Leveraging the EN-16931 for compliance in and outside Europe

Leveraging the EN-16931 for compliance in and outside Europe

The European Directive on electronic invoicing for public authorities (EN 2014/55 / ​​EU) defined a standard invoice (European Norm core invoice aka EN-16930) and made it mandatary to be supported by all public organizations throughout the European Union. At the same time, a number of building blocks have been defined as EIF (European Interoperability Framework), that  combined with the EN-16931 provide a definition for VAT compliance.

The European Interoperability Framework (EIF) provides transaction compliance comfort

Legal context
The EU has facilitated this with the 2010/45 amendment to the VAT Directive and with the e-Invoicing  directive 2014/55.

Invoice standard with a semantic model
Semantic interoperability ensures that the precise format and meaning of exchanged data and information is preserved and understood throughout exchanges between parties

Additional specifications to the model
On a document level, a number of countries have defined a national CIUS, specifying additional transaction compliance rules. These rules that are applied before sending a document to a buyer, do add compliance comfort and are updated following a bi-annual schedule.

Exchange infrastructure
The standard addresses the interconnection services, exchange and communication protocols with a guideline on Message transport.

Process integration
The standard does not define how a supplier or buyer needs to organize the internal work processes. Organization need to be able to transpose these but by defining a data model that contains a specific set of data it aims to support the most common processes

A number of member states have mandated B2G invoicing where suppliers need to implement e-Invoicing.

Following tables present an overview of the e-Invoicing regulations in different countries.

  • B2G mandates in European member states;
  • B2G mandates in non-member states.
  • B2G support in European member states.


Country Additional syntaxes Compliance Platform Peppol
Austria CIUS web Yes
Belgium Peppol Mercurius portal Yes
Croatia CIUS Fina Yes
Denmark OIOubl Peppol Nemhandel Yes
Estonia CII, EVS Peppol multiple Yes
Finland CII, Finvoice Peppol mutliple Yes
France CII,  FacturX CIUS Chorus Pro Yes
Germany CII, ZUGferd CIUS web portals, e-mail partially
Greece Peppol EDHT Yes
Lithuania Peppol eSaskaita Yes
Luxembourg Peppol portal Yes
Malta (2022) Peppol portal Yes
Netherlands CIUS Logius Digipoort Yes
Portugal CII CIUS B2AP AS2, web services
Slovakia Peppol slovensko.sk e-mail
Slovenia CII e-Slog 2.0 Extension PPA Yes
Spain FacturE CIUS FACe
Sweden EDIFACT Peppol DIGG Yes

B2G mandates by European member states


Country Additional syntaxes Compliance Platform Peppol
NewZeeland (2022) GST Yes
Australia (2022) GST Yes
Iceland CII Peppol FJS portal Yes
Switzerland CII, GS1, ZUGferd  eDirectory.ch
Norway EHF Peppol Yes
Singapore GST InvoiceNow Yes

B2G Mandates outside European Union


Country Additional syntaxes Compliance Platform Peppol
Cyprus Peppol Ariadni Yes
Ireland EDIFACT Peppol Yes
Latvia CII Peppol eAddress Yes
Liechtenstein PDF Peppol e-mail
Poland Peppol PEF Yes
UK-England CII, EDIFACT, PDF multiple
UK-Wales CII Yes

Public body receivers ready for e-Invoicing, no mandate for suppliers



  • Every country in the list supports EN-16931 in UBL syntax
  • For historic reasons, national syntaxes can still be supported
  • Some countries have an EDIFACT legacy
  • CII is syntax is not generally supported


  • Some countries have defined their specific rules as a national CIUS or refer to the Peppol CIUS
  • Besides specific network rules, the Peppol CIUS includes national rules for a number of countries


  • Some of the countries have selected Peppol as their main exchange standard
  • Most countries have organized a bespoke platform or exchange standard
  • Most countries have a Peppol gateway established that is interfaced to their internal platform

We can conclude that by supporting the UBL syntax as well as EIF (with Peppol being the dominant implementation) most of the B2G compliance requirements are fulfilled.

As Peppol is present in EMEA, the same standards can be re-used for B2G implementation to non-European countries.

Country Additional syntaxes Compliance Platform Peppol
NewZeeland (2022) GST Yes
Australia (2022) GST Yes
Singapore GST InvoiceNow Yes


If you want to assess your transactions for compliance, AdValvas as a certified Peppol Access Point can help you by offering following services

  • Translate to / from ERP formats with UBL, CII, ZUGferd
  • User our free validation tool supporting all CIUS specifications for conformance testing
  • Reach assessment where for suppliers and buyers Peppol presence is validated in bulk

So, does complying with the EN-16931 norm provides compliance in all countries? The answer is no. Besides VAT reporting requirements (SAF-T), a growing number of countries is imposing clearance models for B2B transactions. We will address these in separate posts.