B2B e-invoicing mandates in Europe 2026 to 2028: does your Dutch BV have to comply?

The rule that decides: where is your company established?

An e-invoicing mandate is a national rule under the EU VAT Directive. Since 14 April 2025, Directive (EU) 2025/516 (ViDA) lets a member state require domestic e-invoicing for taxable persons established on its territory, and the customer can refuse a structured invoice only where national law says so. That word, established, is the test: a seat, a place of management or a permanent establishment in that country. A VAT registration alone, through direct identification or a fiscal representative, creates an obligation to report and pay VAT there, and in most countries it leaves you outside the e-invoicing mandate.

The test cuts both ways. A Dutch BV with a warehouse and staff in Germany can have a permanent establishment there and then falls under the German mandate for the supplies of that establishment. A Dutch BV that uses a German fulfilment partner, with the stock in the partner’s warehouse and the decisions taken in the Netherlands, usually keeps its only establishment in the Netherlands. The facts decide, and they decide the corporate tax position as well. See substance requirements for a Dutch BV.

ViDA: the EU timeline every Dutch BV follows

• 14 April 2025. Directive (EU) 2025/516 in force. Member states may mandate domestic e-invoicing for established businesses.
• 1 January 2027. Clarifications in the one-stop shop (OSS) and the import one-stop shop (IOSS); revised OSS guidelines of 24 July 2026 and Implementing Regulation (EU) 2026/1869 of 28 July 2026 on the transfer of own goods.
• 1 July 2028. Single VAT registration: the OSS extends to domestic supplies by businesses established elsewhere and to transfers of own stock; the reverse charge becomes mandatory when a supplier that is established elsewhere sells to a customer that is VAT-identified in that country; platforms for short-term accommodation and road passenger transport become deemed suppliers (a member state may postpone that part to 1 January 2030).
• 1 July 2029. The call-off stock simplification ends.
• 1 July 2030. Electronic invoices become the standard for cross-border B2B supplies within the EU, with digital reporting per transaction; the EC sales list ends. The Dutch domestic mandate starts the same day.
• 1 January 2035. Countries with an older domestic real-time system (Italy, among others) must have connected it to the EU standard.

For a Dutch BV with stock in several EU countries, the 2028 step is the big one: many foreign VAT registrations can end, while the invoicing and reporting go into the Dutch return. We cover this in the EU VAT route finder and in Dutch VAT registration and the OSS return.

What to prepare now, in order

1. Map your establishments. Where does your BV have staff, premises or management decisions outside the Netherlands? Those countries decide which mandates bind you. The rest is customer demand.
2. Choose software that produces EN 16931 invoices and connects to Peppol. Belgium runs on Peppol today; German customers accept XRechnung and ZUGFeRD; the Netherlands will decide its exchange model before the 2030 start. Most Dutch bookkeeping packages already deliver this. See choosing Dutch bookkeeping software.
3. Agree the format with large customers in France and Germany. Their platforms set the format from September 2026 and January 2027. A supplier that sends the right format gets paid faster; that is the practical gain, before any mandate.
4. Prepare for structured invoices from suppliers. Polish, Italian and Croatian suppliers issue through their national systems; your bookkeeping must read those files and keep them for the Dutch retention period of seven years (ten years for real estate).
5. Plan the 2028 VAT clean-up. List your foreign VAT registrations and check which ones the single VAT registration makes redundant from 1 July 2028. Deregistering early saves filings and fees.
6. Keep the invoice content right in every country. E-invoicing changes the format, the mandatory content stays: VAT numbers, the reverse-charge reference, the OSS or import reference. See Dutch invoice requirements.

The Netherlands: what the cabinet decided on 11 September 2026

The Dutch cabinet chose the EU option, as France, Germany, Belgium, Poland and Italy did: mandatory e-invoicing for B2B transactions, domestic and cross-border, from 1 July 2030, and digital reporting of domestic transactions from 1 July 2031. Businesses in the small business scheme (turnover up to €20,000 a year) stay exempt. The tax administration keeps the data for ten years; data protection is a hard condition in the decision. The draft bill goes to public consultation in the autumn of 2026 and to the House of Representatives before the summer of 2027. The exchange model is still open; Peppol, already used for invoices to the Dutch government, is the obvious candidate.

For a new Dutch BV this means one choice today: bookkeeping software that can send and receive structured invoices. Everything else can wait for the bill. Our corporate services team sets up the bookkeeping with that in mind.

Questions founders ask

Sources

• Directive (EU) 2025/516 (ViDA): eur-lex.europa.eu; European Commission, VAT in the Digital Age: taxation-customs.ec.europa.eu
• Germany, Federal Ministry of Finance, FAQ E-Rechnung: bundesfinanzministerium.de
• France, impots.gouv.fr, la facturation électronique: impots.gouv.fr
• Belgium, FPS Finance, B2B e-invoicing FAQ: einvoice.belgium.be
• Poland, Ministry of Finance, KSeF implementation plan: gov.pl
• Italy, European Commission country page: ec.europa.eu
• Spain, Agencia Tributaria, Verifactu: sede.agenciatributaria.gob.es
• Greece, AADE, mandatory electronic invoicing FAQ: aade.gr
• Croatia, Tax Administration, Fiskalizacija eRačuna: porezna-uprava.gov.hr
• Latvia, Romania, Slovenia, Portugal: European Commission eInvoicing country sheets 2026: ec.europa.eu
• Denmark, Danish Business Authority, digital bookkeeping: erhvervsstyrelsen.dk
• Netherlands, Government of the Netherlands, cabinet decision of 11 September 2026: rijksoverheid.nl; KVK background: kvk.nl