily.

Identifiers

0183CH:UIDB — the Swiss business identification number (Unternehmens-Identifikationsnummer, UID). Formatted on the UID, for example CHE followed by nine digits without separators

9927CH:VAT — the Swiss VAT identifier

0088 / 0209GLN and GS1 identification keys, for parties already working with GS1

Default to 0183 with the UID as the primary corporate identifier for Peppol registration. Use 9927 where the identification specifically has to be tied to the tax number. This is the reverse of the habit most EU-focused platforms have, where the VAT number is the natural first choice.

Peppol in Switzerland

Peppol is available and useful, but it is not the principal channel. Official federal guidance points first at PostFinance, Swisscom, interconnect with other Swiss service providers, PDF by email and the federal web portal. Treat Peppol as a supplementary voluntary channel — particularly valuable for international exchange and for companies already operating in the European Peppol environment.

No national Peppol Authority

No dedicated Swiss Peppol Authority was identified in the OpenPeppol lists, and Swiss Access Points appear as operating under OpenPeppol as their Peppol Authority. OpenPeppol performs the role in jurisdictions without a national one — so there is no Swiss body to apply to and no Swiss-specific service provider requirements to satisfy.

Requirements for providers

No separate Swiss state licence comparable to the Slovak digitálny poštár was identified. Operating as a Peppol Access Point means meeting the ordinary OpenPeppol requirements: the Service Provider Agreement, passing the mandatory conformance tests, obtaining and using Peppol PKI certificates, complying with the technical specifications, service level requirements and security rules, and supporting the relevant versions of the transport and business specifications.

A certified Access Point from Germany, Belgium, the Netherlands or elsewhere can register and serve Swiss Peppol participants without a separate Swiss status

No requirement to incorporate in Switzerland, hold a Swiss shareholder, host servers exclusively in Switzerland, obtain a state "official electronic mailbox" or appoint a local e-invoicing representative

Swiss e-invoicing systems address participants by participant number, invoice address, email or technical endpoint — there is no state mailbox equivalent

Peppol connectivity is not the same as reaching the federal administration. A foreign Access Point can connect a Swiss client to the Peppol network — but delivering into the traditional federal e-invoicing infrastructure may require an interconnect with PostFinance, Swisscom or another provider that already reaches that recipient.

One distinction to keep separate from all of this: a foreign business that itself becomes a Swiss taxpayer generally has to appoint a tax representative domiciled or established in Switzerland. That is a VAT compliance obligation of the foreign company, not a licensing condition for a Peppol Access Point.

Cross-border and ViDA

ViDA was approved by the EU Council on 11 March 2025, with mandatory digital reporting for the relevant intra-EU B2B transactions from 1 July 2030. Switzerland is not an EU member state, so ViDA does not create a mandate for ordinary Swiss-to-Swiss B2B, does not oblige Switzerland to build a clearance platform, and does not turn a direct export from Switzerland into the EU into an intra-Community supply.

Swiss supplier → EU companyNo Swiss structured-invoice requirement. But the recipient state's rules may apply — especially with an EU permanent establishment, a local VAT registration, a supply treated as domestic there, a mandate covering non-established VAT-registered suppliers, or an EU public buyer

Swiss group trading intra-EUWhere the transaction runs through an EU company, establishment or VAT registration, the member state's mandate applies — and from 1 July 2030 so do the ViDA reporting requirements

Foreign supplier → Swiss companyThe ESTV has clarified that the formal requirements of the Swiss VAT Act do not apply directly to foreign suppliers' invoices. The document must still describe the supply clearly enough for the recipient to establish its economic substance and tax treatment

So the requirement analysis for a Swiss client is not "which country is the supplier in". It is where the establishment is, where the VAT registration is, and where the transaction is taxed — three questions that can each point at a different jurisdiction.

Consequences and VAT deduction

No fixed administrative fine specifically for sending an invoice through the wrong channel was identified in the federal rules. The consequence is contractual and operational: the invoice may not meet the contract terms, the recipient may demand correction or resubmission, and processing and the payment period may only begin once a properly issued invoice has been received.

The federal terms tie payment to receipt of a properly issued invoice and separately impose the electronic invoicing obligation above the threshold. The realistic outcome of getting it wrong is therefore delayed payment until the defect is cured — not an automatic e-invoicing fine. Individual contracts may of course add general provisions on breach, damages or contractual penalties.

