The rise of e-invoicing CTC models across the world

Angola has made CTC mandatory for all taxpayers with annual turnover greater than USD 250 000 (ca. EUR 231 000). Issuance of valid tax e-invoices must be performed by software certified by the AGT - Adminitraçao Geral Tributária in Angola. For the remainder of Angolan taxpayers, e-invoicing remains voluntary.

The software certification process in Angola resembles the one in Portugal and requires the ability to generate and report to AGT the Standard Audit File for Tax – SAF-T(AO) for sales and purchase operations, which are mandatory in Angola. The certificate issued by AGT is valid for 24 months after approval.

Ghana has been operating under the fiscalization model since 2018.

To further automatize and digitalize business document processes and obtain transaction data, The Ghanaian Revenue Authority (GRA) launched a pilot for e-invoicing adoption on 1 October 2022. Referred to as the e-VAT invoicing system, it is currently available to selected taxpayers.

Applications to obtain the Electronic Tax Clearance Certificate (E-TCC) are required for taxpayers bound to start issuing e-invoices. While not all taxpayers are currently obliged to use the e-invoicing system, and printed VAT invoices remain dominant in the country, GRA expects all VAT taxpayers to be issuing e-invoices by 2024.

Kenya has been operating under the fiscalization model for years, showing promise in moving forward towards electronic invoicing.

Recently, the Kenyan Revenue Authority (KRA) has introduced eTIMS - a software-based e-invoicing upgrade of the Tax Invoice Management System. It allows for connections with existing billing systems, as well as other computerized systems and mobile phone applications.

The expectation is that all VAT-registered taxpayers will have to accept electronic tax invoices exclusively from registered taxpayers by 1 June 2023.

The Central Bank of Nigeria announced in a January 2022 Circular that all transactions related to imports and exports must be accompanied by electronic invoice issuance from suppliers. This approach is largely aimed at achieving accurate pricing for goods purchased or sold abroad and mitigation of tax evasion and fraud.

The logic used to enforce accurate pricing is establishing the requirement to use benchmark pricing for goods, once an invoice is created. Invoices within 2.5% of the benchmark price will be validated and approved.

Currently, the requirement is limited to imports and exports. However, e-invoicing in Nigeria is welcome and spreading. In the foreseeable future, the mandate itself may encompass more transactions.

Like many other African nations mentioned above, Rwanda adopted the fiscalization approach, which takes the form of real-time invoice reporting. Taxpayers are obliged to use electronic billing machines (EBMs). These hardware machines are directly connected to the Rwandan Revenue Authority (RRA), and taxpayers can only acquire them from vendors authorized by the tax administration.

An early party in recognising electronic invoices and transactions, Senegal legally allows the transmission of e-invoices and their digital archiving. This is part of the Law n° 2008-08 on Electronic Transactions.

The law allows for equal recognition of paper and electronic invoices as well as lists the requirements for their maintenance and preservation of integrity and authenticity.

Looking toward the future, the South African Revenue Service (SARS) has recently announced its intentions to introduce requirements for reporting electronic invoices in real time.

Like Senegal, South Africa was early to publish legislation that included e-invoicing. Now, the country is moving forward towards expanding requirements by way of CTC to capture transaction data.

The model South Africa is discussing is a real-time invoice reporting model that obliges taxpayers to transmit invoice data within 24 hours. In a phased approach, the plan is to reduce the duration from 24 to 6 hours, then 1 hour.

E-invoicing for both B2B and B2C transactions is mandatory in Uganda since January 2021. “The Electronic Fiscal Receipting and Invoicing System” (EFRIS) encompasses fiscalization and software-based clearance components.

Taxpayers can choose the transmission channel to the Uganda Revenue Authority (URA) via EFD, EFRIS portal (manually) or via software, such as ERP. As Uganda has adopted the clearance model, an e-invoice may only be issued and exchanged between the trading partners after receiving approval from URA.

Yet another country in Africa that requires the use of Electronic Fiscal Devices (EFDs) to collect tax information from economic operators, Zimbabwe separates the distinction of EFDs into three categories. These categories are:

• Fiscalized electronic register;
• Non-fiscalized electronic register;
• Electronic signature devices (ESD).

