The webinar“E-Invoicing across Europe: lessons learned and what’s next brought together experts from OpenText and PwC to discuss how organizations are navigating the growing wave of e-Invoicing mandates.

Moderated by Michelle Sandhu (OpenText), the session featured Philip Kelly (PwC) and Ken Clark (OpenText), who shared practical lessons from real implementation projects in Poland, Belgium, and Greece—along with insights into upcoming mandates in the UAE, France, and Germany.

Poland: Pre-clearance, KSeF, and practical pitfalls

Poland has gone live with mandatory e-Invoicing in waves, starting in February for large taxpayers with turnover above PLN 200 million, followed by additional waves later in the year. The country uses the government platform KSeF (version 2.0) and the FA3 XML format, combining a pre-clearance and central gateway model: all in-scope invoices must first pass through KSeF and obtain a KSeF ID before they can be shared with customers.

Domestic customers retrieve their invoices directly from KSeF, while international customers receive a PDF that contains both a QR code and the KSeF ID. The legal invoice is always the XML; the PDF is only a visualization, and any mismatch between the two can lead to serious tax risks, including potential double VAT payment.

Although penalties are suspended until 2027, companies are already struggling with late regulatory changes, unresolved questions around offline modes, and complex use cases such as travel expenses, collective credit notes, and cancellations.

Belgium: PEPPOL model and data quality challenges

Belgium has chosen a PEPPOL-based four-corner model rather than a centralized platform, using the PEPPOL BIS 3 format aligned with EN 16931. The regime is domestic in scope, with no current requirement to report cross-border or B2C invoices. It focuses on established entities, while nonresidents without a permanent establishment mainly need to be able to receive PEPPOL invoices.

In practice, projects reveal significant data quality issues: many invoices lack the information needed for straight-through processing, and the schema itself has limitations such as only one purchase order field. Companies therefore need proactive supplier communication to agree on where and how to populate additional business data within the PEPPOL structure.

Financial penalties start at €1,500 and increase with repeated noncompliance. The planned introduction of near real-time e-reporting also means that “temporary” alternatives such as EDI are only a short-term option.

Greece: MyData and fiscal incentives

Greece is rolling out its e-Invoicing requirements via the MyData platform, also based on EN 16931 and already familiar to many taxpayers. Large companies with turnover above €1 million are in scope from February, while smaller taxpayers follow from October. Both waves benefit from transition periods without penalties.

A notable feature of the Greek regime is its incentive structure. Businesses can claim 100% additional depreciation for technology and software, as well as a 100% increase in deductible expenses related to creating, transmitting, and archiving e-invoices in the first year.

These incentives apply to both early movers and second-wave companies, provided they comply within the specified deadlines in 2026.

Looking ahead: UAE, France, and Germany

Beyond the early adopters, a new wave of mandates is approaching in the UAE, France, and Germany.

The UAE is planning a pilot from July 2026, with a main go-live in 2027 and a five-corner model similar to France. Businesses must nominate a single authorized service provider per legal entity for both inbound and outbound flows, which prevents the common split-provider model.

France is preparing a five-corner architecture using certified PDP platforms that handle both e-Invoicing and e-reporting. All France-taxable companies fall within scope, including certain overseas territories. Non-established taxpayers are generally not obliged to send e-invoices but may still be subject to e-reporting where French VAT is charged.

There is discussion of a two-year grace period for companies acting in good faith, but this is not yet confirmed and should not be the basis of planning.

Germany is currently in a transition phase. Since 2025, invoices must be EN 16931-compliant, but there is no mandated transmission channel or single legal format. In practice, the market is converging on two main formats: XRechnung and ZUGFeRD/Factur-X. In both cases, the embedded XML is the legal document and overrides the PDF if the two differ.

From 2027, e-Invoicing becomes mandatory for most businesses, with paper and unstructured PDFs being phased out. EDI remains permissible as long as it becomes EN 16931 interoperable by 2028.

Strategic lessons and recommendations

From the projects discussed, several strategic lessons emerge that are relevant across all countries.

First, data readiness is often underestimated. Some regimes require up to 400 fields per invoice, many of which are not available in today’s ERP systems because they were previously added only at the print-template level. A thorough data assessment—starting at least six to nine months before each mandate—is critical to identify missing fields, conditional scenarios, and edge cases that must still be compliant.

Second, businesses should define early which information is truly nonnegotiable for their customers, beyond what tax law requires. Fields such as PO numbers, sales order references, or bank details may not be strictly required by VAT legislation but are essential for customers to accept and pay invoices.

Many of these data points currently reside only in PDF logic or local tools such as Word or Excel. Organizations must therefore bring decentralized and manual invoicing into standard processes and update output management to avoid duplicate or invalid invoices.

Third, robust transition and contingency planning is vital. Examples include manual access to government portals in Poland as a fallback, or using existing EDI connections in Germany as a bridge while new formats and business rules mature.

This planning should include clear “Plan B through Plan E” scenarios if system integrations are delayed—especially when multiple major mandates such as France and Germany must be implemented in parallel.

Finally, the speakers emphasized validation quality. Many solutions stop at checking XML syntax and schema rules, but a third step is needed to verify compliance with national VAT invoice requirements so that input VAT remains deductible.

Despite short-term disruption and higher manual effort immediately after go-live, mature e-Invoicing environments lead to fewer errors, faster processes, stronger automation, and better use of AP resources.

OpenText, with its Business Network and long experience in global e-Invoicing projects, positions itself as a strategic partner to guide organizations through this increasingly complex landscape.

The session closed with an invitation to continue the dialogue and a pointer to an upcoming webinar, Legacy to cloud: Transforming your EDI platform for the future.

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