Managing e-Invoicing compliance when entities are live at different phases
Digital Content Manager at Medius
- Your entities are not on the same timeline
- Where does each mandate actually stand right now?
- Why do receiving and issuing obligations arrive separately?
- Dual-track AP is now the default operating mode
- Design the workflow around the strictest entity
- How do you keep processing invoices from suppliers who are not ready?
- January 1, 2027 is the next date that changes your workflow
- Running it as one workflow, not four projects
Your entities are not on the same timeline
Most guidance on phased rollouts assumes the phasing was your decision. Pick a pilot entity, learn from it, extend to the next region. That framing does not describe what many multinational AP teams are actually managing right now.
Four tax authorities, working independently of each other, have placed your entities into as many as four different compliance states at the same time. A Belgian subsidiary has been under active enforcement since April. A French entity crossed its go-live on September 1. A German entity can still expect PDFs from most of its suppliers. A Polish entity is legally obligated but not yet financially exposed. None of these entities is behind schedule. Each one is exactly where the law puts it.
The AP team processing invoices for all four absorbs the difference. Understanding how e-Invoicing mandates work country by country is the easy part. Running one payables process across four of them at once is the part nobody hands you a playbook for.
Where does each mandate actually stand right now?
Four jurisdictions, four positions on the curve:
Belgium
Structured invoicing over Peppol has been mandatory for domestic B2B between Belgian-established businesses since January 1, 2026. The tolerance window closed on March 31, and progressive penalties of 1,500, 3,000, and 5,000 EUR have applied since April 1. Entities holding a Belgian VAT number without establishment in Belgium fall outside the scope.
France
As of September 1, 2026, every VAT-registered business established in France must be able to receive structured invoices through an accredited platform. Large and intermediate businesses must also issue and submit e-reporting data, with small and medium businesses following on September 1, 2027. The tax authority has confirmed no postponement, though it will not apply penalties automatically where a company can document a genuine compliance effort. Medius supports France's e-Invoicing mandate as an approved platform.
Germany
The receiving obligation has been in force since January 1, 2025. Issuing becomes mandatory on January 1, 2027 for businesses above 800,000 EUR in prior-year turnover, and on January 1, 2028 for everyone else. Invoices under 250 EUR stay out of scope.
Poland
KSeF became mandatory on February 1, 2026 for taxpayers above 200 million PLN in 2024 sales, and on April 1, 2026 for all other VAT-registered businesses. Penalties do not apply until January 1, 2027, at which point they reach up to 100% of the VAT shown on a non-compliant invoice.
Why do receiving and issuing obligations arrive separately?
Nearly every mandate splits the obligation in two, requiring businesses to receive structured invoices well before requiring them to issue any. That gap runs one year in Belgium and two full years in Germany.
The sequencing is deliberate. It builds a base of capable recipients so that when issuers switch on, the invoices have somewhere to land. For AR teams, it reads as a manageable preparation curve. For AP, it creates the operational problem, because receiving is the AP-side obligation and it always lands first.
The result is an intake function running different rules per entity. Your French entity had to accept structured invoices through an accredited platform starting September 1, whether or not it issued a single one. Your German entity has been able to accept them since 2025, but most of its suppliers will keep sending PDFs until their own issuing obligation arrives in January. Same team, same week, opposite assumptions about what shows up.
Dual-track AP is now the default operating mode
Running legacy and structured intake side by side is not a transition state to push through. With mandates staggered from 2025 to 2028 across a single European footprint, it is the operating model for the next several years. Four things make it hold up:
An entity status registry: Keep a record of every legal entity with its receiving status, issuing status, enforcement date, and required format. Treat it as master data rather than documentation, and have routing logic read from it directly.
Routing keyed to entity status, not country: A rule that says “France” breaks in September 2027 when the second phase lands. A rule that reads the entity’s current obligation state does not.
Supplier readiness flags: Track which suppliers are issuing structured invoices and which are still sending PDFs. Without this, AP cannot tell a supplier who is late from one who is not yet obligated.
Sandbox access ahead of each phase: Testing environments for upcoming mandates need to be available while live entities run in production. Validating a January configuration in December leaves no room to fix what the test finds.
The trade-offs between staggered and simultaneous go-lives cut in both directions. Medius research on mandate rollout approaches found that 42% of finance professionals anticipate significant disruptions during a big bang go-live, while 25% report severe confusion during phased rollouts. Neither model is safe by default.
Your quick guide to global e-invoicing deadlines
E-invoicing mandates are accelerating worldwide. This cheat sheet gives you a clear, at-a-glance view of which mandates apply where, helping you plan with confidence.
Design the workflow around the strictest entity
When entities sit at different stages, the instinct is to build the process around the least demanding one and bolt on exceptions as each new mandate lands. That produces a different AP process per country and a rebuild every time a phase date passes.
The alternative is to build once against the strictest requirement in your footprint and let entities with lighter obligations run inside it. If the workflow already captures structured invoice data, validates it, and stores it in its original format with a full audit trail, then a German entity moving from receive-only to issuing in January becomes a configuration change instead of a project.
Platform architecture matters more here than the length of a country coverage list. A platform that adds each jurisdiction as a separate module produces the fragmented outcome by design. One that treats country variation as configuration inside a single workflow does not. The criteria that separate the two are worth working through before the next phase date rather than after it.
How do you keep processing invoices from suppliers who are not ready?
Supplier readiness is the part of the timeline you do not control. A German supplier below the turnover threshold has no obligation to issue structured invoices until 2028 and is entitled to keep sending PDFs. Rejecting those invoices is not a compliance position, it is a broken payables process. What works instead:
Segment suppliers by their own obligation date rather than by yours, since a supplier’s requirement follows the rules where they are established, not where their customer sits.
Keep a compliant PDF and paper intake path open for as long as any supplier in scope is legally permitted to use one, which in Germany means through the end of 2027.
Give suppliers correct routing details well ahead of their go-live. In France, invoices sent to the wrong platform address are rejected, and a rejection at the platform layer is invisible to a supplier who assumes delivery succeeded.
Watch the switchover itself. Periods when intake channels change and suppliers update bank and routing details are exactly when payment fraud risk rises.
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January 1, 2027 is the next date that changes your workflow
Three of the four mandates move on the same day. Germany’s issuing obligation begins for businesses above the turnover threshold, which means your German entity’s larger suppliers stop sending PDFs. Poland’s penalty suspension ends, converting an existing obligation into financial exposure of up to 100% of the VAT on a non-compliant invoice. Poland also begins requiring the KSeF number on payment references.
That last one is the easiest to miss, because it is not an invoicing change at all. It sits in the payment run rather than in invoice intake, and a team working from an invoicing readiness checklist will not find it there.
That leaves roughly four months to configure and test three changes across two entities, while a Belgian entity stays under active enforcement and a French entity works through its first weeks live.
Running it as one workflow, not four projects
Whether an entity is under active enforcement, newly live, or counting down to January, it doesn’t have to run as its own separate project. Medius centralizes global e-Invoicing mandate compliance inside a single AP automation platform, so entities at different stages run one workflow rather than one project per jurisdiction.
Book a demo to map your own entity timeline against the January deadlines.
