E-Invoicing in the EU: Spain vs Germany, France, Italy and Other Countries in 2026-2030
Mandatory e-invoicing is not just a Spanish matter. The entire European Union is in the process of digitalising B2B invoicing, driven by the ViDA (VAT in the Digital Age) initiative adopted in March 2025. But each country has arrived at this point via a different path — with different timelines, different formats and different platform models. For businesses operating across multiple European countries, understanding these differences is not optional: it is essential to avoid invoicing in the wrong format at the wrong time.
The European framework: ViDA and the EN 16931 standard
Before looking at individual countries, the common context needs to be established.
ViDA: the EU's major push
The VAT in the Digital Age (ViDA) initiative, adopted by the EU Council in March 2025, sets the framework guiding the digitalisation of VAT across Europe through to 2035. Its three pillars are B2B e-invoicing, real-time digital transaction reporting and an expanded VAT One Stop Shop.
Since the implementation of the eInvoicing Directive 2014/55/EU in April 2020, all public administrations across the EU are required to accept electronic invoices compliant with the European Standard for contracts above EU public procurement thresholds. With ViDA, that obligation is progressively extending to B2B.
A key ViDA milestone: from 2024-2025, member states gain the right to mandate domestic e-invoicing without needing individual EU derogations. In July 2030, mandatory digital reporting for all intra-EU B2B transactions comes into force.
The technical standard: EN 16931
EN 16931 is the European semantic data model standard for electronic invoices. It defines which fields are mandatory, their format and structure. If you invoice businesses or government entities in any EU country with an e-invoicing mandate, your invoice format must conform to EN 16931. National formats such as XRechnung (Germany), Factur-X (France), FatturaPA (Italy) or Facturae (Spain) are national implementations of this standard or formats compatible with it.
Spain: the dual SIF + B2B e-invoicing system
Spain has a particularly distinctive framework because it has developed two parallel, independent obligations:
1. VeriFactu / RRSIF (RD 1007/2023): governs invoicing computer systems (SIF). All invoicing software must generate records with chained hash and a QR code, guaranteeing the integrity and immutability of records. Deadline: companies by 1 January 2027; freelancers by 1 July 2027.
2. B2B e-invoicing (RD 238/2026): requires issuing and receiving invoices in structured formats (Facturae, UBL or CII) for all transactions between businesses and professionals. Deadlines run from the pending Ministerial Order: 12 months for companies with more than €8M turnover, 24 months for all others and 36 months for freelancers and income-attribution entities with turnover ≤ €8M.
Primary format: Facturae (Spain's native XML format, already mandatory for B2G transactions for many years). UBL and CII are also accepted.
Platform: public solution managed by the AEAT (free for freelancers and SMEs), plus private platforms interoperable with each other.
Key differentiator: Spain is the only EU country combining a software integrity system (VeriFactu/RRSIF) with a structured exchange obligation (B2B e-invoice). Most countries have only one of the two.
Italy: the EU pioneer (since 2019)
Italy was the first EU country to impose mandatory universal B2B e-invoicing. Italy has operated a mandatory B2B e-invoicing system since 2019, using the FatturaPA format and a centralised clearance model through the Sistema di Interscambio (SDI) platform.
The Italian model: centralised clearance
The Italian model is the most interventionist in Europe: every invoice (B2B, B2C and B2G) must mandatorily pass through the SDI (Sistema di Interscambio), the Tax Agency's centralised platform. The SDI validates the invoice before it reaches the recipient. If the SDI rejects it, the invoice has no legal validity.
Format: FatturaPA, Italy's own XML format. Invoices in other formats (UBL, CII) must be converted to FatturaPA before transmission to the SDI.
Archiving: mandatory for 10 years in digital format.
Consequence of non-compliance: an invoice not sent through the SDI is treated as if it were never issued — with all the VAT and payment enforcement consequences that entails.
What other countries have learned from Italy
The Italian model has proven effective in reducing tax fraud. The EU Council extended Italy's mandate through 2027, after which it must align with ViDA standards. Germany, France and Spain have all studied the Italian model, though none has replicated its total clearance approach exactly.
Germany: reception mandatory from 2025, issuance from 2027-2028
Germany has adopted a more gradual and decentralised approach than Italy. As of 1 January 2025, reception of electronic invoices became mandatory: no company can refuse an e-invoice from its supplier. Mandatory issuance begins for companies with turnover above €800,000 in January 2027, and for all companies in January 2028.
The German model: decentralised, no central platform
Unlike Italy (centralised SDI) and France (PA/PPF), Germany has no national centralised platform for B2B. Invoices are exchanged directly between parties or through private operators and the Peppol network.
Accepted formats: two formats coexist and are accepted:
- XRechnung: pure XML format, the de facto standard for German B2G.
