Monthly developments
Jochen Stärk
Hello,
What I learned since my post at the beginning of march:
Philp Helger
https://github.com/phax again released a lot of open source, including, but not limited to PHORM https://github.com/phax/phorm (his peppol validator Phive https://github.com/phax/phive as REST API?) and (as a reaction to Zebra) https://github.com/phax/ph-redact . Additionally he apparently managed to consolidate the previously individual parts of what was needed to run a Peppop AP into a single PHOSS-AP https://github.com/phax/phoss-ap/wiki/Known-Users and already has pilot users . Please note that Peppol is a non-profit not a non-commercial EDI provider, i.e. you will still need a commercial Peppol certificate to actually go live with our AP as well as to comply to their rules e.g. often requiring ISO 27001.
Half time
The B2B eInvoicing mandate has so far been introduced in six european states (Croatia, Greece, Italy, Poland, Romania, and Spain) and is currently planned in seven more including Estonia, France (September 2026), Ireland, Latvia, Slovakia, and Slovenia. Germany (officially already the case, de facto I would count this only after 01.01.2027/2028)
Examples
Since March 27th, the AWV extended it's set of (PDF+XML)
examples and publishes updates independently from the
Factur-X/ZUGFeRD releases on https://www.ferd-net.de/faqs/zugferd-beispielrechnungen
France
Around mid April I leaned that also an free english version ("consultation") of AFNOR XP-Z12012, which will become important as of September particularly in France. Actually someone has patched (issue #1089) parts of it's schematron into Mustang (according release announcement) . Mustangproject is on a trajectory to also being able to validate e-invoices for the french e-invoicing reform as of September. If you consider to contribute in that domain please feel free to sign up for the according webinar on May 7th .
You will need commercial service providers (formerly called PDPs) to send/receive domestic e-invoices in France as of September.
As regards to the question
If commercial service providers will also be required in Germany
We know that the obligation to submit german B2B e-invoices to the authorities will be introduced after the obligation to write electronic invoices 01.01.2027 for big and medium companies and 01.01.2028 for small companies, but on or before ViDA in July 2030. In my previous post I had mentioned that the german IRS does not yet know if it will become free or only "cheap" and now towards end of April at least one political party - the CDU - now also plays it safe with an very unspectacular this-is-not-yet-decided-statement .
This is independently from B2G-invoices whose manual submission will most probably remain free: the possibility for an automatic submission via an open REST API had been turned off, potentially to support the proprietary Peppol channel?
However, as long as nobody confirms B2B e-invoicing will remain free: You (!) can feel free to support my petition to keep e-invoicing free in germany.
Learnings from open source
One of the many(!!) things I learned from easy e-rechnung
is the PDF->PDF/A conversion library Freespire.PDF
, from the chinese company e-iceblue.
PDF to PDF/A conversion is a incredibly complex task, and done in
open source (honorable mentions to iText and PDFBox) de
facto currently only by restrictive-open-source-licensed
Ghostscript which requires many users to use their commercial
version instead. Unfortunately Freespire is no open source at all,
just freeware :-(. Plus the output may not always be perfectly
valid, so please keep validating your output PDF/A.
However, available for free without watermarks, relatively quick
and simple, like this a native Java library, or similar in .net:
PdfStandardsConverter
converter = new
PdfStandardsConverter("calistoMTNoFontsEmbedded.pdf");
converter.toPdfA1B("ToPdfA1B.pdf");
My colleague (thanks Vincenzo!) compiled compared it to
Ghostscript using the The
Archivist's PDF Cabinet of Horrors as benchmark and
validated using VeraPDF:
| pdfCabinetOfHorrors | Freespire | Ghostscript |
| balloon_a1b_jp2k.pdf | Unknown | valid |
| calistoMTNoFontsEmbedded.pdf | valid | valid |
| corruptionOneByteMissing.pdf | valid | valid |
| digitally_signed_3D_Portfolio.pdf | invalid | invalid |
| embedded_video_avi.pdf | invalid | valid |
| embedded_video_quicktime.pdf | invalid | valid |
| encryption_nocopy.pdf | invalid | valid |
| encryption_noprinting.pdf | invalid | valid |
| encryption_notextaccess.pdf | invalid | valid |
| encryption_openpassword.pdf | Unknown | valid |
| externalLink.pdf | invalid | invalid |
| fileAttachment.pdf | invalid | invalid |
| fileAttachment_fileAttachmentAnnotation.pdf | valid | invalid |
| javascript.pdf | invalid | valid |
| pdf-17-header18.pdf | invalid | valid |
| test_fontArialNotEmbedded.pdf | invalid | valid |
| text_only_fontsEmbeddedAll.pdf | invalid | valid |
| text_only_fontsEmbeddedSubset.pdf | invalid | valid |
| text_only_fontsNotEmbedded.pdf | invalid | valid |
| text_only_pdfa1b.pdf | valid | valid |
| veraPDFHiRes.pdf | valid | valid |
| veraPDFHiResChangedHeight.pdf | valid | valid |
| veraPDFHiResWrongObjectID.pdf | Unknown | valid |
| webCapture.pdf | invalid | invalid |
But at least there is now a kind of contender! Let me know if
there is a better converter!
Finally, two follow-ups on my previous post <What's new / "monthly" developments since december> from March 1st, 2026:
The
Changes in the upcoming new version of EN16931
I have heard of I would currently roughly summarize as
- item prices, quantities and percentages will be restricted from previously ~18 digits to de facto 4 digits after the decimal, except for percent, which will be 2 digits (source: Afnor). The current two-digits-after-decimal for subtotals and totals will remain.
- it will likely upgrade UBL from 2.1 to 2.5 and CII from 2016b to 2025a. Since both versions are backward compatible this should be relatively little cause for headache.
- Apparently there will not only be a plethora of extensions, but also some kind of extension registry. Since there are additionally rumours for (XML based) cash discounts and collective invoices I would expect them to show up as extensions. In their CII representation probably very similar, if not identical to what ZUGFeRD Extended has, which supports that today. Of course the acceptance of extensions will have to remain bilaterally agreed, i.e. their acceptance is optional. Some candidates ones we might have seen already at https://github.com/svanteschubert/complex-business-cases .
- Contratry to the extensions: I'm not sure if it is true but for a while there were rumours of a now at last mandatory CIUS registry
- The examples have been stripped from the specification texts
- The issue with tax type for outside scope (typecode "O") will probably be resolved. So far that could not be used and Z or E was used instead because it required the non-existence of a VAT ID where many other rules required the opposite, the existence of a VAT ID
- I have no idea when this whole conglomerate is scheduled to be released (apparently around mid 2026), or even of which parts it will eventually consist. Apparently a BS-EN-16931 (whatever that is) is already released. I have heard of a transition period but I do not know if the version, i.e. EN16931:2017 is not actually mentioned somewhere where it would need to be updated. We do know that while EN16931:2017 had 7 sub-documents EN16931-1 to EN16931-7, -1 (calculation and rounding rules) as well as -2 (list of allowed syntaxes) being available for free, there is a draft for a EN16931-8 about simple invoices.
- Plus I learned that there will also be a new version of (B2G) guideline 2014/55/EU
Thanks and happy e-invoicing,
Jochen
-- mit freundlichen Grüßen Jochen Stärk www.usegroup.de Tel: (069)569940-20 Mobil: (0177)4512645