Since 1 October 2020, Zimbabwe has required VAT-registered retail operators that meet the Zimbabwe Revenue Authority’s (ZIMRA) stipulated thresholds to have either the fiscalized electronic register or a non-fiscalized electronic register with a fiscal memory device.

VAT-registered taxpayers that are not retail operators may use the same options as their retail operating counterparts, with an additional option of using e-signature devices.

The Pre-Clearance or Hard Clearance model has been adopted by Argentina, Brazil, Chile, Colombia, and Costa Rica among others. As a first step, the supplier creates an e-invoice (known as DTE, CPE, CFDI, or e-CF) in an XML format and sends it to the tax administration platform for clearance. Once the e-invoice passed TA validations, it generates a unique number (known as CAE, CAF, etc.) associated to the  e-invoice  and returns it back. 

The supplier now adds that number (known as UUID) to the e-invoice and delivers it to the buyer. The buyer then has either an option or obligation to validate that e-invoice with TA. Additionally, the buyer may be obliged to return a receipt acknowledgment of invoice (e.g., in Chile or Colombia), a commercial approval or rejection message (e.g., in Colombia, Costa Rica or Chile), which is also becoming more and more common in Brazil. 

Bolivia is about to implement the Pre-Clearance model, starting with large taxpayers. El Salvador is also implementing this model and will make the timeline available shortly. The only main difference is that the electronic invoice (DTE) will be based on a JSON format in El Salvador, unlike the other countries that either have developed domestic XML or adapted versions of UBL specifications. 

Another variation is the Post-Clearance model or Soft Clearance. Here, an e-invoice can be exchanged between trading parties prior to obtaining clearance from the tax authority.

In Uruguay, the CFE (electronic tax document) must be sent to the TA, but without the supplier waiting for clearance response (authorization) prior to sending the CFE to the buyer. Both parties will get an “Invoice ID” number immediately for checking invoice status at the later stages. The Dominican Republic will adopt a similar approach making e-invoicing mandatory for some taxpayers, starting from 2023. 

In other countries, such as Ecuador or Paraguay, the e-invoice can be delivered to the buyer as a first step. Then, during the next 24 hours and 72 hours respectively, the supplier must report the e-invoice to the TA. 

Although in the Post-Clearance jurisdictions e-invoice submission can be performed after the invoice delivery or prior to obtaining the authorization, most taxpayers still initially clear the e-invoice with the TA to avoid creating a credit note or cancellation invoice in case of invoice rejection by the tax authority. 

Lastly, we have the Delegated Clearance approach, which has among others been adopted in Mexico, Peru, Guatemala, and Panama. Under this model, the tax authority delegates the clearance task to accredited private services providers, known as PAC (Guatemala, Mexico and Panama) or OSE (Peru) to operate on its behalf.

Unlike the above two clearance models, which can be seen as alternatives to each other, the delegated approach can exist in both of those, as it merely defines who has the right to validate the fiscal validity of e-invoices: the government or private companies authorized by it. While in all countries with PAC, an e-invoice has to be transmitted to the accredited service providers for clearance before being delivered to the buyer, taxpayers in Peru can exchange the e-invoice with buyers directly and send it to OSE within 3 days.

While the rise of electronic generation and real-time reporting of invoice data to tax administrations across the region has been significant, the real business automation and efficient use of the digitalized data by the businesses have barely lifted here. Unlike Europe or other districts, where e-invoicing has been driven by businesses to gain efficiency and lower costs, businesses in Latin America had to comply with requirements set by their governments. Although invoices in that region are XML based, most businesses still use their PDF versions; moreover, over 90% of e-invoices are exchanged over e-mail, instead of more secure or automated methods.

Currently we are seeing some Latin America-based businesses looking for solutions that will not only help them comply, but also automate their workflows, improve the data quality and lower processing costs.

