What is an e-invoice: why a PDF is not one, and who now requires them

What Is an E-Invoice? Formats, Rules and Deadlines

What an e-invoice is, why a PDF is not one, the formats you will meet, and e-invoicing deadlines by country, including France and the US.

Quick answer

An e-invoice is an invoice issued, sent and received in a structured digital format, such as UBL or CII XML, that the buyer's system can read automatically without anyone typing it in. A PDF sent by email is not an e-invoice. E-invoicing between businesses is now mandatory in several EU countries, including Germany, Belgium, Poland and France, but not in the US.

Why listen to us: ECIT Digital is a certified Peppol Access Point. We receive e-invoices and read PDFs in the same pipeline for finance teams, so we see both sides of this every day.

Confession: for years I proudly called my PDF invoices "e-invoices", because they arrived by e-mail [polishes PDF lovingly]. The German tax office would like a word. It turns out my beloved PDF is, legally speaking, a picture of an invoice.

If you run finance at a US company, you may wonder why any of this is your problem. Short answer: your European customers and suppliers are now required to use e-invoices, and they are about to ask you for them [phone rings, it is Belgium].

E-invoice vs PDF invoice, at a glance

Both arrive on a screen, which is where the similarity ends [holds the two side by side, squints].

PDF invoiceE-invoice
What it isA picture of an invoiceStructured data, field by field
Typical formatPDF, scan or Word fileUBL or CII XML, Peppol BIS, XRechnung, Factur-X
How it is sentEmail attachment or postA network such as Peppol, a government platform or EDI
How the buyer reads itA person or capture software extracts the dataThe buyer's system imports it directly
Counts under EU mandatesNoYes, if it follows the required format

What is an e-invoice?

The EU defines it precisely. Under Directive 2014/55/EU, an electronic invoice is one that "has been issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing".

The same directive adds, a little coldly, that "a mere image file should not be considered to be an electronic invoice". That is the moment my PDF found out it was adopted [hands PDF a tissue]. Germany's finance ministry says the same in plainer words: a simple PDF no longer counts, because it has no structured format.

The rules for what the data must contain sit in the European standard EN 16931, which describes the core fields every e-invoice carries. Think of it as the recipe, and the formats below as the different kitchens that cook it.

How an e-invoice travels

Most cross-border e-invoices in Europe travel over Peppol, a network where each company connects through an access point. The supplier's access point sends the invoice, the buyer's access point receives and checks it, and the data lands in the buyer's ERP without anyone retyping it.

How an e-invoice travels in the Peppol four-corner model: supplier, supplier's access point, buyer's access point, buyer
How an e-invoice travels in the Peppol four-corner model: supplier, supplier's access point, buyer's access point, buyer

In Peppol's own words, "Peppol is not a portal, or a provider of exchange services. Peppol is an enabler". It is less like a website and more like a postal system for invoices, with stricter envelopes [licks stamp, regrets it]. One connection to an access point reaches every other company on the network.

E-invoice formats you will run into

An e-invoice is always structured data, but the structure has several names depending on the country and the network. Here are the ones a US finance team is most likely to meet [puts on reading glasses, then a second pair].

FormatWhat it isWhere you meet it
UBL 2.1An XML invoice syntax recognized by EN 16931Peppol and many EU countries
UN/CEFACT CIIThe other XML syntax recognized by EN 16931Factur-X, ZUGFeRD and several EU systems
Peppol BIS Billing 3.0The Peppol rules for an EN 16931 invoice, in UBLAnyone sending over Peppol
XRechnungGermany's national version of EN 16931German public sector and B2B
Factur-X / ZUGFeRDA PDF with the structured XML embedded insideFrance and Germany
FatturaPAItaly's national XML formatInvoices to Italian companies
EDI (ANSI X12 810, EDIFACT)Older structured messages between trading partnersUS retail and supply chains

Syntax bindings as listed for EN 16931 by the European Commission. National formats are versions of the standard for one country.

