Which Peppol service if you send under 50 invoices?

Short answer: under 50 invoices you don’t need your own access point

If you issue 1–50 invoices a month by hand, there is no point buying a separate Peppol access point (Access Point), the technical connection point into the network. An ordinary web-based invoicing program is enough, as long as your provider is itself a certified access point and forwards your invoice onward as a machine-readable e-invoice. An API interface is worth considering only once the invoices are already being created in some other system. And if your only e-invoicing need is a couple of Lithuanian public-sector invoices a year, the state invoicing environment SABIS and its portal will do: according to the European Commission’s Lithuania country sheet, an invoice can be submitted to SABIS through the portal, through an interface or through Peppol. One clarification straight away: 50 invoices is not a limit set by any law. It’s a cost-and-workload limit, the point where manual work starts costing more than the service.

Start with who you’re invoicing, not with the software

The choice depends on your customer, not on your invoicing tool. Three situations are genuinely different.

In the Lithuanian public sector, a structured e-invoice has been mandatory for suppliers under public procurement contracts since 1 July 2017, and every invoice to a public body travels through SABIS, which is connected to the Peppol network and supports the European e-invoicing standard EN 16931, the common machine-readable data model for an invoice. The same country sheet states that a supplier may use any service provider it likes, as long as the invoice matches the European standard.

The second situation is Estonian recipients. Since 1 July 2025, a company with accounting obligations can register itself in the business register as an e-invoice recipient and name its e-invoice operator or other receiving channel. Under § 7¹ of the Accounting Act, a recipient marked that way has the right to demand an e-invoice, and an e-invoice meeting EN 16931-1 counts as suitable unless the parties have agreed on another suitable standard. If your customer has made that mark, your PDF invoice is simply extra work for them.

Third, ordinary private-sector customers. In Lithuania, a private-sector supplier has no general legal obligation to issue EN 16931 e-invoices; there is no B2B or B2C mandate. In those relationships the e-invoice is a commercial arrangement: a large customer asks for it because of its own accounting, not because of the law.

A Peppol access point is not the same thing as an invoicing program

This is where most comparisons go off the rails. A single invoice’s journey is made up of four separate things:

• Creating the invoice: fields, lines, VAT, payment term. That’s the invoicing program.
• Producing the machine-readable file: the same data is turned into XML that matches the EN 16931 model and the Peppol BIS Billing 3.0 rules.
• The access point: the certified operator that sends the invoice into the network and receives invoices from it.
• The accounting or ERP interface: invoice entries land in your software automatically.

Up to 50 invoices, the first three should come in one price. The only thing worth paying separately for is the fourth — and only if you genuinely have a system to connect to.

Does a small business need its own access point?

No. Certification is the provider’s problem. On the Lithuanian side this is even written into the rules: according to the description of SABIS terms of use, Peppol invoices travel through registered access points and may be sent from any registered point, and the point operated by the state shared services centre (NBFC) is not intended for sending outgoing invoices. So what you need is a provider that has a point, not a point of your own.

How to check whether your invoicing program is really Peppol-ready

Three checks that take about fifteen minutes in total, and all of them can be done before you send your first invoice.

First: look up the provider’s name in OpenPeppol’s list of certified service providers. The list shows Access Point and SMP (Service Metadata Publisher, the publisher of address data) certification in separate columns, so insist on the “AP Certified” row rather than general membership. In the list updated on 18 September 2026, Baltic and Nordic providers appear under both their commercial and their legal names, so search for both.

Second: ask which BIS version the provider actually supports. OpenPeppol’s post-award documentation gives the Peppol BIS Billing 3.0 specification a publication date of 20 May 2026 and a mandatory date of 17 August 2026. “We have Peppol” is not an answer to that question.

Third: send a test invoice. You don’t have to write XML or buy a validation tool separately. A certified provider checks the invoice against the BIS rules before it goes out and should show you the specific error when a required field is missing. Ask during the sales conversation: what does that error message look like? For Lithuanian customers there’s no extra worry here, because the country applies no national CIUS and no additional rules on top of the European standard, so there is no separate “Lithuanian format” to worry about.

When the SABIS portal is enough, and when it turns into data entry

An invoice can reach SABIS in three equally valid ways: through the user interface (the portal), through the universal interface, or through the Peppol network. The test is simple. If you have a couple of occasional B2G documents a year, key them in through the portal and buy nothing. If public-sector invoices are a steady part of your turnover, or you want to track all your sales invoices in one place, the portal becomes a second data-entry point sitting next to your invoicing program.

One mechanism is worth unpicking here, because it gets mixed up constantly. Addressing and sending are two different things. Buyers registered in SABIS are added automatically to the SMP database of the NBFC access point, so a public buyer is findable in the network. That does not mean you can send invoices out from that point.

