# Peppol Is Not E-Invoicing: What Each Country Actually Mandates > Peppol is a network. EN 16931 is a format. A mandate can require one, both, or neither. Which countries require which, and why conflating them leads teams to build the wrong thing. Peppol is a delivery network. EN 16931 is a data format. A country can mandate a format, a network, both, or neither. Belgium mandates Peppol. Germany mandates only the EN 16931 format and no transport at all. France mandates its own approved-platform model. Poland and Italy mandate a government portal instead. Almost every vendor page treats "Peppol" and "e-invoicing" as synonyms. They are not, and the difference decides what you actually have to build. Teams have bought Peppol access points to satisfy German rules that never mentioned Peppol, and teams have joined Peppol expecting it to cover France, where it does not. Here is the distinction, and then the country-by-country reality. ## Four layers, and mandates pick from them An e-invoicing regime is made of four separable parts. 1. **Identity.** Who you are on the network. In Peppol this is a participant ID plus a scheme code, such as a GLN or a VAT number. 2. **Transport.** How the document moves. Peppol uses AS4 over a four-corner model: you connect to one access point, your counterparty connects to theirs, and the two interoperate by rule. 3. **Format.** What the document is. `EN 16931-1:2017+A1:2019` is the European semantic standard, expressed either as UBL 2.1 or UN/CEFACT CII D16B. 4. **Rules.** What counts as valid. Peppol BIS Billing 3.0, XRechnung, and Factur-X are all national or sectoral narrowings of EN 16931, formally called CIUS documents, each enforced by its own schematron ruleset. A law can require any subset of those four. That is the whole source of the confusion. ## What each country actually requires | Country | Format mandated | Transport mandated | In practice | | --- | --- | --- | --- | | Belgium | Peppol BIS Billing 3.0 | Peppol network | Full Peppol stack | | Slovakia | EN 16931 | Peppol, five-corner | Full Peppol stack, from Jan 2027 | | Norway | EHF 3.0 | Peppol network | EHF 3.0 is aligned to Peppol BIS Billing 3.0 | | Germany | EN 16931 | **None** | Email a valid ZUGFeRD file and you are compliant | | France | Factur-X, UBL, or CII | Approved platform | Not Peppol. See below | | Poland | FA(3) XML | KSeF government portal | No private network involved | | Italy | FatturaPA XML | SdI government portal | No private network involved | ### Germany mandates the format and not the transport Germany's obligation comes from the Growth Opportunities Act, which amended Section 14 of the German VAT Act (UStG). It requires that an invoice conform to EN 16931. It says nothing about how the invoice travels. That is why the dominant German pattern is a ZUGFeRD invoice, which is a PDF/A-3 file with the XML embedded as an attachment, sent as an ordinary email. The recipient's tax adviser imports it into DATEV in one step. No access point, no participant lookup, no network membership. If you are selling into Germany and someone tells you that you need Peppol, ask them which provision requires it. There isn't one. ### France mandates a transport model, but not Peppol France runs its own scheme. Invoices must be exchanged through a certified provider, known as a Plateforme de Dématérialisation Partenaire (PDP) and since 2024 formally a Plateforme Agréée. The original design also included a free public portal, the Portail Public de Facturation, through which businesses could issue and receive invoices directly. On 15 October 2024 the DGFiP [announced that this function was being dropped](https://www.kerhis.com/2024/11/29/le-portail-public-de-facturation-ppf-un-recentrage-strategique-de-la-dgfip-autour-de-lannuaire/) to protect the deployment calendar. The PPF now does two things only: it maintains the central directory of VAT-registered businesses and their e-invoicing addresses, and it acts as the data concentrator that passes tax data to the DGFiP. Many approved platforms also connect to Peppol. That is a commercial choice by the platform, not a legal route. Peppol membership alone does not make you compliant in France. ### Belgium is the case where Peppol genuinely is the answer From 1 January 2026 all Belgian taxable persons must issue and receive structured e-invoices, and the Peppol network is the designated channel. If you trade in Belgium, a Peppol access point is not optional and not a workaround. It is the mechanism the law names. Slovakia has proposed the same shape from January 2027, using a decentralised five-corner Peppol model with certified service providers. ### Poland and Italy bypass private networks entirely Poland's KSeF and Italy's SdI are clearance systems. The invoice goes to the state, the state validates and stamps it, and the state passes it on. There is no access point to buy and no network to join. What you need is an integration with the government platform and its schema, which for Poland is FA(3). ## Why this matters commercially Three consequences follow directly. **You may need less than you were sold.** If Germany is your only mandated market, you need an EN 16931 generator and an email server. The access point contract, the participant registry, and the AS4 stack are all solving a problem you do not have. **You may need more than one thing.** A group trading in Belgium, France, Germany, and Poland needs a Peppol connection, a French approved platform, a ZUGFeRD generator, and a KSeF integration. There is no single switch. Vendors who claim otherwise are usually reselling four integrations behind one invoice. **Your ERP may already cover part of it.** Odoo ships a built-in Peppol access point. NetSuite has an Electronic Invoicing SuiteApp. Business Central ships native Peppol format support, though only for a handful of countries and, as of this writing, not France. Check before buying anything. Our [ERP Peppol support guide](/guides/e-invoicing/does-your-erp-support-peppol) covers which systems ship what. ## Three sentences worth remembering Peppol is a network, EN 16931 is a format, and a mandate can require one, both, or neither. Germany mandates the format and not the transport. France mandates the transport model and not Peppol. And every one of these mandates covers invoices. None of them touches the purchase order, because a purchase order creates no VAT event and tax authorities regulate what they can audit. Peppol does define ordering profiles, covered in our [Peppol ordering guide](/guides/e-invoicing/peppol-order-documents), but no government has ever required them. ## Sources - [Growth Opportunities Act and Section 14 UStG guidance](https://edicomgroup.com/blog/germany-b2b-electronic-invoice), EDICOM - [DGFiP announcement on the PPF refocus](https://www.kerhis.com/2024/11/29/le-portail-public-de-facturation-ppf-un-recentrage-strategique-de-la-dgfip-autour-de-lannuaire/), KERHIS - [Peppol BIS specifications](https://docs.peppol.eu/poacc/upgrade-3/), OpenPeppol ## Related reading - [European e-invoicing mandate timeline](/e-invoicing), country by country - [France, 1 September 2026](/guides/e-invoicing/france-e-invoicing-mandate-2026) - [UBL vs X12 vs EDIFACT](/guides/e-invoicing/ubl-vs-x12-vs-edifact), if you already run EDI - [EDI Inspector](/edi-inspector), a free tool for reading EDI files in the browser