Three of Europe's largest economies switched on mandatory B2B e-invoicing this year. If you are opening an entity in any of them, invoicing capability is now part of going live, not a task for the first quarter after.
Key takeaways
- Belgium has required structured B2B e-invoices over the Peppol network since 1 January 2026.
- Poland's KSeF issuing obligation follows establishment, not registration: it applies to businesses with a seat in Poland, or with a Polish fixed establishment that takes part in the supply. A bare Polish VAT number does not trigger it.
- Every Polish VAT registration still needs access to KSeF invoice IDs, because the JPK_V7 return has required the KSeF number in both sales and purchase records since February 2026.
- France starts on 1 September 2026, and the same establishment test applies: businesses established in France must be able to receive, while those only VAT-registered there sit outside the e-invoicing mandate and fall under e-reporting instead.
- Germany has required businesses to receive e-invoices since January 2025, with issuing obligations phased in from 2027.
- The EU ViDA package sets 1 July 2030 for intra-EU B2B e-invoicing, with domestic regimes aligning by 1 January 2035.
For most of the last decade, electronic invoicing in Europe was optional, fragmented, and largely a procurement question. In 2026 it became a condition of trading. Belgium, Poland and France have all brought mandatory business-to-business e-invoicing into force within nine months of each other, and Germany is midway through a phased rollout of its own.
If you are setting up an entity in any of these markets, this changes the go-live checklist. An invoice that is not issued in the required format, through the required channel, may not count as an invoice at all.
What is changing, country by country
Belgium: live since January 2026
Belgium took the simplest and most abrupt route. Since 1 January 2026, VAT-registered businesses have had to exchange structured electronic invoices with other Belgian businesses over the Peppol network, using the Peppol BIS Billing format aligned to the European standard EN 16931. There was no phase-in by company size. Everyone started on the same day. FPS Finance granted a three-month tolerance period through the first quarter of 2026, but only to businesses that could show their compliance work was already under way; it expired on 31 March 2026 and fines now apply without prior warning. The mandate covers VAT-registered businesses established in Belgium, which is the test a newly formed entity needs to apply to itself. Uptake was immediate, with the registered receiver base on the Belgian network passing a million within weeks.
Poland: KSeF, and a clearance model
Poland's national platform, KSeF, works differently in a way that matters operationally. It is a clearance system: invoices pass through the tax authority's platform, which assigns each one a unique identification number before it reaches the buyer. Businesses whose 2024 sales exceeded roughly PLN 200 million came into scope for issuing on 1 February 2026, most remaining taxpayers on 1 April 2026, and the smallest sellers, those whose monthly invoiced sales stay under PLN 10,000, follow in January 2027. Invoices must be submitted in the FA(3) XML structure, and business-to-consumer transactions sit outside the mandate. Penalties under the new provisions were deferred and apply only from 1 January 2027, so this year is in practice a grace period, though the obligation itself is live.
The point most often got wrong is who is actually caught. Being registered for Polish VAT does not by itself put you inside KSeF. Under the amended VAT Act, the obligation to issue through the platform attaches to taxpayers with a registered seat in Poland, and to foreign taxpayers with a Polish fixed establishment where that establishment takes part in the supply being invoiced. A company with a Polish VAT number but no seat and no participating fixed establishment is outside the issuing obligation. Where a non-established business is the buyer, the supplier makes the structured invoice available by some agreed route instead, which in practice often means a PDF by email.
That is a relief, but a qualified one. Fixed establishment is a facts-and-circumstances test rather than a matter of legal form, and it can exist without a branch or a subsidiary. The Ministry of Finance published explanatory notes on 28 January 2026 setting out how it reads the test specifically for KSeF purposes, which broadened the range of foreign entities that might be caught. If you are putting people, premises or operational decision-making into Poland, the question of whether you have created a fixed establishment is worth answering deliberately rather than assuming the answer.
The KSeF number reaches everyone anyway
Even if your Polish registration sits outside the issuing obligation, you cannot ignore the platform. From the February 2026 period, the JPK_V7M and JPK_V7K records require the KSeF identification number for invoices issued through the system, in both the sales and the purchase records. Where an invoice has no KSeF number, one of the designated markers applies instead. Records that are missing this data are rejected at technical validation, so the return simply will not file.
The practical consequence is unavoidable: any entity filing a Polish VAT return has to be able to retrieve the KSeF identifiers attached to the invoices its Polish suppliers issue, whatever its own issuing position. Access to the platform, and a process for pulling those numbers into the ledger, is therefore a requirement of every Polish VAT registration, not only of the ones that must issue through it.
France: the one arriving now
France is the most consequential for most expanding companies, and the deadline is weeks away. From 1 September 2026, every business established in France and subject to French VAT must be able to receive electronic invoices, whatever its size. Large enterprises and mid-sized companies (entreprises de taille intermédiaire, a category defined on a combination of headcount, turnover and balance sheet rather than turnover alone) must also issue them for domestic business-to-business transactions from the same date. Established smaller companies gain a year, with issuing obligations arriving on 1 September 2027.
France applies the same establishment test as Poland, and it is worth being precise about it. The domestic B2B mandate applies where both parties are established in France. A business that holds a French VAT registration but has no establishment there falls outside e-invoicing altogether, for the mechanical reason that it has no entry in the central directory the whole system routes through. It is not exempt from everything, though: it can still owe e-reporting on its French-taxable transactions, and those obligations were deferred to 1 September 2027. A French fixed establishment brings you back inside the mandate.
