E-invoices in Lithuania 2027: what is mandatory for a small business

No. 2027 will not bring an e-invoicing obligation for all small businesses in Lithuania. European Commission Lithuania overview, approved on 14.08.2025, says it out loud, that e-invoicing is mandatory in public procurement (B2G) from 1 July 2017, but there is no obligation for business-to-business (B2B) and consumer invoices (B2C). Also, the Lithuanian Tax Board VMI Summary of changes for 2027 talks about something else: Law No. XV-1036, adopted on 18.06.2026, concerns online marketplaces, OSS and distance selling, not the structured invoice obligation.

Your micro or small business is now subject to an older rule. If the client is a Lithuanian public sector institution, the invoice must be submitted to the SABIS system – and from 01.01.2025, even if the agreement was oral and the amount is 120 euros.

Will 2027 bring e-invoicing obligation for everyone in Lithuania?

The confusion arises from putting three completely different things on one calendar. When you break them apart, the picture becomes clear.

The first layer is public procurement. On the Commission's Lithuanian page, the B2G obligation is marked as "YES" and the B2B and B2C obligations as "NO". The obligation applies both below and above the EU procurement threshold and the entire public sector - national, regional and local - must accept e-invoices via SABIS, which is connected to the Peppoli network and follows the European e-invoice standard EN 16931, i.e. the Common Data Model for Machine-Readable Invoices. E-invoicing is still a matter of agreement between private companies.

The second layer is the VAT Act. The VMI announces that Act No. XV-1036, amending the VAT Act No. IX-751, will enter into force on 1 January 2027 – with the exception of Articles 1, 3, 5–7, 9 and 10, which will enter into force only on 1 July 2029. The content is that online marketplaces will become deemed suppliers to a wider extent than before, the scope of the OSS special scheme will be expanded, the calculation of the EUR 10,000 threshold for distance sales will be clarified, and the IOSS will no longer be available to those implementing the small business scheme in Lithuania. There is no line there regarding the obligation to issue a structured invoice.

The third layer is the EU framework: Council Directive (EU) 2025/516 of 11 March 2025, which Lithuania has just adopted with this legislative amendment. The „Next steps“ section of the Commission’s Lithuanian page lists 1 January 2028 as the target date for mandatory e-invoicing. Note: this is a target date, not a deadline that has come into force – I cannot refer to the Lithuanian legislation that would establish this, as I have not identified it.

Who you bill: decision table

The seller's VAT status does not determine anything here. A non-VAT-liable major contractor (MB) must also submit an invoice to a public sector buyer in SABIS. The type of buyer and the form of the contract are decisive.

Buyer	Sample invoice	What is mandatory	Channel
Lithuanian private company (UAB, MB)	€1,200	There is no obligation to use an e-invoice, format by agreement	Email, operator or Peppol
Private consumer	€120	There is no obligation.	Free choice
Public sector buyer, written contract	€1,200	Structured invoice to SABIS; the contract must be in SABIS, linked to the vendor, and the contract number on the invoice must match	Portal, Universal Interface or Peppol
Same buyer, verbal agreement	€120	SABIS also for small amounts, from 01.01.2025	The role of the oral invoice registrar in the portal or Peppol

The requirements for a written contract and the conditions for submission through Peppoli are listed In the official SABIS FAQ section. In the case of an oral agreement invoice, the authorized user on the buyer's side, when checking or approving the invoice, fills in the BVPŽ procurement classification (Lithuanian Public Procurement Nomenclature) and the purchase type or indicates that the invoice will not be disclosed. For you, this means one thing: if the buyer's side does not move, the invoice will not reach completion.

SABIS deadlines: what is already in effect

The main obligation dates from July 1, 2017. The SABIS guidance materials refer to Article 6(4) of the Financial Accounting Act No. IX-574, Government Regulation No. 405 of 27.04.2022, and Amendment No. XIII-327 to the Public Procurement Act as the legal basis.

Then the platform changed. From the perspective of the public procurement supplier, the exact order in which the Vieššųjų pirkimų tarnyba 22.08.2024 wrote in the message: the previous system E. säätta became unavailable on 30.08.2024 and SABIS began full operation on 01.09.2024. This was not an instantaneous or frictionless transition, as is sometimes described in retrospect.

The third change is the one that micro-enterprises stumble over most often today. There was a temporary exemption of 1,000 euros excluding VAT for invoices from oral procurement contracts – and this exemption expired on 31.12.2024. From 01.01.2025, data on such invoices must be submitted to SABIS regardless of the amount. This is not a permanent benefit for small businesses that will continue to apply.

Free portal, interface or Peppol

Data can be entered into SABIS in three ways: via the portal, where data is entered manually or imported as an XML file; via the universal interface directly from the business software; or via Peppol, if the organization is a member of this network. The formats used are Peppol BIS Billing 3.0 e-invoice and credit note.

