Regional Strategies in E-Invoicing Mandates: Case Studies from Europe and Beyond

The global push for e-invoicing is unified in purpose, but the paths to that goal look very different from country to country. While frameworks like the EU’s ViDA signal a shared destination, the real action is happening at the national level, where legal structures, technical readiness, and political priorities shape how mandates take form. In a recent webinar hosted by Comarch and PwC, we explored how countries translate regulatory ambition into practical mandates. This article dives into those case studies, revealing what’s working, what isn’t, and why execution matters more than ever.

From Global Goals to Local Execution

E-invoicing may be a global trend, but no two national rollouts look alike. From clearance models to PEPPOL networks, each country is navigating its own route—shaped by local constraints and strategic choices. The following case studies unpack these approaches, offering unique lessons in strategy, structure, and execution.

Belgium: Phased Mandate with PEPPOL as the Backbone

Belgium is taking a structured approach toward mandatory B2B e-invoicing, adopting PEPPOL as a default infrastructure. The nationwide mandate begins in January 2026, applying to nearly all Belgian established and VAT-registered businesses, regardless of size. Most domestic transactions between Belgian-established entities fall within scope, with limited exceptions such as medical and insurance services under Article 44 of the Belgian VAT Code.

Approach

Invoices must be exchanged in a structured format using the PEPPOL four-corner model, aligned with the European standard (EN 16931). An opt-out is permitted only if both parties agree and the format remains compliant.

A second phase, expected by 2028, will introduce real-time reporting, shifting toward a five-corner model, where access points extract and report invoice data directly to tax authorities, tightening VAT control without disrupting business-to-business flow. This phase is already in pilot testing, with implementation of the PEPPOL CTC model planned at the end of 2025.

Challenge

The biggest risk is uneven adoption. While suppliers may be PEPPOL-ready, unprepared buyers can force dual processes—structured e-invoicing for some clients and fallback PDFs for others. Authorities advise businesses to clearly document such exceptions to remain compliant during the transition period.

France: From Hybrid to Five-Corner Model

France is rolling out one of the most complex e-invoicing reforms in Europe, applying a nationwide B2B e-invoicing mandate alongside an e-reporting requirement for B2C and cross-border transactions. From September 2026, issuing e-invoices will become mandatory for large and medium businesses, with small and micro enterprises following in 2027. A draft law could push both deadlines back by one year, but a major delay remains uncertain.

Approach

France is transitioning from a hybrid “Y” model to a five-corner architecture, requiring all invoices to pass through certified service providers (PDPs). The national platform (PPF) will serve solely as a directory and e-reporting hub, no longer handling invoice exchange directly. Beyond structured e-invoicing, the reform mandates real-time reporting of B2C and international transaction data, including status messaging and payment tracking.

Challenge

The broad scope and dual obligations create a significant compliance burden. Integrating e-invoicing and e-reporting across transaction types is demanding, especially for smaller businesses navigating both technical setups and PDP coordination.

Poland: Centralized Clearance, Complex in Practice

Similarly to France, Poland’s e-invoicing reform is considered incredibly complicated in terms of implementation. But while France relies on a decentralized five-corner model with certified platforms, Poland is pursuing a centralized clearance system (KSeF), managed directly by the government. The B2B mandate is scheduled to take effect in February 2026, covering most domestic transactions. While conceptually similar to Italy’s SDI, its technical and legal specifications are far more complex.

Approach

Invoices must pass through the government-run KSeF platform. Poland uses its own structured format, unrelated to the EN 16931 standard. It remains unclear whether the rollout will proceed in waves or via a “big bang” for all businesses. A temporary offline mode may be allowed through 2026, enabling invoice reporting without live API transmission.

Challenge

The primary hurdle lies in the technical implementation. KSeF’s API and evolving legal framework are highly complex, and further changes are expected after public consultation. Businesses face steep integration demands, compounded by uncertainties around final specs and potential legislative tweaks expected in mid-2025.

Baltic States: Format-Led Reform with Transmission Uncertainty

The Baltic countries are taking a gradual and format-driven approach to e-invoicing, focusing on aligning with the European standard EN 16931 rather than defining a centralized transmission infrastructure. Mandates are upcoming, but details remain in development, and each country is progressing at its own pace.

Approach

In Estonia, a nationwide mandate is scheduled for 2027, but starting mid-2024, registered invoice receivers have the right to request structured e-invoices. This opt-in phase is designed to ease adoption, though broad engagement isn’t expected until closer to the full mandate.

Latvia is targeting 2026 for its B2B mandate, along with an e-reporting obligation, but technical specifications have yet to be published—leaving vendors and taxpayers in a holding pattern. In both countries, transmission channels remain undefined. Businesses may rely on national registries to communicate delivery preferences, but there is no mandated platform or routing standard.

