
If you own a Latvian company and speak no Latvian, the e-invoicing question reaches you as a rumour: a partner mentions a deadline, a software vendor sends a warning, an international compliance blog names a year. The answer does not depend on the size of your company, and it does not depend on where you live. It depends on who receives your invoice. If the recipient is a Latvian budget institution, a structured electronic invoice has been mandatory since 1 January 2025, for transactions entered into before 2025 the requirement started to apply not later than from 1 January 2026, and since 1 January 2026 the data of that invoice must also be submitted to the State Revenue Service (VID). If the recipient is another undertaking registered in Latvia that is not a budget institution, the duty to draw the invoice up as a structured e-invoice starts on 1 January 2028. The law says undertaking, not company, and that word carries further than it looks: the section below explains why it covers a self-employed person as well. If the recipient is not registered in Latvia, the duty does not arise at all under Section 11, Paragraph fourteen, though the parties may agree to use a structured e-invoice anyway. One case sits apart: an invoice that a budget institution issues to a company. There the wording of the Transitional Provisions and the guidance of the authorities pull in different directions, so the date for that transaction is checked on its own rather than read off the general 2028 deadline.
This article was rewritten from primary sources on 17 September 2026: the Accounting Law in force, Cabinet Regulation No. 749 of 9 December 2025, Cabinet Regulation No. 877, and the published explanations of the State Revenue Service and the Ministry of Finance. Every date below carries the provision it comes from, so you can check it yourself. One caution that matters more here than in the Latvian version of this text: the Accounting Law exists in an official English translation, the portal marks that translation as outdated, and the Cabinet regulations that carry the mechanics have no English version at all. English is a convenience here, not the legal text. Where the versions differ the Latvian wording prevails, and the answer on language at the end of this article says exactly where they differ.
The red tick marks the date from which the duty applies. The dotted line marks the voluntary stage. The diagram carries only the type of recipient and the date: the provisions, the delivery channels, the derogations and the draft law submitted to Parliament are in the tables and the text below.
The duty itself sits in Section 11, Paragraph fourteen of the Accounting Law: "A source document which is issued by an undertaking to another undertaking registered in the Republic of Latvia, which is the recipient of goods or service for payment (invoice) shall be drawn up as a structured electronic invoice." Two conditions hide inside that sentence, and summaries lose both. First, the recipient has to be an undertaking registered in the Republic of Latvia. Second, the document has to be one issued for payment. That second condition turns on the function the document performs in the transaction, not on the heading it carries: a document issued for payment for goods or a service meets it whatever it is called.
The dates are not in that Section. They are in the Transitional Provisions, and they differ by recipient. Paragraph 9 says that for transactions entered into until 31 December 2024 with a budget institution, Section 11, Paragraph fourteen "shall commence not later than from 1 January 2026". That is why each deadline in the table names its own provision instead of a single headline year.
| Who receives the invoice | E-invoice mandatory | Data to the tax authority | Provision |
|---|---|---|---|
| A budget institution, whether the invoice comes from an undertaking (B2G) or from another institution (G2G). Both authorities place an institution's invoice to an undertaking (G2B) under the same date, a borderline case explained under the table | From 1 January 2025 | From 1 January 2026, mandatory | Section 11, Paragraph fourteen as amended on 31 October 2024, in force from 1 January 2025; Transitional Provisions, Paragraph 10 |
| A budget institution, under a transaction entered into until 31 December 2024 | Not later than from 1 January 2026 | From 1 January 2026 | Transitional Provisions, Paragraphs 9 and 10 |
| Another undertaking registered in Latvia that is not a budget institution (B2B) | From 1 January 2028 | From 1 January 2028 | Transitional Provisions, Paragraphs 8 and 10 |
| The same undertaking, ahead of the deadline, by choice | Possible already now | Voluntary from 1 January 2026 until 31 December 2027 | Regulation No. 749, Paragraph 18; the end of the window follows from Transitional Provisions, Paragraphs 8 and 10; explanation of the State Revenue Service |
| An undertaking that is not registered in the Republic of Latvia | Not mandatory, but the parties may agree to use it | Not provided for | Section 11, Paragraph fourteen; explanation of the State Revenue Service |
| A private individual who does not perform economic activity (B2C) | Not mandatory | Not provided for | Section 11, Paragraph fourteen speaks of an invoice to another undertaking |
One borderline case is shown in the table the way the authorities describe it, not the way we would read it on our own. Both the State Revenue Service and the Ministry of Finance place all three public sector segments, including an institution's invoice to a company, under the 2025 date. At the same time Paragraph 8 of the Transitional Provisions ties the later deadline to the status of the recipient, and in that segment the recipient is not a budget institution. If an institution issues invoices to your company, this is a case worth checking against the current explanation of the authority rather than against a summary.
