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Albania E-invoicing

Albania introduced a comprehensive fiscalisation model known as “Audit System” or “e-Fiskal” (fizkalizimi), a mandatory, real-time e-invoicing system in phases in 2021.

This system requires B2G, B2B and B2C transactions to be submitted through Albania’s Central Information System (CIS) platform, which is regulated by the General Directorate of Taxes (GDT).

This system seeks to improve efficiency, modernise tax collection, and combat fraud while aligning with EU standards.

This page provides an ideal overview of e-invoicing requirements. Bookmark it to stay ahead of regulatory changes.

B2B e-invoicing in Albania

As of 2018, all VAT-registered businesses in this country are required to issue e-invoices via the e-Fiskal system.

In 2021, the system was expanded, meaning that all e-invoices must now be transmitted in real-time to the Central Information System (CIS), a centralised electronic invoicing and fiscalization platform in Albania managed by the General Directorate of Taxes (DPT).

B2G e-invoicing in Albania

Similar to B2B transactions, all businesses in Albania must issue e-invoices in real-time when processing or conducting transactions with public authorities and government entities. These e-invoices must be submitted to CIS in real-time.

The use of Peppol in Albania

While Albania e-invoicing is mandatory with its own fiscalistion model, it is also integrated within the Peppol network—aligned with EU standards and processes.

Albanian businesses can use Peppol Access Points to exchange e-invoices with international companies, governments and customers in other Peppol-connected countries and territories. Albanian businesses can use Peppol Access Points to exchange e-invoices with international companies, governments and customers in other Peppol-connected countries and territories.

Peppol is an international framework that facilitates cross-border and intergovernmental trade.

Learn more about Peppol e-invoicing.

E-invoicing requirements

Albania e-invoicing follows a structure that ensures compliance with CIS and GDT.

All companies and businesses in Albania are required by law to use certified software to prepare and issue e-invoices. Furthermore, all e-invoices must be submitted to CIS, which is maintained by the National Agency for Information Society (AKSHI).

The CIS system accepts formats such as UN/CEFACT Cross-Industry Invoice (XML Schema 16B) and UBL 2.1 (ISO/IEC 19845:2015). E-invoices must also be stored for a minimum of five years as part of the archiving obligations.

The CIS portal is also managed by the General Directorate for Tax (DPT), which is responsible for verification and assigning unique codes known as NIVF (Invoice Unique Verification Number). A PDF invoice is then issued with a QR code of the NIVF, and can then be saved, downloaded or printed via the CIS portal.

Timeline of e-invoicing adoption

Discover the key dates in Albania’s mandatory e-invoicing journey:

  • September 2020: VAT-registered businesses are required to submit e-invoices via the e-Fiskal system if their annual turnover exceeds 8 million Lek
  • January 2021: Mandatory e-invoicing for B2G transactions between taxpayers and public administrations comes into effect
  • July 2021: Albania makes e-invoicing for cashless transactions between businesses (B2B) mandatory
  • September 2021: Albania makes e-invoicing for cashless business-to-customer (B2C) transactions mandatory

Setting up e-invoicing adoption with Sovos

E-invoicing in Albania has quickly evolved since its first regulation in 2018, culminating in the mandates introduced in 2021.

International e-invoicing compliance can be complex, as mandates can happen frequently and without notice. Sovos can help.

Contact us to learn how to free yourself up by choosing a compliance partner who can handle tax and e-invoicing for you, both now and as changes happen.

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FAQ

Albania’s e-invoicing is mandatory for B2G, B2B and B2C cashless transactions as of 2021, as part of the e-Fiskal or Audit System. All e-invoices must be transmitted in real-time to the Central Information System (CIS), a centralised electronic invoicing and fiscalisation platform of Albania.

There are specific exemptions from Albanian e-invoicing requirements, including:

  • Agricultural producers
  • Public transport ticket sales
  • Individuals registered as ambulatory trailers with no fixed premises
  • VAT-exempt supplies such as medical care items
  • Services and goods related to education

The accepted formats for Albania e-invoicing are UN/CEFACT Cross-Industry Invoice (XML Schema 16B) and UBL 2.1 (ISO/IEC 19845:2015), both of which are XML formats widely used in the EU for e-invoicing purposes.

In this instalment of our VAT Snapshot series, our experts will chart the latest government publications, timelines and scope changes, keeping you up to speed on what’s confirmed, what’s proposed, and where guidance is evolving in Poland, France, Greece, UK, UAE and Spain.

Event

19th Group Indirect Tax Exchange

Date

March 11-12, 2026

Venue

Marriott Hotel Leidseplein, Stadhouderskade 12, 1054 ES Amsterdam, Netherlands

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Event summary

Join Sovos at the 19th Group Indirect Tax Exchange to gain expert insights into the industry adoption of e-invoicing and the challenges of e-reporting. We will also be hosting a dedicated session with Kelly Muniz, Senior Regulatory Counsel, Sovos, on Keeping Up with Legislative Changes and Shifting Local Reporting Requirements, covering:

  • Dealing with increased demand on transactional and master data in near real time
  • Managing localised non-standardised e-invoicing requirements

Stay ahead of the latest e-invoicing conversations and make the most of this leading conference and networking event. Reserve your ticket today!.

To review the agenda and registration details click here

Meeting Venue

Marriott Hotel Leidseplein, Stadhouderskade 12, 1054 ES Amsterdam, Netherlands

European manufacturers and supply chain teams are facing growing VAT complexity as real time reporting expands and scrutiny of cross-border movements increases. In this webinar we’ll simplify the latest rules impacting operational flows from import VAT and call-off stock to inventory management and reverse charge mechanisms. Our expert will share what these changes mean in practice and how to adapt processes to stay compliant and efficient across multiple jurisdictions. Join us to learn the key requirements shaping VAT compliance today and how to build a resilient, future-ready framework for your organisation.

Brazil’s tax system is undergoing a historic transformation, and businesses need to be ready. In this webinar, we’ll break down the key elements of the new Tax Reform and what they mean for organizations across different sectors.

Knowing how to calculate IPT and the corresponding parafiscal surcharges (hereinafter collectively referred to as IPT) is an art. Rules differ by national jurisdiction so ensuring compliance with IPT obligations is not just a regulatory requirement for insurers – it’s essential to avoid financial penalties and reputational risk.

That’s why it’s critical to have a clear understanding of which tax rules apply to the insurance products underwritten, and to stay informed about the specific requirements in each relevant jurisdiction.

This blog will provide an overview of IPT calculations, explaining how to calculate IPT, the different methods of calculation, IPT rates and exemptions, and more. If you’ve found yourself asking, “How is IPT calculated?” then read on, because this page is for you.

How to Calculate IPT: Two Main Methods

There are two basic methods for calculating the tax on insurance premiums in Europe:

  1. Percentage of the Premium/sum insured
  2. Fixed amounts per policy/insured

These calculation models are just the basics; IPT regulations are built upon these models, adding several specific rules, which can make an IPT calculation fairly complex.

Percentage of Model

For the first calculation method, the Percentage model, one or multiple tax rates apply depending on the risks covered.

For example, businesses in Bulgaria can easily determine the tax amount by multiplying the taxable basis by the country’s 2% tax rate. This rate applies to all classes of businesses. However, in Italy or France, the applicable tax rate depends on the risks covered.

Several IPT calculations are based on this basic rate model but there are some models where the tax rate applies on the sum insured value and not on the premium amount.

Fixed Amount Model

In the second calculation method, the Fixed Amount Model, local regulations determine the tax amount that needs to be multiplied – usually per policy, but sometimes per insured person.

Irish Stamp Duty and Danish Guarantee Fund contribution are examples of this calculation method in practice.