VAT offences

The Swiss VAT Act provides general sanctions for tax evasion, supplying incorrect information, claiming an unjustified deduction, and failing to meet retention and production obligations. Depending on the offence, fines can reach CHF 400,000, and up to CHF 800,000 in the aggravated cases the law provides for. These attach to the tax outcome, to false information or to an inability to substantiate the transaction — not to choosing PDF over XML.

VAT deduction

An electronic invoice is not the only lawful basis for deducting input VAT. Input tax can be evidenced by the invoice and by other proof that a taxable supply actually took place. The ESTV's position is that a qualified electronic signature is not required, an unsigned electronic invoice can support a deduction, and what is decisive is the audit trail together with the accounting records, contracts, payment documents and other evidence.

A paper invoice or a PDF does not lose legal force merely because there is no structured XML. Formal defects create audit risk — but Swiss deduction is not built on the "no state e-invoice, no deduction" principle familiar from clearance systems.

Archiving

Swiss accounting documents generally have to be retained for at least ten years. Electronic storage is permitted provided integrity, availability and legibility of the documentation are ensured.

The Swiss test is evidential rather than formal: you must be able to produce the original document in readable form, show that its content is unaltered, and connect it to a real transaction

Where the invoice was structured, keep the XML alongside a readable rendition — the audit trail is what carries the weight here, and it should link both

Documents must contain no changeable dynamic elements — a rendering that pulls live data at open time will not satisfy the requirement

Because there is no clearance platform and no state archive, everything rests with the parties. That is the trade-off of a technology-neutral regime: fewer format rules to comply with, and correspondingly more weight on being able to prove what happened.

How we help

Switzerland needs no licence and no local entity. What it needs is the right identifier, the right route, and a correct QR-bill:

Addressing on 0183 with the UID as primary and 9927 where the tax number is required

Peppol BIS Billing 3.0 alongside SwissDIGIN UBL 2.1, with conversion between them

A realistic route to federal recipients — interconnect with PostFinance or Swisscom, a partner, or the PDF-by-email fallback where that is what the buyer actually accepts

QR-bill payment data with structured addresses, ahead of the 30 September 2026 transition deadline

Human-readable PDF generation alongside the structured document

Document retention and an audit trail that lets the original be produced in readable form for ten years

Cross-border analysis by establishment and VAT registration, not by the supplier's country alone

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

Frequently asked questions

Is e-invoicing mandatory in Switzerland?

Only towards the central federal administration, and only where the contract value exceeds CHF 5,000 excluding VAT — in force since 1 January 2016. There is no domestic B2B mandate, no B2C mandate, and no uniform requirement for cantons and municipalities. Even in federal B2G, a PDF sent to the dedicated email address remains acceptable.

How is the CHF 5,000 threshold measured?

On the value of the contract, not the individual invoice, and excluding VAT. So a framework contract worth CHF 40,000 billed in monthly instalments of CHF 3,300 is in scope for every instalment. Below the threshold, paper invoices can still be accepted.

Is a Swiss B2B mandate coming?

Nothing has been published: no law on general domestic B2B e-invoicing, no draft with a confirmed commencement date, no phased schedule by size or turnover, and no obligation to transmit B2B invoices to the ESTV. The Federal Council has noted that Swiss VAT law does not impose formal invoice requirements comparable to the EU's, and has treated e-invoicing as a possible consequence of deeper future integration with European VAT mechanisms rather than a decision taken.

Is the QR-bill an electronic invoice?

No — it is a payment instrument. A QR-bill is a paper or PDF invoice carrying a standardised QR code with the payment information; it replaced the old payment slips entirely on 1 October 2022. It is not a structured e-invoice and has nothing to do with EN 16931. eBill is different again: a voluntary bank channel delivering invoices into online banking, not Peppol and not a tax system.

What changed for the QR-bill, and by when?

New requirements took effect on 21 November 2025, replacing version 2.2 of the Swiss Implementation Guidelines with version 2.3. Only structured addresses — street, house number, postal code and town as separate fields — may be used in the Swiss QR code, for both creditor and debtor, and additional special characters are supported. QR-bills with unstructured free-text addresses are tolerated during a transition period ending 30 September 2026, after which the risk of payment rejections rises. The consequence is failed payments rather than a fine.

Does Switzerland use EN 16931?