So the question to settle before you sign a platform contract is not whether you will be VAT-registered in France, but whether you will be established there. A subsidiary plainly is. A registration used to sell into France from elsewhere plainly is not. Between those poles sits the same fixed establishment analysis that Poland now applies. Note too that the Portail Public de Facturation has been retired as an invoice exchange route: invoices now flow through accredited private platforms, with a central directory handling routing.
France also permits several formats, which is easier for suppliers and harder for finance teams: UBL, CII, and Factur-X, the last of which wraps structured XML inside a PDF. Invoices move through accredited platform providers rather than a single state portal.
Germany, Spain and the wider field
Germany has required businesses to be able to receive electronic invoices since January 2025, with issuing obligations phased in from 2027 and completing in 2028. Spain is rolling out its own regime for corporates and the self-employed. Beyond Europe, mandates have gone live or expanded across Saudi Arabia, the United Arab Emirates, Morocco, Singapore, Malaysia and others, so this is not a European story alone.
The direction of travel: ViDA
The EU's VAT in the Digital Age package, adopted in March 2025, sets the endpoint. Intra-EU business-to-business e-invoicing becomes mandatory on 1 July 2030, and national domestic regimes must harmonise by 1 January 2035. In the meantime, each country keeps its own format, network and enforcement timetable. The updated European semantic standard, EN 16931-1:2026, published in March 2026, is the closest thing to common ground.
What this means when you open an entity
Three practical consequences, in the order they tend to bite.
Your accounting partner has to be on the right network
This is the question to ask before you appoint anyone. A firm that handles Belgian clients needs Peppol access. A Polish partner needs to be operating through KSeF. A French partner needs a relationship with an accredited platform provider. "We will look into it" is not an acceptable answer in August 2026, and it is a reasonable proxy for how current the firm is generally. Our guide to choosing a local accounting and payroll partner covers the rest of that conversation.
Receiving is an obligation too
The receiving side is easy to miss because it feels passive. It is not. In France, every business established there must be able to receive from 1 September regardless of size, so a subsidiary with two employees has an obligation from day one. In Poland, the reach is different but just as awkward to ignore: even a registration that sits outside the issuing obligation has to be able to pull the KSeF identification numbers off its suppliers' invoices, because the VAT return will not validate without them.
It moves onto the critical path
Registration, platform onboarding and testing take weeks, not days, and they cannot start until the entity exists and has a VAT number. That places e-invoicing readiness squarely inside the launch sequence rather than after it. If your first invoice is due in month one, the platform work has to be running in parallel with incorporation. This is the same trap we describe in why expansion timelines slip: work that could have run alongside something else ends up queued behind it.
A short readiness checklist
- For each market, decide whether you will be established there or only VAT-registered. That distinction, not the registration itself, usually determines which obligations apply.
- List the countries where you have, or will have, a VAT registration, and put each one's mandate date against it.
- Confirm which network or platform each market uses, and whether your accounting partner is already connected.
- Check that your ERP or invoicing tool can produce the required format, not just a PDF.
- Clean up customer master data: VAT numbers, legal addresses, and network identifiers where they are required.
- Test receiving as well as issuing, and test before the deadline rather than on it.
None of this is difficult work. It is simply work that has to happen at a particular time, and the countries have now set that time for you.
Frequently asked questions
When does e-invoicing become mandatory in France?
From 1 September 2026, businesses established in France must be able to receive electronic invoices, regardless of size. Large enterprises and mid-sized companies (ETI) must also issue them from that date, with established SMEs and micro-enterprises following on 1 September 2027. Businesses that are only VAT-registered in France, without an establishment there, fall outside the e-invoicing mandate but may have e-reporting obligations from September 2027.
Does a small foreign subsidiary have to comply?
Yes. A subsidiary is established in the country, so it is inside the mandate from the start in France, Belgium and Poland alike. Size affects when you must issue, not whether you must be able to receive. The different case is a bare VAT registration with no local establishment, which generally sits outside these mandates, though in Poland it still needs access to KSeF invoice numbers in order to file its VAT return.
Is there a single European e-invoicing standard yet?
Not in practice. Countries currently use different formats and networks, though most implement the European standard EN 16931 to some degree. The EU ViDA package requires intra-EU B2B e-invoicing from 1 July 2030 and harmonisation of domestic regimes by 1 January 2035.
Sources
Primary sources for the rules described above. Regulatory dates change; check the source before acting on anything here.
- European Commission — eInvoicing in Belgium (country factsheet)
- Belgium FPS Finance — e-invoicing
- Poland Ministry of Finance — KSeF (Krajowy System e-Faktur)
- Poland Ministry of Finance — tax explanatory notes of 28 January 2026 on determining a fixed establishment for KSeF purposes
- Poland — VAT Act provisions on the scope of the KSeF obligation, and the JPK_V7M/V7K(3) structures applicable from the February 2026 period
- DGFiP — Facturation électronique entre entreprises
- Council Directive (EU) 2025/516 — VAT in the Digital Age (ViDA)
- EN 16931 — European standard on electronic invoicing (CEN)
Written by the Nexus Notabu team. If this raises a question about a market you are considering, tell us where you want to grow.