The second practical difference is statuses. When your invoice reaches SABIS over Peppol, the supplier gets the invoice processing statuses back: PROVIDED, APPROVED, REJECTED, ACCEPTED and PAYED. In the portal you have to go and look yourself. If you catch yourself asking every month “has that invoice even been approved?”, that is the one place where a Peppol service pays for itself immediately at under 50 invoices.

Seven things to ask a provider before you sign

• Access Point certification: is the provider on OpenPeppol’s list with AP certification, not only as a member or an SMP service provider?
• Sending and receiving: does the price cover both? Receiving purchase invoices is half the benefit, because those are the ones you’d otherwise retype by hand.
• Supported BIS version: is Peppol BIS Billing 3.0 in use in the version that became mandatory on 17 August 2026?
• Finding the recipient: how does the provider establish that your customer can receive? A Peppol Directory search helps, but it isn’t proof. In Estonia the binding signal is the e-invoice recipient mark in the business register and the channel shown there; for Lithuanian public buyers it’s the SABIS registration and the SMP entry that comes with it. Ask what the provider does when the recipient isn’t found.
• Invoice statuses: which messages come back to you? Peppol’s Message Level Response is a separate document type in the post-award documentation, and it proves the technical side only: the message reached the recipient’s access point and passed the checks. It does not prove that an accountant approved the invoice, and it says nothing about how good your provider’s support is. Business processing progress is shown by SABIS-style statuses, not by MLS.
• Export and archive: can you get your invoices out as XML and CSV without an extra fee and without an exit conversation?
• Users and the price after the free limit: how many users are included (the accountant is usually the second one), and what happens when the free invoice allowance runs out?

Price comparison at up to 50 invoices: the per-document price is the small number

Your real monthly cost is the monthly fee + invoices sent + invoices received + setup + interface + extra users. The price per invoice is the smallest variable in that formula. Below is a sample calculation. The figures are assumptions, but the questions in the “What to ask” column are the ones that actually move the price. Assume a monthly fee of €9, €0.30 per invoice sent, free receiving, and one extra user at €5.

Cost component	What to ask	30 invoices/month	50 invoices/month
Monthly fee	Are invoices included or charged on top?	€9	€9
Invoices sent	Does a credit note count as a separate document?	€9	€15
Incoming purchase invoices	Is receiving free?	€0	€0
Setup	One-off joining fee, Peppol ID registration	€0	€0
Accounting interface	Does export replace the interface, or do you pay for the interface?	€0	€0
Extra users	How many users are in the price?	€5	€5
Total		€23	€29

Now put your own manual work next to that. If entering, checking and copying 30 purchase invoices into the bank takes 5–7 minutes each, that’s roughly three hours a month. What those three hours cost in your company is a number only you know. That’s the number to compare against, not one price list against another.

ViDA 2030: how to choose today without paying in advance for the future

ViDA (VAT in the Digital Age) is generating a lot of hurry, but the date is a long way off. Council Directive (EU) 2025/516, adopted on 11 March 2025, sets out new digital reporting requirements for EU cross-border B2B transactions from 1 July 2030 and requires the European e-invoicing standard to be used in those situations. Peppol is not named as the only mandatory transmission network. For domestic private-sector B2B in Lithuania, none of this creates an access point obligation today. The European Commission’s eInvoicing Country Sheet notes that the first changes towards meeting ViDA requirements are planned to take effect from 2025, with mandatory e-invoicing targeted for 1 January 2028. That’s an intention, not a rule in force, and it’s worth watching rather than signing a three-year contract over.

So what does that mean for the choice? Take a service you pay for month by month, whose data you can get out in a standard format, and that already both sends and receives today. If invoice volumes grow, or some large customer insists on an interface, buy it then. The most expensive mistake at under 50 invoices isn’t picking the wrong provider. It’s a long contract and an API integration you never use.

Also available in: eesti keeles · lietuviškai

Last reviewed: 21 September 2026

FAQ

Kas väikeettevõte vajab Peppoli kasutamiseks oma ligipääsupunkti?

Ei, väikeettevõte ei pea ise ligipääsupunkti sertifitseerima ega haldama. Piisab veebipõhisest arveprogrammist, mille teenusepakkuja omab OpenPeppoli AP-sertifikaati ja edastab arved automaatselt võrku.

Millal piisab Leedu riiklikust SABIS-e portaalist?

SABIS-e portaalist piisab juhul, kui väljastate vaid mõne üksiku arve aastas Leedu riigiasutustele ning olete valmis andmed käsitsi sisestama. Pideva arvelduse puhul muutub portaal dubleerivaks töökohaks, mistõttu tasub kasutada integreeritud Peppol-teenust.

Kuidas kontrollida, kas tarkvara on päriselt Peppol-valmis?

Kontrollige pakkuja juriidilist või kaubanduslikku nime OpenPeppoli sertifitseeritud teenusepakkujate nimekirjast just AP-sertifikaadi veerus. Samuti küsige, kas süsteem toetab kohustuslikku Peppol BIS Billing 3.0 vormingut ja teeb automaatset EN 16931 reeglite valideerimist.