What the table does not contain is a turnover figure, a headcount figure or an industry. The law in force sets no such threshold, and for a foreign owner who assumes that small companies are left out of European mandates, that is the most important line in this article.
Mandatory e-invoicing between companies was originally set to start at the beginning of 2026. The start was moved to the beginning of 2028, and it was moved by Parliament through a law, not by the government through a decision. The reference sits under Paragraph 8 of the Transitional Provisions: the wording of the law of 31 October 2024, as amended by the law of 5 June 2025, in force from 12 June 2025. This matters in practice, because a deadline set in a law does not shift by administrative decision either.
One deadline moved, not the whole reform. Precisely: the duty to draw up an e-invoice in a transaction with another undertaking registered in Latvia that is not a budget institution, and with it the submission of that invoice data to the tax authority. Everything concerning budget institutions stayed where it was. An invoice to an institution has been an e-invoice since 1 January 2025, and submission of that invoice data to the State Revenue Service started on 1 January 2026 as a duty, not as an option. The voluntary submission from the same date applies only to undertakings that are not budget institutions, exchange invoices between themselves, and use the channels referred to in Sub-paragraphs 10.2 and 10.3 of Regulation No. 749.
The second source of confusion is the penalty. The Accounting Law contains no separate administrative offence for failing to draw up a structured e-invoice; the requirement itself is in Section 11, Paragraph fourteen. Penalties in accounting are set by Sections 41 to 44. For failure to comply with the procedures for the drawing up, registration and use of source documents, Section 43, Paragraph one provides for "a warning or a fine of up to eighty-six units of fine", and one unit of fine is EUR 5 (Section 16, Paragraph two of the Law on Administrative Liability), so eighty-six units means up to EUR 430. Failure to comply with the provisions for the keeping of accounts, failure to submit an annual statement or submission of a statement that does not conform to the law is a different offence with its own ceiling: Section 42 provides for a warning or a fine of up to four hundred units, that is, up to EUR 2000. These are the maximums of general offences, and a fine for a particular situation cannot be calculated from them: whether a case falls under one of these provisions, and which penalty applies, is assessed by the State Revenue Service in administrative offence proceedings (Section 45, Paragraph one).
If any of the points below describes your company, waiting until 2028 has stopped being a plan.
The first step is not new software. It is one check: which of your clients hold the status of a budget institution. That answer tells you whether the requirement is already running for you.
Everything above rests on this single fact, so it is worth establishing on paper rather than by intuition. The name of the organisation does not settle it: the status follows from the registration number, not from the word "state" or "centre" in the title.
The term is defined by the law itself, and this is a place where you have to read the Latvian. Section 3, Paragraph one, Clause 3 in the wording in force names budget institutions, derived public persons partly financed from the state budget and institutions not financed from the budget within the meaning of the Law on Budget and Financial Management, and, in brackets, the law calls all three together budget institutions. So a partly financed derived public person is a budget institution for the purposes of this law, and an invoice to it falls under the earlier deadline. The English translation still carries the earlier wording of that clause, which says only "budget institutions", so the translation will not get you to this answer.
The State Revenue Service recommends checking the status in the classification tool of the Central Statistical Bureau: search the organisation by registration number and check which institutional sector (ISK) is assigned to it and whether that sector corresponds to the sector of budget institutions. The tool has an English interface, and searching by registration number is more precise than searching by name.
