By Todd L Gould, CEO, Loren Data Corp. who was in attendance at the Peppol Conference Europe 2026 in Brussels.

BRUSSELS. For more than a decade, Peppol was a piece of plumbing that almost nobody outside a small circle of tax officials and software engineers had heard of. It was a network for shuttling electronic invoices between businesses and governments, built on consensus and run by a nonprofit association in which membership was voluntary and decisions were made, for the most part, by agreement rather than decree.

That era appears to be ending.

At the Peppol Conference Europe, held here over two days in June, the talk in the hallways and on the panels was not about whether governments would require companies to use the network. It was about how many more of them are about to, and what that means for an organization that was never built to be told what to do.

Peppol has crossed a line. The challenge now is scaling our governance to fit this new world.” — Simon Foster, Global Director of Electronic Invoicing, Xero

That line, more or less, ran through every session of the conference, from the opening keynote to the closing panel two days later. Below is a guide to what was said, organized the way the conference itself was: a set of plenary sessions for the big picture, a business track on the rules countries are writing, and a technical track for the engineers building the thing.

The Big Picture: From Cooperative to Infrastructure

The Numbers Behind the Growth

André Hoddevik, the secretary general of OpenPeppol, the nonprofit that governs the network, opened the conference with numbers meant to convey scale: 1,059 member organizations now operate across 48 countries and territories, with 26 governments formally designated as Peppol Authorities overseeing the network within their borders. More than 3.4 million businesses can now receive an invoice over the network, according to figures current as of late May.

What is driving that growth is not enthusiasm so much as law. Belgium’s mandate took effect on Jan. 1. Norway, Slovakia, Oman and the United Arab Emirates have set the same date for 2027. Singapore is completing a phased rollout that extends to 2028, and Ireland follows that same year.

Peppol by the Numbers

• 1,059 member organizations across 48 countries and territories
• 26 governments formally designated as Peppol Authorities
• 3.4 million+ businesses now able to receive an invoice over the network

Belgium’s Test Case

Belgium offered the conference its first real test case, and the numbers presented by Wouter Bollaert of the country’s Ministry of Finance were striking. Adoption climbed from 18 percent of businesses in July of last year to roughly 88 percent by early June, with more than 1.16 million companies now registered. Much of that growth came in a short window before and after the Jan. 1 deadline, a pattern Mr. Bollaert called, without much exaggeration, an “inverted hockey stick.”

The government’s approach was deliberately hands off. Rather than build a free public portal for businesses to send invoices through, as some countries have done, Belgium left the entire market to private software vendors, calculating that a state-run alternative would discourage investment and leave businesses worse off in the long run. The number of registered invoicing applications in the country has more than quintupled since the mandate was announced, according to figures Mr. Bollaert presented.

There were rough patches, including invoice delays of up to 48 hours in the first weeks and a handful of fraud attempts traced to access points with weak identity checks. The government responded with a three month grace period rather than penalties.

Edward Roosens, chief economist at the Federation of Belgian Enterprises, offered the view from industry, recounting nearly two decades of failed voluntary efforts to get companies to adopt structured invoicing before the mandate finally forced the issue. “Businesses digitized the sending of invoices,” he said of the years before the law took effect, “not the process itself.”

Beyond Invoicing

Other sessions made the case that Peppol’s ambitions now reach well beyond invoicing. A presentation from the Norwegian oil and gas company Equinor described an expanding use of Peppol’s logistics messages, things like advance shipping notices and transport status updates, to digitize parts of the supply chain that invoicing alone never touched. A separate talk connected that work to a new European Union framework for electronic freight data known as EFTI.

Tomi Rusi of Finland’s State Treasury introduced what may be the most ambitious idea on the table: a European Business Wallet that would let companies prove their identity and banking details directly within the Peppol network, adding a layer of trust to transactions that today rely largely on the good faith of intermediaries.

Nick Davies, of the International Centre for Digital Trade and Innovation, went further still, arguing in a Wednesday session that Peppol, paired with an international invoicing standard known as PINT, could become something closer to a backbone for global trade itself, linking invoices to customs declarations, shipping documents and bank financing across borders. It was, by his own description, an ambitious pitch.

The Governance Question

But the session that seemed to unsettle the room most was the last one, devoted entirely to governance. Mr. Hoddevik did not soften the dilemma: OpenPeppol’s bylaws were built for a member driven cooperative, the kind of organization that works well when participation is optional and decisions can wait for consensus. A network that multiple governments now require by law needs something else, he argued, though nobody at the conference, including him, claimed to know exactly what.

