E-invoicing mandates in France, Germany, Italy, Poland and Portugal
Which of the five countries requires what, from which date, and through which channel, read from each country's law and tax administration. One table first, then what the table cannot show: the three different ideas of what an obligation to e-invoice means, and the EU rules above them. No software vendor is compared to another.
The five countries at a glance
Domestic business-to-business invoices only, as of 24 September 2026. Each row is a summary of the country guide it links to, where every date is quoted from the text that sets it.
| Country | What is mandatory | From when | Through what |
|---|---|---|---|
| France | Receiving electronic invoices, for every company. Issuing them, by company size. | Receiving: 1 September 2026, all companies. Issuing: 1 September 2026 for large companies and ETIs, 1 September 2027 for SMEs and micro-enterprises. | An approved platform (plateforme agréée). Formats: Factur-X, UBL or CII. |
| Germany | Issuing and receiving a structured electronic invoice. | Receiving: since 1 January 2025. Issuing: paper or other formats remain allowed for supplies up to the end of 2026, and up to the end of 2027 for companies with a prior-year turnover of at most €800,000 or on EDI. Mandatory for every covered supply from 1 January 2028. | No channel prescribed. Formats conforming to EN 16931, such as XRechnung or ZUGFeRD. |
| Italy | Issuing every invoice between parties established in Italy electronically, consumers included. | 1 January 2019. Flat-rate regime (forfettario): 1 July 2022 above €25,000 of revenue, 1 January 2024 for all others. | The Sistema di Interscambio (SdI), in the FatturaPA format. |
| Poland | Issuing structured invoices through the national system, KSeF. | 1 February 2026 for taxpayers whose 2024 sales, VAT included, exceeded PLN 200 million; 1 April 2026 for all others. Until 31 December 2026, invoices outside KSeF remain allowed up to PLN 10,000 a month. | KSeF, in the FA(3) structure. |
| Portugal | No obligation to send the invoice electronically between businesses. Mandatory: the ATCUD code on every invoice, certified software above a threshold, and a monthly report of invoice data. | ATCUD: 1 January 2023. Certified software: above €50,000 of prior-year turnover, among other conditions. Monthly report: by the 5th of the following month. | The tax authority (AT), by SAF-T (PT) file, real-time transmission or the tax portal. |
The table covers invoices between businesses. Invoices to public bodies follow rules of their own, which the French and German guides point out, and invoices to consumers are outside the mandate in every country here except Italy, whose rule makes no difference between a business and a consumer.
Three different ideas of what the obligation is
The table puts five rules in one grid, which hides how differently they work. The question each country answers is not the same one.
The state system is where the invoice comes into existence: Italy and Poland
In Italy and in Poland the invoice legally exists only once it has gone through the national system. Italy's decree says that an invoice issued any other way between parties established in Italy
«si intende non emessa», that is, is treated as not issued.
Poland's VAT act fixes the date of issue at the moment of transmission:
„Fakturę ustrukturyzowaną uznaje się za wystawioną w dniu jej przesłania do Krajowego Systemu e-Faktur.” A structured invoice is considered issued on the day it is sent to KSeF.
A platform of the company's choice carries it: France
France does not route invoices through the state. It requires a private platform, approved by the tax administration, chosen and paid for by the company:
« L'émission, la transmission et la réception des factures électroniques s'effectuent en recourant à une plateforme agréée. » Issuing, transmitting and receiving electronic invoices is done through an approved platform.
What that means for a company in practice, and how to check that a platform is approved, is on its own page: choisir sa plateforme agréée (in French).
Only the format is prescribed: Germany
German law defines an electronic invoice by its structure, and says nothing about how it travels:
„Eine elektronische Rechnung ist eine Rechnung, die in einem strukturierten elektronischen Format ausgestellt, übermittelt und empfangen wird und eine elektronische Verarbeitung ermöglicht.“ An electronic invoice is one issued, transmitted and received in a structured electronic format that allows electronic processing.
E-mail, a customer portal or EDI all remain possible. Which of the two common formats to send, and when a public buyer's routing identifier is needed, is on its own page: XRechnung oder ZUGFeRD? (in German).
The data is reported, the invoice is not cleared: Portugal
Portugal leaves electronic sending to the recipient's acceptance, and puts the obligation on the software and on the data sent to the tax authority instead:
«As faturas e demais documentos fiscalmente relevantes podem, mediante aceitação pelo destinatário, ser emitidos por via eletrónica.» Invoices may be issued electronically, subject to the recipient's acceptance.