One thing needs to be made clear right away: a PDF invoice does not replace data submission. Invoice data must reach the system in a structured format, i.e. XML, documents can be added as attachments. A beautiful PDF in the attachment box is not an invoice submitted in the sense of SABIS.

SABIS itself is currently free to use, and the portal, interface and Peppol are alternative routes – however, the official guide does not promise that the fee and prices for third-party services will remain the same in the future. The choice is made by volume, not price. A few invoices per month to a state agency – the portal is the easiest. Dozens of invoices, recurring contracts, your own accounting software – then the interface or Peppol is worth it, because manual double entry eats up time in terms of accuracy as long as you do it.

Another practical pitfall is access. In the first case, the head of the legal entity registers the organization in SABIS using the VIISP-tapaviivastus service, after which an organization account and a user with the administrator role are created. The submitted access request (prieigos prašymas) can be The organization administrator can review and approve or reject it according to the SABIS user guide.. The roles are narrow: invoices for written contracts are entered by an invoice registrar, verbal invoices by an oral invoice registrar, and both by a supplier specialist.

Estonian company invoicing a Lithuanian public sector buyer

Foreign suppliers will not be able to log in to the SABIS portal in the near future. For Estonian OÜ, this means that the invoice must be sent via the Peppol network, choosing the appropriate access point. In the case of an invoice submitted based on a written contract, the contract information must already be in SABIS, be related to that particular seller, and the contract number on the invoice must match the contract. If the number is wrong or the contract is not in the system, even a technically correct Peppol invoice will not help.

i.SAF is not sending an invoice to the customer

These two things are constantly confused. i.SAF is a VMI system where registers of received and issued invoices, i.e. lists of received and issued VAT invoices, are submitted to the tax authorities. It has nothing to do with delivering the invoice to the customer.

VMI according to the instructions A legal entity must submit the registers for the tax period by the 20th day of the following month (valid from 01.07.2019), a natural person must submit the registers by the 20th day of the first month of the following half-year or by month if they submit a monthly VAT return. When deleting from the register of VAT payers, the data must be provided within 20 days. The legal basis is the decree of the Head of the VMI of 21.04.2004 No. VA-55.

There are two important exceptions for small businesses. Users of the Lithuanian Small Business Scheme (smulkiojo verslo schema) are exempt from submitting invoice registers, and non-VAT taxpayers do not submit these registers either. However, this does not exempt you from SABIS if you sell to the public sector. Conversely, submitting an usin i.SAF does not count as an invoice being submitted to the customer.

2027, 2028 and 2030: what to do now

Three years, three different statuses.

• In force: public sector invoices to SABIS from 01.07.2017, SABIS platform from 01.09.2024, invoices from oral agreements regardless of the amount from 01.01.2025.
• Accepted, but of different content: Amendment No. XV-1036 to the VAT Act will enter into force on 01.01.2027 and some articles on 01.07.2029. This is a takeover of ViDA, not an e-invoice obligation.
• Target date, not deadline: 01.01.2028, as the Commission's Lithuanian page calls it.
• 2030: The Lithuanian sources I cite here do not mention this year. If someone sells you a „2030 commitment“ in Lithuania, ask for the legal act number.

With this knowledge, you can prepare without having to think about a deadline. Five points that are worth going over and writing down in a document:

• Customers classified: Which of your buyers is a public sector institution? They are invoiced to SABIS, the rest by agreement.
• Channel selected: portal, universal interface or Peppol – and Peppol in practice for Estonian companies.
• Access owner known: who registered the organization, who is the administrator, and who has the registrar role. Vacation or resignation should not stop invoicing.
• Contract details in order: contract in SABIS, linked to the correct seller, same number on the invoice.
• Reporting responsibility in place: who submits i.SAF records by the 20th of the following month or knows that your company is under an exemption.

Read also: English · Lithuanian

Last checked: September 16, 2026

FAQ

Will e-invoicing become mandatory for all companies in Lithuania in 2027?

No, there will be no general B2B or B2C e-invoicing obligation in Lithuania in 2027. Amendment No. XV-1036 to the VAT Act concerns online marketplaces and the OSS regime, while business-to-business invoicing remains subject to agreement between the contracting parties.

When is the use of the SABIS system mandatory in Lithuania?

SABIS is mandatory for all settlements with Lithuanian public sector institutions from 1 July 2017. From 1 January 2025, the requirement will also apply to invoices submitted based on oral agreements, regardless of the transaction amount.

How can an Estonian company submit an e-invoice to the Lithuanian public sector?

Since the foreign company does not have direct access to the SABIS portal, the e-invoice must be sent via the Peppol network in Peppol BIS Billing 3.0 format. In the case of a written contract, the contract number on the invoice must exactly match the number entered in SABIS.