Start a conversation

Customs & VAT

Electronic invoicing is becoming mandatory in Europe: what your customer will expect

Member states are progressively requiring invoices between businesses to be structured data transmitted through a platform or a network. An invoice outside that form does not arrive late — it does not arrive.

China → France

The invoice you send as a PDF attached to an email is, in several European countries, already on its way to being unusable. Member states are progressively requiring that invoices between businesses be issued as structured data and transmitted through a platform or a network rather than mailed to a person. The change looks administrative and it is not. An invoice that is not in the expected form does not arrive late; it does not arrive, and the payment that was supposed to follow it does not happen.

A PDF, a structured invoice and a network transmission are not the same thing

This is where almost every conversation goes wrong, because all of them get called the same thing. A supplier says they already invoice electronically and means they email a PDF. A customer says they need an electronic invoice and means something a machine can read without a human retyping it. A provider says they are connected and means they can reach the network the customer's system listens on. Separating those layers is the whole subject.

  • A PDF is a picture of an invoice. A person reads it and a machine guesses. It can be a perfectly legal invoice, and it still means manual work at the other end — which is precisely what the new rules exist to remove.
  • A structured invoice is data. Fields in an agreed format, validated against a schema, where the customer's reference, the tax treatment and the line items occupy defined places. Either the field is correctly filled or the document is rejected.
  • The transmission is a separate layer. The data travels through a platform or an interoperable network, to an electronic address, with an acknowledgement that it was delivered. Having a correct invoice and no way to deliver it to the right address is a common and expensive mistake.
  • Archiving is a layer again. Issuer and receiver each have to keep the invoice in a form that stays readable and unaltered for the retention period their country sets. A copy left in a mailbox is not an archive.

What changes for a supplier established outside the European Union

Your European customer is not being difficult. Once their country's arrangement applies to them, their accounting system rejects an invoice that arrives outside the expected channel or without a field it requires, and no amount of goodwill at their end pushes it through. The accounts payable clerk you used to telephone is the part being removed from the process. What used to be a conversation becomes a return code.

  • The mandatory particulars become controlled fields. Your identification, theirs, the tax treatment, the currency, the description of what was supplied — all checked automatically, and anything missing produces a rejection rather than a query.
  • A reference error stops the payment with nobody noticing. A purchase order reference that does not exist in their system, a delivery number that does not match, and the invoice is refused by a machine. You find out when the money does not arrive.
  • Corrections follow the same channel. A credit note or an amended invoice has to travel the same way and refer correctly to the original document. Sending a corrected PDF alongside is noise, not a correction.
  • Your identifiers have to be right and stable. The electronic address, the tax identification used, the exact legal name: a change you make without telling the customer breaks the routing silently.
  • The invoicing party decides which rules apply. If your European subsidiary or your importer issues the invoice, that entity's country arrangement governs, not yours. Deciding who invoices is therefore a compliance decision, not only a commercial one.

Why the calendar and the arrangement differ from one country to another

There is a common European direction and there is no single European system. Some member states route invoices through a public platform operated by the administration. Others rely on a network of certified or registered providers exchanging between themselves. Several require that data about the invoice be reported to the tax administration alongside, or instead of, the invoice itself. The dates on which business-to-business issuing becomes compulsory, and for which size of company, are set country by country and have moved more than once. Generalising from the single customer who explained their system to you is how a supplier gets caught in the next country.

What to do before the next order

  1. Ask every European customer which channel they use. Not whether they accept electronic invoices — which channel, which format, and from when they will stop accepting anything else. Put the question in writing and keep the answer in the customer file.
  2. Collect their electronic address and their required references. The routing identifier, the order or contract reference they want on every invoice, and the name of the person who sees a rejection. Those are what prevent silent failures.
  3. Settle who issues the invoice. You, your European entity, or your importer of record. The answer determines which country's obligation you live under and who has to be connected to what.
  4. Choose how you connect. Directly, through your accounting software if it already speaks the formats, or through a service provider. Compare the options on the countries each one actually reaches, not on the price of the subscription.
  5. Test with a real invoice while a failure is still harmless. Send one, confirm the acknowledgement, confirm it entered the customer's ledger, and keep the proof. A test done early costs nothing; a first attempt made on a large order costs a payment cycle.

Send one message this week to every European customer: on which channel do you receive invoices, in which format, with which references, and from when will you refuse anything else. The answers will differ, including between subsidiaries of the same group, and that difference is the information you need. Then decide who issues the invoices before you connect anything, because connecting the wrong entity is work you will have to do again.

Where to read it yourself

Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.

Questions we get on this.

We are not established in Europe — does the obligation apply to us?

The obligation attaches to the invoice, not to your head office. Where the invoice is issued by a supplier with no establishment in the country, the local arrangement may not bind you directly, but it binds your customer to receive and process invoices in a particular way, and they will require that of you contractually. The practical result is the same as being covered. It changes completely if you invoice through a European entity of your own, or if an importer of record invoices the final customer: an established party is then squarely inside the local rules and the obligation is theirs. Ask each customer what they require, and look at who is named as supplier on the invoice.

Can we keep sending a PDF if the customer agrees?

For as long as their system still accepts one, and that is a shrinking window with no warning attached to it. It is a bad plan for reasons that have nothing to do with goodwill. A customer's agreement does not override their own obligation, so the day the mandate reaches them the arrangement ends without a negotiation. And a PDF accepted as a favour is processed by a person who is being taken out of the process, which makes your invoice the exception handled last. If you want to keep the PDF, keep it as a courtesy copy for the human, and send the structured invoice through the channel the system reads.

Who decides which format we must use?

Your customer's country first, and then your customer. The national arrangement sets which formats are legally acceptable and how invoices must be transmitted; within that, the customer tells you which of the permitted formats their system handles and which references it needs. You do not get to choose, and neither does your software provider. This is why the useful question is never what the European format is, but what do you receive, where do I send it, and what must be on it — asked of every customer, and asked again when they change system.

Keep reading on this.

Customs & VATVAT and customs on imports into the EU: who pays what, and whenDuty is a cost. Import VAT usually is not — it is cash flow. Confusing the two produces prices that are either uncompetitive or unprofitable.Customs & VATGetting paid in Europe: terms, delays and what the law gives youEuropean buyers expect to pay after delivery, not before it. That is normal here, it is bounded by law, and the protections only work if they are written into the contract before the first shipment.France–ChinaThe European compliance stack, in the order you should deal with itSix obligations, and doing them in the wrong order wastes months. A map for a Chinese company that has decided to sell in Europe and wants to know what it is walking into.Customs & VATSending someone to sell in Europe, and creating a permanent establishment without knowing itA durable presence — a person or a place — can make your company taxable in a country where you thought you only had a salesperson. The question is decided on facts, and best decided before the trip.

If this raised a question about your own project, tell us where you are — the first conversation usually clarifies more than a proposal.

Talk about selling into Europe →Read the full guide