Compliance · 🇪🇪 Estonia Phased rollout

Estonia — B2B-on-request mandate & Peppol BIS

B2B-on-request live since July 2025 · B2G universal · Peppol BIS — regulator: Maksu- ja Tolliamet (Tax & Customs Board). Facts last refreshed: 2026-05-05.

Coverage model

Flowie operates a registered Peppol Access Point in this jurisdiction directly where we hold national accreditation, or via a vetted local partner registered with the in-country regulator where on-the-ground presence is required (KSeF, SDI intermediario, ZATCA service-provider, etc.). Either way, you call the same POST /v1/documents/send.

TL;DR

Estonia introduced B2B-on-request from 1 July 2025: any Estonian buyer registered as an e-invoice recipient can demand a structured invoice and the seller must provide one.
B2G is universal since 2019; recipients are registered in the Estonian e-invoicing register (RIK).
Format: Peppol BIS 3.0 + the legacy Estonian e-invoice XML (EVS 923:2014) for backward compat.
Flowie's AP is registered for Estonia under 9931:flowie.

Deadlines

Date	Who	What
2017-03-01	Central government	B2G receive obligation.
2019-07-01	All public authorities	B2G send obligation.
2025-07-01	Domestic B2B (on-request)	Sellers must issue a structured e-invoice when the buyer is a registered e-invoice recipient.
≥ 2027	Universal B2B (expected)	Pending legislation; would convert on-request to mandatory.

Background

Estonia, fittingly, took the digital-first path. The B2B-on-request model bridges voluntary and mandatory: it doesn't force every seller to issue structured invoices, but it gives every buyer the right to demand one. In practice, a few months in, almost every B2B counterparty had registered as an e-invoice recipient — making the mandate de facto universal even before the formal full-B2B step.

Recipients self-register in the central e-invoicing register operated by RIK (Centre of Registers and Information Systems). Flowie checks the register at send-time; if the buyer is registered, we route via Peppol; if not, we fall back to PDF.

Format profile

Peppol BIS 3.0 is the canonical format.
Legacy EVS 923:2014 XML still accepted by some older Estonian ERPs.
Estonian VAT: EE + 9 digits.

Required fields

seller.vatNumberstringrequired

Format EE123456789.
buyer.eInvoiceRegisteredbooleanauto-resolved

Flowie populates this from the RIK register; you don't pass it.

Public sector (B2G)

Hub	Peppol identifier scheme	Lookup
Riigi e-arvete register (RIK)	`9931:EE-<regcode>`	https://www.rik.ee

Public buyers and B2B-registered companies share the same register; Flowie's /v1/directory/search?country=EE mirrors it.

B2B reporting / clearance

No central B2B reporting hub — pure transmission only.

Error codes

Code	Meaning	Fix
`EE-REG-404`	Buyer not registered in RIK e-invoice register.	Either fall back to PDF or ask the buyer to register (it's free and takes 5 minutes).

Testing in sandbox

What you want to test	How
Estonian B2B happy path	Buyer reg code `EE12345678`, sender VAT `EE100000001`.
Buyer not registered	Buyer reg code `EE99999999` in sandbox → returns `EE-REG-404`.

FAQ

Do I need to query RIK before sending?

No. Flowie does it for you on every send. The response carries routing.eInvoiceRegistered: true|false so you know whether the structured path or PDF path was used.

References

Primary sources (government / regulator / standards body):

EU Commission · eInvoicing in Estonia — Pan-EU reference factsheet.
EMTA · Estonian Tax and Customs Board — Tax authority owning e-invoice policy.
Ministry of Finance Estonia — Finance ministry — Accounting Act amendments.
RIK · Business Register e-invoice receiver list — Registry of e-invoice receivers (buyer-choice).

Industry analyses (vendor trackers — useful for cross-referencing):

Pagero · Estonia compliance updates — Industry tracker — 2025/2027 timeline.