Mandatory e-invoicing in the energy sector

Companies operating in the field of electricity and natural gas sales faced significant changes on the last day of 2024 regarding the introduction of mandatory electronic invoicing. According to a decision announced by the legislator on 31 December 2024, the deadline to implement mandatory electronic invoicing has been extended from 1 January to 1 July 2025, granting more time for the affected businesses to prepare for the transition.

The new regulation significantly differs from the previous wording on one point, as from 1 July 2025, electricity and natural gas traders will be required to issue electronic invoices for all non-retail customers. In practice, this means that, contrary to the previous regulation, sellers will have to issue electronic invoices not only to business end users but also to energy wholesalers from the second half of the calendar year.

The introduction of electronic invoicing aims to enhance efficiency and speed up the process. It also provides an opportunity for the affected companies to unify and simplify their administrative processes. 

However, it is also important to keep in mind that mandatory electronic invoicing will result in additional obligations not only for issuers but also for invoice recipients. Companies must be able to accept electronic invoices, regardless of format, and both issuers and recipients will have specific retention obligations. In electronic archiving, it is necessary to ensure the long-term preservation of documents in line with relevant tax regulations, for which companies have to apply modern IT solutions.

The longer preparation time provided by the legislator allows companies to comprehensively review and, if necessary, develop their internal processes for technological infrastructure and employee training.

Although the introduction of mandatory electronic invoicing has been postponed, it is important for businesses to begin with preparations to comply with the relevant electronic invoicing, acceptance and retention rules, so the July 2025 transition can be completed smoothly.

It is also important to note that until the mandatory introduction begins, the current rules apply to electronic invoicing in the energy sector. This means that applying paper-based or electronic invoicing depends on the agreement between the parties. Thus, as part of preparation, if a company has already agreed to receiving electronic invoices from its energy provider, it can receive electronic invoices before the mandatory transition, but such e-invoices must be properly archived.