E-invoicing in the EU: deadlines and sanctions by country

Anyone in the EU who fails to issue an e-invoice even though it is mandatory faces very different consequences depending on the country: in Germany, the main risk is a dispute over input tax deduction; in Belgium and France, there are fixed fines per violation or per invoice; in Spain, up to 50,000 euros per year for non-compliant invoicing software. This article shows, country by country, until when a PDF invoice is still sufficient and which sanctions apply afterwards.
As of: 28 September 2026. The background to ViDA and the national obligations as a whole is explained in the article E-invoicing in the EU 2026: ViDA and national obligations.
Overview: deadlines and sanctions by country
| Country | End of transition period | Sanctions |
|---|---|---|
| Germany | Sending: 31 Dec 2026 or 31 Dec 2027 (prior-year turnover up to €800,000) | No specific e-invoicing fine, risk to input tax deduction, fine of up to €5,000 for a missing invoice |
| Belgium | Tolerance period until 31 Mar 2026 | €1,500, €3,000, then €5,000 per violation |
| Poland | Mandatory since 1 Feb or 1 Apr 2026 | Fines announced from 2028, law still in the legislative process |
| France | Sending for SMEs from 1 Sep 2027 | €50 per invoice, maximum €15,000 per year |
| Italy | Mandatory since 2019 | Percentage-based sanctions on the undocumented tax |
| Spain (VeriFactu) | 1 Jan 2027 or 1 Jul 2027 | €50,000 per year for non-compliant software |
Germany
Deadlines
- Receiving: since 1 January 2025, all businesses must be able to receive e-invoices. There is no transition period here.
- Sending until the end of 2026: for transactions in 2025 and 2026, you may still issue paper invoices or, with the recipient's consent, PDF invoices.
- Sending in 2027: businesses with a prior-year turnover of up to 800,000 euros may continue to do so until 31 December 2027. A transitional rule until the end of 2027 also applies to EDI procedures.
- From 1 January 2028: obligation to send e-invoices for all businesses in the domestic B2B sector.
The legal basis is § 14 and § 27(38) UStG (German VAT Act). An e-invoice must comply with EN 16931, for example as XRechnung or ZUGFeRD. The article EN 16931 explained simply explains what the standard requires.
Sanctions
German law has no specific fine for a missing e-invoice. The consequences are nevertheless noticeable:
- Input tax deduction: once the transition periods have expired, a PDF invoice within the mandatory scope is not a proper invoice. Your customer risks having the input tax deduction denied in a tax audit. Many customers will therefore reject such invoices.
- Fine: anyone who fails to issue an invoice, or fails to issue it on time, commits an administrative offence under § 26a UStG. The fine is up to 5,000 euros.
- Late payment: public authorities and many businesses now only book e-invoices. An incorrect invoice delays payment.
Belgium
Deadlines
The B2B obligation has applied to all VAT-registered businesses in Belgium since 1 January 2026. The standard channel is Peppol. During the first three months of 2026, a tolerance period applied to businesses that could prove they had started the changeover in good time. It expired at the end of March 2026.
Sanctions
A Royal Decree of 8 July 2025 provides for fixed fines: 1,500 euros for the first violation, 3,000 euros for the second and 5,000 euros for each further violation. In addition, there is the risk to the recipient's input tax deduction.
Poland
Deadlines
Invoices run via the central KSeF platform. The obligation has applied since 1 February 2026 to businesses with a turnover of more than PLN 200 million in 2024 and since 1 April 2026 to all others. Micro-enterprises with very low monthly turnover have until the end of 2026.
Sanctions
The law provides for fines for violations of the KSeF obligation. They were originally to be applied from 2027. In September 2026, the Polish Ministry of Finance announced that their application would be postponed to 1 January 2028. The legislative process for this is still ongoing. Regardless of this, an invoice issued outside KSeF within the mandatory scope does not meet the requirements and can cause VAT problems.
France
Deadlines
Since 1 September 2026, all businesses must receive e-invoices, and large and medium-sized businesses must also send them and start e-reporting. Small and micro-enterprises follow on 1 September 2027. Invoices run via approved platforms, the Plateformes Agréées (PA).
Sanctions
Under Article 1737 of the French General Tax Code (CGI), each invoice that is not issued electronically although it should be costs 50 euros. The total is capped at 15,000 euros per calendar year. Separate fines apply to e-reporting violations. Businesses without an approved platform must also expect sanctions.
Italy
Deadlines
Italy has required e-invoices via the Sistema di Interscambio (SDI) for almost all domestic transactions since 2019. There are no longer any transition periods, and businesses under the flat-rate scheme are now also covered.
Sanctions
An invoice that does not go through the SDI is deemed not to have been issued. The sanctions are based on the VAT on the amount not correctly documented, with a minimum amount per transaction. The recipient also risks losing the input tax deduction.
Spain
Deadlines
Spain has two obligations. VeriFactu requires tamper-proof invoicing software: businesses subject to corporate income tax must use compliant systems from 1 January 2027, all others from 1 July 2027. The B2B e-invoicing obligation was adopted with Real Decreto 238/2026. Its deadlines depend on a ministerial order that has not yet been published in final form. According to the draft, it begins on 1 October 2027 for businesses with a turnover of more than 8 million euros and on 1 October 2028 for all others.
Sanctions
For VeriFactu, Article 201 bis of the Spanish General Tax Act (Ley General Tributaria) governs the sanctions: anyone using invoicing software that does not meet the requirements pays a flat 50,000 euros per financial year. Manufacturers and distributors of non-compliant software face a fine of 150,000 euros per year and product. Find out more about VeriFactu in the article VeriFactu in Spain: obligation, 2027 deadlines.
What you should do now
- Clarify whether you are affected: the obligations apply to businesses that are established or registered for VAT in the respective country. Check subsidiaries, branches and registrations.
- Note the deadlines: set the date for each country from which you must send e-invoices, and plan a test phase of several months beforehand.
- Clarify formats and channels: Germany requires a format compliant with EN 16931, Belgium in practice Peppol, Poland KSeF, Italy SDI, France an approved platform.
- Check invoices before sending: a rejected invoice is often more expensive than the fine because payment does not arrive.
faktoora creates e-invoices in the formats XRechnung, ZUGFeRD, Factur-X, FatturaPA, KSeF and VeriFactu and transmits them by email or via Peppol. The page E-invoicing in Europe provides an overview of all supported countries.
Frequently asked questions
Is there a fine in Germany for missing e-invoices?
There is no specific e-invoicing fine. Anyone who fails to issue an invoice at all or on time risks up to 5,000 euros under § 26a UStG. The bigger risk is usually the recipient's input tax deduction.
Until when may I still send PDF invoices in Germany?
For transactions until the end of 2026, with the recipient's consent. If your prior-year turnover is no more than 800,000 euros, this also applies to transactions in 2027. From 2028, e-invoicing is mandatory in the domestic B2B sector.
How high are the penalties in France?
50 euros per invoice not issued electronically, up to a maximum of 15,000 euros per calendar year. Separate fines apply to e-reporting.
What penalties apply in Belgium?
1,500 euros for the first violation, 3,000 euros for the second and 5,000 euros for each further violation.
Sources
- § 14 UStG, § 26a UStG and § 27 UStG, gesetze-im-internet.de
- Belgium, FPS Finance: E-Facturation
- UCM: E-facturation obligatoire à partir de 2026
- Légifrance: Article 1737 CGI
- Spain, BOE: Real Decreto-ley 15/2025
This article is for general information purposes only and does not replace tax or legal advice.