E-invoicing is gaining momentum

E-invoicing continues to be a key focus area in the evolving landscape of indirect tax compliance. As governments worldwide accelerate their adoption of digital tax reporting requirements, businesses are increasingly recognizing the importance of staying aligned with these trends. The movement towards e-invoicing is gaining momentum, driven by the need for greater transparency, efficiency, and real-time reporting.

Last week, three countries took significant steps forward with key updates, reaffirming their commitment to the broader implementation of B2B e-invoicing.

France

Starting in France, significant changes have been announced regarding e-invoicing operations. Moving forward, businesses will need to engage with a certified and registered Partner Dematerialization Platform (PDP), accredited by the French tax authority (DGFiP), to exchange e-invoices and comply with reporting obligations. The public invoicing platform (PPF) will focus solely on transaction data collection, and invoice exchanges must be handled through certified PDPs

These recent changes in France's e-invoicing system mean that the originally planned Y-model is being adjusted significantly. The Y-model was designed to be a hybrid between a centralized system (using the Portail Public de Facturation or PPF) and a decentralized model that relied on certified Partner Dematerialization Platforms (PDPs) for invoice transmission and reporting.

The Y-model's hybrid approach (where businesses had the option to directly interact with the PPF or rely on PDPs) will be replaced by a system entirely dependent on PDPs for invoice exchange, making the process more decentralized and reliant on third-party platforms.

Moreover, France has reconfirmed the previous communicated timeline:

• 1 September 2026: All companies will be required to receive electronic invoices, while large and intermediate-sized enterprises must also issue electronic invoices.

• 1 September 2027: Small and medium-sized businesses, as well as micro-enterprises, will be required to issue electronic invoices.

Germany

Next to that, Germany also provided further clarifications in relation to their upcoming e-invoicing mandate.The German Tax Authorities have introduced updated guidelines in a circular letter that offer more clarity and flexibility for businesses during the transition and initial adoption phases.

One of the main takeaways is that businesses will need to agree with their partners regarding the format and transmission solutions, which could include a standard email inbox, a network, a portal, etc. The circular letter also lays the foundation for standardized EN16931-based formats such as ZUGFeRD, XRechnung and Peppol-BIS.

Moreover, although not yet mandatory, this circular letter is preparing businesses for transactional e-reporting.

Other topics, including archiving, invoice content, corrections and input tax deductions are detailed in this document, which represents the final effort to clarify the e-invoicing landscape before its phased introduction as of January 2025.

Belgium

Lastly, in Belgium, where the e-invoicing mandate will enter into force on 1 January 2026, the government has published a first version of a list of compliant software solutions for sending, receiving and processing electronic invoices. However, this list does not imply that the mentioned providers are certified by the FPS Finance. It rather serves as a resource for end-users and an incentive for the IT sector to offer solutions that help companies comply with the obligation to use structured electronic invoicing as from 1 January 2026.

This update serves as a reminder for businesses to ensure their systems and processes are well-prepared for the upcoming changes.

If you would like to discuss how your business will tackle these new obligations, our dedicated team of e-invoicing experts is at your disposal.