Global E‑Invoicing & E‑Reporting Regulatory Update – September 2026

 

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Updates on e‑Invoicing and e‑Reporting

More countries are introducing mandatory e‑invoicing and e‑reporting, making timely regulatory monitoring essential for compliance and business continuity. This newsletter provides an overview of the latest global developments, helping tax, finance and compliance leaders anticipate regulatory changes, assess operational impacts and adapt their systems and processes with agility.

🇫🇷 France: E‑Invoicing Launches with Transitional Penalty Relief Through 2026

• What changed: France’s B2B e‑invoicing and e‑reporting reform took effect on 1 September 2026. The authorities confirmed that noncompliance penalties will not be imposed through 31 December 2026 where businesses demonstrate active and documented implementation efforts. The temporary tolerance does not postpone the underlying legal obligations, which apply according to the established phased implementation timetable for affected businesses and transactions nationwide.
• Who is impacted: All French-established businesses must be capable of receiving structured electronic invoices through an approved platform. Large enterprises and intermediate-sized enterprises must also issue electronic invoices and submit required transaction and payment data. SMEs and micro-enterprises are not yet required to issue electronic invoices, but they must maintain receiving capability and prepare for the subsequent implementation phase beginning in September 2027.
• Timing and next steps: The first implementation phase started on 1 September 2026, with administrative tolerance applying until the end of 2026. SMEs and micro-enterprises will become subject to issuance and e‑reporting requirements from 1 September 2027. Businesses should complete platform onboarding, test invoice exchanges, strengthen cybersecurity controls and retain evidence demonstrating reasonable and continuous efforts to achieve compliance.

🇵🇭 Philippines: Detailed E‑Invoicing Guidelines Issued Ahead of December 2026 Deadline

• What changed: The Philippine Bureau of Internal Revenue issued Revenue Memorandum Circular No. 98-2026, setting detailed policies for mandatory electronic invoicing. A compliant electronic invoice must be generated through registered, approved or accredited software, use structured and electronically extractable data, and be transmitted digitally to the customer. A conventional PDF sent by email does not independently qualify as an electronic invoice.
• Who is impacted: The mandate covers specified e-commerce and internet businesses, taxpayers administered by the Large Taxpayers Service, businesses classified as large under the Ease of Paying Taxes framework, and taxpayers using computerized accounting systems, electronic books or invoicing software. Micro taxpayers with annual gross sales below PHP 3 million are excluded, while other taxpayers may adopt electronic invoicing voluntarily.
• Timing and next steps: Covered taxpayers must be capable of issuing compliant electronic invoices by 31 December 2026. They must obtain a Permit to Issue Electronic Invoices and subsequently secure EIS certification within the prescribed period. Electronic invoicing remains legally distinct from transmitting electronic sales data to the BIR’s EIS platform, which will be governed through separate implementing rules and future deadlines.

🇸🇰 Slovakia: Mandatory E‑Invoicing and Digital Reporting Infrastructure Ready for 2027

• What changed: Slovakia confirmed the operational readiness of its decentralized electronic-invoicing and digital-reporting infrastructure. The system uses a five-corner model based on Peppol, certified delivery-service providers and reporting to the Slovak Financial Administration. In-scope invoices must be issued as structured electronic documents compliant with EN 16931, normally using UBL or CII syntax, rather than paper, scanned documents or ordinary PDF files.
• Who is impacted: Slovak VAT-registered suppliers conducting covered domestic B2B and B2G transactions must issue, transmit and report structured electronic invoices. Legal entities and taxable persons receiving covered domestic supplies must be able to receive them through the prescribed delivery network. The requirements therefore affect businesses, public bodies, sole traders, accounting departments, ERP owners, shared-service centres and providers supporting invoicing or reporting processes.
• Timing and next steps: The domestic mandate remains scheduled for 1 January 2027, while relevant intra-EU transactions are expected to enter the framework from 1 July 2030 under ViDA. Businesses should select an accredited digital-postman provider, establish Peppol connectivity, map Slovak VAT codes to the required invoice categories, validate structured invoice formats and complete end-to-end testing before the mandatory commencement date arrives.

🇸🇰 Slovakia: Proposed VAT Amendments Modify the January 2027 E‑Invoicing Mandate

• What changed: Slovak Government Bill No. 1454 proposes targeted amendments to the January 2027 electronic-invoicing and digital-reporting framework. Most notably, the bill would remove buyers’ obligation to report data from electronic purchase invoices. It would also introduce temporary penalty relief for specified supplier-side obligations, while preserving the fundamental requirement to exchange structured invoices and report relevant sales-invoice information through the designated infrastructure.
• Who is impacted: The proposed amendments principally affect Slovak VAT-registered suppliers responsible for issuing and reporting electronic invoices, together with buyers previously expected to report purchase-invoice data. All legal entities and taxable persons required to receive structured invoices remain operationally affected. Multinational businesses should assess the consequences for accounts receivable, accounts payable, reporting interfaces, service-provider contracts, controls and planned Slovak system configurations.
• Timing and next steps: Mandatory receiving capability through the Peppol-based delivery service would still begin on 1 January 2027. The proposed supplier penalty-relief period would continue until 30 June 2027. Bill No. 1454 remains at first reading and is not yet law, meaning businesses should continue implementation while closely monitoring parliamentary review, possible amendments, final enactment and corresponding updates to technical guidance.