Challenge

The key risk is transmission uncertainty. With no enforced delivery channel, businesses may face fragmentation and coordination issues—especially if registry data is incomplete or inconsistently used. While open models offer flexibility, they can delay adoption and complicate integration, particularly for smaller firms lacking robust IT capacity.

United Arab Emirates: PEPPOL Five-Corner Pioneer

The UAE is rapidly moving toward a mandatory B2B e-invoicing system, becoming the first country to implement a PEPPOL-based five-corner model. While legislation is still pending, it is expected imminently, with no anticipated delays. The mandate is part of a broader digital reform effort and may eventually extend to B2C transactions as well.

Approach

The UAE’s model mirrors Belgium’s long-term vision but is advancing on a faster timeline. In this five-corner architecture, PEPPOL access point providers will handle not only the exchange of invoices between businesses but also the reporting of invoice data to tax authorities. To ensure trust in this role, the UAE is enforcing a strict accreditation process. Only providers that meet specific criteria—such as minimum market presence and ISO certifications—will be eligible. Unlike Belgium, the UAE will mandate its own local PINT format, which all invoices must follow.

Challenge

The main challenge lies in the stringency of the accreditation process. Providers already active in other countries may not automatically qualify, limiting cross-border compatibility and potentially reducing the pool of available access points. Combined with the country’s accelerated timeline, this places pressure on both businesses and solution providers to move quickly.

Malaysia: On-Time Rollout with Focus on Reporting

Malaysia successfully launched its mandatory e-invoicing system in August 2024, following a brief two-month delay. Despite early concerns over missing technical documentation, the system went live and is seen as a rare case of timely execution in the region. The rollout began with large taxpayers, with future phases expected to follow a similar structure.

Approach

Malaysia’s model is a reporting-first system, where businesses submit structured invoice data to a government platform, but do not use the platform for actual invoice transmission. During the initial rollout, large taxpayers were allowed to issue consolidated invoices to simplify the transition—an approach expected to continue in future waves. While PEPPOL was mentioned in documentation and subject to an accreditation process, adoption remained limited, possibly due to format differences between PEPPOL and Malaysia’s required reporting structure.

Challenge

The biggest challenge was the disconnect between transmission expectations and reporting reality. Although PEPPOL was anticipated to support invoice exchange, most businesses defaulted to traditional delivery channels, focusing only on compliance with the reporting requirement. The platform’s early use for invoice reception was quickly curtailed by authorities, who clarified its role as report-only and warned against misuse.

Singapore: Controlled Rollout via InvoiceNow

Singapore is introducing InvoiceNow, a PEPPOL-based e-invoicing framework developed by the Inland Revenue Authority (IRAS) and the InfoComm Media Development Authority (IMDA). The rollout is intentionally phased, starting with voluntary participation to build adoption ahead of a future mandate. A timeline for the full inclusion of all GST-registered businesses has not yet been set.

Approach

InvoiceNow uses the PEPPOL network to enable structured invoice exchange and real-time data transmission to IRAS. The rollout follows a phased model:

• May 2025: Early adopters opt in voluntarily.
• November 2025: Newly incorporated businesses applying for GST registration join.
• April 2026: All other voluntarily registered GST businesses are included.

Transactions in scope include standard- and zero-rated supplies and purchases where input tax is claimed, while reverse charges and deemed supplies are excluded.

Challenge

While the rollout is well-structured, businesses must conduct a detailed assessment of transaction scope and ensure data accuracy before integration. Since access point providers report directly to IRAS, any data issues can impact compliance. Additionally, the lack of a fixed deadline for full rollout leaves long-term planning somewhat open-ended.

E-Invoicing in Action: What the Rollouts Reveal

While no two mandates are alike, some early patterns offer meaningful insight into how e-invoicing is unfolding on the ground—and what matters most in implementation:

• Structured formats are non-negotiable: Whether PEPPOL-based or nationally defined, machine-readable data is the foundation of every system.
• Access point providers are becoming compliance actors: In countries like Belgium, France, and the UAE, they’re no longer just conduits—they’re responsible for reporting, security, and system integrity.
• Scope clarity is a recurring blind spot: Understanding what falls under the mandate—and what doesn’t—is critical, yet often overlooked in early implementation.
• Rollout timelines are fluid, but internal readiness can’t be: Countries may revise deadlines, but successful implementation hinges on clean data and integration readiness well in advance.
• Compliance fuels modernization: For many businesses, e-invoicing is as much about streamlining operations as it is about meeting regulatory demands.

Local Strategies, Global Stakes

As these case studies show, there’s no universal approach to e-invoicing mandates. Each country adapts to its own legal, technical, and political context—some with impressive speed, others through cautious, phased rollouts.

Yet the direction remains the same: toward structured data, real-time reporting, and government-verified compliance. The frameworks may differ, but the goals are shared. In the end, success depends not just on regulatory vision, but on its execution—and the coming years will test whose strategies are built to last.