PDF or e-invoice in Estonia 2026: what can the buyer demand?

Short answer: e-invoice can only be requested in certain cases

A PDF invoice sent as an email attachment is not an e-invoice. According to the Ministry of Finance, a machine-readable file prepared based on the common e-invoice standard, not a picture of the invoice – but there will be no general ban on PDF invoices in Estonia in 2026, other invoice formats will continue to be allowed. The buyer can request a machine-processable e-invoice from you in three cases:

• Agreement: The e-invoice format is agreed upon in the contract or order.
• Index note: the buyer is listed as the recipient of the e-invoice in the e-business register – then it gives Accounting Act him/her a claim.
• Public sector: All public sector entities are e-invoice recipients in the register.

Unless another standard has been agreed, the e-invoice is presumed to be compliant with the European standard EN 16931-1.

A PDF invoice is not the same as an e-invoice.

This difference is the most confusing because both are „electronic.“ A PDF is a human-readable document – your customer can see the amount, date, and IBAN code, but the software still has to read the data from there or someone has to type it in manually. An e-invoice is a structured data file that moves from the seller’s software to the buyer’s software so that the invoice data no longer needs to be entered manually.

Take, for example, a 1200-euro service invoice for a client in Tallinn. As a PDF, it is a completely valid invoice if the details are correct. As an e-invoice, it is the same transaction in machine-readable fields: seller, buyer's registry code, amount, VAT, payment term. The content is identical, the form is not.

	PDF invoice by email	Machine-readable e-invoice
What file is this?	Human-readable document	Data file prepared according to a common standard
Is there a valid invoice?	Yes, if the details and VAT requirements are met	Yes
Does it meet the requirement of a registered buyer?	Not fulfilling alone	Yes
Format	Free	Estonian e-invoice standard or European standard (Peppol); in case of dispute, EN 16931-1 is assumed
Work on the buyer's side	Data must be entered or digitized	Data enters the software automatically
Public sector	Possible exception if the institution agrees	Standard practice

The Ministry of Finance names two formats used in Estonia – the Estonian e-invoice standard and the later European standard, also known as the Peppol invoice – and recommends a European standard to businesses, because its distribution is expanding. Estonia follows the principle of format freedom: the use of both standards is permitted.

When does the buyer have the legal right to request an e-invoice?

Section 7¹ of the Accounting Act begins with freedom. Format and conditions for submission of a machine-processable source document agreed upon between the transaction partners, unless another legal act provides otherwise. By default, the form of the invoice is therefore a matter of agreement, not a state precept.

Next comes the exception. If an accounting entity wishes to receive only e-invoices, it forwards this information to the commercial register, which marks it as the recipient of the e-invoice and adds the details of the receiving channel or handler (§ 7¹ (3)). It is the buyer registered in such a register who has the right, according to § 7¹ (7), to demand an e-invoice from the seller as payment for the purchased goods or services. The instructions of the Ministry of Finance state this practical consequence directly: unless the parties have agreed otherwise, sellers must provide them with an e-invoice, and there are approximately 18,000 registered companies in Estonia.

There are no limits here. The size of the turnover, the amount of the invoice or the number of employees do not matter – all that matters is whether the buyer is a registered e-invoice recipient. The changes entered into force on 1 July 2025 and replaced the previous general e-invoice obligation in the public sector with the principle of buyer choice, which also extended to the private sector.

There is no specific penalty for sending a PDF in the current sources. The practical risk is simpler and more painful: if the buyer expects a machine-readable file, the invoice may not be processed in their system and payment will be delayed.

What does the seller need to check before sending an invoice?

Three steps that take a few minutes.

• Register status: check whether the client's registry code is listed in the commercial register as the recipient of the e-invoice. There is a separate section for this in the open data e-invoice recipient inquiry called arireg.earveRegistriParing_v1, which has been in use since 01.05.2017 and for which no contract is required. You enter the registry codes as input, the response is a status – OK means a valid connection, MR means that the code was not found or there is no active connection.
• Channel and service provider: The same query also returns the service provider ID, i.e. the one through which the client receives invoices. This tells you where to send the invoice.
• Contract and order: check whether you have already agreed on the format. Agreement is the default rule in § 7¹, so a written agreement in another format is a perfectly valid basis.

If there is no agreement and the customer is a registered recipient, send an e-invoice. If no other standard has been selected, a safe choice is a file that complies with the requirements of EN 16931-1 - it is with this compliance that the law requires that the e-invoice is compliant.

PDF is allowed, but the invoice issuance rule is a separate issue

Separate three things: the content of the invoice, the VAT rules and the form of the invoice. The VAT Act generally requires that a taxable person issue an invoice within seven calendar days after the goods have been dispatched or made available or the service has been provided. According to § 37(6) of the same Act, an invoice may be issued on paper or, with the consent of the buyer, electronically.

This „electronically“ does not automatically mean an e-invoice within the meaning of the Accounting Act. A PDF can be a perfectly valid invoice for VAT purposes and still fall short of the e-invoice requirement of a registered buyer. Two sets of rules, two separate questions.

Public sector, exceptions and what can be agreed upon

In 2019, a general obligation to submit e-invoices was introduced in Estonia if the buyer was a public sector institution. In 2025, this obligation was replaced by the buyer's right to choose the invoice format. Since all public sector entities are already listed in the commercial register as recipients of e-invoices, the e-invoice requirement continued for them. essentially the former regime – but unlike before, they are no longer prohibited from making exceptions and accepting invoices in other formats if necessary. In other words: receiving an e-invoice from a state agency, but there is no longer an absolute ban on „only e-invoices“.

The Accounting Act also lists in § 7¹ subsection 8 the situations where the register and right of claim of the recipient of an e-invoice do not apply: among others, documents for a security authority, documents containing state secrets or classified foreign information, documents involving professional or official secrets, and cases where another legal act provides for a different procedure.

What ViDA will change later and what it won't change yet in 2026

ViDA, or the EU's "VAT in the Digital Age" package, is the one that most often confuses the timelines. The Council Directive (EU) 2025/516 was adopted on 11.03.2025 and published in the Official Journal of the European Union on 25.03.2025. It allows Member States to introduce national mandatory e-invoicing under certain conditions, but EU-wide digital reporting requirements will only apply to cross-border B2B transactions from 01.07.2030.

Therefore, ViDA will not impose a new invoice format obligation on Estonian companies in 2026. And as of 21.09.2026, there is no Estonian legislation in verified sources that would establish a general e-invoice obligation for all B2B transactions within Estonia. The same logic still applies: the format is agreed upon, the registered buyer can request an e-invoice, the rest is an agreement between you and the customer.

Read also: English

Last checked: September 21, 2026

FAQ

Will sending PDF invoices be banned in Estonia in 2026?

There is no general ban on PDF invoices in Estonia in 2026, and the invoice format is a matter of default agreement between partners. The seller is only obliged to send an e-invoice if the buyer is entered in the commercial register as an e-invoice recipient or if the buyer is a public sector institution.

When does a buyer have the legal right to request an e-invoice from a seller?

According to the Accounting Act, the buyer can request an e-invoice if he is registered in the commercial register as an e-invoice recipient and the parties have not agreed otherwise in writing. In addition, the right to request applies if the provision of an e-invoice has been separately agreed in the contract or order terms.

How do I check if a customer accepts machine-readable e-invoices?

To check, you can use the free open data query of the commercial register arireg.earveRegistriParing_v1 or the e-commercial register information system. The query shows the current status based on the client's registry code and the e-invoice operator channel to which the invoice should be sent.