Which PEPPOL service if you send up to 50 invoices per month?

Short answer: for up to 50 invoices, you don't need your own access point.

If you prepare 1–50 invoices per month manually, there is no point in purchasing a separate PEPPOL Access Point, i.e. a technical connection point to the network. A standard web-based invoicing program, whose service provider is a certified access point itself and sends your invoice as a machine-readable e-invoice, is sufficient. The API interface is worth considering only if the invoices are already generated in another system. If your only need for e-invoices is a few Lithuanian public sector invoices per year, the SABIS portal of the state invoicing environment is sufficient – According to the European Commission's country report on Lithuania You can submit an invoice to SABIS via the portal, API interface or Peppol. And one clarification: 50 invoices is not a legal limit. It is a cost and work organization limit, at which the craft starts to become more expensive than the service.

First, look at who you are sending invoices to.

The choice depends on the customer, not the software. The three situations are quite different.

In the Lithuanian public sector, structured e-invoicing has been mandatory for suppliers of public procurement contracts since 01.07.2017 and all invoices to public institutions are sent via SABIS, which is connected to the Peppol network and supports the European e-invoicing standard EN 16931, a common machine-readable invoice data model. The same country report states that the supplier can use any service provider, if the invoice meets the European standard.

The second situation is for Estonian e-invoice recipients. Starting from 01.07.2025, an accounting entity can register itself as an e-invoice recipient in the commercial register and indicate its e-invoice operator or other receiving channel. According to § 7¹ of the Accounting Act The recipient so indicated has the right to request an e-invoice, and an e-invoice that complies with the requirements of EN 16931-1 is considered suitable, unless the parties have agreed on another suitable standard. If your client has indicated this, a PDF invoice is simply additional work for them.

Thirdly, ordinary private sector customers. In Lithuania, there is no general legal obligation for a private sector supplier to issue EN 16931 e-invoices – there is no B2B and B2C obligation. In these relationships, e-invoice is a business agreement: a large customer requires it for its accounting purposes, not for legal reasons.

The PEPPOL access point is not the same as the invoicing program

This is where most comparisons get messed up. The journey of a single invoice consists of four different things:

• Invoice preparation: fields, lines, VAT, payment term – this is an invoicing program.
• Birth of a machine-readable file: The same data is converted into XML that complies with the EN 16931 model and Peppol BIS Billing 3.0 rules.
• Access point: a certified operator who sends and receives the invoice to the network.
• Accounting or ERP interface: Invoice entries will automatically arrive in your software.

For up to 50 invoices, the first three should be included in one price. It's only worth paying separately for the fourth, and only if you actually have a system to interface with.

Does a small business need its own access point?

No. Certification is the provider's concern. On the Lithuanian side, it is even spelled out in legislation: Description of the SABIS Terms of Use According to the law, Peppol invoices are sent via registered access points and can be sent from any registered point, while the point managed by the National Common Service Center (NBFC) is not intended for sending outgoing invoices. So you need a provider who has a point - not your own point.

How to check if your invoicing program is truly Peppol-ready?

Three checks that take a total of fifteen minutes and can be done before sending the first invoice.

First: find the provider's name From the list of OpenPeppol certified service providers. The list shows Access Point and SMP (Service Metadata Publisher) certification in separate columns, so request the "AP Certified" line, not general membership. The list updated on 18.09.2026 also lists Baltic and Nordic providers with both commercial and legal names - search for both.

Second: ask which BIS version the provider actually supports. OpenPeppol post-award documentation shows the Peppol BIS Billing 3.0 specification publication date 20.05.2026 and becoming mandatory 17.08.2026. The answer „we have Peppol“ is not an answer.

Third: send a test invoice. You don't need to write XML or buy a validation tool separately - a certified provider will check the invoice according to BIS rules before sending it and should show you a specific error if any of the details are missing. Ask in the sales conversation: what does this error message look like? There is no need to worry about Lithuanian customers - the country does not implement the national CIUS or additional plans On top of the European standard, so there is no separate "Lithuanian format".

When is SABIS enough and when does it become a craft?

Invoices can be entered into SABIS in three equal ways: through the user interface or portal, through the universal interface, or through the Peppol network. The criteria are simple. If you have a few random B2G documents a year, enter them manually in the portal and don't buy anything. If public sector invoices are your permanent turnover or you want to track all sales invoices in one place, the portal becomes another data entry point alongside your invoicing program.

One mechanism is worth unraveling here, as it is constantly confused. Addressing and sending are two different things. Buyers registered in SABIS are automatically entered into the SMP database of the NBFC access point, so the public buyer is discoverable online - but this does not mean that you can send invoices from this point.

