What if the customer is unable to receive e-invoice?
Short answer
Where a customer is required from 1 January 2027 to be able to receive e-invoice but cannot be reached through the delivery service, for example because it is not connected to Peppol, the supplier still creates and submits the e-invoice through the prescribed delivery channel. Retain evidence of the submission attempt and the resulting error status. The record should state that the invoice was properly created and delivery was attempted, not incorrectly claim that delivery succeeded.
Deadline and Shipping
"If the customer is not able to receive the electronic invoice by the delivery service and the supplier sends the electronic invoice by the delivery service, the supplier's legal obligation to prepare and send the electronic invoice by the delivery service is considered fulfilled."
An unprepared recipient
"In 2027, the use of the Delivery service will be mandatory, and the recipient is obliged to accept the electronic invoice through the Delivery service. If he does not do so and does not communicate, then your obligation as the sender of the invoice is fulfilled after you send the invoice through the Delivery service (it will end in an error, but you did everything you could)."
Technical delivery
"From the point of view of the law, the obligation to send an e-invoice is considered fulfilled at the moment it is sent via the delivery service. If an error message is subsequently returned because the recipient is not registered in the SML, this fact does not affect the fulfillment of the sender's obligation."
Reporting even in the event of an error
Reporting to the financial report (C5) takes place regardless of the success of the delivery — the invoice is reported even if the delivery failed due to a non-existent record in the SML.
Conclusion
Financial Administration FAQ 9/DPH/2025/IM, example no. 13 and technical example no. 9 · VAT Act, § 85o
Not legal advice.