The rise of e-invoicing CTC models across the world

September 26 2023

Written by: The Regulatory Affairs team

What are continuous transaction controls for e-invoicing? Find out about CTC models and solutions for keeping up with developments.

What are continuous transaction controls (CTC) for e-invoicing and why are governments turning to them to strengthen their economies? Find out about CTC models being adopted around the world and solutions for keeping up with developments in your markets.

Why governments are choosing continuous transaction controls

Not so long ago, tax authorities began realizing they were losing tax money by using paper invoices as the principal means for recording and reporting business transactions. Since then, governments have started to take action against tax evasion in new ways.

This blog will not to talk about the benefits of e-invoicing or business automation, rather define and describe different models and requirements that governments implement to reduce tax evasion. Namely, you’ll discover more about continuous transactions controls, or CTC models. 

Go straight to the region you're interested in to read more about their local e-invoice and CTC models or continue reading to learn about the different models.

Middle East

What are continuous transaction controls (CTC)?

Continuous transaction controls (CTC) enable law enforcement agencies, such as tax administrations, to collect data on business activity in their countries. Unlike traditional invoice reporting, data is obtained directly from business transaction processes or data management systems in real time or near-real time.

CTC addresses the inefficiencies that have always characterized the use of retroactive audits, wherein auditors obtain information on transactions long after their conclusion. In traditional audits, they must also rely on data stored by the very businesses they seek to audit.Continuous transaction controls remove dependency on historical evidence ledgers by making it possible for tax administrations to gather relevant information in the form of a dynamic business transaction ledger.

While some countries do still use post-audit models, most have begun to adopt various CTC models. Although not a rule, geographic location can affect market patterns in CTC models from region to region. 

Service providers can agree amongst themselves which formats to exchange, resulting in open networks with many interoperable formats and service providers.


Clearance model

Back in 2002, we saw countries like Mexico and Chile start implementing certain requirements for taxpayers. Businesses had to “clear” or “authorize” invoices via tax authority platforms before they could send them to the end recipient (buyer). This CTC model rapidly gained traction, with most Latin American countries deciding to adopt it. However, each country has implemented its own flavour of this CTC model.

Some countries like Mexico, Guatemala and Panama have delegated invoice clearance to Accredited PAC Service Providers (Sp. Proveedor Autorizado de Certificación) instead of local tax authorities.

Pre-clearance or hard clearance models require invoices to be cleared through local government agencies before sending them to the buyer. Other countries such as Chile and Peru have gone with post-clearance or soft clearance models. These allow taxpayers to distribute tax invoices to the buyer before sending them to the tax authority for clearance shortly afterwards.

The clearance model has been expanding to other countries such as India, Saudi Arabia and some countries in southeast Asia.


Also called a 4-corner model, the main particularity of interoperability is that taxpayers use a service provider to exchange e-invoices. Moreover, service providers can agree amongst themselves which formats to exchange, resulting in open networks with many interoperable formats and service providers.

Interoperability is not considered a CTC model because the tax invoice audit happens months or even years after transactions occur. The main goal of the interoperability model is to facilitate business automation and digitalization.

Peppol and Peppol CTC

Peppol is a network that allows the electronic exchange of various documents, including e-invoices. It requires taxpayers to use services of a Peppol Service Provider, or Peppol Access Point, to exchange documents within the Peppol network (a 4-corner model). Access Points are service providers that can generate, send and process the Peppol BIS format, based on UBL 2.1 or CII.

The main difference between Peppol and the interoperability model is that the exchange mechanism is regulated by Peppol, so service providers can only exchange documents in the Peppol BIS format. Even though invoice exchange via Peppol is mandatory in some countries, (e.g., Sweden, Finland, Norway) it is not considered a CTC model because there are no tax authority controls involved.

Peppol CTC is the upgraded version of the current Peppol 4-corner model. In this CTC model, Peppol Access Points report transaction data to tax authorities or via official platforms in real time. This is a great model to allow both automation for businesses and greater control over the economy for tax authorities.


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Centralized model

Since the release of the EU Procurement Directive obliging public entities to accept e-invoices, many European countries have implemented new requirements. Mandated e-invoicing from suppliers to government entities (B2G) is becoming common ground across the EU.

Belgium, France, Italy, Portugal, and Spain are just a few markets that have already established infrastructures for receiving invoices on behalf of public buyers. Some countries have selected Peppol as the mandatory exchange mechanism within the centralized model. In these cases, the mandatory platform in the country receives Peppol invoices on behalf of every public entity.

In 2018, Italy went even further and obtained an EU Commission derogation to mandate e-invoicing in the business sector. Every business in Italy is now required to send FatturaPA e-invoices to SDI for the latter to deliver the invoice to the buyer. This led to a successful reduction of tax evasion and more opportunities to strengthen the economy, inspiring other European countries to implement similar models for the same outcome.

Now, Poland is planning to follow suit and adopt this model on a countrywide level starting in 2023.