The second way to check is your own contract. An institution states the method and address for receiving an e-invoice in the contract: the Ministry of Finance currently considers it a mandatory element unless another way of providing the information has been agreed. An institution is entitled to require one specific delivery channel, provided the requirement applies equally to all suppliers.
Section 1, Paragraph one, Clause 9 defines the document as an invoice "which has been prepared, sent, and received in structured electronic format allowing to process it automatically and electronically and which conforms to the European Union standard LVS EN 16931-1:2017 ... and which the undertaking issues in accordance with the technical specification LVS CEN/TS 16931-2:2017". The definition names two documents, the standard and the syntax specification, and both of them bind: a file that satisfies the first and not the second is not what the law describes. In practice this means three things. The format is XML, and the tax authority states that the structure has to conform to PEPPOL BIS Billing 3.0; Paragraph 7 of Regulation No. 749 also names UBL 2.1. The version of the standard is not the 2017 first edition: the authority explains that e-invoices are to be prepared in accordance with the specified 2020 version. And the definition says "received", not only prepared and sent. No separate duty for the recipient follows from that word, but in practice it does follow that the parties have to agree on a channel in which the recipient is able to receive and process the structured invoice (Regulation No. 749, Paragraph 5).
The human-readable document does not disappear anywhere. Paragraph 31.1 of Regulation No. 877 requires a structured electronic invoice to be presented on the screen in a human-readable format with the possibility of producing a printout; the same requirement for electronically kept accounts is in Section 6, Paragraph five of the Accounting Law. So the XML file is the accounting document, and the system has to be able to display it readably and print it. A separate PDF file does not follow from that provision, and the Ministry of Finance puts it plainly: a structured e-invoice is not to be prepared in addition to something else, it is to be prepared primarily, as the default document.
Three practical cases have to be kept apart, because they decide daily work.
Corrections have their own route. Paragraph 25.1 of Regulation No. 877 provides that a document correcting or revoking a previously issued invoice drawn up as a structured electronic invoice is itself prepared as a structured electronic invoice, with a reference to the number of the invoice being corrected or revoked. It covers both an erroneous invoice and a transaction cancelled in part or in full. The practical consequence is worth writing into your internal rules: decide in advance who in the company is entitled to issue a corrective invoice.
The circulation procedure is set not by the law but by Cabinet Regulation No. 749 of 9 December 2025, in force from 13 December 2025. It answers the practical questions the law leaves open. It has no English translation on the legislation portal, which is one reason this section quotes paragraph numbers rather than paraphrasing.
For circulation with a partner, Paragraph 4 provides three channels: the official electronic address, if the account is activated; the channel of a service provider, that is, an operator; and another channel, namely integration between systems, an email address or another electronic delivery channel. You do not pick the channel unilaterally: Paragraph 5 requires companies to agree on a mutually usable channel, one that both sides can actually operate. Email is permitted, yet the Ministry of Finance does not recommend it as the main channel because of security and fraud risks, and recommends channels in which the counterparty can be identified unambiguously.
What technically delivers the data to the tax authority depends on the channel you chose, and this is where the practical question appears: does the invoice have to be submitted a second time.
| Channel to the partner | Who submits to the tax authority | Provision |
|---|---|---|
| The official electronic address | The system submits it automatically, and the authority receives it from 1 January 2026 (Paragraph 19). The undertaking and the operator have to use a current software version for the integration | Paragraphs 11 and 19 |
| The channel of a service provider, that is, an operator | The authority receives the invoice through the operator's channel integrated with its interface (API), except in the case referred to in Paragraph 11 | Paragraph 12; channel under Sub-paragraph 10.2 |
| Another channel: integration between systems, email or another electronic delivery channel | The undertaking submits it itself: through the interface (API) of the Electronic Declaration System (EDS) or by uploading the file there | Paragraph 13; channel under Sub-paragraph 10.3 |
Into that system the authority accepts an upload of the XML file only. The deadline is in Paragraph 14: the e-invoice is submitted to the State Revenue Service once, not later than within five working days after the day it was sent.
