State of EU e-invoice interoperability — October 2026

Monthly report of the e-invoice conformance matrix. Data as of 25 Oct 2026. All numbers come from files in this repository; every upstream status links to its source.

Summary

• Update 25 Oct 2026: two generators were added after the first snapshot: easybill/zugferd-php 6.0.0 (XRechnung CII, 600/600 pass) and invopop/gobl 0.510.0 (CII + UBL, 1,200/1,200 pass; on 22/600 orders the amount due is €0.01 above the charged total). Totals below include them.
• Update 25 Oct 2026 (2): two Python generators were added: PyCheval 0.3.3 (Factur-X EN 16931 CII, 600/600 pass) and python-en16931 0.2 (Peppol BIS 3 UBL). python-en16931 has no line allowances, so the coupon goes in as one document discount. On the 138 orders that mix 19 % and 7 % VAT and carry a coupon, the library books the whole discount against the first VAT rate. That gives a wrong VAT breakdown (57 invoices even show a negative 19 % taxable amount) and an amount due €0.42–€535.50 below the correct figure. The CEN calculation rules still pass, because the invoice is internally consistent. Every file also fails Peppol rules R003/R005, because the template always writes TaxCurrencyCode and has no BuyerReference.
• 16,200 synthetic invoices from 14 open-source generators (27 configurations × 600 orders: 300 B2B + 300 B2C) were checked against KoSIT 1.6.3 (XRechnung 3.0.2 configuration), the CEN EN 16931 rules and Peppol BIS 3.0.20. Source: results/matrix_totals.json.
• 21 of 27 configurations are clean (pass every matrix validator check). 6 have validator failures: josemmo default config, Odoo 19 Factur-X (both rounding modes), WooCommerce PDF Invoices Factur-X (both settings), ZUGFeRD-csharp CII without a delivery date. Definition: a configuration is clean when, in both segments, every file is accepted by KoSIT or has no applicable KoSIT scenario, and has 0 XSD failures, 0 CEN EN 16931 calculation-rule failures and 0 Peppol R120 failures. These are the matrix columns in results/matrix.csv. python-en16931 0.2 is clean by this definition, but every one of its files also fails the full Peppol BIS rules PEPPOL-EN16931-R003/R005, which are not a matrix column.
• Passing the validator is not enough: 7 of the 21 clean configurations still state an amount due (BT-115) that differs from what the order charged: 4 of them on 472 of 600 invoices each (Mustang 2.26.0 library totals, speedata 0.0.23 CII and UBL, josemmo 0.3.1 with 2-decimal rounding), python-en16931 0.2 on 494 of 600, and invopop/gobl CII and UBL on 22 of 600 each. These are tax-inclusive shop orders converted to EN 16931 net arithmetic; no validator checks the original order total.
• New this month: French scenarios. 5 French-mandate scenarios × 2 Factur-X profiles (EN16931, EXTENDED) × 3 generator versions = 30 invoices, 30 pass (details below).

Upstream fixes and reports

Full per-version history with dates: results/history/version_history.json (also CSV).

Matrix results by generator

Source: results/matrix.csv, results/matrix_totals.json.

France: new Factur-X scenarios

France's receiving obligation and the issuing obligation for large and mid-size companies started on 1 Sep 2026, through approved platforms; accepted formats are UBL, CII and Factur-X. We added 5 French scenarios (scenarios/fr/scenarios.json):

1. Standard 20 % + 5.5 % VAT
2. VAT franchise ("TVA non applicable, art. 293 B du CGI", category E, code VATEX-FR-FRANCHISE)
3. Domestic reverse charge (autoliquidation, category AE)
4. Intra-EU supply to Germany (category K, art. 262 ter I CGI, delivery country and date)
5. All four French rates: 20, 10, 5.5 and 2.1 %

Each invoice carries the seller SIREN (BT-30, scheme 0002), SIRET (BT-29, scheme 0009), a SIREN-based electronic address (scheme 0225), the buyer SIREN, and header notes for late-payment penalties (PMT), the EUR 40 recovery fee (PMD) and the early-payment discount (AAB).

Checks: Factur-X 1.09.2 XSD for the profile, CEN EN 16931 CII rules, the official Factur-X EXTENDED schematron for EXTENDED, KoSIT (EN16931 profile only, since KoSIT has no EXTENDED scenario), and our structural checks that each French field reaches the XML.

Notes: - With horstoeko, the ship-to address (needed for BR-IC-12 on intra-EU invoices) is silently dropped unless setDocumentShipTo() is called before setDocumentShipToAddress(). Our first driver did this and produced a BR-IC-12 failure; that was our usage error, not a library bug. - horstoeko 1.0.132 passes these scenarios because we pass the exemption reason text explicitly; issue #390 (fixed in 1.0.133) was in the ZugferdQuickDescriptor helper, while our driver uses ZugferdDocumentBuilder with the reason text set explicitly. - We have not yet tested the French platform-specific (PA/PPF) rule sets, since they are not available as free, pinned validators. Results: results/fr/fr_results.json.

Regulatory calendar

Method

Deterministic corpus of 600 synthetic orders (tax-inclusive shop carts with % discounts and shipping), generated per library with the library's own API. Validators are pinned by SHA-256 in validators/pins.txt. Reproduce with scripts/run_matrix.sh and scenarios/fr/run_fr.sh. Corrections: see CONTRIBUTING.md.