Factur-X is the one that confuses people, because it looks exactly like a PDF. It is a PDF that secretly carries the real invoice inside, which is the most my PDF has ever wanted to be [PDF looks hopeful].

E-invoicing regulations by country

E-invoicing regulations usually come in two parts: a date from which companies must be able to receive e-invoices, and a later date from which they must send them. Here is where the main markets stand, from each government's own pages.

CountryMust receive e-invoicesMust issue e-invoicesSource
GermanySince 1 January 2025From 1 January 2027, or 2028 for issuers with up to €800k turnoverBMF
BelgiumSince 1 January 2026Since 1 January 2026FPS Finance
PolandFrom 1 February 2026 (KSeF)1 February 2026 for the largest sellers, 1 April 2026 for othersKSeF
FranceSince 1 September 2026, all companiesLarge and mid-sized since 1 September 2026, SMEs from 1 September 2027Service-Public
United KingdomFrom April 2029From April 2029, all VAT invoicesgov.uk
EU, cross-borderDigital reporting from 1 July 2030 under ViDABuilt on e-invoicesEuropean Commission
United StatesNo B2B mandateNo B2B mandateFederal Reserve

Dates as published by each government, checked on 26 October 2026. Rules change, so check the linked source before you plan around a date.

If that table made your eyes water, you are reading it correctly [passes the eye drops]. The pattern is simple, though: Europe is moving country by country, and by 2030 cross-border invoices inside the EU will be reported digitally too.

Belgian companies felt it first-hand. On a software forum, one user wrote that "We are a Belgian entity, so this is MANDATORY for us to continue doing business in Belgium from 1 January", before the deadline arrived. For UK specifics, our guide to the UK e-invoicing mandate goes deeper.

PDFs and e-invoices, one pipeline

ECIT Digital is a certified Peppol Access Point. We receive e-invoices and read PDFs and scans in the same flow, and deliver one clean data set to your ERP. See our electronic invoicing service.

The France e-invoicing mandate

France's reform started on 1 September 2026. According to the French government's business portal, every company in France must be able to receive e-invoices from that date, large and mid-sized companies must also issue them, and SMEs and micro-companies must issue them from 1 September 2027.

Company sizeMust receive e-invoicesMust issue e-invoices
Large and mid-sized1 September 20261 September 2026
SMEs and micro-companies1 September 20261 September 2027

Source: French government business portal (Service-Public), checked 26 October 2026.

The tax authority confirms the system is live, with data transmission to the administration "effective since 1 September 2026". If you sell to French companies, expect your customers to ask how you will send invoices from here on. Saying "by email, obviously" is no longer the charming answer it used to be [practices French apology].

Is e-invoicing mandatory in the US?

No. There is no federal or state mandate for e-invoicing between private companies in the US. Federal agencies are a different story: OMB memo M-15-19 directed them to move to "electronic invoicing by the end of FY 2018", mostly through the free Invoice Processing Platform.

WhoWhat appliesSource
Federal agenciesElectronic invoicing, mostly through the free Invoice Processing PlatformIPP
Private companiesNo mandate. A voluntary exchange framework run by the Digital Business Networks AllianceFederal Reserve
US companies selling to the EUIn practice, the national rules of their EU customersThe country table above

For private companies, the Federal Reserve worked with the Business Payments Coalition on a market-ready e-invoice network, which led to the Digital Business Networks Alliance and an exchange framework launched in 2023. It is voluntary, so US adoption moves at the speed of enthusiasm [checks enthusiasm, finds coffee].

Worldwide, Billentis estimates that only 29% of B2B invoices are currently electronic, against 64% in Europe, according to a summary by its sponsor Qvalia. PDFs are not going anywhere soon, and honestly, my PDF is relieved.