🇧🇬 Bulgaria: Mandatory Domestic E‑Invoicing and Real-Time VAT Reporting Proposed from 2028

• What changed: Bulgaria’s Ministry of Finance published draft VAT legislation proposing mandatory structured electronic invoicing and real-time reporting through NISSEF, a national system operated by the National Revenue Agency. Invoices would follow EN 16931 and become legally issued after system validation and assignment of a unique compliance code. Collected transaction data would support pre-filled VAT returns and replace existing sales and purchase ledgers.
• Who is impacted: The proposal primarily covers VAT-registered suppliers established in Bulgaria making domestic supplies or receiving advance payments from Bulgarian taxable persons, non-taxable legal entities or public authorities. Certain non-registered suppliers invoicing public authorities would also be covered. Businesses would need capabilities for structured invoice issuance, receipt, validation, reporting, correction management and reconciliation of National Revenue Agency pre-filled VAT declarations.
• Timing and next steps: The proposed e‑invoicing, real-time reporting and pre-filled VAT return framework would apply from 1 January 2028. The public consultation remains open until 23 October 2026, after which the draft requires governmental and parliamentary approval. Businesses should review transaction scope, assess ERP readiness, evaluate EN 16931 capabilities and participate in consultation where the proposed design creates operational concerns.

🇳🇱 Netherlands: Domestic B2B E‑Invoicing and Digital VAT Reporting Roadmap Confirmed

• What changed: On 11 September 2026, the Dutch government confirmed that it intends to extend the ViDA electronic-invoicing and digital-reporting framework beyond intra-EU transactions to domestic B2B transactions. Mandatory structured e‑invoicing would apply domestically from July 2030, followed by domestic transaction reporting one year later. The approach would use EN 16931, although the final exchange infrastructure remains undecided.
• Who is impacted: The planned requirements will affect businesses conducting domestic B2B transactions in the Netherlands and companies participating in intra-EU trade. Businesses applying the Dutch small-business scheme, or KOR, with annual turnover not exceeding EUR 20,000 would remain exempt from domestic e‑invoicing. Multinationals must nevertheless evaluate Dutch billing, procurement, tax reporting, master-data, archiving and cross-border transaction processes before implementation begins.
• Timing and next steps: Mandatory e‑invoicing for domestic and intra-EU B2B transactions would start on 1 July 2030. Intra-EU transaction reporting would begin simultaneously, while domestic reporting would follow on 1 July 2031. Public consultation is expected in autumn 2026, followed by legislation before summer 2027 and parliamentary completion targeted before July 2028, allowing businesses approximately two years for implementation and testing.

🇵🇱 Poland: KSeF Penalty Deferral Proposed Until the End of 2027

• What changed: Poland plans to postpone the application of specified financial penalties for KSeF noncompliance until 1 January 2028. Draft Bill UD477 would extend the current penalty suspension throughout 2027, creating an additional adaptation period. The proposal does not postpone or remove the underlying obligation to issue structured invoices through KSeF, and the tax administration will continue monitoring how taxpayers use the system.
• Who is impacted: The relief is particularly relevant to smaller businesses entering mandatory KSeF after transitional arrangements expire, but it also benefits other taxpayers exposed to technical or procedural invoicing errors. Large taxpayers, businesses already using KSeF and companies joining during later phases remain legally required to comply. Tax authorities may investigate invoices issued outside KSeF where no statutory exception permits alternative invoicing.
• Timing and next steps: Large businesses entered KSeF on 1 February 2026, most other taxpayers followed on 1 April 2026, and the smallest businesses under the transitional exemption enter on 1 January 2027. If enacted, dedicated KSeF financial penalties would start on 1 January 2028. Businesses should not treat the deferral as postponement and should continue testing, onboarding suppliers and strengthening controls.

🇸🇲 San Marino: Mandatory Domestic B2B E‑Invoicing Introduced from January 2027

• What changed: San Marino adopted Delegated Decree No. 133 of 4 September 2026, extending mandatory electronic invoicing to domestic supplies between Sammarinese economic operators. Structured invoices must be transmitted through the government’s HUB-SM platform to the Tax Office, which performs formal controls before making invoices available to recipients. The domestic framework builds upon infrastructure already used for electronic invoicing with Italy.
• Who is impacted: The mandate applies to qualifying businesses, agricultural enterprises and public or private entities holding a San Marino economic-operator code. Operators whose previous-year revenue does not exceed EUR 100,000 may remain outside mandatory electronic invoicing, although they can opt into the system voluntarily. An operator choosing electronic invoicing should consider the continuing effect of that election during subsequent reporting periods.
• Timing and next steps: Voluntary domestic electronic invoicing is available from 1 October through 31 December 2026. Mandatory participation for in-scope operators begins on 1 January 2027, while the reported EUR 100 administrative penalty for failing to issue or transmit an invoice applies from 1 January 2028. Businesses should configure HUB-SM connectivity, review transmission deadlines, monitor rejections and test structured invoice validation promptly.

