Peppol Invoice Response: when is it mandatory for SMEs?

Peppol Invoice Response is a structured message that the buyer sends to the seller for a specific about the status of an invoice or credit note – this is different from a regular delivery confirmation, which only says that the message was delivered online without affecting the substantive processing of the invoice. No one is automatically obligated to use it. From August 17, 2026 became mandatory Peppol BIS Billing version 3.0.21, which added an optional profile "Billing with Response" - it has a separate identifier and requires separate registration. If your company remains with the standard invoicing profile, nothing will change: you will only need an invoice response if you or your client selects this specific profile.

How is an invoice reply different from a delivery confirmation?

The delivery confirmation travels within the Peppol network and only confirms the arrival of the message, not the processing of its content. Invoice response is a business-level message - the buyer reports whether the invoice has been approved, conditionally approved, disputed, or already paid. The response only travels in one direction, from the buyer to the seller, and the seller cannot automatically request it.

Is the use of invoice response mandatory by law?

The specification says clearly that neither the buyer nor the seller is required to use the invoice response. Directive 2014/55/EU obliges public sector contracting authorities to accept e-invoices that comply with the standard, but does not create an obligation to send invoice statuses. In Estonia, it provides Accounting Act A company registered as an e-invoice recipient will have the right to request e-invoices from July 1, 2025, but this does not affect the obligation to respond to the invoice. ViDA Directive will introduce cross-border digital reporting from July 1, 2030, but will not make the invoice response profile mandatory for small businesses.

What actually changed on August 17, 2026?

OpenPeppol published On May 20, 2026, version 3.0.21, which became mandatory from August 17, 2026. It added profile 02, "Billing with Response"„, in which case the buyer must send at least one response for each invoice received. Those who remain on the regular Billing profile are not subject to this obligation.

What statuses apply and what happens if rejected?

Fixed statuses are AB (approved), IP (in process), UQ (questioned), CA (conditionally approved), RE (rejected), AP (approved), and PD (paid). The supporting buyer must be able to send AB, RE, and AP at a minimum. For UQ, CA, and RE, the buyer adds a code or text explanation that tells the seller what to fix. RE and PD are final statuses, only PD can come after AP.

Is three business days the payment deadline?

Process rule stipulates that the buyer sends the first response within three business days. 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.

What to check before turning on the profile?

Ask your Peppol operator whether they support the "Billing with Response" profile and what identifier they will use to register your company at the service point. Agree with your trading partner which optional statuses (UQ, CA, PD) are required for each of you, and check whether the accounting software can automatically link the incoming status 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.