 

Key Variables That Impact IPT Amount Calculation

While many factors can ultimately impact the IPT amount calculation, there are certainly some primary factors that many calculations will need to get right.

 

Step-by-Step Example: How to Calculate IPT

While each IPT calculation will vary based on the factors at play, we can provide a sample calculation to illustrate how the process can work.

Identify Risk Class

The first step is to identify the risk category the policy falls under, as this will dictate the location of risk.

Determine the Location of Risk

Determining the location of the risk(s) will determine the country of which the IPT calculation rules apply. Most European countries include a section in IPT regulations to determine the location of risk, citing the Solvency II EU Directive location of risks (LoR) rules.

Determine the Reporting Currency and the Exchange Rate

The reporting currency is the currency in which the tax should be settled to the local tax office. If the premium amount in the policy is determined in a currency other than the reporting currency, then it is important to use the correct exchange rate. Exchange rate rules are not harmonised in the EU. It can be the national bank average monthly/quarterly rate, or rate on the last day of the reporting period.

Calculate the Taxable Basis

The taxable basis is vital for determining the compliant IPT and parafiscal amounts. Look for the local legislation for the definition of the taxable basis. Taxable basis can be the net premium, the sum insured, the value as per the land registry, or net premium plus fees, commissions or even taxes.

Choose Applicable Rate or Fixed Amount

Knowing the correct tax rate/fixed amount is vital. Search for the local IPT legislation, review the risk covered and determine the correct tax rate.

Apply Any Parafiscal Charges

Depending on the risks covered, some countries also levy parafiscal charges on insurance premiums, impacting the total IPT amount to be paid. France is an example of a country that levies various surcharges on the premium amounts depending on the risk(s) covered.

Search for the Exemptions

It is also vital to determine which insurance premiums fall into an exempt class. Usually, risks covering international or exports class of businesses are exempt, such as export credit, or international goods in transit. Some of the EU countries exempt sickness policies too.

Verify Rounding Rules

Lastly, it is essential to follow rounding rules when calculating the total IPT amount to be settled towards the local tax offices, because the settlement of the IPT amount can be rounded. In France, for example, you are required to round to the nearest whole EUR. In Hungary, IPT is declared in thousands HUF.

 

What are some common mistakes in IPT calculations?

With IPT often being complicated to calculate, especially if you don’t know the nuances of the country where the location of risk sits, mistakes can be common.

There are simple mistakes like determining the wrong location of risk or using the incorrect or out-of-date IPT rates (e.g. incorrectly interpreted transitional rules), and misunderstanding exemptions.

More errors come from miscalculating the value of the premium or the sum insured or incorrectly applying surcharges.

 

Rules for IPT amount calculation

There are rules taxpayers must abide by to comply with IPT regulations. Here is a selection of IPT rules for amount calculation.

Here are some examples of these specific rules:

 

Conclusion

As you can tell, IPT calculations can be complex—but they don’t need to be. If you are aware of the common pitfalls and the key considerations in these calculations, you can work out the amount payable with accuracy and confidence.

Knowing the rules and requirements of the country you are operating in is key, from the tax rate to how they require insurers to calculate Insurance Premium Tax. Non-compliance can be costly, both financially and reputationally, so be sure to put your best foot forward by knowing how to calculate IPT correctly.

 

FAQ

What countries use a sliding scale for IPT?

Hungary is the only country that utilises a ‘pure’ sliding scale rate model to calculate its Insurance Premium Tax. The sliding scale model is a method of calculating IPT where the tax rate changes once the insurance premium exceeds a threshold. Malta, on the other hand, applies a mixture of fixed amount and sliding scale model.

Can IPT be refunded if a policy is cancelled?

Yes, there is generally a chance that Insurance Premium Tax (IPT) can be refunded on a cancelled policy. Refunds are done pro rata on policies that have been active for longer than the mandatory 14-day cooling-off period. There are exemptions from this general rule, with the best example being Italy.

Does IPT apply to reinsurance?

While countries have their own nuances regarding IPT, the general rule of thumb in countries like the UK is that Insurance Premium Tax does not apply to reinsurance.

This is because countries like the UK want to avoid double taxation, as the original direct insurance policy is already subject to IPT.

Is IPT calculation harmonised in the EU?

No, IPT is not harmonised in the EU. Although the Solvency II EU directive provides some basic rules which are mandatory for EU countries to follow, the specifics of the IPT calculation, such as the rates and taxable basis are not harmonised.

What is the highest and lowest IPT rate in the EU?

Currently, the highest IPT rate in the EU is 30%, applying to certain policies in France. The highest generic IPT rate of 25.5% applies in Finland. The lowest IPT rate, not mentioning the exemptions, is the 1.4% IPT rate applied for certain specific policies in Belgium. The lowest generic IPT rate is 2% in Bulgaria.

How do you calculate IPT?

Put simply, Insurance Premium Tax (IPT) is calculated as a percentage of the insurance premium. The percentage, also known as the IPT rate, depends on the type of insurance policy and the rates of the country to which the policy applies.

To calculate the IPT amount, you multiply the insurance premium by the appropriate tax rate. The insurer then adds the cost to the figure paid by the policyholder.

This calculation is the simplest, but it’s worth mentioning that there are various calculation methods e.g. fixed amount method, sliding scale methods.

What factors influence IPT calculation?

There are various factors that need to be considered to compliantly calculate IPT. These factors include, but are not limited to, location of risk, the risk covered, the exchange rate, the definition of the taxable premium, the IPT and parafiscal tax rates and the exemptions.

European tax authorities are accelerating the move to real-time digital reporting, creating new rules and tighter deadlines for organisations. This session will break down the latest developments in Poland and Bulgaria, including Poland’s draft regulation aligning JPK_VAT with KSeF from February 2026 and Bulgaria’s mandatory SAF-T go-live in January 2026. With clear explanations and a short demo, Sovos’ experts will outline key requirements, practical impacts and how to generate, validate and submit accurate files. Join us to understand how these changes affect your reporting processes and how to prepare for a future-ready compliance strategy.

Monaco E-invoicing

Unlike its geographical neighbour, France, the sovereign city-state of Monaco has not introduced any regulation for the mandatory use of electronic invoices.

The Principality currently follows a voluntary post-audit model, where e-invoices are allowed but not required.

Having chosen to adopt the principles of Council Directive 2010/45/EU through Ordinance 4.199 of February 20, 2013, which governs electronic invoicing between taxable persons, various methods are allowed for ensuring invoice authenticity and integrity.

Considering its status as a nation with less stringent tax rules than most, many anticipate that the country will continue not to require the use of e-invoices for its taxpayers. It’s not impossible, however.

Monaco e-invoicing requirements are relaxed—not requiring the transmission or secure signing of such electronic documents, for example—but there is a rule for voluntary e-invoices to be securely archived for 10 years.

This page provides all the necessary information for e-invoicing in Monaco.

VAT territory status

Although Monaco is a sovereign state, it is considered part of the French VAT territory for customs and VAT purposes. As a result, VAT is applied on the same basis and at the same rates as in France, and transactions between entities in both countries are treated as domestic operations for VAT purposes.

However, when it comes to e-invoicing, Monaco is treated as a foreign country. This means that French taxpayers buying from or selling to Monegasque entities must e-report those transactions under France’s upcoming e-invoicing and e-reporting framework, but the e-invoicing requirement itself will not apply to Monaco-based businesses.

It is therefore essential to distinguish Monegasque entities that hold a French SIREN number – the registration number for businesses in France. These entities are considered to be established in France for VAT purposes and will fall within the scope of the French e-invoicing mandate, which begins its phased rollout in September 2026.

