Peppol Invoice Response is a structured message the buyer sends the seller about the status of one specific invoice or credit note. This is different from a plain delivery confirmation, which only confirms a message arrived on the network without touching what happens to the invoice afterwards. No one is automatically required to use it. As of 17 August 2026, Peppol BIS Billing version 3.0.21 became mandatory across the network, and that version introduced an optional profile called “Billing with Response,” which comes with its own identifier and requires separate registration. If your business stays on the standard invoicing profile, nothing changes for you: invoice response only becomes something you need to handle if you or your customer deliberately switches to that specific profile.
How is invoice response different from a delivery confirmation?
A delivery confirmation moves inside the Peppol network and only proves the message landed. It says nothing about whether anyone acted on it. Invoice response sits a level above that: it's a business-level message where the buyer tells the seller whether the invoice has been accepted, conditionally approved, disputed, or already paid. The message only flows one way, buyer to seller, and the seller has no way to request it automatically.
Is using invoice response a legal requirement?
The specification is explicit.: neither the buyer nor the seller is obliged to use invoice response. Directive 2014/55/EU requires public-sector buyers to accept e-invoices built to the standard, but it creates no duty to send status messages back. In Estonia, the Accounting Act gives any company registered as an e-invoice recipient the right to demand e-invoices from 1 July 2025 onwards, but that right has nothing to do with any invoice-response obligation. The ViDA directive brings cross-border digital reporting from 1 July 2030, but it doesn't force small businesses onto the invoice-response profile either.
What actually changed on 17 August 2026?
OpenPeppol published version 3.0.21 on 20 May 2026, and it became mandatory from 17 August 2026. That release added Profile 02, “Billing with Response”, under which the buyer must send at least one response for every invoice received. Anyone who stays on the standard Billing profile is unaffected by that requirement.
Which statuses apply, and what happens if an invoice gets rejected?
The fixed statuses are AB (accepted), IP (in process), UQ (under query), CA (conditionally approved), RE (rejected), AP (approved) and PD (paid). A buyer supporting the profile has to be able to send at least AB, RE and AP. For UQ, CA and RE, the buyer adds a code or free text explaining what the seller needs to fix. RE and PD are in final statuses. Once an invoice hits AP, only PD can follow.
Does the three-business-day rule count as a payment deadline?
The process rule says the buyer must send the first response within three business days. That's an internal Peppol timing rule, not an Estonian statutory payment deadline. Sending a response does not change the invoice itself or release the buyer from whatever payment obligation already applies under the contract.
What to check before switching the profile on
Ask your Peppol access point whether it supports “Billing with Response” and which identifier it will register for your company. Agree with your trading partner on which optional statuses, UQ, CA and PD, each side actually needs, and confirm whether your accounting software can automatically match an incoming status message back to the original invoice.
FAQ
How is an invoice reply different from a delivery confirmation?
A delivery confirmation only confirms that the message has arrived on the network, not that its content has been processed. An invoice response is a business-level message where the buyer reports whether the invoice has been confirmed, conditionally approved, disputed, or paid. The response travels from the buyer to the seller and cannot be automatically requested by the seller.
Is the use of invoice response mandatory by law?
No. The Peppoli specification clearly states that neither the buyer nor the seller has to use the invoice response. Directive 2014/55/EU obliges public contracting authorities to accept e-invoices, but does not create an obligation to send invoice statuses. Neither the Estonian Accounting Act nor the ViDA Directive makes the invoice response mandatory.
What actually changed on August 17, 2026?
OpenPeppol released version 3.0.21, which became mandatory on August 17, 2026. It added the "Billing with Response" profile, which requires the buyer to send at least one response for each invoice received. Those who remain with the regular Billing profile are not subject to this obligation.
Is three business days the payment deadline?
No. The process rule stipulates that the buyer sends the first response within three business days, but this is an internal Peppol rule, not a payment deadline under Estonian law. The response does not change the invoice or release the buyer from the current payment obligation.