The situation
The group’s entities and the countries they invoice in
A Munich packaging group has companies in Germany, Poland and Spain, each running its own instance of the ERP. The CFO wants one memo before budget season: which entities must issue or receive structured e-invoices, through which channel, in which format, and what the IT project has to deliver in each country.
The rules exist, but they arrive in pieces: an amendment to the VAT act, a regulation on technical formats, a phase moved back by a later law. Getting a current, cited answer for three countries, and keeping it current while the project runs, is where the time goes.
What the research has to settle
The rules behind the answer
- The EU now lets states require it
- Following the ViDA package, the VAT Directive lets member states make structured e-invoices mandatory for domestic business-to-business supplies without first seeking EU authorisation. Intra-EU supplies are brought into e-invoicing later under the same package.
- A PDF is not a structured e-invoice
- The mandates require invoices in a structured format that a system can process automatically, generally built on the European standard EN 16931. A PDF sent by email does not meet that requirement where a mandate applies.
- Three countries, three models
- Poland routes invoices through a central government platform, KSeF. Germany has no central platform: structured invoices pass between businesses, starting with a duty to be able to receive them. Spain runs two strands, a B2B e-invoicing obligation and separate requirements for invoicing software.
- Scope and phase are set per entity
- Each mandate sets who is in scope, often by establishment and turnover, and phases obligations in. Several timetables have already moved, so the memo should record each entity’s phase and the law it rests on as at its date.
How it runs in azta
From the question to the document
The question, as you would type it
Group with a German GmbH (turnover about €40m), a Polish sp. z o.o. and a Spanish S.L., all selling to domestic businesses. For each, which e-invoicing obligations apply now and which are scheduled, in what format and through which channel, and who must be able to receive?
You start with
The group’s entities and the countries they invoice in
- 01
Name the entities and countries
Give each entity’s country, establishment and turnover band. azta searches the VAT Directive, the national VAT acts and the implementing regulations on formats and channels.
Cited research· Free - 02
Check the version in force
Timetables have changed by amendment. Open each provision in the reader and compare versions to see what changed and when.
Atlas statute reader - 03
Draft the memo
Ask for one table per country covering scope, format, channel, phase and the open questions for IT. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for the steering group
Export to Word for the project steering group. The citations stay with the research, ready for the next update.
Word export· Pro You send
A memo on the e-invoicing obligations that apply to each entity
What you get
A memo on the e-invoicing obligations that apply to each entity
Internal memo · draft
E-invoicing obligations by entity: Germany, Poland, Spain
Germany. The GmbH must be able to receive structured e-invoices from domestic suppliers. Its obligation to issue them is phased by turnover, as set out in Annex 1. Accepted formats are structured formats built on EN 16931; a PDF alone does not qualify. No central platform is involved.
Poland. Domestic B2B invoices are issued through KSeF, the national platform, which assigns each invoice its identifier. The ERP must connect to KSeF. The phase that applies to the sp. z o.o. is set out in Annex 1 with the provision relied on.
Spain. Two projects run in parallel: the B2B e-invoicing obligation and the requirements for invoicing software. The implementing rules and the timetable for each are in Annex 2. Open question for IT: whether the ERP vendor will confirm compliance for the Spanish instance.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
13 minutes a month
At €130 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 32
- Capacity at your rate
- €4,212
- More e-invoicing scope memos a quarter
- 0.8
- Return on Pro
- 13×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
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What stays with you
- The project plan and the IT decisions.
- Watching for further changes to the timetables, which the memo records as at its date.
- Agreeing the scope with each entity’s finance lead.
Frequently asked questions
- Will the memo stay up to date?
- The memo records the law at the date you ask. Legislation in azta is indexed daily, so ask again before each project milestone and compare the provisions’ versions in the reader.
- Does azta connect to KSeF or to our ERP?
- No. azta researches and drafts. Connecting the ERP to KSeF or any other platform is a project for your IT team or vendor.
- Does it hold the technical specifications?
- It cites the legislation and regulations that set the format requirements. Detailed technical specifications are published by each tax administration, and azta does not hold all of them.