A new task force has been formed to work out an answer, with results expected at the association’s next general assembly.

Serge Libert, of the Belgian government agency that oversees the country’s Peppol rollout, put a finer point on the stakes during his own remarks.

“Peppol now resembles a worldwide systemic component — not so different in kind from the financial clearing systems that move money between banks.” — Serge Libert, Belgian government Peppol oversight agency

Components like that, he suggested, do not get to stay informal forever.

The Business Track: A Crowded, but Converging, Map

If the plenary sessions dealt in sweep, the business track dealt in detail, country by country.

The ViDA Timeline

Much of the conversation centered on the European Union’s VAT in the Digital Age package, known by the acronym ViDA, which was adopted last year and will reshape how value added tax is reported across the bloc. Fernando Matesanz, president of the International VAT Association, walked through a timeline that runs to 2030, when electronic invoicing on the EU’s standard becomes mandatory along with new digital reporting requirements that will replace the bloc’s existing sales lists. Some of the package, he noted, is already in force, including a provision letting member states require electronic invoicing without needing a buyer’s consent.

Mr. Matesanz also flagged a set of questions that remain genuinely unresolved, starting with what European officials mean when they say reporting must happen “at the time” an invoice is issued. Does that mean instantaneously, he asked, or is some delay, measured in hours or days, acceptable. The answer carries real operational weight for any company building software around the deadline, and as of June, nobody had one.

OpenPeppol’s own answer is a pilot program led by Andriana Prentza, which has drawn 140 participating organizations, including 22 national tax administrations and dozens of service providers. The pilot completed its first live, end to end test the day before the conference began, demonstrating that the network’s architecture can carry both an invoice and the tax data tied to it through what officials call a fifth or sixth “corner” in the network’s data flow.

A Tour of National Rollouts

Beyond the ViDA timeline, the business track amounted to a tour of national rollouts, each recognizably built on the same foundation but each, in its particulars, slightly different.

Singapore has been phasing in a GST InvoiceNow requirement since late 2025, starting deliberately with smaller businesses, which officials there argued face higher compliance risk and benefit most from structured support; the full rollout extends to 2028. Slovakia’s mandate takes effect at the start of 2027, built around a government run lookup directory and a dedicated reporting channel operated by its tax authority.

The United Arab Emirates has already gone live with a five party model ahead of a pilot phase that begins in July, with 39 accredited service providers approved at the time of the conference and more than 100 expected by year’s end, a pace officials credited partly to a decision to keep the country’s tax reporting system separate from its central data platform so each could move on its own schedule.

France, meanwhile, is midway through its own staged rollout, with larger companies required to issue electronic invoices from September 2026 and smaller ones following in September 2027. Britain announced that beginning in April of 2029, all VAT invoices will need to be issued in a specified electronic format, a decision that followed a 12 week public consultation that drew nearly 350 responses.

Denmark described an effort to retire one of its two existing invoicing specifications, a national format called OIOUBL, in favor of a single standard built on the newer Peppol BIS 4. Japan, which has no mandate at all, reported that voluntary adoption among businesses has roughly doubled year over year regardless.

Country / Region	Mandate Status
Belgium	In effect since Jan. 1, 2026
Norway, Slovakia, Oman, UAE	Mandate effective 2027
Singapore	Phased rollout, GST InvoiceNow, through 2028
Ireland	Mandate effective 2028
France	Large companies Sept. 2026; smaller companies Sept. 2027
United Kingdom	All VAT invoices in specified e-format from April 2029
Denmark	Retiring OIOUBL in favor of Peppol BIS 4
Japan	No mandate; voluntary adoption roughly doubling year over year

What’s Coming Next from Brussels

Two sessions from the European Commission suggested where the rules themselves are headed next. Irina Riviere, of the commission’s internal market directorate, described a revision of the 2014 directive that first established electronic invoicing requirements for European governments, with a new legislative proposal expected by the end of this year. Among the options under consideration are extending mandatory invoicing to all public contracts regardless of size and, notably, requiring interoperability not just in invoice format but in how invoices are actually transmitted, a gap officials have identified as a persistent source of friction.

