Lithuania Public Sector Invoices 2026: Email or SABIS?

Well. In 2026, you generally cannot send an invoice to a Lithuanian public-sector buyer (a ministry, a municipality, a school) by email. Under the procedure set out in the Lithuanian government Regulation No. 405, a document matching the European e-invoice standard has had to go through the PEPPOL network (the international e-invoice exchange network) since January 1, 2025, or, if that's not technically possible, get entered by hand into the SABIS portal. SABIS is Lithuania's central invoicing system. It replaced the older E. account system on September 1, 2024. Emailing a PDF is allowed only in one narrow case: a foreign supplier can't get into SABIS, PEPPOL doesn't fit the situation, and the buyer agrees to accept email instead.

Does a PDF attached to an email count as an e-invoice?

Well, it doesn't. Directive 2014/55/EU is blunt about this: a file that's essentially a picture, such as a scanned paper invoice or an ordinary PDF, is not an e-invoice for public procurement purposes, even though it travels electronically. An e-invoice, in this context, means a specific structured format that matches the European e-invoice standard (EN 16931-1:2017), which Regulation No. 405 references as mandatory. So your carefully formatted PDF might be a completely valid invoice on its own terms, but sent to a contracting authority by email, it doesn't satisfy the legal obligation.

SABIS or PEPPOL: which channel should you use?

The difference here is technical capability, not personal preference. If your accounting software or your e-invoice operator is already connected to the PEPPOL network, the invoice routes through automatically under Regulation No. 405. If you don't have an automatic PEPPOL connection, you enter the invoice through SABIS instead. The same regulation sets this up as a fallback, not a convenience you choose for yourself. SABIS's own FAQ confirms there are three ways to get data in: typing it into the portal manually or importing an XML file, using a universal interface from your accounting software, or submitting automatically as a member of the PEPPOL network.

What if you have neither a PEPPOL connection nor accounting software?

Then the answer is straightforward: log into the SABIS portal and enter the invoice by hand. Login runs through the VIISP identification service, the same one used across a wide range of Lithuanian e-government services. After your first login you'll need to register your organization, as the SABIS FAQ walks through. From there, depending on your role, you can enter, submit and track invoices. It doesn't cost you anything beyond your own time, but it does require that the contract details already exist in SABIS before you try to invoice against them (more on that below).

Does the €1,000 oral-contract exception still apply?

Well. The exception that let businesses invoice under oral agreements worth up to €1,000 excluding VAT was only ever meant to be temporary, and it ended on December 31, 2024. Since January 1, 2025, an invoice issued under an oral agreement, regardless of the amount, has to go through SABIS just like any other. The only real difference is procedural: for an oral-agreement invoice you pick the separate “oral incoming invoice” type inside SABIS, and you don't need to link it to any contract record, as the SABIS FAQ explains. The old €1,000 threshold was a transition-period rule. It has no bearing on how things work in 2026.

When can a foreign supplier invoice by email?

This exception is built specifically for cross-border suppliers, not for Lithuanian companies. The SABIS FAQ says outright that, for the time being, foreign suppliers of goods, services or works cannot log into the SABIS portal at all. Their main route is submitting through the PEPPOL network, picking a suitable service provider's Access Point (the connection point that routes your invoice into the network). If PEPPOL isn't a sensible option, say a small Estonian business sending a single one-off invoice to a Lithuanian municipality, the invoice can be submitted in whatever way the buyer is willing to accept, and email is one of those options. This is not a blanket permission for everyone. It's a solution worked out with the buyer in advance, for one specific cross-border situation.

What contract data has to match inside SABIS?

For an invoice tied to a written contract, SABIS checks three things: the contract has to already exist in the system, it has to be linked to the seller submitting the invoice, and the contract number written on the invoice has to match, exactly, the number registered in SABIS, as laid out in the SABIS supplier guide. Entering the contract correctly is the buyer's job, not the supplier's. If the contract isn't in SABIS, you can't submit the invoice at all. The only sensible move is to contact the buyer directly, before your invoice deadline gets close.

One exception still stands in the law: under Article 12(12) of Public Procurement Law No. 22, an invoice may be non-electronic only when SABIS or PEPPOL has actually broken down during mobilization, war or a declared state of emergency. Declaring an emergency on its own is not enough. The outage has to be real and factual. This is an exception, not a routine backup plan, and in day-to-day invoicing you're unlikely to ever run into it.

FAQ

Is a PDF attached to an email considered an e-invoice?

It does not count. Directive 2014/55/EU states that a scanned paper invoice or a regular PDF is not an e-invoice for the purposes of public procurement, even if it is transmitted electronically.

Will Lithuanian public sector invoices be allowed to be sent by email in 2026?

Generally not. From 1 January 2025, a document compliant with the European e-invoice standard must be sent via the PEPPOL network or, failing that, manually to the SABIS portal.

Which is the right channel: SABIS or PEPPOL?

There is essentially no freedom of choice: if there is a PEPPOL interface, the invoice will be transferred automatically. If there is no PEPPOL connection, the data must be entered using SABIS tools.

When can a foreign supplier send an invoice by email?

Email is an exception, applicable to cross-border suppliers and only in cases agreed with the buyer. The main route is via PEPPOL, in case of PEPPOL incompatibility the buyer may accept email.