- ZUGFeRD: hybrid format combining a visual PDF with an embedded XML (EN 16931). Allows the document to be both human-readable and automatically processable.
Both are EN 16931 compliant.
Key differentiator: Germany is the only major European market without a central B2B exchange platform. The model relies on Peppol and direct bilateral agreements. This offers more flexibility but also more complexity for businesses issuing in many formats.
Leitweg-ID: mandatory identifier on B2G invoices for routing to the correct authority.
France: the "Y-model" with certified platforms from September 2026
France has had one of the most complex implementation processes in Europe, with multiple postponements from the original July 2024 date. The confirmed final date: from 1 September 2026, all businesses must be able to receive e-invoices, with mandatory issuance for large and medium companies from September 2026 and for SMEs from September 2027.
The French model: the "Y-model" with PA
France has designed a system called the "Y-model" that requires all invoices to pass through a Plateforme Agréée (PA) — formerly known as PDP (Plateforme de Dématérialisation Partenaire). PAs are private service providers accredited by the tax authority to intermediate data flows between trading partners and the public portal (PPF). They act as the interface between businesses and the government.
Important: following the French government's announcement in October 2024, the PPF (public portal) will act only as a directory and e-reporting platform. All companies must partner with a PA. It is not possible to exchange invoices directly between businesses without going through a certified PA.
Accepted formats: Factur-X (hybrid PDF+XML format, equivalent to Germany's ZUGFeRD), UBL and CII. All EN 16931 compliant.
Additional e-reporting: France also requires e-reporting for B2C transactions, international sales and cross-border operations — data that PAs automatically transmit to the PPF for tax control.
Archiving: e-invoices must be archived for six years for VAT compliance and ten years for accounting and commercial law compliance.
Poland: KSeF, the EU's strictest clearance model
Poland has implemented KSeF (Krajowy System e-Faktur), a centralised clearance system similar to Italy's but stricter. Poland implements the KSeF clearance system from February 2026 for large taxpayers (turnover above PLN 200 million) and from April 2026 for all other VAT-registered businesses.
Model: all B2B invoices pass through KSeF, which validates them and assigns a unique identification number. Without that number, the invoice has no legal validity in Poland.
Format: Poland's own FA_VAT XML format, specific to KSeF. FatturaPA and XRechnung cannot be submitted directly.
Key differentiator: Poland has opted for the model closest to Italy's clearance approach, but with an even more exhaustive level of control. Paper and PDF invoices have lost legal validity for B2B transactions between Polish companies.
Belgium: Peppol as national infrastructure since January 2026
Belgium has adopted the most open model of those analysed. Belgium launched mandatory B2B e-invoicing on 1 January 2026, using the Peppol network with UBL 2.1 format. All Belgian businesses conducting B2B transactions must be capable of sending and receiving e-invoices.
Model: no centralised national platform. Invoices are exchanged through the Peppol network (Pan-European Public Procurement On-Line), a network of interoperable access points.
Format: UBL 2.1, EN 16931 compliant.
Advantage of the Peppol model: any company on the Peppol network can exchange invoices with any other company on the network, regardless of which European country they are in. This makes Belgium one of the countries with the greatest cross-border interoperability potential.
Comparison table: Spain vs major EU countries
| Country | Model | Primary format | Platform | B2B mandatory | Key feature |
|---|---|---|---|---|---|
| Spain | Post-audit + SIF integrity | Facturae / UBL / CII | AEAT (public) + private | 2026-2027 (B2B), 2027 (VeriFactu) | Only EU country with dual SIF + B2B system |
| Italy | Centralised clearance | FatturaPA (XML) | SDI (Tax Agency) | Since 2019 (B2B+B2C) | Every invoice passes through SDI before reaching recipient |
| Germany | Decentralised post-audit | XRechnung / ZUGFeRD | No central platform (Peppol) | Reception 2025 / Issuance 2027-2028 | No national central platform; ZUGFeRD is hybrid PDF+XML |
| France | Y-model with certified PAs | Factur-X / UBL / CII | PA (certified) + PPF (directory) | Reception Sept. 2026 / Issuance Sept. 2026-2027 | Every invoice must go through a certified PA |
| Poland | Centralised clearance (KSeF) | FA_VAT (Polish XML) | KSeF (Polish Tax Authority) | Feb-Apr. 2026 | KSeF number mandatory; without it the invoice does not exist |
| Belgium | Decentralised post-audit | UBL 2.1 | Peppol network | Since Jan. 2026 | Most open model; Peppol as infrastructure |
The three major design decisions that separate countries
1. Clearance vs post-audit
The clearance model (Italy, Poland/KSeF) requires the invoice to be validated by the tax authority before it reaches the recipient. The tax authority acts as a real-time intermediary. The post-audit model (Germany, Belgium, Spain B2B) allows invoices to be exchanged directly between businesses, with the authority reviewing them after the fact through reports or audits.