B2B e-invoicing in Monaco

B2B e-invoicing in Monaco is voluntary, meaning sellers can issue electronic invoices with the buyer’s approval. Monaco’s Department of Tax Services has yet to announce a concrete implementation schedule for an e-invoicing mandate.

That said, from 1 September 2026, Monegasque entities registered in the companies register, SIREN, that are also registered for VAT in France, will need to comply with the French e-invoicing mandate.

As Monaco is not an EU Member State, it will not be required to follow the upcoming VAT in the Digital Age mandate, which will enforce e-invoicing from 2030 onwards.

B2G e-invoicing in Monaco

B2G e-invoicing is not mandatory in Monaco. If sellers wish to issue e-invoices, they can do so if the buyer has given prior approval.

It is worth noting that France, Monaco’s neighbour, has an e-invoicing mandate in place as of 1 September 2026, which will require Monegasque businesses subject to French VAT to send and receive invoices electronically.

The use of Peppol in Monaco

While e-invoicing is currently voluntary in Monaco, it does leverage the Peppol network in the exchange of e-documents on a voluntary basis.

The country is not an official member of Peppol—a pan-European e-invoicing framework and network for cross-border trade—but it utilises the framework to enable businesses to easily exchange electronic documents like e-invoices with public authorities.

Learn more about Peppol e-invoicing.

Timeline of e-invoicing adoption in Monaco

Find out the key moments in Monaco’s e-invoicing journey so far.

  • 1 September 2026: Taxpaying entities in Monaco that are subject to VAT in France will need to comply with the e-invoicing requirements under the French mandate

Setting up e-invoicing in Monaco with Sovos

Businesses operating in multiple countries, like Monaco, need to be aware of varying e-invoicing requirements. This can be time-consuming, but using a single vendor for your tax and e-invoicing compliance can free you up to concentrate on what matters: growing your business.

Let’s chat.

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FAQ

No, there is not an e-invoicing mandate in Monaco—nor has the nation announced intentions to implement electronic invoices on a compulsory basis. Businesses can voluntarily issue e-invoices if they obtain the buyer’s approval first.

Yes, businesses can issue invoices electronically in Monaco. There is no mandate for the transmission of e-invoices, but sellers can do so voluntarily if the buyer’s consent is obtained.

As a general rule, businesses established in Monaco will not have to issue e-invoices or e-report transactions to the French Tax administration as, for the purposes of the e-invoicing mandate, Monaco will be considered a foreign country.

However, Monaco-based entities who have a SIREN number are considered established and, therefore, under the scope of the e-invoicing mandate.

Montenegro E-invoicing​

Montenegro is in the early stages of its e-invoicing journey.

While the country’s Ministry of Finance signed an agreement with Serbia in 2023 to create a centralised e-invoicing platform—with plans to mandate electronic invoices for both B2B and B2G transactions in the process—these plans have yet to come to fruition.

This page is your ideal overview of Montenegro e-invoicing. Keep up with future mandates and regulatory changes by adding it to your bookmarks.

B2B e-invoicing in Montenegro

Businesses are not mandated to issue electronic invoices to other companies in Montenegro. There are plans for mandatory B2B e-invoicing; however, there is currently no regulatory obligation to implement it.

That said, businesses can voluntarily opt to issue e-invoices to other organisations—but only if they have obtained the buyer’s explicit consent to do so. If businesses choose to issue e-invoices, the issuer must ensure the integrity of the content and the authenticity of the origin by using, for example, an electronic signature.

Electronic fiscalisation is mandated for all businesses in Montenegro, requiring businesses to automatically report invoice data to the nation’s tax administration through certified software. However, there is no indication of when electronic invoicing will also become a requirement.

B2G e-invoicing in Montenegro​

As with B2B e-invoicing, Montenegro has yet to mandate the issuance of electronic invoices for business-to-government (B2G) transactions. It signed an agreement with Serbia in 2023 that planned to introduce a mandate, but such a regulation has yet to come into effect.

A B2G e-invoicing mandate is anticipated to come before a B2B mandate, but the country’s Ministry of Finance has issued no concrete timeline at the time of publication.

Timeline of e-invoicing adoption in Montenegro

Find out the milestones in Montenegro’s e-invoicing journey.

  • 27 October 2023: The Ministry of Finance for both Montenegro and Serbia signed an agreement to transfer a software license for a centralised e-invoicing platform, with plans to mandate B2B and B2G e-invoicing in the process
  • 1 July 2030: Montenegro aims to become an EU Member State by 2028. If this happens, Montenegrin VAT-registered businesses must comply with VAT in the Digital Age (ViDA) requirements, which include mandatory e-invoicing and digital reporting for Intra-Community B2B transactions

Setting up e-invoicing in Montenegro with Sovos

While Montenegro does not mandate the use of e-invoices, organisations like yours can voluntarily do so. The country does plan on requiring electronic invoicing to be implemented for both B2B and B2G transactions, so it’s important you are prepared for this change.

If you do business in multiple jurisdictions, then you will know that every country is in a different stage of its e-invoicing journey. Staying on top of all these regulatory updates can be time-consuming and complicated, but Sovos can help.

Get in touch to find out more about the peace of mind we can provide where tax and e-invoicing are concerned.

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FAQ

No, there is no mandate for businesses to issue electronic invoices in Montenegro.

Montenegro announced intentions to enable and enforce e-invoicing for both B2B and B2G transactions in October 2023. As part of an agreement with Serbia that would see Montenegro license its e-invoicing platform, the country revealed that it was exploring mandates for the electronic transmission of invoices.

There is currently no public timeline for such obligations to come into effect.

Gwenaëlle Bernier – Partner & Avocate Associée G56, Tax Technology & Transformation at EY

As France’s ambitious e-invoicing mandate approaches, Gwenaëlle Bernier – speaker at the Tax Compliance Summit Sovos Always On: Paris (19 Nov.) – shares expert insights on how digital transformation is reshaping tax compliance and operational performance. This interview dives into the real-world challenges and opportunities facing finance and tax leaders, revealing why the intersection of technology, regulation, and data is the hottest topic in French business today.

 

EY supports many companies as they prepare for France’s e-invoicing mandate — a reform that brings deep regulatory and technological change. In your view, what are the main challenges facing finance and tax departments, and how can they balance compliance with operational performance?

The first challenge is organizational: companies need a truly cross-functional framework that continuously involves the finance and accounting department, the tax department, and IT. Today these three pillars exist but often operate in silos, whereas the reform requires a unified view of accounting, tax, and IT issues, with dedicated time and clear governance. Implementation cannot be entirely “outsourced” to a service provider — some decisions and trade-offs must remain within the company, as they relate directly to its data and processes.

In practice, we first help companies establish this governance framework: clear executive sponsorship, shared accountability, and regular coordination points among teams. In large groups and mid-caps, this is crucial — the scale, diversity of flows, and ERP history make fragmented approaches ineffective. For small businesses, on the other hand, the challenge is simpler and the reform can fit into a broader simplification process supported by accountants or certified platforms.

Finally, companies must build new skills: tax teams need to understand data, while IT must understand tax logic. Anticipating business impacts — data quality, timing, upstream controls, reconciliations — has become essential. Successful projects are those where companies stop opposing “IT project,” “accounting project,” and “tax project,” and instead treat the reform as a single transformation, driven by a mixed, long-term team aligned around common goals.

 

Through your work, have you observed a shift in the digital maturity of French companies regarding taxation? What best practices distinguish those who are succeeding?

It’s important to remember that the e-invoicing reform is, first and foremost, a tax reform — it is written into the French General Tax Code under the VAT chapter. It is therefore part of a broader framework of compliance and tax control, which is often overlooked, though it is key to understanding why data quality is so central to its implementation.