Australia adopted Peppol invoices in 2019, and from July 2022, all Commonwealth government agencies have been able to receive and process electronic invoices. Contractual suppliers can start sending e-invoices via Peppol to the Commonwealth Government agencies. Meanwhile, the Australian Treasury has released a consultation on Business e-invoicing Rights (BER), introducing a legal framework whereby Australian businesses reserve the legal right to request to receive electronic invoices via the Peppol Network.

Fapiao is an official invoice administered by the National tax tracking system, including General VAT Fapiao and Special VAT Fapiao. China launched the OFD fapiao system in September 2020, in which invoices can be issued in OFD format (similar to PDF) via a Ukey device. At the end of 2021, the Chinese government introduced a new advanced e-invoicing program to encourage taxpayers to issue fully digitalized e-invoices (e-fapiao). Unlike OFD fapiao, e-fapiao is a ‘true’ electronic invoice issued in a structured format (XML). The e-fapiao pilot program has been deployed country-wide and foreseen replacing the Ukey and printed paper invoices.

The Indian government has rolled out the e-invoicing mandate gradually since January 2021 to boost economic growth and address the tax gap issues, starting from turnover exceeding 100 crores (c.a. EUR 12M) to the latest one INR 5 crores (ca. EUR 560 000). Following the roadmap, it can be expected that the government intends to cover all businesses to adopt electronic invoices.

Along with the QIS (Qualified Invoice System) launches in October 2023, the Japanese government established the Digital Agency, which later obtained the Peppol Authority status in Japan, to prompt e-invoices to accelerate digitalization and streamline processes. Japan is the first country to implement Peppol PINT, and the government has recommended Peppol invoices as their preferred format and a national e-invoice standard.

With the 2023 Pre-Budget statement issuance, Malaysia joins a growing list of countries that are digitalizing their tax administrations by switching to e-invoicing.

The Malaysian National e-invoicing Initiative plans to introduce a hybrid centralized pre-clearance CTC model combined with the Peppol network. The mandatory implementation will gradually roll out from 1 August 2024, based on the business revenue.

To facilitate the adoption of e-invoices, the Malaysian Inland Revenue Board has introduced a 6-month grace period for each scope of phased taxpayers. This period includes allowance to issue consolidated e-invoices for all transactions, exemptions from applicable penalties, and an incentive policy.

Like Australia, New Zealand established Peppol as a preferred format in 2019 and has been taking part in the global Peppol network. According to the latest statistics, 60% of Central Government Agencies have been enabled to receive e-invoices via Peppol already.

The Philippines implemented the Electronic Invoicing/Receipting System (EIS) pilot project in July 2022. The project was kicked off from a pilot project on selected 100 businesses and has expanded to more taxpayers. Taxpayers using the EIS system must issue receipts and invoices electronically and transmit the data in JSON format within three calendar days from the transaction date, which is a setup of a real-time reporting (RTIR) model.

Singapore was the first country outside of Europe to obtain Peppol Authority. The government implemented the nationwide E-invoicing network (InvoiceNow), established on the Peppol framework in 2019, to help businesses improve efficiency and reduce costs. InvoiceNow has become the preferred method for e-invoice submission to public sector recipients and is expected to become the channel for all transactions.

In April 2024, the Inland Revenue Authority launched a phased e-invoicing mandate, enhancing the current InvoiceNow framework to transmit invoice data to tax authorities. Starting with newly incorporated companies that voluntarily register for GST to report e-invoices from November 2025 and later expand to all GST payers.

The government of South Korea introduced the electronic tax invoice system in 2010 and became one of the earliest countries to introduce the e-invoicing mandate in this region with RTR as a CTC model. It started with large corporations and has been extended to more businesses by reducing the obligation thresholds gradually. In light of the success of the National e-invoicing system, there are also discussions on e-invoice exchanging via Peppol on cross-border transactions.

Taiwan has a special VAT invoice system called Government Uniform Invoice (GUI), with the government regulating GUI numbers (same as invoice numbers). Along with the e-invoicing launch in 2000, most businesses have moved to eGUI today. The eGUI includes all transactions: companies have to report to the e-invoicing Platform within 7 days for B2B transactions and 48 hours for B2C transactions after the issuance of e-invoices.

