{"id":29495,"date":"2026-09-21T07:00:01","date_gmt":"2026-09-21T07:00:01","guid":{"rendered":"https:\/\/bilnex.io\/en\/e-invoicing-lithuania-2027\/"},"modified":"2026-09-21T07:00:07","modified_gmt":"2026-09-21T07:00:07","slug":"sahkoinen-laskutus-liettuassa-2027","status":"publish","type":"page","link":"https:\/\/bilnex.io\/fi\/sahkoinen-laskutus-liettuassa-2027\/","title":{"rendered":"S\u00e4hk\u00f6inen laskutus Liettuassa 2027: mit\u00e4 silt\u00e4 oikeastaan vaaditaan"},"content":{"rendered":"
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No. 2027 does not bring a general e-invoice obligation for small businesses in Lithuania. The European Commission’s Lithuania country page, confirmed on 14 August 2025, says it plainly<\/a>: e-invoicing is mandatory in public procurement (B2G, meaning you selling to a state body) since 1 July 2017, while there is no obligation for business-to-business (B2B) or consumer (B2C) invoices. The Lithuanian tax authority VMI’s own summary of the 2027 changes<\/a> is about something else entirely: law No XV-1036, passed on 18 June 2026, covers online marketplaces, the OSS scheme and distance selling, not structured invoices.<\/p>\n

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Key facts<\/strong><\/p>\n\n\n\n\n\n\n\n\n\n\n
Fact<\/th>\nValue<\/th>\nValid from<\/th>\nSource<\/th>\n<\/tr>\n<\/thead>\n
B2B and B2C e-invoicing obligation in Lithuania<\/td>\nNo obligation (B2G obligation applies since 1 July 2017)<\/td>\nas of 2025-08-14<\/td>\nec.europa.eu<\/a><\/td>\n<\/tr>\n
VAT law amendment No XV-1036<\/td>\nPassed 18.06.2026; enters into force 01.01.2027, articles 1, 3, 5\u20137, 9 and 10 only on 01.07.2029<\/td>\n2027-01-01<\/td>\nvmi.lt<\/a><\/td>\n<\/tr>\n
End of the \u20ac1,000 exemption for invoices under oral procurement contracts<\/td>\nExemption applied until 31.12.2024; from 01.01.2025 the invoice must be submitted to SABIS regardless of the amount<\/td>\n2025-01-01<\/td>\nvpt.lrv.lt<\/a><\/td>\n<\/tr>\n
SABIS in full operation<\/td>\nFrom 01.09.2024; the E. s\u0105skaita system became unavailable on 30.08.2024<\/td>\n2024-09-01<\/td>\nvpt.lrv.lt<\/a><\/td>\n<\/tr>\n
Ways to submit data to SABIS<\/td>\nPortal (manual entry or XML import), universal interface from accounting software, Peppol; formats are Peppol BIS Billing 3.0 invoice and credit note<\/td>\nas of 2026-09<\/td>\nsabis.nbfc.lt<\/a><\/td>\n<\/tr>\n
i.SAF submission deadline for a legal entity<\/td>\nRegisters for the tax period by the 20th of the following month; users of the small business scheme and non-VAT-registered businesses do not submit the registers<\/td>\n2019-07-01<\/td>\nvmi.lt<\/a><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n

What does touch your micro or small company today is an older rule. If your customer is a Lithuanian public-sector body, the invoice has to go into SABIS, and since 1 January 2025 that holds even when the deal was oral and the amount is \u20ac120.<\/p>\n

Does 2027 make e-invoicing mandatory for everyone in Lithuania?<\/h2>\n

The confusion comes from three separate things being pushed into one calendar. Pull them apart and the picture gets simple.<\/p>\n

The first layer is public procurement. On the Commission’s Lithuania page the B2G obligation is marked “YES” and the B2B and B2C obligations “NO”. It applies both below and above the EU procurement thresholds, and the whole public sector (central, regional and local) must be able to receive e-invoices through SABIS, which is connected to the Peppol network and follows the European e-invoicing standard EN 16931, the common data model for a machine-readable invoice. Between two private companies, an e-invoice is still a matter of agreement.<\/p>\n

The second layer is VAT law. VMI states that law No XV-1036, which amends VAT law No IX-751, enters into force on 1 January 2027, except for articles 1, 3, 5\u20137, 9 and 10, which only apply from 1 July 2029. The substance: online marketplaces become a “deemed supplier” in more situations than before, the scope of the OSS special scheme (one registration covering VAT in several member states) is widened, the calculation of the \u20ac10,000 distance-selling threshold is clarified, and IOSS can no longer be used by those applying the Lithuanian small business scheme. There is not a single line there about mandatory structured invoicing.<\/p>\n

The third layer is the EU frame: Council Directive (EU) 2025\/516 of 11 March 2025<\/a>, which Lithuania has just transposed with that same amendment. The “Next steps” part of the Commission’s Lithuania page names 1 January 2028 as the target date for mandatory e-invoicing. Read that as a target, not as a deadline in force \u2014 I cannot point you to a Lithuanian legal act that imposes it, because I did not find one.<\/p>\n

