Regulation · · 4 min read

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

Belgium is live on plain Peppol. France runs a PDP register. Germany phases in from 2027 with XRechnung. What differs, and what you can build once.

Last updated .

The short answer

Three neighbouring countries, three genuinely different designs:

Belgium France Germany
B2B status Live, enforced since 1 Apr 2026 Rolling out 2026–2027 Receiving since 2025; issuing from 2027
Format Peppol BIS Billing 3.0 Factur-X / UBL / CII XRechnung, ZUGFeRD 2.1, Peppol BIS
National CIUS None Yes Yes (XRechnung)
Channel Peppol, four-corner Registered PDPs Peppol and others
Provider accreditation Not required Required (PDP register) Not required
Reporting Five-corner from 2028 E-reporting alongside Not yet

If you only take one thing away: Belgium is the cheapest of the three to satisfy and the only one already enforcing. If you trade into all three, do Belgium first — it is both the most urgent and the least work.

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:

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: the channel is the difference

France's design 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, later deadline

Germany started at the other end. The receiving obligation has applied since January 2025 — every German business must be able to accept a structured invoice — while the issuing obligation phases in from 2027, reaching all businesses by 2028.

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

  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 is already in force even though issuing is not.
  3. France next, and start with the vendor question rather than the format: is your provider a registered PDP, or partnered with one?
  4. Then reporting — Belgium 2028 and France together, since both push you toward the same architecture.

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.

Frequently asked questions

Which of the three mandates is live first?
Belgium. Its B2B mandate has applied since 1 January 2026 and has been fully enforced since 1 April 2026. Germany phases its issuing obligation in from 2027, and France is rolling out across 2026 and 2027.
Is Peppol enough for all three?
For Belgium, yes - plain Peppol BIS Billing 3.0 with no national CIUS. Germany accepts Peppol BIS alongside XRechnung and ZUGFeRD. France routes through registered PDPs, so Peppol capability alone does not satisfy it.
Which is easiest to comply with?
Belgium, by a clear margin. It publishes no national specification, so plain Peppol BIS Billing 3.0 is the entire technical requirement and there is no provider accreditation to obtain.
Can one integration cover all three?
Largely. The invoice model and Peppol transport are shared. What differs is the national profile, the channel in France, and the reporting obligation, which is why a provider covering all three matters more than the format itself.

Related posts

Building on Peppol?

GoRoute is a certified Peppol Access Point & SMP. Book a demo or read the docs to get started.

Book a demo Read the docs