Thai taxpayers can issue e-invoices and submit them to the e-Tax system voluntarily. The Thai e-invoicing programs were launched in 2017 and have become a mature system. Similarly to South Korea and the Philippines, after issuing the e-invoice to the buyer, the supplier must report the invoice to the government in a local XML format by the 15th day of the following tax month. To encourage businesses to adopt e-invoicing, the government extends tax reduction measures to promote e-Tax systems.

Vietnam had pre-printed paper invoices replaced with electronic ones in July 2022. All businesses must adopt e-invoicing without thresholds. Businesses falling under the scope of e-invoicing need to send e-invoices in mandatory format to the government for approval, and an authentication code will be returned after validation.

Sweden was early out with its e-invoicing obligation in the public sector. Since 2008, issuing electronic invoices to governmental institutions has been mandatory. This was further extended in 2019 to encompass the entire public sector through the Peppol framework. 

From a B2B perspective, the country is purely a post-audit market. While e-invoicing is widely used in the private sector, it is not mandated. This, however, may change soon. 

The latest development in Sweden is that The Agency of Digital Government (DIGG), along with The Swedish Companies Registration Office (Bolagsverket) and the Tax Agency (Skatteverket), have submitted a formal request to the Swedish Government to investigate the introduction of mandatory e-invoicing in both the B2B and G2B segments. This request follows the latest developments in the EU with the ViDA proposal. There have also been rumors that Sweden is moving towards a Peppol CTC model for B2B e-invoicing as well.

There has yet to be final confirmation from the Swedish Tax Authority (Skatteverket) on settling for a specific CTC model, but Peppol CTC still seems to be a likely candidate. With B2B e-invoicing being expanded across the European Union (VAT in the Digital Age), Sweden is closely following these developments.

Norway also has been long ahead of other countries with regard to digitalizing their economy. Since 1 July 2012, all central government entities in Norway have been obliged to receive invoices electronically. This was executed using Peppol infrastructure using the EHF format, the Norwegian national version of Peppol BIS. 

The country has no mandate for B2B transactions today, but companies extensively use e-invoicing. 

Similar to its neighbours, Finland has gone a slightly different path for their e-invoicing. The country follows the post-audit model – the same as the other Nordic countries for B2B invoicing. However, for public invoicing, Finland has adopted an approach of interoperability and Peppol.

There are a few alternatives for sending e-invoices to the government. Suppliers can establish an interoperability agreement with the contracted Service Provider of the Finnish Government or send e-invoices through the Peppol network via a Peppol Service Provider. Worth mentioning in Finland is Tieke (the Finnish Information Society Development Centre), which, besides running an e-invoicing forum for Service Providers, also developed a search engine – the E-invoice address registry – that can be used for finding the e-invoicing addresses of companies.

The latest news in Finland is that it has joined the growing list of countries with their own Peppol authorities. Furthermore, it has formally announced its support for the ViDA initiative, the first Member State of the EU to do so.

In Iceland, government agencies only accept e-invoices complying with the national standard TS-236 technical specification. However, the Icelandic government neither mandates nor recommends any e-invoicing service provider or using a particular e-invoicing platform.

Suppliers can issue electronic invoices via their billing systems or service providers. Invoices sent to governmental entities are also accepted through the Peppol network.

There are currently no indications of Iceland introducing mandatory e-invoicing for business transactions, but things can change anytime.

Another Nordic country that does not mandate B2B transactions is Denmark. The country uses Peppol/NemHandel for B2G e-invoicing.

The most significant development in Denmark recently has been the introduction of the new Danish Bookkeeping Act, effective as of 1 July 2022. The major change the act brings to the table is the requirement for businesses to use “digital bookkeeping systems” capable of issuing, receiving, exchanging, processing and archiving invoices electronically.

Software providers of the services above must also register with ERST (Erhvervsstyrelsen) to become classified as “digital bookkeeping systems”.

