In short: EN 16931:2026 exists, but Peppol does not use it yet

As of 15 August 2026, the short answer is: no, not yet. European Commission according to a published review The new version of the European e-invoice data model EN 16931-1:2026 was published in May 2026 and the 2017 version was officially cancelled. However, the 2017 model will still be valid during the transition period. Peppol BIS Billing 3.0 becomes mandatory version 3.0.21, which will take effect on August 17, 2026, will still identify invoices as compliant with the 2017 standard, not the new one. What this means for your business is that August 17 did not bring a format change, but improvements within the existing 2017 model.

What is EN 16931 if it is not a transmission channel or a file format?

EN 16931 describes what data should be included in an invoice. It is a semantic data model, i.e. an agreement on the meaning of the invoice, not its appearance, which European Standards Organisation CEN has established. Peppol adds to it a transmission network, identifiers and validation rules, UBL XML (Universal Invoice Markup Language) is one of the possible file formats in which this data model is expressed. A PDF invoice is not a structured e-invoice, because a machine cannot automatically read and process its content.

What changes with the EN 16931-1:2026 version and what remains the same?

The driving force behind the revision is ViDA, the EU VAT Directive Amendment, which text requires e-invoices to comply with the European e-invoice standard and its listed syntaxes. This part will enter into force on 1 July 2030. The publication of a new version of the standard does not in itself mean that all businesses should switch tomorrow: the Commission according to the same page Migration plans are still being developed in the Member States and no general deadline has been set.

How do I know if Peppol is already using EN 16931:2026?

Version 3.0.21 published on May 20, 2026 and will become mandatory on August 17, 2026, bringing a new optional profile for invoice response and updated code lists. However, the decisive factor is the invoice field CustomizationID, which technical rule still requires an identifier that starts with „urn:cen.eu:en16931:2017#compliant”. Until this identifier changes, Peppol has not adopted EN 16931:2026. The name „2026 release” does not change this fact.

What does this mean in Estonia and Latvia?

In Estonia, a company listed in the business register as the recipient of an e-invoice may request an e-invoice from its supplier from 1 July 2025; Accounting Act assumes that the invoice complies with the requirements if it complies with EN 16931-1, but the parties may also agree on another suitable standard. In Latvia, a structured e-invoice must be in XML format and comply with the PEPPOL BIS Billing 3.0 specification; According to VID data e-invoicing is mandatory in the G2G/B2G/G2B segment from January 1, 2025, data transmission to VID from January 1, 2026, and in B2B transactions and the obligation of full VID reporting will enter into force from January 1, 2028.

A 30-minute checklist for your billing software

Before changing export settings or interfaces, ask your software provider directly:

  • What Peppol BIS Billing 3.0 version and CustomizationID value are we sending today?
  • Will the August 17, 2026 update be applied automatically, or does it require action on our part?
  • Do outgoing UBL invoices and credit notes go through validation before being sent?
  • What is the provider's roadmap for transitioning to EN 16931:2026?

Peppol invoices destined for Latvia must therefore currently undergo validation according to the 2017 model, as the CustomizationID still refers to this version. This will not change on August 17, even if invoice content, such as VAT breakdown and reference numbers, is validated according to the updated rules.

FAQ

Does Peppol already use the EN 16931:2026 standard?

No, as of August 15, 2026, it is not used. Peppoli version 3.0.21, which will become mandatory on August 17, 2026, will still identify invoices according to the 2017 standard. This is indicated by the CustomizationID field in the invoice, which requires the identifier "urn:cen.eu:en16931:2017#compliant".

What is the difference between EN 16931 and Peppol?

EN 16931 is a European standard that describes what data should essentially be on an invoice – it is a semantic data model. Peppol adds to it a transmission network, identifiers and validation rules. UBL XML is one of the possible file formats in which this data model is expressed.

What does EN 16931:2026 mean for Estonian and Latvian companies?

In Estonia, a company can request an e-invoice from a supplier from 1 July 2025, which must comply with the EN 16931-1 standard. In Latvia, a structured e-invoice must be in XML format and comply with the PEPPOL BIS Billing 3.0 specification. In both cases, the 2017 model is currently valid.

When will EN 16931:2026 become mandatory?

According to the European Commission, migration plans are still being developed in the Member States and no general deadline has been set. The ViDA Directive requires e-invoices to comply with the European e-invoice standard from 1 July 2030.