The answer for 2026: B2B and B2G at the same time in a nutshell
No. In Estonia, e-invoices will not be mandatory for every B2B invoice in 2026. Section 7¹, subsection 7, of the Accounting Act gives the right to request an e-invoice only to those companies that have registered themselves as e-invoice recipients in the commercial register. If your client has not done so, you may continue to send a PDF invoice or an invoice in another agreed format. In the case of public sector institutions, the story is different: they are all already listed in the register as e-invoice recipients, so European Commission's overview of Estonia The previous e-invoice practice, which began on July 1, 2019, will essentially continue. In short: in B2B, the buyer's registration decides, in B2G, the answer is still yes in practice.
| B2B (business to business) | B2G (public sector as buyer) | |
|---|---|---|
| Is e-invoice mandatory? | Only if the buyer is registered as an e-invoice recipient | In practice, yes, all public sector entities are on the register. |
| Legal basis | Accounting Act §7¹(7) | The same provision applies to all accounting entities. |
| How to check | RIK's free inquiry about e-invoice recipients | Expect an e-invoice unless otherwise agreed in writing. |
| If the buyer does not require | Free form (PDF, paper, other agreement) | Agreement on exemption allowed after 2025 amendment |
| Default standard | EN 16931 is assumed to be correctly formatted | Same |
What changed on July 1, 2025?
Until the summer of 2025, a separate provision in the Accounting Act applied only to public sector buyers. The B2G e-invoice obligation has been in effect in Estonia since 1 July 2019, as confirmed by European Commission eInvoicing overview. With the amendment to the Accounting Act, published under number RT I, 10.10.2024, 1, this specific provision was replaced by a more general, register-based rule: the “buyer chooses” principle now applies to all accounting entities, not just state authorities. In essence, this means that B2G and B2B now fall under the same section. The difference is not the sector, but whether a specific buyer has registered as a recipient.
B2B: when can an Estonian company request an e-invoice?
If your client is an Estonian company, the first question is simple: has it registered as an e-invoice recipient in the commercial register or not? Explanation from the Ministry of Finance According to the law, all accounting entities will have this right from July 1, 2025, and as of January 12, 2026, approximately 18,000 companies have registered.
Check it yourself, not by believing the customer. RIK's free inquiry about e-invoice recipients, whose query name is arireg.earveRegistriParing_v1, returns the recipient's status and their service provider ID based on the registry code, and no contract is required to use it.
- Check: enter the client's registry code into the RIK query and see if the response is "OK".
- Send a structured e-invoice: Once the customer is registered, receive the invoice via their specified channel or operator, not via email as a PDF.
- Please agree in writing if you would like a different format: The Accounting Act allows the parties to agree on a different format or standard. Write this agreement down somewhere, it doesn't have to be verbal.
If the buyer is not registered as a recipient, you are not obligated to create an e-invoice at all. The PDF invoice still works.
B2G: Why expect an e-invoice from a public sector partner?
State and local government agencies were recipients of e-invoices even before the 2025 change. According to the European Commission The B2G e-invoice obligation in Estonia has been in effect since July 1, 2019. After the 2025 change, all public sector entities remained listed in the commercial register as e-invoice recipients, and Explanation from the Ministry of Finance according to the previous regime, they will essentially continue to be subject to the previous regime. The difference from before: after the change, public sector institutions are no longer prohibited from making exceptions and accepting invoices in other formats if they wish. In practice, this means the same thing for you: if you sell to a state institution or local government, expect an e-invoice until you have written confirmation that they agree to something else.
Which format and sending method is correct: EN 16931, Estonian XML, PDF or Peppol?
An e-invoice is not a PDF sent by email. Explanation from the Ministry of Finance According to the e-invoice standard, an e-invoice is a digitally originally created, standardized, and machine-readable file. A PDF is only an image of the invoice, not an e-invoice. This distinction is important because many companies assume that a PDF sent via email already meets the requirement.
According to the Accounting Act, it is assumed To European standard EN 16931-1 (i.e. the European e-invoice standard and machine-readable requirement) will automatically be correctly formatted. The parties may also agree on another suitable standard, such as the Estonian local e-invoice XML format, which is still in use in parallel with the European standard.
Peppol is a separate topic here, which is worth clarifying: Peppol is a secure invoice transmission network, not a legal obligation. European Commission overview According to the Estonian government, Estonia uses a decentralized model where companies receive e-invoices through private operators (e.g. Telema, Finbite, Billberry, Unifiedpost, E-arveldaja), and the state does not require the Peppol channel to be the only one allowed. This is one possible connection channel among others.
Is there a limit for e-invoices, or will the KMD INF remain at 1,000 euros?
This is where most of the confusion comes in: the accounting law does not have any limit on the e-invoice obligation. §7¹ paragraph 7 There is no euro amount. The trigger is only the registered status of the buyer, not the invoice amount.
This is a different rule than the VAT return annex, known by the abbreviation KMD INF. KMD INF form instructions According to the VAT return, the data on invoices issued to legal entities, sole proprietors, and state, rural municipality, and city authorities, on which the turnover taxable at the VAT rates of 24%, 13%, and 9% is indicated, are reflected in the appendix to the VAT return, if the total amount of the invoices, excluding VAT, is at least 1,000 euros per tax period and transaction partner. Invoices issued to private individuals are not reflected there.
So the 1,000 euros concerns tax reporting, not the creation of an e-invoice obligation. These are two different laws and two different processes that tend to get confused.
What can change: what will Estonia's 2027 plan and the EU ViDA bring?
You have to be careful with the wording here, because two separate things are moving in parallel.
Within Estonia, the Ministry of Finance has proposed to abolish the 1000-euro threshold of the KMD INF and make e-invoicing mandatory for all VAT payers. The exact year of entry into force is not confirmed by any of the official sources cited here, so it must be considered an unconfirmed plan for now. This is currently policy development, not a valid law. The draft has not yet been adopted, so it cannot be claimed in 2026 that a universal B2B e-invoicing obligation is already in force or is firmly fixed for entry into force.
At the EU level, a separate process called ViDA (VAT in the Digital Age), or the package for adapting the VAT system to the digital age, is underway. European Commission Work Plan 2026 announcement According to the EU’s digital reporting requirements for cross-border B2B transactions, i.e. the rules based on mandatory e-invoicing, will enter into force on 1 July 2030, and e-invoicing will become the default method of payment for cross-border transactions from that date. This deadline concerns cross-border trade within the EU, not directly B2B turnover within Estonia. Estonia’s proposed domestic amendment and the EU’s 2030 ViDA deadline are not the same reform and should not be conflated.
FAQ
Will e-invoice be mandatory for every B2B invoice in 2026?
No, an e-invoice is only mandatory if the buyer has registered as an e-invoice recipient in the commercial register. If the customer is not registered, a PDF invoice or other agreed format can be sent.
What changed on July 1, 2025?
The amendment to the Accounting Act replaced the special provision for the public sector with a more general register-based rule. The 'buyer chooses' principle now applies to all accounting entities, not just state institutions.
How to check if a customer is the recipient of an e-invoice?
Use the free RIK query arireg.earveRegistriParing_v1. Enter the client registry code and see if the response is 'OK'. The query does not require a contract.
Is there a limit for e-invoices?
No, there is no limit on the amount of the e-invoice obligation in the Accounting Act. The 1,000 euro limit only applies to KMD INF tax reporting, not to the creation of the e-invoice obligation.