Real-time invoice reporting model (RTIR)

RTIR is a model established in Hungary and South Korea for which there are no regulations regarding invoice exchange. Still, the supplier must report a subset of the invoice to their tax authority in real time after sending it to the buyer. The e-invoice must be in the mandatory format and include specified data such as document type, name and VAT number of trading parties and VAT amounts.

If you do business in markets that have already adopted continuous transaction controls, it’s important to note that not all CTC compliance solutions are the same.


Policy frameworks around electronic invoicing and CTC are being defined all over the world, so now let’s take a closer look at different regions. 


Latin America

Tax evasion has always been a hot topic in the region. Looking into the requirements, we can see that most of the countries in the region have introduced CTC models, making e-invoicing mandatory for most of the taxpayers. The continuous transaction control approach in those countries has a common denominator, as they follow the Clearance model.

In this model, taxpayers are required to send an invoice (or other transaction documents, such as invoice response, dispatch advise, payment receipt) in a structured format and digitally signed to the tax administration (TA) platform for invoice fiscal validation (clearance). Only e-invoices cleared with the TA obtain the legal validity and can be used between the trading parties.

Furthermore, Clearance model has additional flavours we’re reviewing in greater detail below.


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. 

Delegated Clearance

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.

Business automation

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.

North America

Moving to this region, neither Canada nor USA have not implemented a CTC model yet. They have Post-Audit, where tax-relevant documents may be audited by tax authorities months or years after the transactions have occurred. As opposed to Latin America, e-invoicing in these two jurisdictions is driven by businesses that have automation, analytics and cost reduction as their focus areas.

With that said, there is a mainly private driven, countrywide project in the USA to create homogeneous specifications that would allow automation of the Order to Cash (O2C) and Purchase to Pay (P2P) processes – BPC E-Invoice Exchange Market Pilot. After several years of designing and specifications drafting, BPC (Business Payments Coalition) has now entered into an active testing phase with several large corporates participating, advocating for a wider adoption of this standard. One will as well find many similarities between BPC pilot and Peppol

While we’re not expecting a specific mandate, we foresee a significant voluntary uptake of BPC specifications in the US. Companies can still enroll in the pilot.

Canada is closely monitoring what is being developed in the US, being a member of Peppol at the same time. If Canada were to adopt countrywide e-invoicing or continuous transaction controls, it would rather be following Peppol or BPC standards and specifications, as both frameworks are much more business- and automation-friendly than the models adopted by the Latin American governments. 

Middle East

In recent years, a lot has happened in terms of digitalization in some of GCC countries, especially after the introduction of VAT in many parts of the region. Saudi Arabia was the first nation in the GCC to officially announce countrywide e-invoicing regulations. The implementation began on 4 December 2021 with the so-called ‘Generation Phase’ and will continue through 2023 during the ‘Integration Phase’. All sales transactions carried out by resident VAT registered taxpayers will be obliged to issue an electronic invoice. This is expected to be a massive challenge for businesses, as they will have to upgrade their ERP/billing systems, onboard their employees, and stay compliant with the rapidly changing e-invoicing developments.

Other countries in the region are not lagging far behind. Oman, which released a tender for an e-invoicing Project in The Sultanate in the last couple of months, is looking into a potential design for a CTC model.

This May, the National Bureau for Revenue (NBR) in Bahrain launched a digital study survey about invoicing. The questionnaire aims to assess taxpayers’ readiness for the potential introduction of an e-invoicing regime in the country. 

In the United Arab Emirates and Qatar, the tax authorities have been analyzing and exploring various continuous transaction controls models. However, Kuwait has not publicly announced any CTC plans, nor has it implemented the VAT system, though this is expected in 2023-2024. 

Developments in Egypt, Israel and Jordan

Egypt has been adopting a robust strategy and strong course of action for its digital transformation plans with several initiatives and changes to boost an entirely digital and data-driven ecosystem. The country was one of the early adopters of CTC models in the region, choosing to adopt the clearance model, similar to KSA, where tax invoices need to be cleared and approved by the mandatory infrastructure. Since 2020, the Egyptian Tax Authority (ETA) has been gradually rolling out a compulsory e-invoicing system to new taxpayer categories. According to the timelines anticipated by the Ministry of Finance, all tax invoices issued in Egypt should follow the e-invoicing mandate by 2023-2024. 

As a complement to the current e-invoicing system and the national plans to curb tax evasion, Egypt introduced the ‘electronic receipt’ system, expanding the mandate scope to B2C transactions. The e-receipt system will allow the tax authority to monitor B2C transactions in real-time through an integration with the point-of-sale devices or ERP systems of the retail traders. The system adoption has been already rolled-out among certain taxpayers and is expected to be fully implemented in 2024.

Moreover, Egypt is proceeding with its digital transformation plans to go beyond invoicing. In 2021, customs practices were also going digital with the Advance Cargo Information (ACI), where shipment data needed to be submitted electronically to the Egyptian Customs Authority 48 hours prior to the shipment’s arrival.