Failures have their own procedure, and it is better known in advance than on the day it happens. If the invoice cannot be submitted because of a disruption in your information system, you notify this in the electronic declaration system not later than on the next working day, stating the reason, and submit within three working days after the disruption has been remedied (Paragraph 15). If you use the channel under Sub-paragraph 10.2 or 10.3 and the disruption is on the side of the system run by the State Revenue Service, the invoice is submitted not later than on the next working day after it has been remedied, and the authority itself announces the disruption and its remedy (Paragraph 16). If the reason is something other than a system disruption, you notify it in the same system, stating the reason and the period, and submit within 30 calendar days from establishing the reason (Paragraph 17).
For choosing an operator, the tax authority publishes and updates an informative list of e-invoicing service providers. The list is informative: it is not a recommendation or an approval of any particular company. Before the first transmission the authority advises checking the prepared XML with the invoice validation tool of the European Commission: according to the authority, it helps to confirm conformity with technical and business requirements, including the data structure, mandatory fields and the correctness of calculations.
The exceptions are not in the Cabinet regulations. They are in the law itself, in Section 11, Paragraph sixteen, and the law frames them as a right to derogate rather than as an automatic carve out: "The following may derogate from the requirement laid down in Paragraph fourteen of this Section for the drawing up of structured electronic invoices". There are three such cases.
Outside that list are the cases in which the requirement never arises in the first place: an invoice to a private individual who does not perform economic activity, an invoice to an undertaking not registered in Latvia, and a delivery note that is not at the same time an invoice issued for payment. These are not exceptions from the provision, they simply fall outside Section 11, Paragraph fourteen.
Invoices you receive from abroad have their own provision, and it is the one a foreign owner needs first. Paragraph 33.1 of Regulation No. 877 allows an invoice issued by a foreign participant of an economic transaction to be treated as a source document even without all the elements required by Latvian law, provided it states at least the following:
The honest answer today is a status, not a provision. A draft amendment to the Accounting Law has been submitted to Parliament. Its text has been published only as an image file, so we do not retell its content here. Below is only what the card of the draft shows.
Draft law No. 1493/Lp14, "Amendment to the Accounting Law"
Submitted on 18 August 2026, before the Presidium on 19 August, referred to committees on 20 August. The responsible committee is the Budget and Finance (Taxation) Committee. The first reading column in the card of the draft law was empty as at 17 September 2026.
What this means in practice: the content of the draft may still change, it has not passed a single reading, and the date of its examination is not known. Until the law is amended, Section 11, Paragraph fourteen contains no turnover threshold.
So the answer has two halves. Following the progress of the draft is worth the effort, because it would amend the very law on which every deadline in this article rests. Planning on the basis of it is not: until amendments are adopted, obligations are assessed under the version in force.
The time left until 2028 sounds like plenty, but most of the work is organisational rather than technical, which is exactly why it cannot be done in the final week. This sequence works for a company with a hundred partners and for a one person business alike.
If your accounts are kept by your own employee, this list is their work plan for two years. If your accounts are outsourced, e-invoicing becomes a selection criterion: ask for a specific answer about the software and the channel rather than an assurance that everything will be fine. Before signing, it is also worth checking the provider's licence, and the procedure for that is described in our article on how to check an outsourced accountant's licence.
A readiness review can be handled together with taking over the accounts. SIA "Lex & Finance" is entered in the register of licensed outsourced accountants of the State Revenue Service and offers accounting support for the e-invoicing switch on a full or partial cycle: we check which of your transactions already fall under the requirement, assess the software and the channel, put the circulation procedure in order and take over day-to-day accounting.
This article explains the procedure and the deadlines; it does not replace advice on a specific situation. In borderline cases the terms of the contract, the parties to the transaction and the date the transaction was entered into decide the answer.
No. What became mandatory from 1 January 2026 is the submission to the tax authority of data on invoices issued to budget institutions; those invoices themselves have had to be drawn up as e-invoices since 1 January 2025, and for transactions entered into until 31 December 2024 the requirement started to apply not later than from 1 January 2026. In transactions between undertakings the duty starts on 1 January 2028, and between 1 January 2026 and 31 December 2027 the submission of data in that segment is voluntary for those who exchange invoices between themselves and use the channels under Sub-paragraphs 10.2 and 10.3 of Regulation No. 749.
