No, there is no separate mandatory e-invoice format in Latvia, which PEPPOL BIS Billing 3.0 would replace. Cabinet of Ministers Regulations No. 749 of 9 December 2025 stipulate that the XML structure of an e-invoice submitted to the VID (Latvian Tax Board) must meet two requirements at once: it must be written in UBL 2.1 syntax (Universal Business Language, i.e. a specific XML file format) and comply with the rules of the PEPPOL BIS Billing 3.0 specification. Latvian Tax Board confirms on your e-invoice page, that there are no plans to expand this format. Each company must adapt its system to the PEPPOL BIS Billing 3.0 rules, not the other way around. B2G, or business-to-government, e-invoices and the submission of their data to the VID are already mandatory, while the obligation for B2B, or business-to-business, invoices will only come into effect on January 1, 2028.
Short answer: does Latvia have an e-invoice format that replaces PEPPOL?
A common misconception is that Latvia has its own “national” e-invoice format that differs from the PEPPOL standard. In reality, the opposite is true. Regulations No. 749 specify that the XML of the e-invoice received in the VID solution must be written in UBL 2.1 syntax and comply with the business and validation rules of PEPPOL BIS Billing 3.0. In other words, Latvia did not create a competing format, but adopted PEPPOL BIS Billing 3.0 as its official profile. If your accounting software can already create PEPPOL-compliant e-invoices, the technical basis for meeting Latvia's requirements is already in place. All that is missing is the correct data transmission channel to VID, which will be discussed below.
Three layers that are often confused: EN 16931, UBL and PEPPOL
The confusion arises because the three terms describe three different layers of e-invoicing, not three competing things.
- EN 16931 is a semantic data model, i.e. a description of which data fields must be present on the invoice: seller and buyer information, VAT, payment term, amounts. Accounting law This standard defines structured e-invoices: the invoice must comply with the LVS EN 16931-1:2017 standard.
- UBL 2.1 is XML syntax, a specific file format and markup language in which EN 16931 data fields are written. UBL itself does not yet say anything about whether the invoice complies with Latvian requirements; it is simply the “language” in which the invoice is written.
- PEPPOL BIS Billing 3.0 is the so-called CIUS, or Core Invoice Usage Specification, a narrowed user guide that says how to exactly use the EN 16931 data model in UBL 2.1 syntax, and adds validation rules. PEPPOL BIS Billing 3.0 documentation confirms that all documents in accordance with this specification are automatically also in accordance with the European standard EN 16931.
Imagine an invoice for 1500 euros. EN 16931 specifies which data fields must be present on this invoice, such as amounts and invoice parties. UBL 2.1 specifies which XML element this amount is in. PEPPOL BIS Billing 3.0 adds a rule that this amount must match the invoice lines and VAT amount. Otherwise, the invoice validation will fail.
Which formats theoretically comply with the EU standard and what does the Latvian VID actually accept?
At the EU level, both UBL 2.1 and UN/CEFACT CII D16B are suitable as syntax for EN 16931. European Commission overview calls both the corresponding syntax. In theory, there is therefore more than one permissible path in Europe.
In Latvia, however, this choice has already been made for you. Regulations No. 749 specifically mention the combination of UBL 2.1 and PEPPOL BIS Billing 3.0 as the VID solution format. VID confirms on your e-invoice page, that the Latvian national standard must comply with the PEPPOL BIS Billing 3.0 specification and the agency has no plans to expand this format.
This gives a direct answer to the question of whether a regular UBL 2.1 XML file meets Latvian requirements: it does not. UBL 2.1 is a correct syntax, but without the business and validation rules of PEPPOL BIS Billing 3.0 it is half the job, like a sentence that complies with spelling rules but lacks grammar. Your software must be able to produce a file that passes both the UBL 2.1 schema check and the PEPPOL BIS Billing 3.0 validation rules.
Are the PEPPOL specification and the PEPPOL network one and the same?
This is where most people get confused again. PEPPOL BIS Billing 3.0 is a document format requirement. This does not mean that the invoice must travel through the PEPPOL network, via the so-called Access Points. Regulations No. 749 explicitly list which transmission channels Latvian companies can use: official email address or official electronic mailbox of the Latvian state (if the company has an activated email account), service provider or operator channel, or other electronic channel, such as integration between systems, email or some other electronic transmission method.