The real shift today is that every tax department is becoming digital. It’s no longer just a few tech-curious tax professionals — it’s a broad transformation. Most tax departments are acquiring new skills, and tax professionals themselves are learning to understand systems, data flows, and formats, and to translate regulatory requirements into technical language. This allows them to apply the rules more intelligently and in closer alignment with business needs.

The best practice is to embrace this evolution toward a “tech-enabled” tax professional. Digital tools allow tax teams to collaborate with the rest of the company through a shared language: data. And this data — long used mainly for financial performance or marketing — has now become a core tool of tax compliance. That’s what makes this reform unique: though rooted in taxation, it impacts the entire company. It forces organizations to question the very nature of their ERP data — whether it’s structured, reliable, and truly usable.

 

The gradual shift toward prefilled VAT returns marks a new stage in digital tax administration. Are companies ready for this reversal — where the administration sends rather than receives declarations? How can they ensure data consistency and reliability in this new model?

The move to prefilled VAT returns will not affect all companies in the same way. For small and medium-sized enterprises, it’s primarily an administrative simplification. They will benefit from support through their accountants or simple tools, sometimes mobile applications offered by certified platforms. For them, prefilled returns will reduce administrative work without significantly changing their organization.

For large companies and mid-caps, however, the impact will be far more structural. Until now, VAT returns have been prepared mainly by accounting teams, with tax departments stepping in only later — during interactions with the tax authorities or audits. Prefilled returns will change that division of labor: tax teams will now need to monitor data continuously, as it will be transmitted to the authorities daily and may prompt immediate follow-up questions.

We are entering an era of reciprocal transparency: companies will reveal their VAT treatment of each transaction in real time, while the administration will send back a synthesized view in the form of a prefilled return. This will inevitably require companies to rethink their internal organization — particularly the split between accounting and tax functions — and to strengthen coordination with IT. It will also demand new skills and heightened vigilance on data quality. The goal will no longer be to produce an accurate return at month-end, but to ensure the reliability of information transmitted day by day. That means better mastering ERP configurations, which in France have often been defined without real tax input. The pace, granularity, and nature of the work will change: companies will need to anticipate, validate upstream, and reconcile accounting and tax data more precisely.

 

Artificial intelligence is increasingly used in compliance and tax management processes. How is this trend taking shape within the French tax administration?

The French tax administration is already equipped with artificial intelligence tools, the most well-known being Galaxie. This data-mining and analytics system, whose early versions date back to 2017, was formally established by decree a few years ago. It now forms the core of the administration’s intelligent data-processing capabilities.

As the reform rolls out and companies begin transmitting their e-invoices and e-reporting data, the administration will have not only the necessary technical infrastructure but also the software capabilities to analyze this information on a massive scale. By 2027, once all businesses are connected, the tax authority will have an almost complete view of France’s economic activity — what each company buys, sells, and trades domestically and abroad.

With Galaxie and this immense volume of data, the State will be able to conduct highly detailed economic and fiscal analyses. It will also transform the way audits are carried out: by the time a tax inspection begins, auditors will already have a detailed profile of the company, its operations, and any anomalies or unusual patterns compared to its sector. This is no longer theoretical — the public administration is ready to use these tools, and their effects will become tangible as the reform is fully implemented.

 

Do you believe AI is already transforming the role of finance and tax departments? Are they becoming, in a sense, key players in the company’s data strategy?

Today, finance and tax departments are still poorly equipped when it comes to AI. We’re at an early, experimental stage. Most companies are only beginning to explore the subject — often through general-purpose tools like office suite copilots — but very rarely with solutions designed specifically for tax or finance functions. True AI tools for compliance, anomaly detection, or tax data analytics are still being built.

There’s also a simple economic reason for this: finance and tax are not the company’s core business. Investment naturally flows to operational functions — those that produce and sell — while support functions come later, which explains the current gap.

However, the e-invoicing reform will accelerate this transition. Once companies are connected to certified platforms and able to exchange structured invoices, the next question will inevitably be: how can we use this data intelligently? That’s where AI will come in — to automate controls, enhance reliability, and anticipate discrepancies. Some platforms already offer advanced data-analysis features powered by AI, but adoption remains limited. Over the next few years, we’ll likely see rapid growth in these applications as tax departments realize the value of the data they now possess.

 

You stand at the intersection of tax and technology. How can we ensure that the growing use of AI in taxation remains ethical, transparent, and trustworthy?

AI is already legally regulated in the French tax sphere. The main framework stems from Article 154 of the 2020 Finance Law. When this law was adopted in December 2019, the Constitutional Council defined the conditions under which the administration could use AI tools, setting out eight criteria to ensure ethical, transparent, and compliant usage — particularly regarding personal data protection. These principles were further clarified by the French Data Protection Authority (CNIL) in its September 2019 report, which remains the reference for AI oversight today.

We therefore already have a clear legal framework: the State has set the guardrails. But risks still exist. With the generalization of e-invoicing, the tax administration will gain access to a vast amount of transactional data between companies. Over time, it could end up knowing an enterprise’s ecosystem better than the company itself — its suppliers, clients, and business relationships.

The challenge, therefore, extends beyond personal data protection to include trade secrecy. This is crucial: authorities must prevent even unintentional disclosure of sensitive business information that could weaken competition or expose strategic details. As long as our economic model is based on fair competition, protecting trade secrets must remain a fundamental safeguard.

 

France has adopted an ambitious, comprehensive model for its e-invoicing reform. How do you explain this leadership, and what does it reveal about France’s approach to digital taxation?

France made a decisive political choice in the summer of 2019: to make e-invoicing a cornerstone of economic modernization and efficiency. This commitment took shape in Article 153 of the 2020 Finance Law, which integrated e-invoicing and e-reporting into the General Tax Code. The decision reflects a longstanding conviction. Studies conducted at the European level as early as 2007 had already highlighted the potential benefits of such reforms in terms of simplification, productivity, and transparency. But France chose an ambitious path — to move forward on a fixed timeline, making the reform mandatory for all actors to accelerate digital transition.

Another reason for France’s leadership is the scope of its model. While most European countries separated the steps — first mandating structured e-invoicing, then, later, real-time reporting — France decided to do both at once. That makes the project more complex but also more complete.

At the same time, the 2020 Finance Law introduced a separate provision authorizing data mining, which led to the creation of the Galaxie system. In other words, France simultaneously launched digitalized exchanges, large-scale data collection, and AI-based analysis capabilities. This strategic decision explains why France now appears to be leading in both digital taxation and economic data governance.

 

As a member of the Global Exchange Network Association (GENA) and a former member of the European Commission’s VAT Expert Group, how do you see France’s position in the discussions around the VAT in the Digital Age (ViDA) project? Could it serve as a reference for other Member States?

France’s influence within the ViDA project will depend largely on how its representatives engage in European discussions. Within the Fiscalis group — which brings together finance ministry representatives from all Member States and the European Commission — much will hinge on France’s ability to defend its approach and share its experience.

In practice, France is already implementing, more than three years ahead of schedule, one of ViDA’s core pillars: the Digital Reporting Requirements. Starting in September 2026, France will effectively apply the same principles set to take effect across the EU in 2030. As a result, when ViDA comes into force, little will actually change for French businesses. Having already gone through this transition, they will likely serve as pilots and references for their European counterparts.

