E-invoicing is the next compliance wave after IOSS, GPSR and the customs changes, and it is the one that generates the most confused questions from online sellers: does a UK Etsy or Shopify store need to send German XRechnung files from 2027? Does the UK mandate cover consumer orders? This guide separates what applies to an e-commerce seller from what applies to a German or French company, and lists what is worth doing now.
What an e-invoice actually is
An e-invoice is an invoice issued, sent and received in a structured electronic format that allows automatic processing. Since April 2025 that is also the EU legal definition under the ViDA package, and it excludes PDFs: a PDF is an image of an invoice, not data.
| Format | What it is | Where you meet it |
|---|---|---|
| UBL XML | The most common structured invoice syntax; the basis of Peppol BIS | Belgium, the Nordics, the Netherlands, the UK’s planned Peppol network |
| CII XML | The UN/CEFACT syntax; the basis of the German and French hybrids | Germany, France |
| Factur-X and ZUGFeRD | A PDF with the CII XML embedded, so a human and a machine can both read it | France (Factur-X), Germany (ZUGFeRD) |
| XRechnung | The German public-sector profile of UBL or CII | German B2G, accepted for B2B |
| Peppol BIS Billing | A UBL profile exchanged through the Peppol four-corner network of access points | Belgium since 2026, the UK from 2029 |
The hybrid formats matter for small sellers because they look like a PDF and travel by email, while still carrying the data a German or French accounting system needs.
The EU timetable, and who it binds
| Country | Receive | Issue | Who is bound |
|---|---|---|---|
| Italy | Since 2019 | Since 2019 | Established businesses |
| Romania | 2024 | 2024 | Established businesses |
| Belgium | January 2026 | January 2026 | Established businesses and permanent establishments; Peppol BIS |
| Croatia | January 2026 | January 2026 | Established businesses |
| Greece | February 2026 | February 2026 | Established businesses; myDATA |
| Poland | February 2026 (turnover above PLN 200m), April 2026 (others) | Same | Established businesses; KSeF platform |
| France | September 2026, all companies | September 2026 large and mid-size; September 2027 SMEs and micro | Businesses established in France; B2C and international sales fall under e-reporting instead |
| Germany | Since January 2025 | January 2027 (turnover above €800k); January 2028 all | Businesses established in Germany |
| Slovakia | 2027 | 2027 | Established businesses; Peppol |
| Spain | Expected 2027 | Expected 2027 | Established businesses; regulation pending |
| Latvia, Slovenia | 2028 | 2028 | Established businesses |
| EU-wide (ViDA) | July 2030 | July 2030 | Digital reporting of intra-EU B2B supplies by EU-established suppliers |
The column that matters for a cross-border seller is the last one. Every national mandate in the table is limited to businesses established in that country, or holding a permanent establishment there. A store in London or Istanbul that ships to Munich has no German establishment and is not required to issue a German e-invoice. Holding a German VAT number alone, for example through an EU fulfilment warehouse, does not change that under the current German rules, but a warehouse can create a permanent establishment in some countries, which is a question for your accountant.
What does change is the customer’s side. A German business buying from you in 2027 must be able to receive and process e-invoices; its accounting system will prefer a ZUGFeRD or XRechnung file to a plain PDF, and the French e-reporting regime means your French B2B customer reports the purchase from you to the French tax authority. Sellers who can hand over a structured file will simply be easier to buy from.
The UK: 2029 and Peppol
The government’s consultation response of 26 November 2025 confirmed mandatory e-invoicing for VAT invoices from 2029, with a detailed roadmap promised at Budget 2026 in November. In June 2026 HMRC confirmed Peppol as the network: a four-corner model in which you send through an access point of your choice and the customer receives through theirs, without real-time reporting to HMRC in the first phase.
Three things follow for an online seller.
- Consumer orders are outside it. The mandate attaches to VAT invoices, and a sale to a consumer does not require one. A B2C Etsy or Shopify store is not the target.
- Business orders are inside it. Every invoice you issue to a VAT-registered UK business customer will need to be an e-invoice from the go-live date, whatever the channel. If you sell to trade customers, this is your project.
- The detail is not settled. Thresholds, phasing by business size, the exact date within 2029 and the treatment of simplified invoices all wait for the roadmap. Nothing bought today is guaranteed to fit.
What an e-commerce seller should do now
- Separate B2B from B2C in your data. Collect and verify the customer’s VAT number on business orders, as described in the reverse charge guide. Without it you cannot tell which invoices the mandates will touch.
- Keep the master data clean. Legal name and address of both parties, VAT numbers, HS codes and country of origin, tax rates per line, unit prices and discounts. Every e-invoice format is a strict schema; missing fields fail validation.
- Export invoices as data, not only as PDFs. Your invoicing app should give you CSV or JSON of every invoice and credit note with line-level tax. That is the raw material for any future format.
- Choose tools that separate numbering from delivery. The invoice number sequence is a legal record; the delivery channel (email PDF today, Peppol tomorrow) should be replaceable without breaking it.
- Ask before you build. If you have EU trade customers, ask them which format they want now. A Factur-X or ZUGFeRD PDF satisfies most German and French buyers and needs no network.
- Do not connect to Peppol for a B2C store yet. Access point subscriptions are a recurring cost with no benefit until the UK mandate is specified.
Sellers in Türkiye are ahead here: e-Fatura and e-Arşiv have been mandatory for years under GİB turnover thresholds, with a lower threshold for online sellers. The EU and UK are moving to the same model, ten years later. Where a Turkish seller sells B2B into the EU or UK, the same rule applies: the mandate binds businesses established there, not you.
Frequently asked questions
I sell on Etsy and Shopify to consumers in Germany. Do I need XRechnung in 2027?
No. The German mandate binds businesses established in Germany, and consumer sales do not require a VAT invoice in the first place.
Is a PDF invoice still legal?
Yes, in the UK until the 2029 mandate and for any transaction the EU mandates do not cover. Inside a mandate, a PDF without embedded XML is not a valid invoice between the parties it binds.
Does the UK mandate apply to my consumer sales?
No. It applies to VAT invoices, which are required for sales to VAT-registered businesses. Sales to consumers are outside it.
I have stock in an EU warehouse and a local VAT number. Am I bound?
A VAT registration alone does not make you established. A warehouse can create a permanent establishment in some countries, and a permanent establishment is bound in Belgium and Poland, for example. Check with your accountant for the specific country.
What is Peppol?
An international network of certified access points that exchange structured documents. You send through your access point, the customer receives through theirs; neither party needs a direct connection to the other. Belgium uses it now; the UK will from 2029.
When will there be more detail on the UK mandate?
The government committed to a roadmap at Budget 2026, expected in November 2026. Until then the confirmed facts are the 2029 start, the scope of VAT invoices and the Peppol network.
General information, not tax advice
Dates as of September 2026; several mandates have already moved once and may move again. Check the national authority or your accountant before committing to a system.
InvoiceFlow Pro issues numbered PDF invoices and credit notes on every Shopify order with line-level tax data, which is the data foundation any future e-invoice format is built on; we will update this guide when the UK roadmap is published. If your store needs its B2B flow, tax settings and invoicing reviewed together, the e-commerce consulting sessions cover it.
Sources
- GOV.UK: Promoting electronic invoicing across UK businesses and the public sector, consultation outcome, 26 November 2025
- vatcalc: UK April 2029 Peppol confirmed for B2B e-invoicing
- Marosa VAT: E-invoicing B2B and B2G in Europe, overview and dates
- Invoice Navigator: EU e-invoicing deadlines 2026 to 2030
- Pennylane: French e-invoicing calendar, official dates 2026 and 2027