Germany's issuing obligation reaches businesses above €800,000 turnover on 1 January 2027. Slovakia starts the same day.
Of everything on this wall, this is the mandate with the cleanest runway — far enough out to build properly, near enough to fund now.
Who it binds
- Germany: receiving has been mandatory for all businesses since 1 January 2025. Issuing from 1 January 2027 for businesses above €800,000 turnover; all businesses from 1 January 2028.
- Slovakia: domestic B2B, VAT-registered, from 1 January 2027.
- UK groups are caught through German or Slovak entities.
What it actually demands
- Germany: XRechnung, ZUGFeRD 2.1 or Peppol BIS 3.0, all EN 16931-based.
- Slovakia: Peppol BIS 3.0 UBL.
- EN 16931 mandatory field completeness — which in practice means customer master remediation, not invoice formatting.
Twelve months looks comfortable until you find that the mandatory fields are populated inconsistently across ten years of customer records, and that the entity data was never maintained because nothing downstream depended on it. The format is a week. The master data is the project.
What it means for the estate
Sage X3 2026 R1 shipped e-invoicing for Belgium, France, Germany and Spain in June 2026 — which sets a version floor of 12.0.39 and makes this a reason to schedule the estate remediation rather than a separate line of work.
Build once for the EN 16931 core and the country variations become configuration. Build per country and you pay for the same customer-master clean-up three times.
Caveat
ViDA's intra-EU digital reporting requirements arrive July 2030, and legacy domestic regimes introduced before January 2024 must harmonise by January 2035. Nothing to do now; worth knowing the direction before choosing an architecture.
Primary sources
Related
Run the exposure check — three minutes, free, and it will tell you which of the other 11 dates catch you as well and in what order they have to be done. Sequencing is most of the cost on these programmes.