Alina Radu, from a separate commission unit, previewed the planned European Business Wallet regulation in more technical detail, describing a system of verified digital identities, electronic signatures and secure channels meant to be usable directly within Peppol transactions.

Cybersecurity Becomes Non-Negotiable

A fourth session, on cybersecurity, served as something of a warning. André Årnes, a security consultant, reminded the room that the EU’s NIS2 directive is no longer a future obligation but current law, with strict reporting deadlines. Personal liability for executives who fail to oversee their organization’s risk management applies throughout. Certification under the ISO 27001 security standard, he argued, is the most practical path to meeting those obligations, and OpenPeppol has already decided to require it of every service provider starting in 2028.

NIS2 Reporting Deadlines

• Early warning: within 24 hours of a significant incident
• Full notification: within 72 hours
• Final report: within one month
• ISO 27001 certification required for all Peppol service providers starting in 2028

The Technical Track: Rebuilding While the Plane Is Flying

The technical sessions were, by design, narrower and more granular, aimed at the engineers and architects who keep the network running. But even there, the same pressure showed through: a system designed for a smaller, more homogeneous group of participants is being adapted, in real time, to serve a much larger and more demanding one.

Rebuilding the Standard

The European invoicing standard at the heart of Peppol, known as EN 16931, has itself been revised, with the update formally published on March 18 and a three year transition window before the older version is retired. Built on top of that revision is a newer specification called Peppol BIS 4.0, and underlying both is something called the PINT methodology, which allows individual countries to layer their own requirements onto a shared base specification without breaking compatibility with everyone using the simpler version. Martin Forsberg of OpenPeppol, who presented the BIS 4.0 work, was candid that some of the coming changes solve real problems and others mainly add complexity, a tension he said the project’s working group is still negotiating, field by field.

Trust Architecture in Flux

A separate session addressed the network’s trust architecture, the systems that let one party verify another’s identity and certify that a message was sent and received intact. Rune Kjølaug, presenting for OpenPeppol, was careful to frame the coming changes as evolution rather than repair. “This is not about fixing something broken,” he said, before laying out several possible paths toward a system better aligned with new European identity rules and a category of regulated services known as qualified electronic registered delivery services. Which path the organization eventually takes remains unsettled.

Taking Control of the Lookup System

Some of the most consequential changes were the least visible ones. OpenPeppol is in the process of taking direct control of the network’s central lookup system, known as the SML, moving it off infrastructure run by the European Commission and onto servers it operates itself, a migration that reached a key milestone on June 9 and is expected to finish by midsummer.

A longer term project is exploring whether that lookup function could eventually be split across several operators rather than concentrated in one place, an idea driven partly by a desire for resilience and partly by countries wanting more say over where their data lives. Separately, the commission’s own technical team used its session to invite OpenPeppol to formally evaluate a new version of the underlying transport protocol, called eDelivery 2.0, which adds modern encryption methods and more flexible ways for systems to find one another.

Fixing the Small Stuff

Two smaller sessions addressed problems familiar to anyone who has tried to operate a large, decentralized system at scale. Philip Helger walked through an overhaul of the network’s message status reporting, the mechanism by which a sender learns whether a document actually arrived and passed validation, complete with an audience quiz testing the new rules’ more confusing edge cases.

Patrick van Heijst introduced a new development toolkit meant to fix what he described as a genuinely outdated workflow, one in which national specifications have long been built by a small number of specialists using complex tools, with errors often caught only after publication. The new system, he said, validates specifications as they are written rather than after the fact, a change he expects to matter most to the smaller national authorities that have historically struggled to keep up.

The Direction Was Not in Dispute

The governance question that closed the conference remains open, as do several of the technical questions about how, exactly, a system built for cooperation should now operate as a utility. The obligations involved are no longer confined to the invoice itself: security certification, identity verification and now, potentially, a digital wallet for businesses are all becoming part of what it means to participate in the network, rather than separate concerns layered on top of it.

The resulting patchwork of national rules, however different in their particulars, keeps landing on the same underlying standard, which is some comfort to any company that has to build for more than one country at once. And Peppol’s transformation from voluntary standard to government mandate is no longer a prediction. It has already happened in Belgium, and a calendar filling up with deadlines through the end of the decade suggests it will keep happening.

A network that began as an optional convenience for businesses willing to adopt it has become something closer to plumbing that European tax systems, and increasingly tax systems well beyond Europe, now depend on. Plumbing of that kind tends not to stay quiet for long.