Although the bookkeeping act is active, the digital obligations will be gradually rolled out, with the expected starting date from 1 January 2024, with the larger companies that are obliged to submit an annual report to ERST being the first out and smaller companies later on. The timeline is subject to change since there have been delays in the implementation process. It is still quite unclear regarding the digital obligations and what additional requirements could be in store for businesses and service providers operating in Denmark. What’s clear is that the introduction of the new bookkeeping law reflects a new paradigm with regard to Danish e-invoicing.

Therefore, several private service providers offer e-invoicing exchange services in Estonia via interoperability or the Peppol network. For small companies (start-ups and SMEs) that want to send invoices to the public sector, the Estonian Center of Registers and Information Systems (RIK) made available, at no charge, the use of e-Financials, a web-based infrastructure to send invoices to governmental entities. On the B2B side, Estonia has not yet imposed specific requirements; thus, taxpayers can issue and exchange invoices and other documents in any preferred format or mechanism. 

Earlier in October last year, the Cabinet of Ministers in Latvia revised and approved the informative report initiated by the Ministry of Finance on implementing an e-invoicing system. The key novelty of this report is the introduction of mandatory e-invoicing in the B2B and B2G segments starting in 2025, and Peppol e-delivery network is proposed to be adopted as a single standard for sending and receiving e-invoices.

The eSaskaita platform is the central information intermediary that receives and sends electronic invoices between suppliers and public contracting authorities in Lithuania. It is also Peppol-enabled since 2019: businesses can either connect directly with the platform to issue e-invoices or select an accredited Peppol Service Provider. The Service Provider will convert the data into the Peppol BIS 3.0 format, apply the necessary validations, and submit the e-invoice via the AS4 communication protocol to eSaskaita, which will provide the e-invoice to the buying public entity.

While the B2G sector in the country follows the centralized CTC model, Lithuania applies post-audit for business transactions.

It has been mandatory in Austria to issue structured e-invoices to the Federal Government since 2014. To issue e-invoices to the Federal Government, taxpayers must utilize the centralized Federal Service Portal (Ger.: Unternehmensserviceportal – USP).

As of today, there is no official news regarding the introduction of a countrywide e-invoicing mandate in Austria. Nevertheless, as in most of Europe, this could change quickly upon approval of the ViDA proposal.

Like most European countries, Belgium has an e-invoicing mandate for B2G transactions. Suppliers for public entities can use Peppol to send e-invoices to the Governmental Mercurius platform to reach all their public entity customers.

Belgium is one of few countries in the world that also mandates Message Level Response (MLR) and Invoice Response Message (IRM) as a part of the B2G mandate. The latter is a business response (accept/reject) from the buyer to the issuer of the invoice, and the former is a document transport status response between the sending and the receiving service providers based on technical validations of the e-document.

On the B2B front, Belgium plans to roll out an e-invoicing mandate by 1 January 2026, pending derogation from the European Commission. There are also indications of a future introduction of DRR in line with the ViDA proposal. Similarly to the B2G mandate, Peppol is poised as the default method for both e-invoicing and DRR; however, other standards would be allowed for e-invoicing upon mutual agreement.

Lastly, it is also worth mentioning the Hermes platform to get a more holistic understanding of the Belgian e-invoicing landscape today. Hermes is a platform that converts any EN 16931 structured e-invoice into a PDF format and sends it to the recipient's e-mail address. It is used for business transactions when the recipient cannot process an e-invoice.

Today in France, there is only a CTC mandate for B2G transactions. Invoices to public authorities must be issued in a structured electronic format through the Government’s centralized platform, Chorus Pro. However, much is to change with the upcoming French CTC mandate, which is perhaps one of the most complex CTC mandates to date.

There are many components to the French mandate: for starters, it is a hybrid CTC model with a centralized exchange, the Public Invoicing Portal (Fr.: Portail Public de Facturation or PPF), combined with decentralized invoicing flows via certified service providers (Fr.: Plateformes de Dématérialisation Partenaires or PDP). Domestic business transactions must be issued, exchanged and processed electronically through either of these avenues. This also applies to the issuance of invoice life cycle statuses and payment statuses.