Another practical difference is the statuses. When your invoice arrives in SABIS via Peppol, the invoice processing statuses PROVIDED, APPROVED, REJECTED, ACCEPTED and PAYED are sent back to the supplier. You have to go to the portal to check for yourself. If you ask yourself every month „has this invoice been approved at all?“, this is the only place where the Peppol service pays for itself immediately for up to 50 invoices.

Seven points to ask the provider before signing

• Access Point certificate: whether the provider is listed on OpenPeppol with an AP certificate, not just a member or an SMP service provider.
• Sending and receiving: Does the price cover both? Receiving purchase invoices is half the battle, because they are the ones that otherwise have to be reprinted manually.
• Supported BIS version: whether Peppol BIS Billing 3.0 is in use in the mandatory version on 17.08.2026.
• Finding the recipient: how the provider identifies the client's readiness to accept. A Peppol Directory search is helpful, but it is not proof – in Estonia, the binding signal is the e-invoice recipient's note in the commercial register and the channel indicated there, in the case of Lithuanian public buyers, the SABIS registration and the accompanying SMP entry. Ask what the provider does if the recipient cannot be found.
• Invoice statuses: what messages you get back. Peppoli's Message Level Response is a separate document type in post-award documentation and it only proves the technical side: the message reached the recipient's access point and passed the check. It does not prove that the accountant approved the invoice, and does not say anything about how good your provider's customer support is. The status of the business process is indicated by SABIS-e-type statuses, not MLS.
• Export and archive: Can you export your invoices as XML and CSV without additional fees or exit interviews?.
• Users and price after free limit: how many users are included in the price (the accountant is usually the second user) and what happens when the free invoice limit is reached.

Price comparison for up to 50 invoices: don't just look at the price of the document

The actual monthly cost is the monthly fee + invoices sent + invoices received + setup + interface + additional users. The price of one invoice is the smallest variable in this formula. Below is a sample calculation - the numbers are hypothetical, but the questions in the "What to ask" column are the ones that really change the price. Let's assume a monthly fee of €9, an invoice sent of €0.30, free reception and €5 for one additional user.

Cost component	What to ask	30 invoices per month	50 invoices per month
Monthly fee	Is the number of invoices included or additional?	€9	€9
Invoices sent	Does a credit note count as a separate document?	€9	€15
Incoming purchase invoices	Is the reception free?	€0	€0
Setup	One-time subscription fee, Peppol ID registration	€0	€0
Accounting interface	Does export replace the interface or do you have to pay for the interface?	€0	€0
Additional users	How many users are included in the price?	€5	€5
Total		€23	€29

Put your handiwork aside. If it takes 5–7 minutes per invoice to enter, check, and copy 30 purchase invoices to the bank, it will take about three hours per month. The value of those three hours in your company is a number that you know yourself. Compare that number, not two price lists.

ViDA 2030: How to choose today so as not to pay for the future in advance

ViDA, or the VAT package in the digital age, is causing a lot of rush, but the date is far away. Council Directive (EU) 2025/516, adopted on 11.03.2025, sets out new digital reporting requirements for EU cross-border B2B transactions from 01.07.2030 and requires the use of the European e-invoice standard in these situations. Peppoli is not named as the only mandatory transmission network. This does not result in any access point obligations for Lithuanian domestic private sector B2B today. European Commission eInvoicing Country Sheet It is stated that the first changes to meet ViDA requirements are planned to come into effect from 2025, and mandatory e-invoicing is targeted for 01.01.2028 - this is an intention, not a norm that has come into force, and it is worth monitoring this, not concluding a three-year contract based on it.

What does this mean for the choice? Get a service that you pay for monthly, that you can get data from in a standard format, and that can send and receive today. If the number of invoices increases or a large client requires an interface, you will buy it then. The most expensive mistake with up to 50 invoices is not the wrong provider – it is a long contract and API integration that you do not use.

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Last checked: September 21, 2026

FAQ

Does a small business need its own access point to use Peppoli?

No, a small business does not need to certify or manage the access point itself. A web-based invoicing program with an OpenPeppol AP certificate provider that automatically transfers invoices to the network is sufficient.

When will the Lithuanian national SABIS portal be enough?

The SABIS portal is sufficient if you issue only a few invoices per year to Lithuanian state authorities and are prepared to enter data manually. In the case of continuous invoicing, the portal becomes a duplicate workplace, which is why it is worth using the integrated Peppol service.

How to check if software is truly Peppol-ready?

Check the legal or commercial name of the provider in the OpenPeppol certified service provider list in the AP certificate column. Also ask if the system supports the mandatory Peppol BIS Billing 3.0 format and performs automatic validation of EN 16931 rules.