Who is the buyer: the decision table<\/h2>\n

Your own VAT status decides nothing here. Even a non-VAT-registered ma\u017eoji bendrija (MB, the light-weight Lithuanian small company form) has to put its invoice to a public-sector buyer into SABIS. What decides is the buyer type and the form of the contract.<\/p>\n\n\n\n\n\n\n\n\n
Buyer<\/th>\nExample invoice<\/th>\nWhat is mandatory<\/th>\nChannel<\/th>\n<\/tr>\n<\/thead>\n
Lithuanian private company (UAB, MB)<\/td>\n\u20ac1,200<\/td>\nNo e-invoice obligation, format by agreement<\/td>\nEmail, operator or Peppol<\/td>\n<\/tr>\n
Private consumer<\/td>\n\u20ac120<\/td>\nNo obligation<\/td>\nYour choice<\/td>\n<\/tr>\n
Public-sector buyer, written contract<\/td>\n\u20ac1,200<\/td>\nStructured invoice into SABIS; the contract must be in SABIS, linked to you as the seller, and the contract number on the invoice must match<\/td>\nPortal, universal interface or Peppol<\/td>\n<\/tr>\n
Same buyer, oral agreement<\/td>\n\u20ac120<\/td>\nSABIS also for small amounts, from 01.01.2025<\/td>\nOral invoice registrar role in the portal, or Peppol<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The requirements for written contracts and the conditions for submitting through Peppol are set out in SABIS’s official FAQ<\/a>. For an invoice based on an oral agreement, an authorised user on the buyer’s side fills in the BVP\u017d procurement classifier (the Lithuanian public procurement nomenclature) and the purchase type when checking or approving the invoice, or marks the invoice as not to be published. For you that means one thing: if the buyer’s side does not move, your invoice never gets to the finish line.<\/p>\n

SABIS deadlines that are already in force<\/h2>\n

The core obligation dates from 1 July 2017. SABIS’s guidance material cites as its legal basis article 6(4) of accounting law No IX-574, government resolution No 405 of 27 April 2022 and amendment No XIII-327 to the public procurement law.<\/p>\n

Then the platform changed. From a supplier’s point of view the exact order matters, and the Public Procurement Office (Vie\u0161\u0173j\u0173 pirkim\u0173 tarnyba) put it in writing on 22 August 2024<\/a>: the old E. s\u0105skaita system became unavailable on 30 August 2024 and SABIS started working in full on 1 September 2024. It was not the instant, frictionless switch it is sometimes described as after the fact.<\/p>\n

The third change is the one micro companies stumble over most often today. Invoices under oral procurement contracts had a temporary exemption of \u20ac1,000 excluding VAT. That exemption ended on 31 December 2024. From 1 January 2025 the data of such invoices must be submitted to SABIS regardless of the amount. This was not a permanent small-business concession that still applies somewhere.<\/p>\n

Free portal, interface or Peppol<\/h2>\n

There are three ways to get data into SABIS: through the portal, where you enter data manually or import it as an XML file (the structured, machine-readable form of the invoice); through the universal interface, straight out of your accounting software; or through Peppol, if your organisation is a member of that network. The formats in use are the Peppol BIS Billing 3.0 invoice and credit note.<\/p>\n

One thing to settle immediately: a PDF invoice does not replace submitting the data. The invoice data has to reach the system in structured form, as XML, and documents can come along as attachments. A nice-looking PDF in the attachment box is not, in SABIS terms, a submitted invoice.<\/p>\n

Using SABIS itself is free at the moment, and the portal, the interface and Peppol are alternative routes. The official guidance makes no promise that this stays free, or that third-party service prices hold. Choose by volume \u2014 not by price. If you send a couple of invoices a month to one state agency, the portal is the simplest. With dozens of invoices, recurring contracts and your own accounting software, an interface or Peppol pays off, because manual double entry keeps eating time for exactly as long as you keep doing it.<\/p>\n

The other practical trap is access. The first time round, the manager of the legal entity registers the organisation in SABIS using the VIISP identity service, after which an organisation account and a user with the administrator role appear. An access request (prieigos pra\u0161ymas) that has been submitted can then be reviewed, approved or rejected by the organisation’s administrator, as the SABIS user manual describes<\/a>. The roles are narrow: invoices under written contracts are entered by the invoice registrar, oral ones by the oral invoice registrar, and both by the supplier specialist.<\/p>\n

A foreign supplier (an Estonian O\u00dc, say) invoicing a Lithuanian public buyer<\/h3>\n

A supplier established abroad has no way to log into the SABIS portal any time soon. For an Estonian O\u00dc that means the invoice goes through the Peppol network, using an access point (the service provider that connects you to the network) of your choice. When the invoice is based on a written contract, the contract information must already be in SABIS, linked to that exact seller, and the contract number on the invoice must match the contract. If the number is wrong or the contract is not in the system, even a technically perfect Peppol invoice will not help.<\/p>\n

i.SAF is not the same as sending an invoice to your client<\/h2>\n

These two get mixed up constantly. i.SAF is a VMI system where you file the registers of gaunamos and i\u0161ra\u0161omos invoices, that is the lists of received and issued VAT invoices, to the tax administration. It has nothing to do with delivering an invoice to your customer.<\/p>\n

According to VMI’s guidance<\/a>, a legal entity must submit the registers for the tax period by the 20th of the following month (in force since 1 July 2019), and a natural person by the 20th of the first month of the following half-year, or monthly if they file a monthly VAT return. If you are removed from the VAT register, the data must be given within 20 days. The legal basis is order No VA-55 of the head of VMI of 21 April 2004.<\/p>\n

There are two exemptions that matter for a small business. Users of the Lithuanian small business scheme (smulkiojo verslo schema) are released from submitting invoice registers, and non-VAT-registered businesses do not submit them either. That does not release you from SABIS if you sell to the public sector. And the reverse holds too: diligent i.SAF filing does not count as having issued the invoice to your client.<\/p>\n

2027, 2028 and 2030: what to do right now<\/h2>\n

Three year numbers, three different statuses.<\/p>\n