No, in 2026, invoices to Lithuanian public sector clients (ministry, municipality, school) may not generally be sent by email. The Lithuanian government Regulation 405 The established procedure stipulates that from 1 January 2025, a document complying with the European e-invoice standard must be sent via the PEPPOL network (international invoicing intermediary network) or, if this is technically impossible, entered manually via the SABIS portal. SABIS is the central invoice information system of Lithuania, which from From September 1, 2024 replaced the old E. säätä system. Sending a PDF by email is only allowed as a narrow exception: if the foreign supplier cannot access SABIS and PEPPOL is not suitable, email may be used with the buyer's consent.
Is a PDF attached to an email considered an e-invoice?
Not counting. Directive 2014/55/EU states directly that a file representing an image, such as a scanned paper invoice or a regular PDF, is not an e-invoice for the purposes of public procurement, even if it is transmitted electronically. An e-invoice here means a specific structured format that complies with the European e-invoice standard (EN 16931-1:2017), the reference of which was published 405. in the regulation mandatory. So your beautiful, hand-formatted PDF may be perfectly correct as an invoice, but when sent as an email to the supplier, it does not fulfill the legal obligation.
SABIS or PEPPOL: which channel to use?
The difference is in technical capability, not freedom of choice. If your accounting software or e-invoice operator is interfaced with the PEPPOL network, the invoice will 405th regulation automatically through there. If there is no automatic PEPPOL connection, the invoice data must be entered using SABIS, as this is a fallback solution provided for in the same regulation, not a convenience that can be chosen on your own. SABIS itself FAQ confirms that data can be entered in three ways: manually in the portal or by importing an XML file, from the company's business software via the universal interface, or automatically as a member of the PEPPOL network.
If you don't have a PEPPOL interface or accounting software
Then the answer is simple: go to the SABIS portal and enter the invoice manually. Log in is done through the VISP authentication service. The same authentication is used more widely in Lithuanian e-services, and after the first login, the organization must be registered, as described SABIS FAQ. From there, you can enter, submit, and track invoices by role. This doesn't cost you anything in addition to your own working time, but it does require that the contract data has already been entered into SABIS (more on that below).
Does the €1000 oral contract exception still apply?
Not applicable. This exception, which allowed for oral contracts up to EUR 1,000 to be exempt from VAT, was only provided for temporarily and expired. December 31, 2024. From 1 January 2025, invoices submitted under verbal agreements, regardless of the amount, must also be sent via SABIS. The only difference is that for verbal invoices, you select a separate “oral incoming invoice” type in SABIS and you do not need to link the invoice to any contract record, as explained by SABIS FAQ. The old €1,000 threshold was a transitional rule, not the reality of 2026.
When can a foreign supplier send an invoice by email?
This is an exception that applies specifically to cross-border suppliers, not Lithuanian companies. SABIS FAQ states directly that foreign suppliers of goods, services or works will not be able to log in to the SABIS portal for a short period of time. Their main route is to submit an invoice via the PEPPOL network, choosing a suitable service provider's Access Point. If PEPPOL is not a reasonable solution, for example, if a small Estonian company submits a single invoice to a Lithuanian municipality, the invoice can be submitted in a way that the buyer accepts, and one such option is e-mail. This is not a general permission for everyone, but a solution agreed in advance with the buyer for a specific cross-border case.
What contract data must match in SABIS?
When an invoice is submitted based on a written contract, SABIS checks three things: the contract details must already exist in the system, they must be linked to the vendor submitting the invoice, and the contract number on the invoice must exactly match the number registered in SABIS, as described in SABIS Supplier Guide. It is the buyer's responsibility to enter the contract and ensure its accuracy, not the supplier's. If the contract is not in SABIS, you cannot submit the invoice at all, and the only sensible course of action is to contact the buyer yourself before the invoice due date approaches.
One exception still remains in the law: Article 22, paragraph 12 of the Public Procurement Act According to the law, an invoice may only be non-electronic if SABIS or PEPPOL has been actually interrupted during mobilization, war or a state of emergency. Merely declaring a state of emergency is not enough, the interruption must be factual. This is an exception, not a regular plan B, and in practice your daily invoices will not be affected by this.
FAQ
Is a PDF attached to an email considered an e-invoice?
It does not count. Directive 2014/55/EU states that a scanned paper invoice or a regular PDF is not an e-invoice for the purposes of public procurement, even if it is transmitted electronically.
Will Lithuanian public sector invoices be allowed to be sent by email in 2026?
Generally not. From 1 January 2025, a document compliant with the European e-invoice standard must be sent via the PEPPOL network or, failing that, manually to the SABIS portal.
Which is the right channel: SABIS or PEPPOL?
There is essentially no freedom of choice: if there is a PEPPOL interface, the invoice will be transferred automatically. If there is no PEPPOL connection, the data must be entered using SABIS tools.
When can a foreign supplier send an invoice by email?
Email is an exception, applicable to cross-border suppliers and only in cases agreed with the buyer. The main route is via PEPPOL, in case of PEPPOL incompatibility the buyer may accept email.