Not as a mandatory universal standard for B2G, B2B or B2C. Compliance arises mainly where a business voluntarily chooses Peppol BIS Billing 3.0, which is a CIUS of EN 16931. The national recommended content standard is SwissDIGIN, published as eCH-0069 — current version 4.2.0, approved 30 January 2024 — with a UBL 2.1 implementation. eCH standards are recommendations, not federal law establishing a mandatory B2B syntax.

Which identifier should I use for a Swiss participant?

EAS 0183 (CH:UIDB) with the Swiss UID is normally the primary corporate identifier for Peppol registration — formatted on the UID, for example CHE followed by nine digits without separators. EAS 9927 (CH:VAT) is used where identification has to be tied to the tax number. GLN 0088 and GS1 keys 0209 are available for parties already using GS1. Note this inverts the usual EU habit of defaulting to the VAT number.

Can a foreign Peppol Access Point serve Swiss clients?

Yes, within Peppol. No dedicated Swiss Peppol Authority was identified — Swiss Access Points operate under OpenPeppol — and no Swiss incorporation, shareholder, local hosting, state mailbox or local e-invoicing representative is required. But distinguish two things: connecting a Swiss client to Peppol, and delivering into the traditional federal infrastructure, which may need an interconnect with PostFinance, Swisscom or another provider that already reaches the recipient. A Peppol certificate does not guarantee a given federal buyer is registered in an SMP.

What happens if I invoice the Confederation the wrong way?

No fixed administrative fine for using the wrong channel was identified in the federal rules. The consequences are contractual and operational: the invoice may not meet the contract terms, the recipient may require correction or resubmission, and processing and the payment period may only start once a properly issued invoice has been received. Delayed payment is the realistic outcome. Separately, the VAT Act's general sanctions — reaching CHF 400,000, and CHF 800,000 in aggravated cases — attach to evasion, false information or unsubstantiated transactions, not to format choice.

Do I lose my VAT deduction without a structured invoice?

No. Input tax can be evidenced by the invoice and by other proof that a taxable supply actually took place. The ESTV does not require a qualified electronic signature, accepts that an unsigned electronic invoice can support a deduction, and treats the audit trail, accounting records, contracts and payment documents as decisive. A paper invoice or PDF does not lose legal force for want of XML — formal defects create audit risk, not automatic loss of the deduction.

Does ViDA affect Swiss companies?

Not directly. Switzerland is not an EU member state, so ViDA creates no mandate for Swiss-to-Swiss B2B, does not require Switzerland to build a clearance platform, and does not make a direct export from Switzerland to the EU an intra-Community supply. It bites where a Swiss group operates through an EU company, permanent establishment or VAT registration and the transaction falls within the intra-EU rules — from 1 July 2030 for the reporting requirements. The analysis follows establishment, registration and place of taxation, not the supplier's country.

Summary

Switzerland is the least regulated invoicing market in this region and likely to stay that way. Federal suppliers above CHF 5,000 of contract value must invoice electronically; everything else is voluntary. VAT law is technology-neutral, an unsigned electronic document is fine, and the deduction turns on the audit trail rather than on the file format.

Two things nonetheless catch foreign providers. Peppol is a secondary channel here — federal delivery runs primarily through PostFinance and Swisscom, and certification alone does not reach every buyer. And the identifier of choice is the UID on scheme 0183, not the VAT number.

The only date worth putting in a diary is not a tax deadline at all: 30 September 2026, when the QR-bill transition ends and unstructured addresses start costing you payments rather than penalties.

Resources

SIX — QR-bill, Swiss Payment Standards The authoritative source for the QR-bill implementation guidelines, structured addresses and the transition SIX — QR-bill transition period 2025–2026 (PDF) The factsheet setting out what changes, what is tolerated and until when ESTV — Federal Tax Administration VAT rules, invoice requirements, the portal for returns and the guidance on electronic documents swissDIGIN — the standard The content standard and the supported formats, maintained by GS1 Switzerland through the swissDIGIN expert group swissDIGIN — service provider directory A neutral list of Swiss e-invoicing service providers — useful when you need an interconnect partner eCH — Swiss e-government standards Where eCH-0069, the SwissDIGIN content standard, is published and versioned eBill The Swiss banking delivery channel — voluntary, and distinct from both Peppol and any tax system Peppol Electronic Address Scheme code list Where 0183 for the Swiss UID and 9927 for the Swiss VAT identifier sit OpenPeppol — Peppol Authorities Confirm that Switzerland has no national authority and that OpenPeppol fills the role Peppol Directory Check whether a Swiss participant — or a federal recipient — is actually reachable over Peppol

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