🇲🇰 North Macedonia: Draft E‑Invoicing Law Establishes Phased E‑Faktura Rollout

• What changed: North Macedonia published draft legislation establishing a centralized electronic-invoicing platform, known as e‑Faktura, managed by the Public Revenue Office. The proposed system would support the creation, transmission, receipt and validation of structured electronic invoices. Implementation would proceed through several phases, replacing traditional invoice processes progressively and giving the tax authority greater transaction visibility, automated data access and enhanced VAT compliance capabilities.
• Who is impacted: The phased framework ultimately covers VAT-registered businesses, non-VAT businesses, public bodies and other organizations conducting transactions within North Macedonia. Each category enters the mandate at a different stage. Multinational groups should determine which local entities and transaction flows fall within each phase, while reviewing ERP connectivity, invoice formats, digital signatures, validation responses, archiving procedures and contingency arrangements for system interruptions.
• Timing and next steps: Voluntary use of e‑Faktura begins in October 2026. Mandatory participation is planned from April 2027 for VAT subjects, July 2027 for non-VAT entities, October 2027 for public bodies and January 2028 for all remaining users. Businesses should monitor final adoption of the draft law and obtain technical specifications before completing integration, testing, process documentation and user training activities.

🇩🇪 Germany: Action Plan Positions E‑Invoicing as the Basis for Near-Real-Time VAT Reporting

• What changed: Germany’s Federal Ministries of Finance and Justice presented a 26-point action plan against tax and financial crime. The plan envisages a near-real-time VAT reporting system using structured B2B electronic-invoice data, supported by centralized analytics and artificial intelligence. Additional measures reportedly include longer archiving requirements and German mirror-server obligations, although these elements currently remain policy proposals rather than enacted legal requirements.
• Who is impacted: If implemented, the planned reporting framework would affect businesses issuing or receiving domestic German B2B electronic invoices, together with ERP providers, invoicing platforms, tax-reporting teams and data-governance functions. Multinational groups would need to connect invoice data with tax-compliance processes while considering potential German data-storage, retention, security and audit requirements. The eventual scope and reporting data fields have not been finalized.
• Timing and next steps: The 26-point action plan remains at the political and policy-development stage, without enacted legislation or a binding implementation date. Separate government planning indicates that legislative work on transaction-based VAT reporting could begin in 2027, with a voluntary pilot in early 2029 and operation targeted for July 2030. Businesses should monitor developments but avoid treating the proposed timetable as legally final.

🇭🇷 Croatia: Fiscalization Rulebook Updated Ahead of January 2027 Changes

• What changed: Croatia published amendments to the Rulebook on Fiscalization of Final Consumption Invoices in Official Gazette No. 97/2026. The amendments revise terminology and requirements concerning digital certificates, technical specifications, message signing and fiscalization procedures. Certain detailed requirements are transferred from the Rulebook to the Tax Administration’s Technical Specification, while the underlying B2C fiscalization framework and its principal operating model remain unchanged.
• Who is impacted: The amendments affect businesses fiscalizing B2C receipts, operators of self-service devices, POS solution providers and technical teams maintaining integrations with the Croatian fiscalization service. A valid digital certificate containing the Croatian OIB remains necessary for fiscalizing receipts or self-service sales. Certificates issued before the new rules take effect may continue to be used until expiry and need not be replaced immediately.
• Timing and next steps: The amended Rulebook applies from 1 January 2027. Businesses should review the updated certificate terminology, technical documentation and procedures before that date, while confirming whether existing integrations require changes. Testing should use appropriate DEMO certificates and environments. Tax, IT and retail teams should also monitor revised Technical Specifications covering message signing, security codes, production connectivity and self-service device requirements.

🇿🇦 South Africa: Consultation Opens on E‑Invoicing and Near-Real-Time VAT Reporting

• What changed: The South African Revenue Service published a consultation paper proposing a Digital VAT Model combining structured electronic invoicing, interoperability and near-real-time electronic reporting. The proposed decentralized five-corner architecture would use accredited service providers to exchange invoices and transmit tax-relevant data to SARS. The information could support automated validation, enhanced risk analysis, pre-filled VAT returns and possible future VAT auto-assessments for taxpayers.
• Who is impacted: The proposed transformation would affect VAT-registered businesses, government entities, consumers, software developers, ERP providers, invoicing intermediaries and accredited service providers. Businesses would need structured invoice capabilities, reliable customer and supplier tax identifiers, accurate VAT coding and integrated reporting processes. Stakeholders must also consider data security, implementation costs, governance, correction mechanisms and reconciliation between transaction-level information and periodic VAT declarations.
• Timing and next steps: Written responses to the consultation are requested by 16 October 2026. The proposed Digital VAT Model remains subject to stakeholder feedback, policy decisions and future legislation, and no general mandatory commencement date has yet been enacted. Businesses should evaluate readiness, identify challenging transaction types and provide practical feedback on standards, sequencing, safeguards, costs, system integration, reporting frequency and implementation support requirements.

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