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    • 01
    Dec

    EU E-invoicing and real time reporting changes in a glance


    Poland

     

    Following the European tendency of extending the already existing e-invoicing mandate, on the 1st of September 2025 Poland published in its Journal of Acts the amendments to the existing e-invoicing regulations.

     

    According to the new rules, the currently voluntary use of structured e-invoices for B2B transactions via the Krajowy System e-Faktur (KSeF) will become mandatory:

     

    • from 1 February 2026 for large taxpayers whose 2024 sales exceeded PLN 200m (circa GBP 41m);
    • from 1 April 2026 for the remaining taxpayers; and
    • additionally, until 31 December 2026, it will be still possible to issue invoices outside of KSeF (paper or electronic), if the total monthly value of sales on such invoices will not exceed PLN 10k.

    Foreign companies  – even if they happen to be VAT registered in Poland – will not be obliged to issue their invoices via the Polish KSeF system so long as:

     

    • they are not established in Poland and they do not have a fixed established in Poland; or
    • they are not established in Poland but they have a fixed establishment in Poland, which (the Polish fixed establishment) however does not participate/intervene in the supply of goods or services for which an invoice is to be raised.

    Since non-resident in Poland companies will not have an obligation to use the Polish KSeF system, the legislation stipulates that structed invoices issued by Polish-based supplier via KSeF should be made available to non-resident in Poland business customers in a manner agreed upon with them (e.g. via PDF, paper invoice).

     

    In order to help businesses, a free KSeF e-invoicing software has been made available on 3rd November 2025 and can be accessed here.

     

    Greece

     

    Greece has decided to introduce B2B e-invoicing in 2026 under a phased approach.

     

    1. The new mandate will come in to force on 2nd February 2026 and will apply to businesses that are either established in Greece or have a fixed establishment in the country with a turnover exceeding EUR 1 million.
    2. In the second phase, all remaining tax payers will need to comply with the e-invoicing requirements starting from 1 October 2026.

    Tax payers will be required to either use a certified e-invoicing provider or free tools provided by the Greek authorities.

     

    Croatia

     

    From 1 January 2026 Croatia will expand its e-invoicing requirements (currently in place for transactions with public entities) to include B2B transactions between resident Croatian businesses.

     

    Another expansion of the e-invoicing requirement is expected in 2027, although it is not clear if this will include non-resident businesses as well. There is also ambiguity as to whether foreign businesses with a fixed establishment in Croatia should comply with e-invoicing requirements from 1 January 2026.

     

    Belgium

     

    B2B invoicing will be required from 1 January 2026 for all invoices issued by Belgian established and VAT registered businesses or foreign entities with a fixed establishment in the country.

     

    Latvia

     

    Latvian has decided to delay the introduction of the mandatory B2B e-invoicing requirement that was meant to start from 1st January 2026. The new proposed date is 1 January 2028.

     

    Further information on the technical requirements are still expected.

     

    Portugal

     

    Portugal has not introduced e-invoicing in a format similar to that used in other countries. However, as of 1 January 2026 it was intending to require invoices to be issued with a qualified electronic signature.

     

    This requirement has been postponed until 1 January 2027 at the moment.


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