Is PDF still acceptable for invoicing in the EU?

PDFs Are Losing Legal Validity Across the EU

A plain PDF — even if sent electronically — is increasingly not considered a valid e-invoice under EU member state mandates. The EU's ViDA (VAT in the Digital Age) directive explicitly redefines "electronic invoice" to mean only structured, machine-readable formats such as XML or EDI, excluding PDFs. According to Invoice Navigator's compliance tracking across all 27 member states, the following country-by-country breakdown shows where PDFs stand in 2026.

Country-by-Country Status

Belgium — PDFs No Longer Valid (Since January 2026)

Belgium's B2B e-invoicing mandate, effective 1 January 2026, requires all domestic B2B invoices to be structured Peppol BIS Billing 3.0 (UBL) documents. Standalone PDF invoices are explicitly excluded from compliance. Critically, the right to deduct input VAT is linked to receiving a compliant structured e-invoice — receiving a PDF may jeopardise VAT recovery.

Germany — PDFs Permitted During Transition (Until 2027/2028)

Since January 2025, all German businesses must be able to receive EN 16931-compliant structured e-invoices. However, during the 2025-2026 transition period, businesses may still issue paper or PDF invoices without penalty. From January 2027, businesses with revenue above EUR 800,000 must send structured e-invoices. From January 2028, all businesses must comply. After these deadlines, a plain PDF will no longer satisfy the invoicing requirement.

France — PDFs Replaced by September 2026/2027

France's phased mandate begins September 2026 for large enterprises, with SMEs following in September 2027. France accepts three structured formats: Factur-X (a hybrid PDF+XML format), UBL, and CII, exchanged via certified PA (Plateforme Agreee) platforms. A plain PDF without embedded structured XML data does not qualify. However, Factur-X — which is a PDF/A-3 file with embedded CII XML — does qualify, making it a practical bridge for businesses transitioning from PDF workflows.

Italy — PDFs Invalid Since 2019

Italy has required all B2B and B2C domestic invoices to use the FatturaPA XML format via the SDI platform since January 2019. PDFs have had no legal standing for in-scope Italian transactions for over seven years.

Poland — PDFs Invalid Since February 2026

Poland's KSeF mandate, effective February 2026, requires all VAT-registered businesses to issue structured e-invoices through the government's KSeF platform. PDF invoices do not satisfy the mandate.

The Hybrid Solution: ZUGFeRD / Factur-X

For businesses that need to transition gradually from PDF workflows, the ZUGFeRD/Factur-X hybrid format offers a practical middle ground. These formats embed structured CII XML data inside a PDF/A-3 document, meaning humans can still open and read the invoice as a PDF while automated systems extract the machine-readable XML. The latest version (ZUGFeRD 2.3/Factur-X 1.07) entered into force on 15 January 2026 and remains compliant with EN 16931. This hybrid approach is accepted in Germany and France and is a valid way to meet e-invoicing mandates while preserving the familiar PDF experience.

Where PDFs Still Work

PDFs remain valid for: B2C invoices in most countries, cross-border invoices where neither country has mandated structured e-invoicing for the transaction type, and domestic B2B invoices in countries that have not yet introduced mandates (though this window is closing as ViDA approaches). Invoice Navigator's compliance data shows that businesses still relying on PDF-only workflows should plan their migration to structured formats well before their country's mandate deadline.