To make this advantage meaningful, France will need to promote both its model and its methodology at the EU level. The country has done extensive work on complex use cases — such as expense notes, multi-vendor invoices, and subcontracting — and on technical standards through AFNOR commissions. These efforts produced a pragmatic, collaborative approach that should be championed in Brussels. If each Member State designs its own rules, the goal of ViDA — harmonization — will be lost. The more aligned the standards, the smoother cross-border exchanges will become, improving both efficiency and competitiveness for European companies.

 

Beyond the current reform, what innovations do you foresee in digital taxation? Does the convergence of technology, compliance, and artificial intelligence signal a new model of tax governance?

We are witnessing a genuine paradigm shift in how the State conducts tax audits — and, consequently, in how companies behave as taxpayers. Until now, France has operated under a retrospective model: companies submitted highly aggregated VAT returns, and audits often took place two or three years later, with inspectors reviewing past decisions and requiring lengthy explanations.

With the combination of e-invoicing, e-reporting, and AI tools like Galaxie, we are entering an era of near real-time tax oversight. The administration will have an immediate view of economic activity and be able to target audits more precisely. This could be a positive evolution if it helps focus efforts on genuine non-compliance while easing the burden on companies acting in good faith.

However, this increased transparency also calls for a change in mindset. Instead of relying solely on ex-post enforcement, the goal could be to establish an ongoing, cooperative dialogue between companies and the tax administration — one in which businesses explain their choices and challenges as they arise. Tax law is rarely black-and-white; it often involves interpretation, especially when business innovation outpaces legislation. The challenge will be to build a relationship of trust, where the State supports companies in applying the rules rather than sanctioning them years later. In essence, this could mean moving from a “rear-view” audit model to a smarter, more collaborative approach that fosters both compliance and economic vitality.

As real-time tax mandates accelerate worldwide, global businesses face growing compliance risks that can halt operations and disrupt ERP transformations. In this session, Brown-Forman’s Director of Enterprise Applications and SAP, Kelly Lewis, joins Vadim Nemtsev, Director of Product Marketing for Indirect Tax at Sovos, to share how the company unified tax compliance within its SAP S/4HANA transformation.

As Insurance Premium Tax (IPT) regulations continue to evolve across Europe, staying compliant is more crucial than ever. This webinar will explore the latest IPT developments impacting insurers, brokers and captives managing cross-border programs. Our specialists will cover Lithuania’s entry into the IPT landscape, Slovakia’s upcoming tax rate increase and key trends shaping the European IPT environment for 2025. Gain practical insights to help your organisation plan ahead, stay compliant and optimise its tax strategy.

Croatia E-invoicing

Croatia is implementing a comprehensive e-invoicing and fiscal reporting system under the Fiscalization 2.0 framework.

This system combines mandatory real-time reporting with e-invoicing for B2B and B2G transactions, aiming to prepare for and align with the requirements of ViDA. This integrated approach requires businesses to exchange electronic invoices and report fiscal data in real time to the Croatian Tax Administration.

This page provides an ideal overview of Croatia e-invoicing, covering the latest regulatory changes and compliance requirements.

B2B e-invoicing in Croatia

Croatia’s e-invoicing mandate operates under the Fiscalization Law (Zakon o fiskalizaciji NN 89/25), which was published in June 2025 and entered into force on 1 September 2025.

This law establishes the “Fiscalization 2.0” framework, which introduces a decentralised mandatory e-invoicing model for domestic B2B and B2G transactions—alongside a continuous transaction control (CTC) real-time reporting system for B2B, B2G and B2C transactions.

Under Croatia’s Fiscalization 2.0 system, VAT-registered businesses must begin mandatory e-invoicing and CTC reporting from 1 January 2026.

Non-VAT registered businesses (small companies, freelancers, certain public bodies) that issue invoices must begin e-invoicing and CTC reporting from 1 January 2027.

CTC e-reporting in Croatia​

Croatia implements a dual electronic reporting system:

  1. CTC e-reporting (Fiscalization) requires real-time reporting of fiscally relevant data from outbound invoices and a 5-day reporting window for inbound invoices.
  • E-reporting of additional events (eReporting, Article 50 of Fiscalization Law) is an additional periodic or real-time reporting of invoice payment information, invoice rejections by the recipients, and transactions where invoices could not be issued because the buyer didn’t register its e-invoice address in the Central DNS-based directory (AMS).

Croatia’s CTC system

Croatia uses a decentralised e-invoice exchange model with CTC e-reporting.

Invoices must be issued electronically in a format that complies with the European Norm. They must be exchanged through Access Points or any other means agreed upon between the parties, e.g. compliant EDI, Peppol, provided they ensure authenticity of origin, content integrity, and readability from issuance until the end of the e-invoice retention period.

CTC reporting and e-invoicing may be outsourced to third-party service providers, referred to as “information intermediaries,” who are listed on the tax administration website.

B2G e-invoicing in Croatia

Since the end of 2018, public sector entities have been required to accept and process e-invoices from suppliers in public procurement. E-invoicing as a whole, i.e. also in the B2G flow, became mandatory in this sector on 1 July 2019.

B2G e-invoicing continues to operate under the existing Law on Electronic Invoicing in Public Procurement (NN 94/18), with FINA’s eRacun remaining the mandatory central platform for public sector transactions.

However, under Croatia’s Fiscalization 2.0 system, B2G transactions now have an additional compliance layer and are now subject to the e-invoice fiscalization process in the form of CTC e-reporting alongside the existing public procurement e-invoicing requirements.

Timeline of e-invoicing adoption in Croatia

Here are the key dates in Croatia’s journey towards mandating electronic invoicing.

  • 1 December 2018: All contracting parties must accept and process e-invoices in public procurement
  • 1 July 2019: E-invoicing becomes mandatory in public procurement
  • 13 June 2025: Croatia approves Fiscalization law (NN 89/25), expanding the legal framework to include mandatory e-invoicing and CTC e-reporting
  • 3 July 2025: Production system available for voluntary testing
  • 1 September 2025: “Fiscalization 2.0” system becomes applicable; start of mandatory testing for technically ready entities
  • 1 January 2026: Mandatory e-invoicing (issuance and receipt) and e-reporting begin for VAT-registered businesses, as part of “Fiscalization 2.0”; mandatory e-invoicing (receipt) begins for non-VAT-registered businesses
  • 1 January 2027: Mandatory e-invoicing (issuance) and e-reporting begin for non-VAT-registered companies, as part of “Fiscalization 2.0”
  • 1 July 2030: Croatian VAT-registered businesses must comply with VAT in the Digital Age (ViDA) requirements, which include mandatory e-invoicing and digital reporting for Intra-Community B2B transactions

Setting up e-invoicing in Croatia with Sovos

Tax and e-invoicing compliance can be particularly time-consuming and complicated when you operate in numerous countries, considering that rules and regulations change often. Having a single partner for compliance wherever you do business saves you time and provides peace of mind.

Sovos can be that partner for you. Get in touch to find out more.

Get in touch with us

FAQ

E-invoicing with CTC reporting becomes mandatory for VAT-registered businesses and non-VAT-registered businesses that receive e-invoices on 1 January 2026, and for non-VAT-registered businesses that issue e-invoices from 1 January 2027 under the Fiscalization 2.0 framework.

Fiscalization 2.0 is Croatia’s comprehensive digital tax system, combining mandatory e-invoicing with Continuous Transaction Controls (CTC). It requires real-time reporting of fiscal data from both issued and received invoices, plus additional e-reporting of events like payments and rejections. The system aims to digitise tax compliance, increase transparency, and reduce administrative burdens.

Croatia implements a combined CTC e-reporting and decentralised e-invoicing system requiring real-time fiscal reporting to tax authorities and exchange of e-invoices via certified service providers. This corner-5 model is similar to other countries that have implemented or are in the process of implementing this CTC model, such as France, Greece and Slovakia and aims to align with ViDA.

