Self-billing means that the customer issues the invoice for a supply it receives, instead of the supplier. It is common when the customer holds the data that determines the price, such as volumes, weights, or royalties. Self-billing is allowed across the EU and in many other countries, but only on certain conditions. The supplier remains responsible for the invoice in most countries.
EU conditions
- Prior agreement. The customer may draw up the invoice where there is a prior agreement between the parties (Article 224).
- Acceptance of each invoice. There must be a procedure for the supplier to accept each invoice (Article 224).
- Mention. The invoice must state “Self-billing” (Article 226, point 10a).
- Which rules apply. A self-billed invoice follows the invoicing rules of the member state where the supply takes place, also in reverse-charge cases (Article 219a).
- ViDA. ViDA does not change these conditions. From 2030 the recipient no longer has to accept the e-invoice format, but the supplier still has to accept each self-billed invoice.
Conditions by country
| Country | Agreement and acceptance | Other requirements |
| Sweden | Agreed in advance, with no formal requirements. The seller approves each invoice; not objecting may be enough (ML 17 kap. 15 §, Skatteverket). | Mention “självfakturering” (17 kap. 24 § 12). A separate continuous number series for each seller. |
| Norway | A written agreement signed and kept by both parties. | The buyer must check the seller’s VAT registration regularly. The document must state that the buyer issued it. |
| Finland | An agreement, which may be tacit. The seller is deemed to accept if it does not react within an agreed reasonable time. | The seller is always responsible for the invoice being correct. Mention “itselaskutus” or “Self-billing”. |
| Denmark | A written agreement made before the supply and signed by both parties, with a procedure for approving each invoice. | The issuer must verify the supplier’s VAT number. Mention “selvfakturering” or “self-billing”. |
| Germany | Agreed in advance. The document loses its effect as an invoice if the supplier objects to it. | Called “Gutschrift” and must be marked as such. E-invoice rules apply. |
| France | A mandate before the first invoice, written or tacit. Each invoice is accepted, expressly or tacitly. | The supplier remains responsible. Mention “autofacturation”. |
| Belgium | Prior agreement and an acceptance procedure for each invoice. | Under the B2B mandate, self-billed invoices use the Peppol self-billing document type and the supplier must be able to receive on Peppol. |
| Netherlands | Agreed in advance. | The supplier remains responsible. The invoice must state that the buyer drew it up. |
| UAE | An agreement between supplier and buyer. Not available if the supplier is not VAT registered. | Under e-invoicing, only tax invoices and tax credit notes can be self-billed, and the buyer must be on the e-invoicing system. |
| Australia | A written agreement that the recipient issues recipient-created tax invoices (RCTI) and the supplier does not. Both must be GST registered. | The invoice must show that it is an RCTI and both ABNs. A copy goes to the supplier within 28 days. |
| Singapore | A buyer-created tax invoice requires approval from the Comptroller of GST. | Labeled “Buyer Created Tax Invoice – Approved by Comptroller of GST”. Self-billed invoices can only be issued outside the InvoiceNow network. |
Self-billing in Peppol
- Specification. Peppol BIS Self-Billing 3.0 (version 3.0.2, mandatory from 17 August 2026) covers self-billed invoices and credit notes.
- Roles. The customer sends and the supplier receives, so the supplier must be registered on Peppol to receive self-billed documents.
- Type codes. 389 for a self-billed invoice, 261 for a self-billed credit note, and 527 for a self-billed debit note.
- Agreement not in the format. The specification does not check the prior agreement or the acceptance procedure. Those stay part of your contract and routines.
- PINT. Self-billing variants also exist for PINT AE, PINT A-NZ, and PINT JP.
See Does Peppol support self-billing? for how to set it up.
Checklist before you start
- Sign an agreement before the first invoice, in writing if the country requires it
- Agree on how and how fast the supplier approves or objects to each invoice
- Check that the supplier is VAT registered, and keep evidence where required
- Use the correct mention and numbering
- Make sure both parties can send and receive the Peppol self-billing document types
Official sources
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.