Spain is an intermediate case: the RRSIF (VeriFactu) is a software integrity system (closer to post-audit), but records can be transmitted to the AEAT in real time in VeriFactu mode.
2. Centralised platform vs decentralised network
Italy and Poland use state centralised platforms (SDI, KSeF). France uses mandatory certified private platforms (PA). Belgium uses the open Peppol network. Germany has no central platform for B2B. Spain will use the AEAT's public solution plus interoperable private platforms.
3. Single mandatory format vs multiple accepted formats
Italy accepts only FatturaPA (mandatory conversion from other formats). Poland accepts only FA_VAT. France accepts Factur-X, UBL and CII. Germany accepts XRechnung and ZUGFeRD. Spain accepts Facturae, UBL and CII. The European trend points towards convergence on EN 16931, but specific national formats will persist for years.
The 2030 horizon: ViDA and European convergence
The ViDA initiative is the EU's comprehensive plan to modernise the VAT system through digitalisation. It introduces a standardised framework for real-time transaction reporting, making e-invoicing the default invoicing system, while allowing countries to align national models with the new rules.
The key milestone: in July 2030, mandatory digital reporting for all intra-Community B2B transactions (between businesses in different EU countries) comes into force. By 2035, all national regimes must be harmonised with ViDA.
What this means in practice: if a Spanish company today invoices a German company, the invoice can be a PDF. From 2030, it will need to be in structured format, with real-time reporting to the tax authorities of both countries.
Implications for businesses operating across multiple EU countries
For a Spanish SME or company with activity in other EU countries, the implications are concrete:
Multiple simultaneous formats: a company invoicing in Spain, Germany and France needs to generate Facturae (or UBL/CII) for Spain, XRechnung/ZUGFeRD for Germany and Factur-X/UBL/CII for France. The ERP must be able to generate all of them.
Multiple platforms or access points: Italy requires the SDI, France requires a certified PA, Belgium requires Peppol. There is no single platform covering all countries.
Non-coinciding timelines: each country's deadlines are different and not synchronised with each other. A company may already be obligated in Italy (since 2019) and Belgium (since 2026) but still in the transitional period in Spain and Germany.
Additional e-reporting in some countries: France requires e-reporting for B2C and cross-border sales. Portugal requires monthly SAF-T. These obligations go beyond simply issuing structured invoices.
Frequently asked questions: EU e-invoicing
Is a Spanish invoice in Facturae format valid in Germany?
Not directly. Each country requires its national formats. A Spanish invoice in Facturae does not meet German formal requirements (XRechnung or ZUGFeRD). To invoice in Germany, the invoice must be generated in a format Germany accepts. EN 16931 guarantees semantic compatibility, but format conversion may be necessary.
What is the Peppol network and why is it relevant?
Peppol (Pan-European Public Procurement On-Line) is an electronic document exchange network using an infrastructure of interoperable access points. Several countries (Belgium, Nordic countries, Netherlands) use it as the de facto infrastructure for e-invoicing. Spain admits it but does not impose it as the only infrastructure.
Is Spain more or less advanced than its European neighbours?
It depends what aspect is measured. On software integrity (VeriFactu/RRSIF), Spain is ahead of most European countries, which have nothing equivalent. On B2B e-invoicing, it arrives later than Italy (2019), Belgium (2026) or Poland (2026), but earlier than Ireland or some Nordic countries.
What happens when an Italian company invoices a Spanish company?
Today, the invoice can be sent in any format accepted by both parties (even PDF). When the RD 238/2026 deadlines enter force in Spain and ViDA in 2030, intra-Community invoices will need to be in structured format conforming to EN 16931 and reported digitally to both tax administrations.
Does InvoSeal cover invoicing in other EU countries?
InvoSeal is designed specifically for compliance with the Spanish framework (VeriFactu/RRSIF and RD 238/2026). For invoicing in other EU countries, the specific national requirements of each market need to be verified. See our technical documentation on the verifiable invoicing system for full details on InvoSeal's scope.
Conclusion: Europe is moving towards universal e-invoicing, but via different paths
Mandatory e-invoicing is a reality across Europe, but each country has made different design decisions on format, platform, validation model and timeline. Spain has opted for a relatively flexible model (multiple formats, interoperable platforms, free public solution) that contrasts with Italy and Poland's centralised clearance, or France's system of certified PAs.
By 2030, ViDA will converge all these systems into a common framework for intra-Community transactions. Until then, businesses operating across multiple European countries must simultaneously manage disparate national requirements.
The key is to treat it for what it is: a digital transformation project, not a simple invoice format change.