Belgium vs France vs Germany: Three E-Invoicing Mandates, Three Different Shapes

The short answer

Three neighbouring countries, three genuinely different designs:

If you only take one thing away: Belgium is already enforcing, France's first wave lands on 1 September 2026, and Germany's issuing obligation does not start until 1 January 2027. Belgium is the cheapest of the three to satisfy, so if you trade into all three it is both the most urgent and the least work. France is the next date on the calendar, and it is the one that constrains your choice of provider.

Belgium: plain Peppol, and that is the whole of it

Belgium made a deliberate choice not to invent anything. The European Commission confirms no national CIUS exists for Belgium, and the country's own guidance points at Peppol BIS Billing 3.0 unchanged.

The consequences are unusually pleasant:

• Nothing Belgium-specific to build in the document itself
• No provider register to join, and no need for a Belgian provider at all
• One identifier rule to respect — the enterprise number under scheme 0208, with its mod-97 check digit

The catches are operational rather than technical: Hermes has closed so unregistered buyers are unreachable, and penalties are already being applied. Full detail on our Belgium page.

France: 1 September 2026, and the channel is the difference

From 1 September 2026 every VAT-registered business in France, whatever its size, must be able to receive electronic invoices, and large and mid-sized enterprises must also issue them electronically and transmit their transaction and payment data. From 1 September 2027 the obligation to issue extends to small and micro-enterprises. Those are the French tax administration's own dates, published on impots.gouv.fr.

Note what the first date does and does not require. Receiving is universal on 1 September 2026 — size is irrelevant to it. Issuing on that date applies to large and mid-sized enterprises only. A small French supplier that cannot yet issue electronically still has to be able to take an electronic invoice from its larger customers on day one.

The design itself is not about the format. Factur-X — a hybrid PDF/A-3 carrying embedded XML — gets the attention, but the structural difference is who is allowed to move the invoice.

France routes B2B invoicing through registered PDPs (plateformes de dématérialisation partenaires). Being a certified Peppol access point does not by itself let you serve the French mandate; the platform has to be in the French register. That constrains vendor choice in a way neither Belgium nor Germany does, and it is the thing to check first when a provider claims "European coverage".

France also pairs invoicing with an e-reporting obligation, so like Belgium it is heading toward continuous transaction control rather than periodic returns. See our France page.

Germany: format plurality, and a turnover threshold

Germany started at the other end. The receiving obligation has applied since 1 January 2025 — every domestic business must be able to accept a structured invoice — while the issuing obligation is phased by turnover.

Businesses with more than EUR 800,000 of prior-year turnover must issue from 1 January 2027; all remaining domestic businesses from 1 January 2028. Which side of EUR 800,000 your prior-year turnover falls on is what decides your date, and that single number is the first thing to establish for each German entity in a group — the phases, formats and a readiness checklist are in Germany B2B e-invoicing: XRechnung and ZUGFeRD.

Germany accepts several EN 16931-conformant formats: XRechnung (the national CIUS, common in public sector), ZUGFeRD 2.1 (hybrid, technically identical to Factur-X), and Peppol BIS. No provider accreditation.

The practical implication is that "compliant in Germany" depends on what your counterparty accepts, not only on what the law permits — so profile negotiation matters more there than in Belgium. See our Germany page and XRechnung and ZUGFeRD explained.

What you can build once, and what you cannot

Shared across all three: the underlying invoice data. Your ERP holds one commercial document. EN 16931 is the common semantic model behind Peppol BIS, XRechnung and Factur-X — they are different expressions of largely the same fields.

Not shared:

• The national profile. XRechnung adds German requirements; Belgium adds none.
• The channel. France's PDP requirement is a routing constraint, not a formatting one.
• The identifier scheme. 0208 in Belgium; German and French participants use their own.
• Reporting. Belgium 2028 requires both parties to file separately. France has its own reporting track. Germany has none yet.

The mistake to avoid is building per country. Three integrations that each speak one national dialect is how a two-country problem becomes a five-year maintenance commitment — and ViDA will add more. Map once to a canonical model and let the profile be a parameter. That is the argument in one API across countries, and the EU direction is set out in the ViDA roadmap.

A sensible order of work

Order by the next date each country puts in front of you, not by how large the country is.

1. Belgium now. Live, enforced, penalties applying, and the least work of the three. Belgium B2B e-invoicing 2026 is the scope, format and checklist in one place.
2. Germany's receiving path, if you have German customers. That obligation has been in force since 1 January 2025 even though issuing is not, so it is already overdue rather than upcoming.
3. France, for 1 September 2026. Receiving is universal on that date and issuing starts for large and mid-sized enterprises, which puts it ahead of anything German issuing requires. Start with the vendor question rather than the format: is your provider a registered PDP, or partnered with one?
4. Germany's issuing path, dated by turnover — 1 January 2027 above EUR 800,000, 1 January 2028 below. Establish which side of the threshold each German entity sits on before you plan anything else.
5. Then reporting — Belgium 2028 and France together, since both push you toward the same architecture.

Related reading

• Belgium · France · Germany
• Belgium B2B e-invoicing 2026 — what changed in January, and the compliance checklist
• E-invoicing mandates 2026 tracker — every country, one table
• How to choose a Peppol access point
• Peppol vs PINT

Primary sources: European Commission — eInvoicing in Belgium · Peppol BIS Billing 3.0 · OpenPeppol

Mandate timelines move. Dates here are as published at the time of writing; the tracker is kept current.