The Future of E-Invoicing: Answers to Your Questions
Interest in e-invoicing is growing fast—and so are the questions. During our recent webinar, “The Future of E-Invoicing: Key Insights from Europe and Beyond,” we received more questions than we could answer live. This follow-up article brings together the most pressing ones. Whether you're dealing with new mandates or planning ahead, these insights will help you navigate all the upcoming changes.
If an EU Member State chooses to implement real-time reporting, should it align with DRR? What are the consequences for that particular Member State?
Each Member State is free to develop its own reporting protocols and technical specifications at the national level. However, these must comply with the ViDA framework—for example, by adhering to the CEN standard rather than using entirely independent formats, such as Poland’s KSeF XML.
In Poland, a new reporting requirement will take effect in 2026: JPK CIT (Book) reporting. Is this applicable in other countries as well?
The JPK CIT (Book) reporting requirement is specific to Poland and does not apply in other countries. While some EU Member States have adopted SAF-T-based reporting obligations, these are generally separate from e-invoicing mandates.
Which countries have clearly defined regulations for foreign-established companies? Many mandates don’t specify if they fall under the scope.
The trend is that mandates usually define who the subject is and clarify the treatment of cross-border transactions. Foreign-established companies are either explicitly exempt (e.g. Belgium) or indirectly included in the scope through reporting obligations imposed on the local counterparty (e.g. Poland, France, Malaysia).
We are partners with a PEPPOL-certified company in the Netherlands. Can we use the same platform for e-invoicing in the UAE?
The UAE is indeed introducing an e-invoicing system based on the PEPPOL infrastructure. However, the Emirati Ministry of Finance has decided to introduce additional requirements for invoicing intermediaries wishing to offer their services in the UAE. Invoicing service providers must undergo an extensive accreditation process to become an Accredited Service Provider (ASP). Therefore, it is crucial to ensure that your provider has completed the necessary steps to obtain ASP status.
How does Belgium handle transactions with non-VAT-registered parties? For example, an individual with rental income?
The Belgian system primarily focuses on B2B transactions between VAT-registered entities, so transactions involving non-VAT-registered parties (B2C, such as private landlords) are excluded. However, B2C transactions may be added to the scope in the future.
If there are local standard structures and different standards between different EU Member States, is it possible to align transactions in the case of B2B transactions? For example, a multi-country, multi-company corporation looking for a common solution?
In general, yes—it is possible to align B2B transactions across multiple countries and companies using a common solution. However, this is not always straightforward due to differences in local standards and formats between Member States.
One of the key goals of the ViDA reform is to address this issue by introducing a common EU-wide standard for e-reporting and e-invoicing—the so-called CEN Norm. While formats may still vary slightly from country to country, this harmonization aims to make cross-border compliance much easier for multinational businesses. Countries with non-CEN-compliant formats will need to adapt by 2035.
From a functional perspective, is there a significant difference between EDI and GS1 standard messaging?
The CEN formats must follow specific validation rules and include a set of mandatory or conditionally mandatory fields. An update to the CEN standard is planned to allow the use of EDIFACT syntax in a way that remains compliant with the CEN norm, which is expected to be published during the summer.
Who bears the extra cost for PDP assistance?
The extra cost of PDP assistance is generally expected to be borne by the taxable person (i.e., the business using the PDP). Since PDPs are private service providers facilitating structured invoice transmission and reporting to tax authorities, they are not free. Businesses will likely incur costs through subscriptions, per-transaction fees, or integration services. The idea of offering a state-run alternative was considered but ultimately dropped by the authorities.
Are there e-invoicing systems capable of handling multi-currency transactions?
It depends on the specific e-invoicing system. In general, most systems can handle multi-currency transactions. For example, the Comarch e-Invoicing Platform supports multi-currency transactions, enabling businesses to manage cross-border transactions more efficiently.
Is mandatory e-invoicing in Poland going to be delayed?
The bodies responsible for developing and maintaining the KSeF system are adamant about keeping the February & April 2026 deadline. A recent announcement (13.04.) confirms the timeline. During some business requirements government added some exclusive stage for “digitally excluded” taxpayers, with a single transaction up to 450 PLN (approx. 105 EUR) for an invoice and up to 10,000 PLN (approx. 2,350 EUR) per month for a total sales value which will affect from first of January 2027 as mandatory for all.
Will Poland be obliged to change their structure to the EN16931 standard?
Yes, by 2035, a state-run alternative will need to be introduced, similar to the handling of B2G invoices. However, the details of the Polish authorities' approach in this regard are not yet known.
Is mandatory e-invoicing in the UAE going to be delayed?
We are not aware of any plans for a delay at this time. The development and accreditation processes appear to be proceeding in a relatively timely manner.
Any news on UK plans for e-invoicing?
Comarch is actively participating in the ongoing public consultations with the government. At this point, the authorities are determining which invoicing model will be best suited to the UK’s conditions.
It was indicated that an entity registered for VAT in Belgium but without a permanent establishment (PE) is not required to use e-invoicing. Does this mean they are not required to meet the January 2026 implementation deadline, or is there a later deadline for compliance?
Under the current regulations, foreign businesses that are VAT-registered in Belgium but do not have a permanent establishment (PE) in the country are exempt from the mandatory B2B e-invoicing obligation starting January 1, 2026. This means they do not need to comply with the 2026 implementation deadline. The exemption is explicitly confirmed by the Belgian Federal Public Service Finance.
In the UAE, what change management steps should be taken to onboard suppliers, especially those still using manual invoices or PDFs?
In the UAE, onboarding suppliers to PEPPOL is primarily about raising awareness and helping them understand the regulatory requirements to adopt structured e-invoicing. Accredited providers play a key role in this process by offering user-friendly tools and support to make the transition as smooth as possible.
What are the compliance considerations in the UAE for companies operating across mainland and Free Zone entities, especially when dealing with intercompany and cross-border invoice flows?
The exact scope of the mandate is expected to be defined in the forthcoming regulation. In other words, this question cannot yet be answered with certainty.
In Belgium, what about self-billing invoices? Will they be possible through PEPPOL?
Yes. Self-billing is an important aspect of commercial transactions and will be supported through the mandated PEPPOL channel.
So, no penalties will be imposed in Belgium for non-compliance?
No—penalties may be imposed in cases of non-compliance.
So, what is the future of e-invoicing?
The future of e-invoicing might seem complicated—but at its core, it’s simple: digital is the direction everyone is moving in, and mandatory e-invoicing is only a matter of time.
Keeping up with changing requirements across countries and regions can be challenging, but that’s exactly where the Comarch e-Invoicing solution comes in. It adapts to local regulations as they evolve, so your business stays compliant without the stress. Wherever you operate, we’ve got compliance covered.
