E-invoice obligation in Estonia 2026: when do you have to send it?

No, there is no general obligation to send e-invoices for Estonian small businesses in 2026. The buyer decides: Amendment to § 7¹ of the Accounting Act, which entered into force on 1 July 2025 According to the law, only a customer who has registered as an e-invoice recipient in the e-Business Register may request an e-invoice from a seller. If your customer is not listed there, the agreed invoice form is sufficient. Explanation from the Ministry of Finance According to the law, this "buyer chooses" principle applies to both private and public sector customers, but public sector institutions are already listed in the register as recipients of e-invoices, so the previous procedure essentially continues for them.

When can a customer request an e-invoice?

A private sector customer has the right to request an e-invoice only if he/she has In the e-Business Register registered as the recipient of the e-invoice. This entry is public and is worth reviewing before creating the invoice, as it also shows the data of the receiving channel. The same law § 7¹ subsection 7 According to the European e-invoice standard EN 16931-1, an e-invoice is considered to be compliant if it complies with the European e-invoicing standard EN 16931-1, which is the common machine-readable standard underlying the Peppol format, but the parties may also agree on another standard, such as the local Estonian e-invoice format. If the customer is not listed in the register, he has no legal basis to request an e-invoice and the parties may use the usual invoice format, including a PDF invoice sent by email.

How is a PDF invoice different from a public sector e-invoice?

Because In the e-Business Register if all public sector entities are already registered as recipients of e-invoices, then in their case, the previous e-invoicing regime will essentially continue. The difference with the previous one is that From July 1, 2025 These institutions may allow other forms of invoices if necessary, but this was previously prohibited. It is important to distinguish between a machine-readable e-invoice and a regular one. PDF invoice, which is essentially an image and does not allow for automatic data transfer to the buyer's system. A PDF sent in a letter will not become an e-invoice even if the customer is a large company - the format is determined by the standard, not the sending channel.

Does turnover or VAT affect the obligation to issue e-invoices?

A company's turnover, VAT liability or number of employees does not affect the e-invoice obligation, because law does not provide a separate limit for this. Confusion often arises KMD INF 1000 euro limit: this concerns which invoices you must declare in the VAT return annex per transaction partner in the tax period, not in what form the invoice should be issued.

What is planned for 2027 and 2030?

Ministry of Finance has proposed a general e-invoice obligation for VAT payers and the abolition of the 1,000 euro limit, naming 2027 as a possible entry into force. This is still a draft intention, not a valid law, and should not be considered as an already valid deadline at this time. The only certainty is Council Directive (EU) 2025/516 Deadline: From July 1, 2030, e-invoices will become mandatory for cross-border B2B transactions in the EU. This rule does not apply to invoices within Estonia.

FAQ

Will there be a general obligation for small businesses in Estonia to send e-invoices in 2026?

No. A general obligation to send e-invoices will not be imposed on Estonian small businesses in 2026, because the buyer's registration in the e-Business Register, not the company's turnover or the KMD INF limit, will decide.

When can a private (private sector) customer request an e-invoice in 2026?

A private sector customer may only request an e-invoice if they are registered as an e-invoice recipient in the e-Business Register. If the customer is not registered, they have no legal basis to request an e-invoice and may use the agreed invoice form.

Does the KMD INF 1000-euro limit affect the e-invoice obligation?

No impact. The KMD INF 1,000 euro limit concerns which invoices must be declared in the appendix to the VAT return per transaction partner, not the form in which the invoice should be issued.

What will change in e-invoicing in the EU by 2030?

From July 1, 2030, e-invoices will become mandatory for cross-border B2B transactions in the EU. This rule does not apply to invoices within Estonia.