The parties agree on the channel. If you use an official email address, its information system will automatically forward the e-invoice message and data to the VID. If you use an operator or another channel, the XML file must be submitted to the VID separately, either via the EDS, or electronic declaration system, which According to VID only accepts files in XML format, or through the accounting software application programming interface (API), which VID calls E-Invoice API V2, if such an interface exists.
Latvia's deadlines: what is already mandatory in 2026 and what will start in 2028?
The schedule is in three stages, and each stage concerns a different party.
From January 1, 2025, e-invoicing will be mandatory in the G2G, B2G and G2B segments, i.e. for invoices between state institutions and invoices between companies and state institutions, confirms VID. Invoices addressed to budgetary institutions, contracts for which were concluded before 31 December 2024, received law follow the transition period until January 1, 2026.
From 1 January 2026, submitting e-invoice data to VID will be mandatory for the same G2G, B2G and G2B segments. From the same deadline, from 1 January 2026 to 31 December 2027, B2B companies can submit data to VID voluntarily, there is no obligation yet, but the option already exists (Regulations No. 749).
From January 1, 2028, B2B will also become mandatory: VID confirms, that Latvian registered companies must prepare invoices for payment as e-invoices and submit them to the VID at the same time. This rule is Accounting Some exceptions have been made, such as transactions supported by a cash register, documents generated in certain systems of public health or employment agencies, and internal documents of security and law enforcement agencies.
Practical checklist for billing software
Before the 2028 deadline, it makes sense to review your software today, not as the deadline approaches.
- UBL 2.1 export: Check whether your accounting or sales software can create invoices in UBL 2.1 XML format, not just PDF invoices.
- PEPPOL BIS Billing 3.0 validation: ask the supplier if the XML file issued passes PEPPOL BIS Billing 3.0 Business and Validation Rules, not just the general UBL scheme.
- Recipient identifiers: Make sure the system can store and use the customer's email address or other PEPPOL identifiers, not just the name and address.
- Transmission channel: decide which one from the channels listed in regulations No. 749 Whatever suits you, email address, operator or direct integration, and agree on it with the client.
- Submitting a VID: Check whether the channel automatically transmits data to the VID (such as an email address) or whether it must be done separately via EDS or API.
- Deadlines: Remember that an e-invoice must be submitted to VID once, no later than five working days after it is sent. In the event of a system failure, there is a period of three working days after the failure is eliminated; in the event of a delay for any other reason, the VID must be notified of this in the EDS and invoices must be submitted within 30 calendar days of discovering the reason (Regulations No. 749).
If your company already has B2G invoices or voluntary VID submission in place today, in the summer of 2026, the transition in 2028 is more of a setup validation than a new project. However, if all invoices are still in PDF format and sent manually, it is worth starting your software selection now, not in January 2028.
FAQ
Will the Latvian e-invoice format be mandatory in 2026?
The Latvian Tax Board (VID) requires that e-invoice XML be written in UBL 2.1 syntax and comply with PEPPOL BIS Billing 3.0 rules. This is not a separate national format, but an implementation of the PEPPOL standard.
What is the difference between EN 16931, UBL 2.1 and PEPPOL BIS Billing 3.0?
EN 16931 is a semantic data model that specifies which data fields must be present on an invoice. UBL 2.1 is the XML file format in which this data is recorded. PEPPOL BIS Billing 3.0 adds constraints and validation rules, ensuring that the invoice exactly meets the requirements.
When will B2B e-invoicing become mandatory in Latvia?
The B2B e-invoicing obligation will enter into force on January 1, 2028. From January 1, 2026 to December 31, 2027, companies can voluntarily submit data to VID.
Does PEPPOL BIS Billing 3.0 mean that the invoice must travel through the PEPPOL network?
No. PEPPOL BIS Billing 3.0 is a document format requirement, not a delivery channel. The invoice can be delivered via email, carrier, or direct integration, but the XML file must comply with PEPPOL validation rules.