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  4. Rejecting an invoice: Peppol status messages versus legal acceptance

Rejecting an invoice: Peppol status messages versus legal acceptance

“Rejecting” an invoice can mean two different things. A technical rejection means the invoice was never delivered, because the receiving service provider could not validate or pass it on. A business rejection means the buyer received the invoice but disputes it. Neither cancels an issued invoice in law. If an invoice that reached the buyer is wrong, the seller corrects it with a credit note.

Technical rejection: Message Level Status (MLS)

Peppol MLS is a message from the receiving service provider (C3) to the sending service provider (C2) about whether the document was delivered to the receiver (C4).

CodeMeaning
APDelivered to the receiver, with verifiable confirmation
ABForwarded to the receiver, but delivery cannot be verified
RENot delivered. Reasons include syntax errors (SV), fatal business rule errors (BV), and delivery failure (FD)
  • Mandatory phase-in. All Peppol service providers must be able to receive MLS by the end of February 2027, and sending is mandatory from the end of March 2027. The older Message Level Response is retired on 1 May 2027.
  • Consequence. After an RE, responsibility for the message returns to the sender. The invoice has not reached the buyer, so the sender must fix the error and send again.
  • Service provider level. MLS goes between service providers. Your provider decides how it is shown to you.

Business rejection: Invoice Response

Peppol BIS Invoice Response lets the buyer tell the seller where the invoice stands in its approval and payment process. It is optional unless the parties agree to use it.

CodeMeaning
ABReceived and submitted for processing
IPIn process
UQUnder query: processing is halted until the seller answers
CAConditionally accepted
RERejected: the buyer will not process the invoice further (final)
APAccepted: final approval, payment is next
PDPaid

A rejection carries a reason, for example REF (references incorrect), PRI (prices incorrect), QTY (quantity incorrect), or LEG (legal information incorrect), and can carry an action such as NIN (issue a new invoice) or CNF (credit fully).

The specification is clear on the legal effect: an Invoice Response “does not have any legal power”. It does not change the invoice or release the buyer from payment obligations. When an invoice is rejected, the seller issues a credit note for it and, if needed, a new invoice (Peppol BIS Invoice Response).

The EU VAT Directive has no rule that lets a buyer reject an issued invoice. Errors are corrected with a document that amends and refers to the original invoice (Article 219). Today the recipient must accept the use of e-invoices as such (Article 232), but from 1 July 2030 that acceptance is no longer required for e-invoices that comply with EN 16931. Some countries have their own rules:

CountryWhat applies
SwedenNo statutory right to reject an invoice. An incorrect invoice is normally corrected by the seller with an ändringsfaktura, such as a credit note, that refers to the original invoice number (Skatteverket).
GermanyA document that should be an e-invoice but is not in a valid structured format counts only as an “other invoice”, which does not meet the formal conditions for input VAT deduction. The buyer should ask for a correct e-invoice.
FranceIn the 2026 reform, a technical rejection (Rejetée) and a buyer refusal (Refusée) are mandatory lifecycle statuses. A refusal is only allowed for specific reasons, such as no underlying supply or missing mandatory data. Disputes use a separate status.
BelgiumAn invoice not intended for you can be rejected with an Invoice Response with status RE. Missing details are handled by asking for a correction, and a buyer cannot reject an invoice just because no PDF is attached (FPS Finance FAQ).
ItalyAn invoice rejected by the SdI platform is considered not issued. The Italian tax agency advises resubmitting it with the same date and number.
UAEAn electronic credit note is mandatory when an issued invoice is canceled, reduced, or contains an administrative or numerical error.

Can you reuse the invoice number?

Technical rejectionBusiness rejection
Who rejectsReceiving service provider or tax platformBuyer
Reached the buyer?NoYes
Legal statusNot delivered. In clearance countries such as Italy, not issuedIssued and still valid
How to fixCorrect and send againCredit note, then a new invoice if needed
Invoice numberItaly allows the same number. Most other countries give no official guidanceNew number. The credit note refers to the original

Our recommendation: if an invoice never reached the buyer, check with your accountant whether to resend it under the same number. If in doubt, or if the buyer may have received it, issue a credit note and a new invoice. See Credit notes and invoice corrections by country.

This article summarizes the rules as of October 2026 and is not legal or tax advice. Check the current national rules or ask an adviser.

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