Jordan and Israel have announced plans towards shifting to CTC model, however, with no clear timelines on the implementation roll-out. Earlier in 2020, Israel had announced its intention to introduce a CTC model in the country to fight tax evasion. The authority planned to adopt a clearance model for invoices exceeding a specific value. Further details of the proposed system are yet to be published. 

The Ministry of Digital Economy and Entrepreneurship (MODEE) in Jordan has also launched two different RFP processes for procuring a central e-invoicing platform. So far, no other specific details are available on the CTC status developments in the country.

All in all, the Middle East region is in a position to fully embrace the disruptive potentials of digital transformation in the tax controls field. Saudi Arabia is not the first country and won’t be the last to implement continuous transaction controls in the Middle East and North Africa, as other Gulf nations also consider introducing a mandate.


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E-invoicing and CTC are still in their very early stages in African nations. Simultaneously, there are no standardized electronic invoicing approaches in Africa's many markets.

The order-to-cash and purchase-to-pay processes in the African region are heavily paper-based. The most common method to exchange invoices between businesses continues to be paper. The extent of utilising electronic means to issue invoices begins and ends with the use of PDF documents. While business automation does not seem to be a priority for many African governments, particular requirements still exist for VAT information transmission to Tax Authorities.

The most popular CTC approach in African jurisdictions seems to be fiscalization. These processes require distinctive hardware devices (Electronic Fiscal devices or EFD) that can report and store VAT data sent to the government. This approach, as well, has been widely adopted with success in several European countries for B2C point-of-sale supplies.

There are still many countries in Africa with no explicit e-invoicing requirements (what would be identified as Post-Audit models), some of which do not allow electronic invoicing at all, equating to the use of paper-based invoicing exclusively. This article presents an overview of select African nations that have implemented e-invoicing and CTC frameworks.

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.

As governments are aware of how powerful the tool of e-invoicing is when it comes to combating tax evasion, it is likely that more countries in Africa will adopt e-invoicing in the coming years.


Northern Europe

The countries of Northern Europe have long been proponents of digitalization and automatization when it comes to business documents and processes. The widespread adoption of Peppol has laid the foundation for new developments and initiatives.  

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

As to the Baltics, Estonia, Latvia and Lithuania are developing and rolling out e-invoicing initiatives within their respective borders. 

The Accounting Act Amendment Act 795 SE made Estonia another European country to go beyond Directive 2014/55/EU requirements and extend the B2G e-invoicing mandate to the suppliers' side.  

As of July 2019, all invoices to the public sector can only be sent as e-invoices compatible with the European Norm. There is no specific mandatory infrastructure for e-invoicing in the country, i.e., contracting authorities and private businesses can contract an e-invoicing service provider. 

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. 

Eastern Europe

The jurisdictions within Eastern Europe seem to highly favor the centralized model, establishing a mandatory infrastructure for issuing and receiving invoices. A few others are utilizing real-time invoice reporting (RTIR) and Peppol. Some also follow the fiscalization approach towards B2C transactions, where special hardware devices must be installed, storing and reporting the data to the government. 

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 centered around the KSeF platform beginning January 2024. Since January 2022, the platform has been available for use voluntarily, but its adoption is currently not widely practiced. 

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. 

To further apply controls around these goods, the RO e-transport system has been introduced in parallel. It allows monitoring of high-risk fiscal goods transportation and requires documentation with a unique ITU code to accompany all such goods transported. While this has been mandatory since July, penalties for not complying with these requirements have been deferred until January 2023. 

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. 

It is planned to extend the mandate for issuing invoices via the SEF infrastructure to the private sector, beginning January 2023. This incorporates another distinctive measure regarding invoice responses in Serbia. 

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 the prototype of its IS EFA infrastructure 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 either 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. 

Southern Europe

Looking at this region, we can see a great variety of implemented or planned CTC models. Italy and Türkiye have adopted countrywide centralized exchange models, Basque Country in Spain introduced a real-time invoice reporting scheme and Malta with Cyprus are embracing the Peppol approach. Greece, facing an accounting data reporting obligation, plans to implement e-invoicing in the public sector via Peppol.

In its efforts 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. 

Furthermore, 1 July 2022 was the date when 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. 

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

In Spain, for e-invoicing in the public sector (B2G), the most commonly used platform for exchanging invoices is the central FACe platform, utilising 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 invoice reporting CTC approach. 

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

Portugal has a mixture of accounting SAF-T reporting and e-invoicing requirements in place. B2G e-invoicing in the country 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. 

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

In Cyprus, since 2019, suppliers to its 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 for complying 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. 

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. 

Comply with continuous transaction control requirements

If you do business in markets that have already adopted continuous transaction controls, it’s important to note that not all CTC compliance solutions are the same. Researching the options available for your key markets will ensure you find the right solution for your business. For those who have not yet encountered CTC, it’s never too early to investigate solutions that can help you meet future regulations. 

Pagero’s CTC experts are dedicated to providing the most recent and relevant updates for as many markets as possible. Get in touch with us to learn more about CTC models and solutions that can help your business stay compliant.

This text was originally published 1 April  2022 and last updated 19 September 2023. 


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