No, Peppol is not required by law for sending invoices to the Estonian public sector. A structured e-invoice is mandatory if a registered buyer requests it, and Peppol is one, but not the only, technical way to deliver this invoice. Amendment to the Accounting Act, which was adopted on 18 September 2024 and entered into force on 1 July 2025, repealed the former requirement that the seller had to send an e-invoice to a public sector institution in any case, and replaced it with the buyer's right to request an e-invoice. Ministry of Finance according to the explanation All public sector institutions are registered as e-invoice recipients, which means that in practice structured e-invoices remain the default solution. However, the buyer may now make exceptions and accept invoices in other formats.
What actually changed on July 1, 2025?
In 2019, a general obligation to submit e-invoices for public sector buyers was introduced in Estonia. This replacement in 2025 „with the "buyer chooses" principle, which was also extended to the private sector: the right to request an e-invoice is available to any accounting entity that has registered as an e-invoice recipient. In the case of public sector entities, the substantive regime remained the same, as they were already registered, but now they are no longer prohibited from accepting invoices in other formats, with exceptions.
What is the difference between Peppol, EN 16931 and Estonian e-invoice?
EN 16931 is a European e-invoice standard that describes what data an invoice must contain. Peppol is a network and set of technical specifications through which an invoice moves from the seller's system to the buyer's system through a certified access point; Peppol BIS Billing 3.0 is a format built on it that complies with EN 16931 requirements. The Estonian e-invoice standard is, in turn, a local, previously common format. Law treats the invoice as correctly formatted, if it complies with EN 16931, but the parties may also agree on another standard. Peppoli does not require this.
How do I know if a specific buyer needs Peppoli?
Before sending an invoice, it is worth checking the buyer's registry code to see which service provider or reception channel is entered in the commercial register. This shows where and in what form the invoice should actually arrive. In addition, ask the buyer about the contract, order number and buyer reference information, as many institutions require them in separate fields on the invoice, regardless of the transmission channel.
What is really binding when it comes to PDF invoices, ViDA and deadlines?
A plain PDF file is not an e-invoice because it is not machine-readable, automatable; The PDF may accompany the e-invoice, but generally cannot be replaced if the buyer has requested an e-invoice. EU Directive 2014/55/EU obliges public procurers to accept invoices in accordance with EN 16931, but does not name Peppoli as a mandatory network. ViDA package adopted on 11 March 2025 and its digital reporting obligation will apply to cross-border B2B transactions from 1 July 2030. This will not change Estonia's current B2G settlement at the moment. For companies already operating in the Peppoli network, newer BIS Billing 3.0 version mandatory from August 17, 2026, but this is a technical upgrade, not a new obligation under Estonian law.
FAQ
Is Peppol mandatory in Estonian public procurement?
No, Peppol is not mandatory. A structured e-invoice is mandatory upon the buyer's request - Peppol is just one technical channel for its delivery. From July 1, 2025, the buyer's choice principle applies.
What changed on July 1, 2025?
The previous general obligation to submit e-invoices has been replaced by the buyer-choice principle. Public sector buyers are still registered as recipients of e-invoices, but they can now, as an exception, accept invoices in other formats.
What is the difference between Peppol, EN 16931 and Estonian e-invoice?
EN 16931 is a European standard that specifies what data an invoice must contain. Peppol is a network for transmitting invoices, Estonian e-invoice is a local format. The law requires compliance with EN 16931, but the parties may agree on a different standard.