What it is
A mandate phase is one slice of a country's (or the EU's) e-invoicing rollout schedule. No EU jurisdiction has switched all businesses to mandatory structured invoicing on a single day. Instead, every mandate so far has been broken into phases that vary along three independent axes: who is in scope (large enterprises first, then mid-sized, then SMEs/micro), what is required (receive-only, then issue-obligation, then full reporting), and which transactions are covered (B2G first, then B2B, sometimes B2C separately).
For an ERP vendor, the phase calendar dictates which customers need which features on which date. Missing a phase boundary means a customer cannot legally issue invoices through the ERP — a hard blocker, not a cosmetic one.
The shape of a typical phase plan
Most EU mandates have followed a pattern that goes roughly:
1. B2G first. Receivers in public administration must accept EN 16931 structured invoices (driven by Directive 2014/55/EU, in force across the EU since 2019–2020).
2. Receive-capability for B2B. All taxable businesses must be technically able to receive a structured invoice, even before they are obliged to issue one. This phase is short, cheap, and politically uncontroversial.
3. Issue-obligation for large enterprises. Issuers above a turnover or headcount threshold (often €800k–€10M turnover, or >250 employees) must send structured invoices.
4. Issue-obligation for mid-sized and SMEs. The threshold drops or is removed entirely.
5. Reporting / clearance layer. A near-real-time reporting (Hungary, Spain SII), a clearance flow (Italy SDI, Poland KSeF), or a Peppol-routed structured exchange (Belgium) is added on top.
6. Cross-border layer. Aligns the national format with the EU-wide ViDA Digital Reporting Requirement deadline.
ViDA's EU-wide phases
The Council adopted the VAT in the Digital Age package on 11 March 2025. The e-invoicing- and reporting-relevant dates are:
April 2025. Directive enters into force; Member States may immediately mandate domestic B2B e-invoicing without requesting derogation, provided the format conforms to EN 16931.1 July 2030. EU-wide Digital Reporting Requirements (DRR) take effect for intra-EU B2B transactions. Structured EN 16931 invoices become mandatory for cross-border supplies, plus near-real-time transaction-level reporting to a central system.1 January 2035. Existing domestic clearance / reporting systems (Italy SDI, Hungary RTIR, Spain SII, etc.) must harmonise to the ViDA standard. This date was pushed from 2027/2028 to 2035 during negotiation to protect Member State investments in legacy CTC systems.Country phase calendars (as of May 2026)
The most material upcoming national phases for ERP vendors are:
France. 1 September 2026: all taxable businesses must be able to receive via the PPF or a Plateforme Agréée; large and mid-sized enterprises must issue. 1 September 2027: SMEs and micro-enterprises must issue. Hybrid Factur-X, UBL, and CII are all permitted.Germany. 1 January 2025: all B2B receivers must accept EN 16931-conformant structured invoices (already in force). 1 January 2027: issuers above €800k turnover must issue structured. 1 January 2028: all B2B issuers, regardless of turnover.Belgium. 1 January 2026 (in force): mandatory B2B e-invoicing for all VAT-registered businesses via Peppol BIS Billing 3.0. No clearance layer at issuance; the reporting model arrives separately under ViDA-aligned legislation expected in 2028.Poland. 1 February 2026: KSeF mandatory issuance for large taxpayers (>PLN 200M revenue). 1 April 2026: all VAT-registered businesses. KSeF runs a clearance model — the platform must accept the invoice before it is legally issued.Spain. Verifactu (Veri*Factu) software certification requirements took effect 1 July 2025 (companies) and 1 July 2026 (individuals). The full mandatory B2B e-invoicing under the Crea y Crece law remains pending implementing regulations.Italy. SDI has been live since 2019 for B2B; cross-border invoicing was added in 2022. Italy must align SDI with the ViDA EN 16931 baseline by January 2035.Romania. RO e-Factura B2B mandatory since 1 July 2024; e-Transport and e-TVA reporting layers added in 2024–2025.Hungary. RTIR (real-time invoice reporting) live since 2018; no separate clearance, no separate cross-border phase until ViDA in 2030.Why phasing matters for ERP roadmaps
A phase boundary is a release-readiness deadline, not a marketing date. The practical implications:
Receive-only is the cheap phase. Detecting and parsing an inbound EN 16931 invoice is order-of-magnitude less work than issuing one. Skipping the receive-only phase to wait for the issue-obligation phase is a frequent and avoidable mistake.Threshold-driven phases hit segmentation. When the issuance threshold drops, the customer base needing the feature grows step-wise overnight. The ERP support model needs to anticipate this — onboarding 500 SMEs in the week before a threshold drop is operationally painful.The clearance layer is a different product surface. Issuing an EN 16931 UBL is one capability. Submitting it to a national platform, polling for status, retrying on failure, reconciling to the platform's identifier, and storing the clearance receipt are five more.Cross-border arrives once. July 2030 is the date that turns every domestic CTC integration into a partial solution; ERPs serving multi-country customers will need a unified reporting layer above the country-specific ones.Relation to EN 16931 and Peppol
Mandate phases do not change the underlying semantic standard: every domestic phase points eventually at EN 16931 conformance. The phases are differences in who must comply when and via what platform, not in what the invoice looks like. An ERP that has internalised EN 16931 as its canonical model can address each phase with a routing and reporting layer rather than a new data model.