The EU rules above the five
Public buyers: EN 16931, everywhere, already
Since Directive 2014/55/EU, every public buyer in the EU must accept an electronic invoice that follows the European standard:
“Member States shall ensure that contracting authorities and contracting entities receive and process electronic invoices which comply with the European standard on electronic invoicing whose reference has been published pursuant to Article 3(2) and with any of the syntaxes on the list published pursuant to Article 3(2).”
That standard is EN 16931, and the French and German formats in the table above are built on it, as their two guides set out. What it defines, and what it leaves to each country: EN 16931, the European invoice standard.
Between businesses: ViDA
The VAT in the Digital Age package, Council Directive (EU) 2025/516, changes the frame the five national rules sit in: what a Member State may impose at home without asking Brussels first, and what every business will have to do for invoices to another Member State. The dates and the articles: ViDA, VAT in the Digital Age.
The network some of them use: Peppol
None of the five countries' B2B rules names Peppol as the required channel. It appears beside them, as a network public buyers and businesses use to exchange invoices. What it is, and whether a business needs it: Peppol, the network.
What this page does not cover
- Other Member States. Several have mandates of their own, in force or announced. This site covers the five countries above and nothing else; for any other country, the only reliable source is its own tax administration.
- Tax advice. Each rule here is quoted from its text, with a link. Whether and how it applies to a particular business is a question for that business's adviser.
One way to meet them
Invoicerr is one way to meet these five sets of rules: open-source invoicing software that builds Factur-X, XRechnung, ZUGFeRD, FatturaPA, FA(3), UBL and CII invoices, and sends them through a French approved platform, Chorus Pro, the SdI, KSeF or Peppol. It is not the only way, and this paragraph does not try to convince you otherwise: the questions each country guide asks apply to any tool, this one included.
Sources
Every national fact on this page is the one its country guide quotes, and links to the same text. Checked at these addresses on 24 September 2026, except where the note on a line says otherwise.
- France: approved platform
- Code général des impôts, art. 289 bis, I, version in force since 21 February 2026. Légifrance refuses automated reads; the text was read in DILA’s official LEGI open data. legifrance.gouv.fr
- France: dates of the obligation
- DGFiP, practical guide to e-invoicing at 1 September 2026 (PDF). impots.gouv.fr
- Germany: definition of an electronic invoice, no prescribed channel
- Umsatzsteuergesetz, § 14 Absatz 1 Satz 3 und Absatz 2 Satz 2 Nummer 1. gesetze-im-internet.de
- Germany: transition to 2028, €800,000 threshold, EDI
- Umsatzsteuergesetz, § 27 Absatz 38. gesetze-im-internet.de
- Italy: SdI obligation, invoice treated as not issued, 2019 start
- Decreto legislativo 5 agosto 2015, n. 127, art. 1, commi 3 e 6; legge 27 dicembre 2017, n. 205, art. 1, comma 916. Not re-read on 24 September 2026: Normattiva serves article text only to a full browser. Quoted as the Italian guide read it on 23 September 2026. normattiva.it
- Italy: flat-rate regime, 2022 and 2024
- Decreto-legge 30 aprile 2022, n. 36, art. 18, comma 3. Same note as the line above. normattiva.it
- Poland: dates, PLN 200 million threshold, PLN 10,000 relief
- Ministry of Finance, KSeF portal, “Od kiedy trzeba wystawiać faktury w KSeF”; VAT act, art. 145l and 145m. ksef.podatki.gov.pl
- Poland: invoice issued on the day it is sent to KSeF
- Ustawa o podatku od towarów i usług, tekst jednolity Dz.U. 2025 poz. 775, art. 106na ust. 1. api.sejm.gov.pl
- Portugal: electronic issuance subject to acceptance, certified software above €50,000
- Decreto-Lei n.º 28/2019, de 15 de fevereiro, art. 4.º e art. 12.º. info.portaldasfinancas.gov.pt
- Portugal: ATCUD mandatory from 1 January 2023
- Despacho n.º 351/2021-XXII, de 10 de novembro de 2021, alínea e). info.portaldasfinancas.gov.pt
- Portugal: monthly report by the 5th
- Decreto-Lei n.º 198/2012, de 24 de agosto, art. 3.º. pgdlisboa.pt
- EU: public buyers must accept invoices conforming to the European standard
- Directive 2014/55/EU of the European Parliament and of the Council, Article 7. eur-lex.europa.eu