Furthermore, taxpayers will have to electronically report cross-border B2B and B2C transactions in near-real time to the tax authority.

It will be interesting to see all of this come together on 1 September 2026.

For B2G transactions, Germany is known for its complex legislative e-invoicing landscape. Essentially, there is the Federal Government (both direct and indirect), which makes it mandatory to issue e-invoices via a centralized exchange. Moreover, there are the Federal States (Ger.: Bundesländer) that can shape their own e-invoicing laws, leading to some of them enforcing mandatory e-invoicing. Most public transactions in Germany can be executed via Peppol; however, there are some exceptions in the case of individual Bundesländer.

Lately, there have been some significant developments in the business sector transactions. With the Growth Opportunities Act (Wachstumschancengesetz), Germany is now introducing an e-invoicing mandate between 2025-2028. For domestic business transactions, paper and unstructured formats such as PDF will be phased out over the next few years, with EN 16931-compliant structured e-invoices becoming the obligatory format.

Starting 1 January 2025, German businesses will have to be able to receive EN-compliant e-invoices. Larger businesses (turnover > EUR 800 000) will have to begin issuing EN-compliant e-invoices in January of 2027, while the rest of the taxpayers will have to start issuing in 2028.

There is yet no official confirmation of the introduction of the domestic Digital Reporting Requirements (DRR). However, if the Germans were to introduce this, they are expected to do so after 2028, which aligns with the ViDA proposal.

From an e-invoicing perspective, Ireland is similar to the UK in many ways. Public authorities are obliged to be able to handle e-invoices, but there is no mandate for suppliers to issue e-invoices.

The latest development in Ireland is that the Irish Ministry of Finance has been doing a public consultation on introducing mandatory e-invoicing together with DRR. It is still too early to say what will come from this initiative, but this strongly indicates the winds blowing in the direction of CTC mandates worldwide.

There has been a B2G e-invoicing mandate in Luxembourg since 2022. Suppliers to public authorities have to issue e-invoices via Peppol. Currently, there is no news on any introductions of a business e-invoicing mandate.

Netherlands has a B2G e-invoicing mandate. Suppliers to public authorities have to issue e-invoices to the Digipoort platform via Peppol. Like most Governmental e-invoicing platforms, Digipoort works as an electronic post office. It receives e-documents such as e-invoices, validates the e-document and confirms receipt of the message.

At this point, there is yet no official confirmation of introducing a B2B e-invoicing or DRR mandate.

In Switzerland, service provider interoperability for e-invoices is the name of the game. While sending e-invoices to the Federal Government is mandatory, this has also led to the widespread use of e-invoices in business transactions, which at this point is not obligatory but still very popular. E-invoices to the Federal Government in Switzerland and between businesses are sent via e-invoicing service providers who facilitate the transmission of the e-invoice between suppliers and buyers.

United Kingdom (UK) has no mandate for e-invoices. Although public authorities must be able to receive e-invoices, suppliers are not required to issue e-invoices.

Outside of the e-invoicing scope, there is another e-document mandate in the UK - electronic orders for the National Health Service (NHS). All NHS trusts in the UK have to issue e-orders to their suppliers via Peppol. 

In 2018, Hungary introduced a voluntary real-time invoice reporting scheme, ultimately mandating invoice reporting for B2B and B2C transactions by April 2021. While not regulating e-invoices themselves, the model requires taxpayers to send a subset of their invoice data to the Hungarian Tax Authority (NAV) via the Online Szamla platform immediately after issuing the invoice.

Encompassing both Hungarian taxpayers and non-established entities with VAT registration in Hungary, the transactions that Online Szamla validates in real time include:

• B2B & B2C domestic transactions;
• B2B intra-community transactions;
• Tax-exempt domestic transactions;
• Export transactions; and
• B2C distance sale transactions.

The requirement to send invoice data is enforced by penalties up to HUF 500 000 (approx. EUR 1500,00) per invoice.

While the Online Szamla platform receives invoice data, it is important to note that this is for reporting purposes exclusively. Issuing and fetching invoices via the platform is not possible.