Croatia’s system uses components with similar functions to Peppol (Access Points, metadata services, AS4 protocol), however, it operates under its own certification processes and requirements. The Peppol network may be used as an alternative method of exchanging e-invoices, provided that it ensures the integrity and authenticity of the e-invoice.

The Croatian mandate through its Fiscalization 2.0 system directly implements ViDA’s central concept of digital real-time reporting based on e-invoicing. Starting with a national application of a real-time transaction-based e-reporting system, the country is building infrastructure that sets the foundation for the transition to a new reporting system for intra-EU trade in the digital age.

Liechtenstein E-invoicing

While Liechtenstein has not introduced any mandates for electronic invoicing in the country, there are rules to be followed for voluntary e-invoicing.

Liechtenstein is earlier in its journey towards mandatory e-invoicing than many countries. There are no mandates, no official platforms and no national standards.

The only e-invoicing rule pertains to the public authorities’ requirement to receive and process EN 16931-compliant electronic invoices for public procurement contracts exceeding a specific value threshold.

This page provides an ideal overview of Liechtenstein E-invoicing. Bookmark it to stay ahead of regulatory changes.

B2B e-invoicing in Liechtenstein

There is no mandate in Liechtenstein for using electronic invoices regarding business-to-business (B2B) transactions.

A supplier must obtain explicit consent from a buyer before voluntarily issuing an e-invoicing for a B2B transaction. E-invoices must meet the EN 16931 European Standard. If they choose to issue e-invoices, the issuer must ensure the integrity of the content and the authenticity of the origin by using, for example, an electronic signature.

B2G e-invoicing in Liechtenstein

In November 2017, the government introduced the Public Procurement Act. This law establishes a legal framework for the use of electronic invoices in public procurement. While no mandate was introduced, the Act laid a foundation for the country’s approach to e-invoicing.

However, the law introduced the requirement for public authorities to receive and process e-invoices that meet the European Standard on e-invoicing (EN 16931). This rule comes into effect when “public authorities pay suppliers for goods or services provided through formal procurement contracts above the thresholds provided in the Public Procurement Directives,” as per the European Commission.

Timeline of e-invoicing adoption in Liechtenstein

Here are the milestones in Liechtenstein’s e-invoicing journey.

  • 10 November 2017: The Public Procurement Act establishes a legal framework for e-invoicing in public procurement—laying the foundation for a potential future mandate
  • June 2020: the Liechtenstein E-invoicing Forum (LEIF) stops playing its observer role in the European Multi-Stakeholder Forum on Electronic Invoicing (EMSFEI)
  • January 2025: Businesses must use the new electronic VAT portal for all VAT-related transactions

Setting up e-invoicing in Liechtenstein with Sovos

While Liechtenstein currently has only one specific use case for e-invoicing, it may follow other countries in introducing mandates in the near future. You must be agile and meet your regulatory requirements everywhere you do business—and that includes electronic invoicing.

Many countries now require businesses to issue e-invoices for both B2B and B2G transactions. Is your organisation set up to meet these demands?

With Sovos, you have a single compliance partner for all your tax compliance needs, helping you now and in the future as rules and requirements evolve. Free up time and headspace by contacting us today.

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FAQ

No, there is no mandate for B2G or B2G e-invoicing in Liechtenstein. The only rule governing electronic invoicing in the country pertains to public procurement, where public authorities must be able to receive and process European Standard-compliant e-invoices for contracts exceeding a specific value threshold.

Public authorities in Liechtenstein are required to be able to receive and process electronic invoices under two conditions:

  1. The e-invoices comply with the European Standard for e-invoicing (EN 16931)
  2. The e-invoice is for a transaction that exceeds the country’s specified value threshold in its national Public Procurement Act of November 2017.

Currently, there is no mandate for e-invoicing in Liechtenstein across B2B, B2G and B2C transactions.

The nation established a legal framework for e-invoicing in 2017, specifically pertaining to transactions in public procurement (B2G).

The Ministry of General Government Affairs and Finance is the specific governmental department that is responsible for overseeing and implementing e-invoicing regulations in Liechtenstein. That said, it has not yet introduced any electronic invoicing mandates, platforms or standards.

E-invoices sent in public procurement must comply with the European Standard (EN 16931), but Liechtenstein’s Ministry of Finance has designated no specific format for these documents.

E-invoices for public contracts must be sent to the Liechtenstein national administration in XML format.

Cyrille Sautereau – President FNFE-MPE & CEO Admarel Conseil 

Ahead of the Tax Compliance Summit Sovos Always On: Paris on 19th November, we asked Cyrille Sautereau, Chair of the AFNOR “Electronic Invoice” Commission and President of the National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE), to discuss the evolving landscape of e-invoicing reform in France, the challenges of interoperability, and the country’s role in shaping European standards.

 

The National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE) plays a key role in coordinating discussions around the reform. Could you remind us of the Forum’s mission and how it serves as a bridge between the administration and businesses?

The National Forum for Electronic Invoicing was created in 2012 following the establishment of the European Multi-Stakeholder Forum on Electronic Invoicing (EMSFEI), which led several Member States, including France and Germany, to create their own mirror forums. From the outset, its mission has been to support the development of e-invoicing in France, across both public and private sectors, in alignment with EU initiatives. We became an association in 2016 and now have more than 280 members divided into three colleges: users, service providers, and independent experts and consultants.

Our role is both normative and educational. Normative, because we actively contribute to the development of European and national e-invoicing standards, in close collaboration with the AFNOR “Electronic Invoice” Commission, which I also chair; and educational, because we provide best practices and help the ecosystem understand the regulations, enabling companies to transition smoothly to e-invoicing.

Finally, we fully play our role as a bridge between public authorities and the market. The FNFE is regularly consulted by the tax administration and lawmakers, particularly on regulatory developments related to the reform. We bring field expertise — our knowledge of invoicing practices, tools, and the operational constraints businesses face. This ongoing dialogue helps fine-tune regulations and ensures a harmonized, effective implementation of the reform.

 

The FNFE-MPE brings together public institutions, businesses, software providers, and technical experts. How do you manage to unite these actors, whose interests sometimes differ, around common standards?

The FNFE-MPE brings together a wide range of stakeholders: businesses, vendors, service providers, accountants, professional federations, and even representatives of the public administration. Our mission is to facilitate dialogue among these groups, which don’t always share the same priorities. The key is transparency and co-construction: everyone can take part in our working groups and contribute to developing the standards.

We hold several plenary sessions each year, along with about ten thematic working groups covering topics such as e-invoicing reform, interoperability, standards and norms, communication, best practices, invoicing and payment, B2G invoicing, and factoring. These forums allow members to share feedback, identify practical challenges, and bring them to standardization bodies.

This collaborative approach has fostered a genuine common language between public and private actors. That’s the strength of the FNFE — its ability to unite the entire ecosystem around a shared vision, ensuring that both technical and regulatory choices remain realistic, effective, and business-oriented.

 

One of the major challenges of the reform lies in ensuring interoperability between private platforms and public systems. In your view, what are the main hurdles to overcome to ensure a smooth and coherent ecosystem?

Interoperability is indeed one of the most sensitive aspects of the reform. Contrary to what people might think, the main challenge doesn’t lie in connecting private platforms to the Public Invoicing Portal — that interface is precisely defined by the DGFiP’s specifications — but rather in ensuring smooth communication among private players themselves.

The first challenge concerns certified platforms (formerly PDPs), which must be able to exchange data without multiplying bilateral integrations. That’s why we supported the rollout of the Peppol network in France — a model where one connection makes you interoperable with all other network participants. The second pillar is a shared addressing system based on the SIREN number and managed within a public directory. This ensures that every business is reachable through a stable e-invoicing address — one that remains unchanged when switching platforms.