What US companies selling to Europe should do

A US company is rarely obliged directly, but its European customers are, so they will start asking for e-invoices. Work through it in this order, ideally before Belgium calls again [unplugs phone].

1

List customers in mandate countries

Germany, Belgium, Poland and France today, the UK from 2029.

2

Ask each customer how they want to receive

A Peppol ID, a national platform or a portal. Their AP team will know.

3

Pick a route

Connect through a Peppol access point or a provider that reaches the national platforms.

4

Send in the required format

Your ERP data goes out as UBL, CII or the national version, validated before it leaves.

5

Keep receiving everything else

PDFs and scans still arrive from the rest of the world, so keep a way to read them.

The receiving side matters too. European suppliers already send structured e-invoices, and taking them over Peppol means no one on your team has to read or retype them, which leaves more time for the things that still arrive as PDFs (hello again, old friend). For the practical side, see how to receive and process e-invoices automatically, or compare the two models in e-invoicing vs traditional invoicing.

Why bother when nobody in the US forces you? Processing cost, mostly. Ardent Partners puts the average cost to process one invoice at $9.90, against $2.67 for Best-in-Class teams, and invoices that never need retyping are a big part of that gap [does the math, smiles for once].

What we see in the field

From inside an access point, e-invoicing looks less like a revolution and more like a long, polite overlap [waves at both formats].

ECIT Digital validation view: invoice header and line data validated by a person, 99.8% accuracy
Our validation view: fields the AI is unsure about get checked by a person before delivery.
  • Every format arrives at once. Peppol e-invoices, PDFs and paper scans land in the same pipeline, and paper is scanned by our partners first.
  • E-invoices still get checked. A structured file can carry the wrong VAT number or order reference, so validation does not stop at the format.
  • PDFs need a person behind the AI. When our AI is unsure about a field on a PDF, someone on our team checks it, which is how the 99.8% accuracy guarantee holds.
  • Clients never touch the document. Clean data goes straight into their ERP, AP workflow tool or property management system.

E-invoices and PDFs, one pipeline

Every invoice format into your ERP, 99.8% accuracy guaranteed

We receive Peppol e-invoices as a certified access point, read PDFs and scans, and have a person check what the AI is unsure about. You pay per document.

As for my PDF: it is still here, still loved, and still being read by a very patient AI and a person with coffee [tucks PDF into a folder labeled "legacy"]. It just is not an e-invoice, and now neither of us will pretend otherwise.

Sondre Bratlandsmo

October 26, 2026

Frequently asked questions

What is an e-invoice?

An e-invoice is an invoice issued, sent and received in a structured digital format, such as UBL or CII XML, that the buyer's system can import automatically. Nobody has to read it or type the data in.

Is a PDF invoice an e-invoice?

No. A PDF is an image of an invoice, so its data has to be read and extracted before a system can use it. EU rules state that a mere image file is not an electronic invoice. Hybrid formats such as Factur-X count because they carry structured XML inside the PDF.

Is e-invoicing mandatory in the US?

No. There is no federal or state mandate for e-invoicing between private companies in the US. Federal agencies were directed to move to electronic invoicing, mostly through the Invoice Processing Platform, and a voluntary exchange framework is run by the Digital Business Networks Alliance.

When is e-invoicing mandatory in France?

Since 1 September 2026, every company in France must be able to receive e-invoices, and large and mid-sized companies must also issue them. SMEs and micro-companies must issue e-invoices from 1 September 2027.

What format is an e-invoice?

Most European e-invoices follow the standard EN 16931 and use one of two XML syntaxes: UBL or UN/CEFACT CII. National versions include XRechnung in Germany, Factur-X in France and Germany, and FatturaPA in Italy. Invoices sent over Peppol use Peppol BIS Billing 3.0.

What is Peppol e-invoicing?

Peppol is a network for sending e-invoices and other business documents. Each company connects through an access point, and one connection reaches every other company on the network. Many European countries use Peppol for business and public sector e-invoicing.

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