Poland has received a derogation from Directive 2014/55/EU to implement a mandatory countrywide CTC model centred around the KSeF platform.

Starting February 2026, businesses with sales exceeding PLN 200 million (ca. EUR 46 million) must comply with the KSeF. As of April 2026, all entrepreneurs will fall under the scope. The KSeF platform has been available for voluntary use since January 2022, but its adoption is currently not widely practised.

While the centralized model with KSeF as a mandatory platform is for B2G and B2B transactions, using PEF (the Polish Governmental E-Invoicing Platform) is still possible in the public sector. PEF, which operates on the Peppol network, will run in tandem with KSeF for the foreseeable future.

Using KSeF has many benefits for taxpayers issuing invoices in the infrastructure. Besides increased speeds for tax refunds and the convenience of end-to-end process automation, taxpayers now have fewer obligations when it comes to archiving, as invoices can be stored in KSeF for up to 10 years. Moreover, using this platform reduces administrative responsibilities such as generating and sending specific audit files. As data will already be transmitted via KSeF, tax authorities will already have access to this information.

Since 2019, Romania has been leading the EU in VAT gaps with a total gap of 34.9%. To curb this and follow the other European jurisdictions successfully combating tax evasion, the country is implementing e-invoicing and e-transportation mandates alongside a new SAF-T schema.

Since July 2022, it has been required for B2G invoices to be issued via the RO e-factura infrastructure. The Romanian government has also mandated to validate invoices concerning high-risk fiscal goods and services between private companies via the RO e-factura platform.

High-risk fiscal transactions allow for a higher risk of tax evasion when bought and sold. These can be anything, e.g., alcoholic beverages, clothing, construction materials, etc.
The RO e-transport system has been introduced in parallel to further apply controls around these goods. It allows monitoring of high-risk fiscal goods transportation and requires documentation with a unique ITU code to accompany all such goods.

From 2024, the scope of the RO e-factura obligation has been extended to B2B transactions, starting from e-reporting as of January and moving to e-invoicing in July. For taxpayers not complying with the RO e-factura system, the penalties will be levied from July 2024.

Furthermore, Romania plans to extend e-invoicing requirements to the B2C sector from January 2025, with optional use available from 1 July 2024.

Serbia is another Eastern European country implementing a centralized exchange model for invoice issuance. Since May 2022, entities have been required to issue e-invoices to their public sector trading partners via the SEF (Sistem E-Faktura) platform, and since July 2022, businesses have had to be able to process e-invoices from the governmental entities.

Moreover, Serbia has extended the mandate for issuing and receiving invoices via the SEF infrastructure to the private sector, beginning January 2023. This incorporates another distinctive measure regarding invoice responses in the country.

Another notable feature of the Serbian implementation is the mandatory issuance of electronic business responses by the buyers. The buyer is given a limited timeframe to issue such a response, which, if not observed, has the effect of the invoice being final and non-disputable for B2G transactions or rejected for B2B transactions. 
As Serbia is not an EU member, there is a freer rein to implement continuous transaction controls in the jurisdiction without requiring a derogation.

Slovakia has been executing test runs on its IS EFA infrastructure prototype since June 2022. This is the stepping stone to adopting a public sector mandate, but the implementation dates, the exact CTC model, and document types are not yet known.

Furthermore, the Slovakian government has announced its intention to extend the mandate countrywide, encompassing the private sector, but further legislation is still to be published.

Allowing for the issuance and reception of e-invoices, Slovenia has adopted the centralized platform UJP eRačun and Peppol for B2G transactions. This provides suppliers with more flexibility when issuing their business documents. Entities can use Peppol BIS, eSlog 2.0 or other EN compatible formats.

The discussions on the future outlines of the CTC model in Slovenia are about to restart. Previous news regarded the introduction of a CTC model involving centralized pre-clearance with exchange via interoperability. The extended scope of the taxpayers is expected to include business entities, budget users, or taxpayers having subscriber status in the jurisdiction, as the government has announced a draft proposal on facilitating the VAT in the Digital Age (ViDA) initiative.