Finally, there’s the “last mile”: connecting companies’ internal systems (so-called “compatible solutions”) to their certified platforms. Given the variety of software tools on the market, proprietary integrations must be avoided. That’s the goal of the AFNOR initiative to design a standardized API — a universal connector that ensures seamless transitions between platforms. Portability is essential for an open, sustainable ecosystem.

 

The French e-invoicing mandate — the progressive obligation for all companies to issue and receive invoices through certified platforms starting in 2026 — is part of a broader European movement driven by the ViDA (VAT in the Digital Age) initiative. How does France position itself in this EU-wide transformation?

The French reform is closely aligned with the European ViDA project, which aims to harmonize e-invoicing and reporting practices across the EU. ViDA calls on Member States to establish systems for e-reporting and e-invoicing based on structured data and standardized formats — exactly what France has already implemented.

Our national model, based on the exchange of structured electronic invoices between French taxpayers and the automatic transmission of data to the tax administration, already mirrors ViDA’s intended architecture. The key difference is that France chose from the outset to combine mandatory e-invoicing with e-reporting to the tax authorities — whereas other countries limited their first phase to B2B e-invoicing, postponing e-reporting to a later stage. We also introduced two unique features: invoice status tracking — ensuring lifecycle traceability and giving suppliers the visibility and value they’re entitled to — and B2C e-reporting, which isn’t covered by the European scope. In short, France won’t need to adapt its system to ViDA; it already embodies it. 

 

Some believe that France could become a reference model in Europe, provided it successfully deploys the reform. Do you share that view? What lessons could other Member States draw from the French approach?

France can indeed become a European benchmark, provided the operational rollout succeeds. What sets us apart is the decision to tackle the issue holistically, integrating technical, regulatory, and business aspects from the beginning. While other countries proceeded step by step — first e-invoicing, then reporting — we decided to merge both dimensions right away.

Requiring VAT data to be transmitted to the tax administration from each invoice inherently assumes that, within each invoice, the seller is responsible for VAT collection and the buyer for deduction. This creates additional complexity in many cases where intermediaries — such as aggregators handling invoice consolidation or grouped payments — play a role without being the actual taxpayer.

Our approach builds on significant collaborative work within the AFNOR “Electronic Invoice” Commission, which I also chair. Over six months, more than 250 experts from all sectors took part in over sixty meetings. This work revealed the real complexity of use cases, often underestimated — for example, scenarios where several service providers appear on a single invoice for one buyer, such as in the water, leasing, insurance, or travel sectors. These configurations turned out to be far more common than expected. The AFNOR work also helped align French practices with the European semantic standard EN 16931 — ViDA’s foundation — while identifying its limitations and addressing them through data extensions or management rule updates.

Finally, this process confirmed the need for flexibility — allowing human-readable formats, like hybrid Factur-X invoices, which include operationally useful data that may not fit within the semantic standard or technical capabilities of some small businesses.

This ability to identify specific cases and address them within a shared normative framework is, in my view, France’s main strength. It helps anticipate complex situations, deliver standardized solutions (“the same problems, the same answers”), and maintain coherence between regulatory requirements and business realities. Many Member States will likely draw inspiration from this integrated approach when implementing ViDA.

 

Beyond compliance, the reform will generate an unprecedented volume of standardized economic data. Do you think this infrastructure could ultimately become a driver of competitiveness and innovation for French companies?

Beyond compliance, the reform will fundamentally change how companies manage their operations. By generalizing e-invoicing, we’re introducing structured, reliable, and continuously available data — replacing the paper and PDF-based exchanges that still dominate today. This is transformative: data becomes instantly usable by management systems, without re-entry or manual processing.

In practical terms, this will allow all companies — including SMEs — to reach levels of automation and visibility previously reserved for large groups. Cash-flow reporting or monthly closings will no longer take days of reconciliation: invoices will be integrated in real time, and discrepancies will appear immediately. This responsiveness will enhance business leaders’ ability to manage performance, detect weak signals, and anticipate payment delays — in short, to shift toward predictive management.

In the long run, value-added services could emerge from aggregated, anonymized data analysis. For example, a platform could offer buyers average market price benchmarks based on peer transactions, helping them better position themselves competitively. These uses will need to be regulated to preserve confidentiality, but they open promising perspectives. Competitiveness will thus depend not only on compliance, but on data quality and intelligent exploitation.

 

You’ll be speaking at Sovos’ Always-On event on November 19, which will bring together public authorities, businesses, and solution providers around e-invoicing and tax compliance. What do you expect from such a gathering at this pivotal stage of the reform?

We regularly take part in events like Always-On because they play an essential role in collective education around the reform. The more opportunities for dialogue, the better. For the FNFE-MPE, it’s a concrete way to fulfill our mission of supporting businesses. These meetings help clarify what the reform truly entails, demystify its implementation, and provide a neutral perspective that complements that of service providers.

That’s important, because many companies still have a fragmented understanding of the reform: some overestimate its complexity, while others haven’t yet grasped its full impact. In this context, direct exchanges among public authorities, experts, vendors, and users are key to building a shared culture and reliable reference points. Such events help reinforce a crucial message: the success of e-invoicing depends on adopting shared standards, ensuring consistency of practices, and rejecting unnecessary complexity.

For too long, everyone built their own processes, portals, and formats — often with limited success. One of the reform’s main goals, and one of the benefits of events like Always-On, is to move beyond this “each to their own” mindset and build a truly interoperable ecosystem.

 

Among the many topics that will be discussed during the event, artificial intelligence stands out as particularly important. AI is now increasingly present in both compliance and tax controls. How can we ensure that this technological evolution strengthens — rather than undermines — the relationship of trust between taxpayers and authorities?

The importance of AI will grow as data volumes increase. AI can first help companies better understand what the administration “sees” about them by comparing their internal data with prefilled information. This “mirror visibility” can help identify and explain discrepancies even before an audit is initiated.

That said, we must remain clear-eyed about technology’s limits. AI is an analytical support tool, not an arbiter of truth. Its effectiveness will always depend on the algorithms behind it and the quality of the data it processes. Used rigorously and transparently, AI can strengthen trust between companies and tax authorities by making processes more objective and efficient. Conversely, if poorly managed, it risks creating new areas of opacity or misunderstanding.

The challenge in the years ahead will be to strike the right balance: leveraging AI’s power to make compliance more reliable and streamlined while preserving human interpretation and dialogue. Only under these conditions can technology truly serve trust, rather than weaken it.

KSeF, or the National E-Invoicing System, is Poland’s approach to continuous transaction controls (CTC), a trend that sees tax authorities gaining real-time visibility of transactions. The ‘clearance’ model implemented in Poland demands that invoices be issued in a structured electronic format and undergo validity checks, ensuring compliance and accuracy of e-invoices before they are sent to recipients.

Operational on a voluntary basis since 2022, the KSeF e-invoicing system is set to become mandatory in phases starting February 2026. Poland’s e-invoicing requirements encompass both VAT active and exempt entities, covering B2B and B2G transactions, while B2C e-invoicing remains optional. Importantly, the system includes both domestic and cross-border transactions, although with specific rules for invoice exchange in cross-border scenarios.

KSeF 2.0: key changes and features

KSeF 2.0 emerged as a direct response to stakeholder feedback during the voluntary implementation phase. After extensive public consultations, the Polish Ministry of Finance addressed several critical concerns raised by businesses. These included the need for offline invoicing capabilities during connectivity issues, support for B2C transactions, clearer rules for self-billing in cross-border scenarios, better handling of complex business structures like VAT groups, and many other concerns.

