Mastering E-Invoicing & Real-Time Reporting: Answers to Your Questions
Interest in e-invoicing and real-time reporting keeps rising as new mandates reshape digital compliance across Europe and beyond. During our recent webinar, “Mastering E-Invoicing & Real-Time Reporting (feat. Agfa & Mastercard),” experts from Comarch, Agfa, and Mastercard explored how organizations can stay compliant while driving process efficiency. The session sparked a flood of questions—from Peppol readiness and ViDA alignment to integration and data quality. We couldn’t address them all live, so this article gathers the most relevant ones to help you prepare for upcoming changes with confidence.
Is e-invoicing obligatory in Denmark? Is there a change coming in January 2026?
Electronic invoicing in Denmark is moving toward wider adoption. Starting January 1, 2026, individually owned businesses and associations with an annual turnover above DKK 300,000 will be required to use accounting software capable of exchanging electronic invoices. This requirement will de facto mean an e-invoice acceptance mandate for these entities. While issuing traditional invoices will still be legal, the overall adoption rate will most likely increase.
What if a Belgian VAT-registered customer isn’t ready or doesn’t provide a Peppol ID, and you can’t look it up using the VAT number?
While Belgium’s e-invoicing reform makes it mandatory for business operators to use Peppol for the exchange of domestic B2B invoices, suppliers can’t assume a customer’s Peppol connectivity without confirmation. If the customer doesn’t provide a valid Peppol ID or can’t be found in the Peppol network, the supplier’s Peppol Access Point provider (e.g., Comarch) will trace the delivery failure to the intended endpoint and issue a notification to the supplier as proof that a legal transmission route has been attempted. In such cases, fallback delivery options should be discussed directly with the customer.
Will it be possible in the future to exchange other structured messages via Peppol, such as reminders or purchase orders?
Yes. Peppol can expand beyond invoicing to support a wider range of business documents, such as purchase orders, catalogues, payment reminders, or dispatch advice, under the Peppol Business Interoperability Specifications (BIS). However, actual adoption of these features depends on each country’s strategy and local mandates.
What recommendations do you have regarding contract adoption for vendors and customers in light of Peppol?
Contracts should clearly define:
- Peppol as the default exchange channel, where available,
- Fallback channels if the counterparty is not yet connected to Peppol,
- Mutual obligations to provide correct Peppol identifiers,
- Compliance with the EN16931 standard.
From a UAE perspective, given that there may be several entities under a VAT group registration, with different entities having different revenues, should e-invoicing implementation be considered at a VAT group level or at the individual entity level?
The UAE mandate applies at the individual entity level, even within the VAT group. Each entity is required to comply based on its own revenue threshold, regardless of the group’s overall registration.
Considering finance month-end close activities, which can run from the first days of the following month, will the e-invoice be dated in real time (i.e., with the actual date in the next month–October 2025) or can it be back-dated to the end of the month being closed (September 30, 2025)?
Under most CTC and e-invoicing regimes, invoices must be dated and transmitted in real time at the moment of issuance. Back-dating for accounting purposes is not permitted—the legal invoice date is always the transmission date. That said, ERP and accounting teams may still use accruals for internal month-end adjustments.
Do you foresee the respective countries’ models being the same in the future (especially in Europe)?
Not immediately. The EU is converging under ViDA, but for now, models will remain hybrid. Full harmonization is expected, yet it will take time before a single, unified framework is achieved across all member states.
How are you dealing with the expense notes process in Peppol? For example, an invoice from a hotel in the name of the company, that is paid in real-time, but then also comes through Peppol, creating a risk of double booking or double payment.
Expense invoices from suppliers (e.g., hotels) should be received via Peppol. To avoid duplication, expense management systems must reconcile these entries using unique invoice identifiers. Modern ERP systems and expense tools include duplicate detection logic that prevents double booking or payment by matching invoice numbers, dates, and supplier details.
What do you find most challenging regarding an e-invoicing implementation?
The main challenges include integration across multiple ERPs and middleware, managing local variations in tax and reporting, ensuring data quality at the source, and change management across business and finance teams.
What were the biggest challenges in the implementation in Belgium?
The main challenge was achieving technical compliance while also ensuring strong project governance across multiple ERP instances. Coordinating different business units and maintaining consistent data flows required a strong central governance model.
Another key challenge was aligning the e-invoicing rollout with ongoing internal projects—such as ERP upgrades, finance transformation, and integration programs—to avoid duplication of effort and ensure consistency. With the help of Comarch as a solution provider, establishing clear ownership, timelines, and decision-making structures proved essential for success.
Are you considering cross-country invoices also in scope now, even though they’re not yet required in many EU countries, but will be under ViDA?
Yes. While cross-border invoices are generally not yet mandatory in many EU countries (with some exceptions, such as e-reporting in France or Italy), ViDA will require near real-time reporting of intra-EU B2B invoices. Preparing now ensures scalability when these requirements take effect.
Have you encountered situations where, due to tight country deadlines, you had to provide an interim solution first and only later move to a strategic one (i.e., without integrating client systems with the Comarch platform for the interim)?
Yes, interim solutions are a possibility, yet the cost and risk must be factored in. While they can serve short-term needs, a strategic integration with the Comarch platform remains the best approach for long-term efficiency and compliance.
How can organizations ensure the completeness and compliance of e-invoicing data when the source is not the ERP system, but a receivables management system or an external platform?
When e-invoicing data comes from a receivables management system or an external platform, organizations can ensure completeness and compliance by using the Comarch E-Invoicing platform as a central control point.
Comarch applies advanced validation rules that automatically check formats, mandatory fields, and tax logic while ensuring full EN16931 and Peppol compliance. The platform also performs cross-system reconciliation, matching invoice data from external systems with internal records to eliminate discrepancies and avoid duplicates.
Every document receives a unique identifier and is stored with a complete audit trail, providing one consistent source of truth across all channels. Continuous updates to local regulations are handled automatically, ensuring compliance without manual effort.
We have two Belgian entities billing each other. As far as I understand, if both entities have a mutual agreement and are compliant with the EN16931 EU standard format, it’s not necessary to send invoices through Peppol, as they can be exchanged directly via EDI (for example, SAP to Oracle). It would only be the case for intercompany invoices, while Peppol would still be used for external partners. Can you please confirm if my understanding is correct?
Yes, your understanding is correct. For intercompany invoices within Belgium, if both entities agree on the process and comply with the EN16931, direct EDI is allowed. Peppol becomes mandatory only when invoices involve external business partners.
Why aren't you using SAP DRC Cloud?
It’s mostly due to flexibility, cost considerations, and preference for a multi-country provider that can cover diverse mandates end-to-end more effectively than SAP DRC Cloud.
Managing different e-invoicing rules can be complex, but solutions like Comarch e-Invoicing make it simpler. The platform evolves with local regulations, so you can focus on business, not bureaucracy. No matter where you operate, we’ve got compliance covered.