Since 2019, suppliers to the Cypriot governmental entities could issue e-invoices voluntarily via Peppol or ARIADNI portal, with institutions processing invoices manually in the following steps.

The government planned to introduce mandatory B2G e-invoicing by 1 January 2022. No announcements have been made up to date, however.

While Greece has implemented the myDATA (My Digital Accounting and Tax Application) schema for reporting various accounting information to the Independent Authority for Public Revenue (IAPR), most invoicing still follows the post-audit approach, where the businesses are free to agree on how they want to exchange invoices with each other.

Recently, the IAPR informed businesses who opted in for certified myDATA agents to comply with the reporting requirements that they would also have to send invoices electronically via such solutions to the public buyers that have been Peppol-enabled. We should be expecting further developments in this respect coming out of Greece.

Greece is also preparing a B2B e-invoicing mandate that could potentially start around 2025, where Dispatch Advises will also be in scope to be issued and reported electronically. 

To combat the VAT gap, Italy has obtained a derogation from Directive 2014/55/EU and implemented mandatory countrywide e-invoicing via the SDI platform. The country applied a centralized model for domestic transactions within the private and public sectors.
  
As a result, e-invoicing has significantly helped reduce tax evasion. At the end of 2021, the European Council authorized Italy to extend the derogation until 2024. 

Since 1 July 2022, all cross-border transactions have been included in the scope of the e-invoicing mandate. The Esterometro scheme used for this purpose was abolished, so now Italian taxpayers must report sales and purchase invoices from non-Italian trading partners in real-time and on a transactional level via SDI.

At the end of 2021, Malta took a step towards complying with the E-procurement Directive and chose Peppol to facilitate B2G e-invoicing. With the help of the Peppol network, digital communication between governmental institutions and suppliers will be standardized and consistent.

Learn more how the Maltese Ministry of Finance and Employment will drive the implementation with Pagero.

Portugal has a mixture of accounting SAF-T reporting and e-invoicing requirements in place. B2G e-invoicing in Portugal follows a centralized model via the FE-AP platform with interoperability through contracted service providers. The business sector is still operating in the post-audit regime.

In previous years, some initiatives were introduced to promote the digitalization of invoicing processes. They have little to do with real e-invoicing, however. These steps are the mandatory application of QES (Qualified Electronic Signature) on non-EDI invoices and the generation of the ATCUD code on all types of invoices. 

On 1 July 2022, e-invoicing for the supply of goods and services became mandatory between Italy and San Marino. Other than this case, the post-audit regime is dominant in the autonomous district of San Marino. 

The most commonly used platform for exchanging invoices for e-invoicing in the public sector (B2G) is the central FACe platform, utilizing the Facturae format. Some regions, such as the Canary Islands and Catalonia, use other e-invoicing approaches, and government buyers have not connected to FACe.

Furthermore, the Spanish government has set sights on introducing mandatory B2B e-invoicing with the “Crea y Crece” law, with the CTC exact model and implementation timelines still being investigated.  

While there are no exact specifications for countrywide business e-invoicing obligation yet, the municipalities in the Basque Country are rolling out their own tax reporting system TicketBAI for B2B and B2C transactions, based on a real-time reporting CTC approach.

Spain has also introduced a system similar to TicketBAI all over Spain since 1 July 2025 (except in the Basque country) called Verifactu. This real-time reporting CTC model is mandatory for every invoice issued by established taxpayers with a turnover below EUR 6 million (not in the scope of SII). This means that B2B, B2G, and B2C invoices, including export invoices, must be reported to AEAT (Spanish Tax Authority).

With such regional and industrial disharmony, Spain is a country to keep a close eye on in the coming years.

Türkiye is a country with a fairly complex but mature CTC environment. They kicked off their journey into mandatory e-invoicing back in 2014, and since then, they have continued to extend the scope of taxpayers (by revenue) or industries that have to exchange and process invoices electronically.

For those operating in Türkiye, it’s important to keep in mind that requirements will differ depending on whether you are handling basic or commercial B2B invoices, B2G invoices or B2C transactions.