Yes, you can still do that. If your Latvian company issues an invoice to another company registered in Latvia, you can still send a simple PDF in 2026 and 2027. The obligation to issue an invoice for payment as a structured e-invoice remains in effect. according to the transitional provisions of the Accounting Act only from 1 January 2028 – and from that same date, invoice data must also be provided to the tax authority VID. The original deadline was 1 January 2026, but the Saeima June 5, 2025 Amendment to the Law postponed it for two years; the change entered into force on June 12, 2025. So as of September 2026, domestic B2B payments in Latvia will still be governed by PDF – but only for two years.
Basic facts
| Fact | Value | Valid from | Source |
|---|---|---|---|
| B2B structured e-invoice obligation in Latvia | An invoice submitted for payment to another company registered in Latvia (which is not a budgetary institution) must be formatted as a structured e-invoice. | from 01.01.2028 | m.likumi.lv |
| Deadline extension 2026 → 2028 | The Saeima amendment of 05.06.2025 replaced the number "2026" in the transitional provisions with the number "2028"; the amendment entered into force on 12.06.2025 | entered into force on 12.06.2025 | likumi.lv |
| Submitting e-invoice data to VID | The e-invoice is submitted to VID once, no later than five working days after the day it was sent. | Regulation No. 749 is valid from 13.12.2025 | likumi.lv |
| XML technical requirement | The XML structure of the e-invoice submitted to VID complies with the UBL 2.1 and Peppol BIS Billing 3.0 specifications (CIUS) | from 13.12.2025 | likumi.lv |
| Voluntary period for B2B data submission | During the period 01.01.2026–31.12.2027, companies may voluntarily submit e-invoice data to VID. | 01.01.2026–31.12.2027 | vid.gov.lv |
| B2G and data reporting in public sector invoices | E-invoices are mandatory for invoices submitted to budget authorities from 01.01.2025; submission of these data to VID from 01.01.2026 | 01.01.2025 and 01.01.2026 | vid.gov.lv |
A timeline that clears up the confusion
Older explanations and even some software vendor presentations still show the date 1 January 2026. This number was indeed in the law until it was replaced. Latvia is moving to e-invoicing in stages and VID e-invoice page describes them as follows:
| From | What changes | Who is concerned? |
|---|---|---|
| 01.01.2025 | Invoices to budgetary institutions must be issued as e-invoices. | B2G, G2G, G2B |
| 01.01.2026 | The data of these e-invoices must be provided to VID. | public administration and companies registered in Latvia |
| 01.01.2026–31.12.2027 | Submission of B2B e-invoice data to VID is voluntary | companies with each other |
| 01.01.2028 | The B2B invoice must be issued as an e-invoice and the data must be provided to VID. | Companies registered in Latvia with each other |
A voluntary period is not an empty promise. Cabinet of Ministers Regulation No. 749, which will enter into force on December 13, 2025, allows companies exchanging e-invoices to submit them to the VID as early as January 1, 2026. The same regulation states that for invoices sent via e-mail, data transmission to the VID will also start from January 1, 2026.
Why is a PDF invoice not a structured e-invoice?
The law does not say „electronic invoice“ in the sense of „an invoice that is transmitted electronically.“ A structured electronic invoice is according to the list of definitions in the law an invoice that is prepared, sent and received in a structured electronic format that allows it to be processed automatically and electronically, and that complies with the European standard LVS EN 16931-1:2017 and the technical specification LVS CEN/TS 16931-2:2017.
Take, for example, an invoice for 1200 euros to a client in Riga. As a PDF, it is an image of paper: a person reads it from the screen, types the amount, reference number and payment due date manually into accounting or pushes it through OCR. With a structured e-invoice, the same invoice arrives as a machine-readable XML file, where each requisite – the seller’s registry code, invoice number, line amounts, VAT, payment due date – is in a separate field. The same content, but the machine doesn’t have to guess it. That is why PDF cannot replace the mandatory file after January 1, 2028, not even if you send it in a proper email.
To whom does the obligation extend and to whom does it not?
The obligation is written regarding invoices between companies registered in Latvia. The VID specifies that the circulation of e-invoices concerns state administration and companies registered in Latvia, including natural persons carrying out economic activities, other subjects of the Accounting Act, and subjects of the Value Added Tax Act.
Some conclusions that directly follow from this:
- There is no threshold for turnover or number of invoices. Neither the law nor Regulation No. 749 links the obligation to turnover, the number of invoices, or the status of a VAT payer. The circle is determined by the type of entity, not its size.
- An invoice issued to a private individual is excluded. The obligation is formulated on the invoice that the company submits to another company registered in Latvia, which is not a budgetary institution. A private individual without economic activity is not included.
