{"id":29363,"date":"2026-09-12T07:00:01","date_gmt":"2026-09-12T07:00:01","guid":{"rendered":"https:\/\/bilnex.io\/en\/lithuania-public-sector-invoicing-2026\/"},"modified":"2026-09-12T07:00:01","modified_gmt":"2026-09-12T07:00:01","slug":"liettuan-julkisen-sektorin-laskutus-2026","status":"publish","type":"page","link":"https:\/\/bilnex.io\/fi\/liettuan-julkisen-sektorin-laskutus-2026\/","title":{"rendered":"Liettuan julkisen sektorin laskut 2026: S\u00e4hk\u00f6posti vai SABIS?"},"content":{"rendered":"
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No. In 2026, you generally can’t send an invoice to a Lithuanian public-sector buyer (a ministry, a municipality, a school) by email. Under the procedure set out in the Lithuanian government’s Regulation No. 405<\/a>, a document matching the European e-invoice standard has had to go through the PEPPOL network (the international e-invoice exchange network) since January 1, 2025, or, if that’s not technically possible, get entered by hand into the SABIS portal. SABIS is Lithuania’s central invoicing system. It replaced the older E. s\u0105skaita system on September 1, 2024<\/a>. Emailing a PDF is allowed only in one narrow case: a foreign supplier can’t get into SABIS, PEPPOL doesn’t fit the situation, and the buyer agrees to accept email instead.<\/p>\n

Does a PDF attached to an email count as an e-invoice?<\/h2>\n

No, it doesn’t. Directive 2014\/55\/EU<\/a> is blunt about this: a file that’s essentially a picture, such as a scanned paper invoice or an ordinary PDF, is not an e-invoice for public procurement purposes, even though it travels electronically. An e-invoice, in this context, means a specific structured format that matches the European e-invoice standard (EN 16931-1:2017), which Regulation No. 405<\/a> references as mandatory. So your carefully formatted PDF might be a completely valid invoice on its own terms, but sent to a contracting authority by email, it doesn’t satisfy the legal obligation.<\/p>\n

SABIS or PEPPOL: which channel should you use?<\/h2>\n

The difference here is technical capability, not personal preference. If your accounting software or your e-invoice operator is already connected to the PEPPOL network, the invoice routes through automatically under Regulation No. 405<\/a>. If you don’t have an automatic PEPPOL connection, you enter the invoice through SABIS instead. The same regulation sets this up as a fallback, not a convenience you choose for yourself. SABIS’s own FAQ<\/a> confirms there are three ways to get data in: typing it into the portal manually or importing an XML file, using a universal interface from your accounting software, or submitting automatically as a member of the PEPPOL network.<\/p>\n

What if you have neither a PEPPOL connection nor accounting software?<\/h2>\n

Then the answer is straightforward: log into the SABIS portal and enter the invoice by hand. Login runs through the VIISP identification service, the same one used across a wide range of Lithuanian e-government services. After your first login you’ll need to register your organization, as the SABIS FAQ<\/a> walks through. From there, depending on your role, you can enter, submit and track invoices. It doesn’t cost you anything beyond your own time, but it does require that the contract details already exist in SABIS before you try to invoice against them (more on that below).<\/p>\n

Does the \u20ac1,000 oral-contract exception still apply?<\/h2>\n

No. The exception that let businesses invoice under oral agreements worth up to \u20ac1,000 excluding VAT was only ever meant to be temporary, and it ended on December 31, 2024<\/a>. Since January 1, 2025, an invoice issued under an oral agreement, regardless of the amount, has to go through SABIS just like any other. The only real difference is procedural: for an oral-agreement invoice you pick the separate “oral incoming invoice” type inside SABIS, and you don’t need to link it to any contract record, as the SABIS FAQ<\/a> explains. The old \u20ac1,000 threshold was a transition-period rule. It has no bearing on how things work in 2026.<\/p>\n

When can a foreign supplier invoice by email?<\/h2>\n

This exception is built specifically for cross-border suppliers, not for Lithuanian companies. The SABIS FAQ<\/a> says outright that, for the time being, foreign suppliers of goods, services or works can’t log into the SABIS portal at all. Their main route is submitting through the PEPPOL network, picking a suitable service provider’s Access Point (the connection point that routes your invoice into the network). If PEPPOL isn’t a sensible option, say a small Estonian business sending a single one-off invoice to a Lithuanian municipality, the invoice can be submitted in whatever way the buyer is willing to accept, and email is one of those options. This isn’t a blanket permission for everyone. It’s a solution worked out with the buyer in advance, for one specific cross-border situation.<\/p>\n

What contract data has to match inside SABIS?<\/h2>\n

For an invoice tied to a written contract, SABIS checks three things: the contract has to already exist in the system, it has to be linked to the seller submitting the invoice, and the contract number written on the invoice has to match, exactly, the number registered in SABIS, as laid out in the SABIS supplier guide<\/a>. Entering the contract correctly is the buyer’s job, not the supplier’s. If the contract isn’t in SABIS, you can’t submit the invoice at all. The only sensible move is to contact the buyer directly, before your invoice deadline gets close.<\/p>\n

One exception still stands in the law: under Article 12(12) of Public Procurement Law No. 22<\/a>, an invoice may be non-electronic only when SABIS or PEPPOL has actually broken down during mobilization, war or a declared state of emergency. Declaring an emergency on its own isn’t enough. The outage has to be real and factual. This is an exception, not a routine backup plan, and in day-to-day invoicing you’re unlikely to ever run into it.<\/p>\n

FAQ<\/h2>\n

Kas meilile lisatud PDF loetakse e-arveks?<\/h3>\n

Ei loeta. 2014\/55\/EL direktiiv \u00fctleb, et skaneeritud paberarve v\u00f5i tavaline PDF ei ole avaliku hanke t\u00e4henduses e-arve, isegi kui see liigub elektrooniliselt.<\/p>\n

Kas 2026. aastal tohib Leedu avaliku sektori arve saata e-postiga?<\/h3>\n

\u00dcldjuhul ei tohi. 1. jaanuarist 2025 tuleb Euroopa e-arve standardile vastav dokument saata PEPPOL-v\u00f5rgu kaudu v\u00f5i, kui see ei \u00f5nnestu, SABIS-e portaali k\u00e4sitsi.<\/p>\n

Kumb on \u00f5igem kanal: SABIS v\u00f5i PEPPOL?<\/h3>\n

Valikuvabadust sisuliselt pole: kui PEPPOL-liides on olemas, liigub arve automaatselt. Kui PEPPOL-\u00fchendust pole, tuleb andmed sisestada SABIS-e vahenditega.<\/p>\n

Millal v\u00f5ib v\u00e4lismaine tarnija arve saata e-postiga?<\/h3>\n

E-post on erand, mis kehtib piiri\u00fclestele tarnijatele ja ainult ostjaga kokkulepitud juhtudel. Peamine tee on PEPPOL-i kaudu, PEPPOL-i mittesobivuse korral v\u00f5ib ostja aktsepteerida e-posti.<\/p>\n