The resulting KSeF 2.0 framework includes both legislative changes (through the KSeF 2.0 Act and other implementing regulations) and technical enhancements (via the new FA3 schema and API). The new system adds support for optional B2C invoicing, previously unavailable in the voluntary phase, giving issuers the discretion to include such transactions within KSeF. It also introduces the KSeF certificates, which will be used for authentication in the system and for the generation of the QR code used in the offline modes. Special attention is given to offline modes, particularly the “offline 24” mode, which allows for invoice submission by the next business day in case of issues on the taxpayer’s side.

Key functionalities and adjustments included in KSEF 2.0

QR codes will be required when exchanging invoices outside of KSeF both in online or offline modes with the need to add a second QR code for invoices issued in offline mode and sent to the recipient before KSeF clearance.

 

The timeline to KSeF implementation

  

What’s next for Poland e-invoicing requirments?

As Poland advances towards the full implementation of KSeF 2.0, businesses must stay informed and prepared for these regulatory changes. The system’s phased rollout offers a window for adaptation, but early compliance will ensure smoother transitions and mitigate potential disruptions.

Sovos has created a number of resources to help businesses prepare for Poland’s KSEF 2.0 e-invoicing requirements:

Sovos’ team of regulatory tax experts answer some of the most frequently asked questions about KSEF 2.0, an upcoming update to Poland’s national electronic invoicing system.

1. What are the main changes in KSeF 2.0?

KSeF 2.0 introduces several important features not available in the 1.0 system in use during the voluntary period. The most significant changes include:

2.    What is the implementation timeline for KSeF 2.0?

The KSeF 2.0 implementation begins with open testing from September 30, 2025, followed by KSeF certificates availability on November 1, 2025. As confirmed by the KSeF 2.0 Act, mandatory structured e-invoicing starts February 1, 2026 for taxpayers with sales exceeding 200 million PLN in 2024, and April 1, 2026 for all other taxpayers.

An exemption allows taxpayers with monthly sales below 10,000 PLN to continue issuing paper or electronic invoices until December 31, 2026.

3. Which entities are obligated to use KSeF?

According to the Polish legislation, the mandatory e-invoicing obligation through KSeF will apply to:

4. Does sole VAT registration in Poland mean a company is subject to KSeF?

Polish legislation states that the taxpayer must have either a registered office or a permanent establishment in Poland that participates in the transaction to fall under mandatory KSeF. VAT registration alone does not trigger the obligation.

5. What documents are included in KSeF and what are excluded?

Not all document types fall within the scope of the KSeF system. The system supports VAT invoices, corrective invoices, self-billing invoices, and VAT RR invoices (optional from April 2026). However, several documents are excluded from KSeF, including internal invoices, pro forma invoices, and traditional debit/credit notes.

6. Are cross-border transactions included in the KSeF mandate?

Yes, Polish businesses must submit e-invoices to KSeF for sales to foreign customers. After submission, the Polish supplier must provide the invoice to the foreign customer in an agreed format, including a QR code for KSeF access. This applies to all cross-border sales by Polish taxpayers under KSeF.

7. How can taxpayers access invoices from the KSeF system?

Taxpayers have multiple options to receive their e-invoices from the KSeF platform:

8. How does KSeF 2.0 handle B2C transactions compared to KSeF 1.0?

Unlike KSeF 1.0, which did not support B2C e-invoicing, KSeF 2.0 allows voluntary B2C e-invoicing. Consumers must still request an invoice before one can be issued, but the issuer decides whether to fulfill this request via KSeF or through traditional methods without requiring consumer consent.

9. How will consumers access their invoices in KSeF?

The KSeF 2.0 legislation establishes an “anonymous access” mechanism for consumers. When sellers issue e-invoices to consumers through KSeF, they must provide one of the following:

Consumers can use these methods to access their invoices without the need to log into the system.

10. How do credit and debit notes work in the KSeF system?

Traditional credit and debit notes as separate document types (commonly used in many countries) won’t be part of the KSeF system. Instead, all corrections must be made through a “corrective invoice” document type that KSeF supports. Additionally, correction notes issued by buyers in Poland will also remain outside KSeF’s scope.

11. What certificates or access credentials are needed to issue in KSeF 2.0?

Authentication can be done via:

The Trusted Profile method will be eliminated from 1 April 2026. KSeF Certificates will be available for download from November 1, 2025 via the Certificates and Authorizations Module (MCU), which will be made available in the KSeF domain.

12. What offline modes are available in KSeF 2.0?

KSeF 2.0 offers four offline modes. Offline24 mode is designed for issues on the taxpayer’s side, such as connectivity problems and internet outages. Offline mode is for planned system maintenance periods when KSeF is temporarily unavailable. Failure mode is for unplanned system failures that are officially announced in the bulletin of the Ministry of Finance. Total failure mode is for extraordinary situations like threats to the country’s infrastructure, announced through media channels.

13. What is the Offline24 mode in KSeF 2.0 and how does it work?

Offline24 mode is a solution created to address concerns about potential delays in invoice submission due to issues on the taxpayer’s side. It allows businesses to issue structured invoices outside the system, and to submit them to KSeF no later than the next business day following the FA(3) format.

14. How do recipients receive invoices issued in Offline24 mode in KSeF 2.0?

Domestic business recipients with a NIP receive invoices exclusively through the KSeF system after their submission and clearance. Other recipients (consumers, foreign entities, or entities without a NIP) receive invoices in a manner agreed with the buyer outside of KSeF, with one or two QR codes.

15. What are the QR code requirements for invoices in KSeF 2.0?

When an invoice is sent to the recipient outside KSeF, it must include one or two QR codes. There are two types of QR codes: one for accessing the invoice and another for ensuring integrity and authenticity. If the invoice is provided to the recipient after KSeF clearance, only the access QR code is required. When providing the invoice to the recipient before KSeF clearance, the two QR codes are needed.

16. Is a QR code required on non-domestic invoices?

Access QR codes are mandatory on all invoices exchanged outside the KSeF system, including cross-border transactions. Polish companies must first submit the e-invoice to KSeF, then provide it to foreign partners in any agreed format along with a QR code. This allows foreign recipients to verify the invoice’s authenticity and access it in the Polish tax authority’s system when needed.

17. What invoice format will be used in KSeF 2.0?

From February 1, 2026, KSeF 2.0 will exclusively use the FA(3) logical structure for all structured invoices. The FA(3) schema includes enhanced features like support for attachments, inclusion of new fields and other updates to code formats, schema variants, and data types.

18. What are invoice attachments in KSeF 2.0 and what can they contain?

Invoice attachments in KSeF 2.0 are an integral part of structured invoices designed specifically for entities who need to include complex detailed data in their invoices. Attachments can only contain mandatory invoice elements specified in the Polish VAT Act or closely related data, while including marketing information and advertising content is prohibited.

19. How can businesses include attachments with invoices in KSeF 2.0?

To include attachments with invoices in KSeF 2.0, businesses must submit a notification via the e-Tax Office to the National Tax Administration before using this feature. The attachment functionality, available from January 1, 2026, is valid for 2 years after approval and requires renewal to continue.

20. Will there be a transitional period when penalties won’t apply for KSeF-related violations?

Yes. From February 1, 2026, to December 31, 2026, financial penalties for KSeF-related violations will not be enforced. This transitional period allows businesses time to adapt without facing fines.

 

Want to learn more about KSEF 2.0 and Poland’s e-invoicing requirements?

Sovos has created a number of resources to help businesses prepare for Poland’s KSEF 2.0 e-invoicing requirements:

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