No. Section 11, Paragraph fourteen speaks of an invoice to another undertaking registered in the Republic of Latvia. The State Revenue Service explains separately that the requirements do not prevent a company registered in Latvia from preparing a structured e-invoice for a company that is not registered here, if the parties agree on it between themselves. For an EU partner already working in the PEPPOL network, a structured invoice is a format their system can read.
No, and the reason is not the email. The channel is permitted: Paragraph 4 of Regulation No. 749 names an email address among the delivery channels, the Ministry of Finance simply does not recommend it as the main one. What does not match is the format: a structured invoice is an XML file conforming to the standard and the syntax specification, while a PDF is a document for a human reader that a system does not read automatically.
The regulations require the data structure to conform to PEPPOL BIS Billing 3.0 and name UBL 2.1 (Paragraph 7), which is a requirement about the file, not about membership of a network. The delivery channels are listed separately in Paragraph 4: the official electronic address, an operator's channel, or another electronic channel agreed with the partner. Working through an operator connected to that network is one way to meet the channel requirement, but the provision does not name the network itself.
Partly, and the gap is worth knowing before you lean on it. The Accounting Law has an official translation by the State Language Centre, consolidated with the 2024 and 2025 amendments that set the 2025, 2026 and 2028 dates. The portal marks that translation as outdated: it gives the validity as 12 June 2025 to 26 March 2026 and states that the amendment of 26 February 2026 is not included. We checked what that amendment touched. Section 11 and Transitional Provisions 8, 9 and 10, which carry every date in this article, were not changed by it; Section 3, which lists who the law applies to and defines a budget institution, was. The Law on Administrative Liability carries the same kind of banner. Regulation No. 749 and Regulation No. 877 have no English version at all, and the guidance pages of both authorities are in Latvian. In a dispute the Latvian wording is what applies.
Once per invoice, not later than within five working days after the day it was sent (Regulation No. 749, Paragraph 14). Two details decide the count in practice: the five are working days, and they run from the day of sending, not from the date printed on the invoice. Failures are handled by three separate regimes in Paragraphs 15 to 17, and they differ by whose system broke. The one worth remembering is Paragraph 16: if the disruption is on the side of the system run by the State Revenue Service, you file on the next working day after it has been remedied, and the authority announces both the disruption and the remedy itself.
Yes, if it is a source document issued for payment to another undertaking registered in Latvia. The title of the document does not decide the matter: Paragraph 29 of Regulation No. 877 lets the company choose the name of the document type according to the substance of the transaction, unless another legal act prescribes the name, while a source document issued for payment to another undertaking registered in the Republic of Latvia falls under Section 11, Paragraph fourteen of the Accounting Law. The Ministry of Finance has confirmed this specifically for advance invoices. If the transaction is outside the provision, for example an invoice to a private individual or to a foreign company, the requirement does not reach it. Note separately that Paragraph 34.2 of the regulations ties the relief on not preparing a final invoice in transactions between undertakings to the advance invoice having been prepared as a structured electronic invoice.
SIA "Lex & Finance", a legal and accounting practice in Riga. Registration number 40203239265. Entered in the register of licensed outsourced accountants of the State Revenue Service, licence No. AGL0001078. The licence confirms compliance with the requirements set for outsourced accountants, not the quality of the work.
Kalpaka bulvāris 10, Riga
Phone +371 29515251, +371 25155167
Email consulting@lexfinance.lv
Checked against primary sources on 17 September 2026: the Accounting Law in Latvian, with its official English translation used only as a reading aid, Cabinet Regulation No. 749, Cabinet Regulation No. 877, and the explanations of the State Revenue Service and the Ministry of Finance, both published in Latvian.
This English text is provided for convenience, and so is the official translation of the law: the legislation portal marks that translation as outdated. Where the versions differ, the Latvian wording prevails.