- The foreign partner is not obligated, but may be in agreement. If your Estonian or Lithuanian company issues an invoice to a Latvian customer, Latvian law does not impose this obligation on you. VID notes, for its part, that the requirements do not prohibit a company registered in Latvia from preparing a structured e-invoice for a company not registered in Latvia – the parties agree on this between themselves. How the cross-border circulation of e-invoices will ultimately be organized exactly is not set out in these rules.
The law also contains individual exceptions to the obligation. Before 2028, it is worth reviewing your document types once and checking the wording of the law itself, not summaries heard from others.
Why are the invoice to the customer and the data to the VID two different movements?
This is where most of the confusion comes in. There are two different processes involved: delivering the e-invoice to the customer and submitting the e-invoice data to the tax authorities.
Peppol is not the only permitted route. Regulation No. 749 lists three channels: official e-mail address (e-mail address), if the account is activated; service provider or operator channel; or other channel – inter-system interface, e-mail address or some other electronic channel. The parties agree on the channel to be used. An XML file can therefore in principle also be sent as an e-mail attachment.
However, the format is specified. The XML structure of the e-invoice submitted to VID must comply with the UBL 2.1 and Peppol BIS Billing 3.0 specifications, or the so-called CIUS. Peppol BIS Billing 3.0 is according to your documentation Core Invoice Usage Specification for the European standard EN 16931 – a narrowed set of usage rules, according to which the invoice prepared also complies with the European standard. In short: you choose the network yourself, but the content and structure of the file are in accordance with Peppol rules.
There are different ways for data to reach VID. When using an email address, the email address information system automatically submits the invoice to VID – for this, both the company and the operator must use an up-to-date integration version. The operator's channel must be interfaced with the VID system API. If you choose an "other channel", such as email or direct interface with the client, you must submit the invoice to VID yourself – either electronic declaration system (EDS) Via API or by uploading a file. EDS can only be uploaded as a file in XML format; an invoice can be sent from an accounting program using the API if the program has an interface with the VID e-invoice API.
Five business days, validation and plan B
The deadline is short and specific: the e-invoice is submitted to the VID once, no later than five working days after the day it was sent. The regulation also describes what happens if the technology fails.
- Your system or the operator's system is not working: notify VID in EDS no later than the next business day after the five-day deadline, indicating the reason, and submit an invoice within three business days after the fault has been rectified.
- VID's own solution does not work: Submit the invoice no later than the next business day after the fault has been rectified. VID will report both faults and their rectification itself.
- The invoice was not submitted for another reason: notify in EDS, indicating the reason and period, and submit invoices no later than 30 calendar days from the date of identification of the reason.
Regulation No. 749 does not stipulate fine rates. The general rules of administrative liability are in the Administrative Liability Act, which leaves the description of specific violations and penalties to the laws of the field.
It is worth checking the XML before sending. VID recommends using the European Commission's e-invoice validation tool to ensure that the data structure, mandatory fields and calculations match, and has published separate instructions for this purpose.
What to do in 2026 and 2027?
Two years seems like a long time until December 2027 arrives and the program update is in the pipeline.
- Map invoice flows: How many sales invoices go to Latvian companies, how many to budget institutions, how many to private individuals and how many abroad. The obligation concerns only a part of them.
- Ask the software provider one specific question: Does the program generate UBL 2.1 XML that meets Peppol BIS Billing 3.0 requirements, and does it have an interface with the VID e-invoice API? Yes or no – there is no other answer here.
- Decide on a channel and agree with the client: email address, operator or direct interface. The regulation itself requires agreement, so this conversation must be undertaken anyway.
- Use the optional period for testing: From January 1, 2026, you can submit invoices to VID without obligation. A few real invoices through the chain and you will know exactly where your process breaks down.
- Review the document circulation procedure: what format invoices are kept in, who is responsible for monitoring the five business day deadline, and what happens in the event of a breakdown. This procedure is easier to write down now than in January 2028.
One more thing to know: VID maintains an up-to-date list of service providers and guidance materials on its e-invoicing page, including EDS submission guidelines and XML validation guidelines. If your current program needs a replacement or a middleware, this list is a reasonable first stop.
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FAQ
When is PDF invoice still valid for Latvian B2B invoices?
A PDF invoice can be the main document until December 31, 2027. From January 1, 2028, structured XML e-invoices and data transmission to VID are mandatory.
What is the difference between a PDF invoice and a structured e-invoice?
A PDF is an image of an invoice that a human can read. A structured e-invoice is a machine-readable XML file that complies with the European standard EN 16931 and allows for automated processing.
Who will be subject to the Latvian B2B e-invoice obligation in 2028?
The obligation applies to all businesses registered in Latvia, including sole proprietors and small businesses. There are limited exceptions, such as cash register documents or B2C invoices.
What is the deadline for submitting e-invoice data to VID?
The data must be transmitted no later than five business days after the invoice is sent. If a technical error occurs, it must be reported on the next business day.