Using EDIFACT or SAP? How to comply with the 2027 e-invoice rules without an expensive module
From 1 January 2027, an invoice in EDIFACT format does not meet the definition of an electronic invoice. The solution is conversion to UBL or CII under EN 16931 — without replacing your ERP and without an SAP DRC licence.
If you exchange invoices with your customers in EDIFACT format, from 1 January 2027 this will no longer be enough for domestic transactions — EDIFACT does not meet the definition of an electronic invoice for VAT purposes. You do not, however, have to change your ERP or buy an expensive native module: it is enough to generate XML following the EN 16931 rules in UBL 2.1 or CII syntax from the invoicing data you already have in EDIFACT, and send it via a digital postman (Peppol access provider).
Why EDIFACT is not enough
You can keep exchanging EDIFACT with your partners, but from 1 January 2027 an invoice in this format will not meet the definition of an electronic invoice for VAT purposes for domestic transactions between domestic persons. It will therefore not fulfil your legal obligation.
How the conversion works
The procedure is standardised. The document CEN/TS 16931-3-4:2017 Syntax binding for UN/EDIFACT Invoice D16B describes how to map the fields of an EDIFACT invoice to the EN 16931 semantic names and those in turn to UBL or CII syntax. XML produced this way is considered compliant and meets the conditions of an electronic invoice.
An example of mapping a single field:
| Layer | Name |
|---|---|
| EDIFACT | Invoice_number |
| EN 16931 semantics | BT-1 Invoice number |
| UBL 2.1 | cbc:ID |
Do we have to report invoices converted this way to the Financial Administration?
If you use a delivery service and the Peppol BIS format, the reporting is done for you by the certified delivery service provider. If you do not use a delivery service, you do not have to report these electronic invoices.
SAP: the DRC module or a connector?
For SAP, the obvious option is the native SAP Document and Reporting Compliance module. However, you can achieve the legally required result — Peppol BIS 3.0 and automatic reporting — with a lightweight connector that runs on-premise in your infrastructure and uses your existing IDoc INVOIC or OData. Only the finished Peppol XML invoice leaves over encrypted HTTPS; no data leaves your network.
| Native ERP module | Lightweight connector | |
|---|---|---|
| New ERP licence | Usually yes | No |
| Changes to the ERP | Larger | Minimal, uses existing IDoc |
| Where the data runs | Depends on deployment | On-premise at your site |
| Legal outcome | Peppol BIS 3.0 + reporting | Peppol BIS 3.0 + reporting |
We charge for the connector by the hour at €35 — depending on scope it comes to 124–228 hours, and we agree a cap before work starts. There is no monthly fee for it; details can be found in the price list. If you use Odoo, Microsoft Dynamics 365 Business Central or ABRA Flexi instead of SAP, the procedure and estimates are on the ERP integration page.
What to do in 2026
- Find out in which format invoices leave your ERP today (IDoc INVOIC, EDIFACT, custom XML).
- Have the fields mapped to EN 16931 semantics — that is the core of the whole job.
- Try both sending and receiving as a dry run during the voluntary phase, which has been running since 1 January 2026.
- Test with a real business partner, not just in a sandbox.
Source: Financial Directorate of the Slovak Republic, methodological guideline 9/DPH/2025/IM — Frequently asked questions and answers on eFaktúra; CEN/TS 16931-3-4:2017.