Don’t wait: what to review before the new e-invoicing framework

What changes in practice

In the published draft, an e-invoice is a structured electronic document that passes through the e-invoice system. The system proposes a check, a unique invoice identifier and an electronic timestamp before a document is validated.

For a team, control does not end when an invoice is created. It matters when it is available in the system, whether it is validated and signed, who monitors receipt, and who responds when it must be accepted, refused, corrected or cancelled.

Proposed timetable: the dates worth tracking

Article 22 of the draft proposes a phased introduction. These are dates from the published draft, not final legal deadlines: verify your category and follow the final law and secondary legislation.

1 Oct 2026

Proposed voluntary registration for issuing and receiving; after registration, the draft provides for structured format only through the system.

1 Apr 2027

Proposed start for VAT taxpayers and the listed public/state entities in Article 16(1), point 1.

1 Jul 2027

Proposed start for legal entities that are not VAT taxpayers but carry out economic activity.

1 Oct 2027

Proposed start for budget users and the listed institutions controlled and funded by the state, municipalities or the City of Skopje.

1 Jan 2028

Proposed general start for all entities carrying out transactions.

Who should start, and when

The draft links phases to the categories in Article 16. The simplified overview below supports an initial discussion, but does not replace checking your company’s specific legal position.

• VAT taxpayers: it makes sense to map data, authorisations and invoice receipt now, because the draft proposes the earliest mandatory phase for them.
• Legal entities outside VAT that conduct business: they should not wait for 2028; the draft provides a separate phase in July 2027.
• Budget and certain public institutions: the draft separates them with an October 2027 phase; check the exact Article 16 scope.
• All entities carrying out transactions: the proposed general date is 1 January 2028, but preparing data and roles is safer to begin earlier.

Where problems are most likely to appear

The risk is not only in sending. It most often appears at the hand-off between data, responsibility and deadlines. These draft provisions deserve to become internal rules and test scenarios.

• Data quality: structured format requires consistent partner, line, tax, amount and date data from entry. Under the draft, validation does not confirm substantive accuracy, legality or tax treatment.
• Incoming-invoice ownership: the recipient may accept or refuse by the 10th of the following month; if there is no response, the draft provides that the invoice is deemed accepted. Set a deputy and a visible task list.
• Signing and authority: the draft provides for a qualified certificate for retrieval, acceptance or refusal. Check who may sign, how cover is provided and whether access is ready.
• System interruption: the draft provides for alternative invoicing after 24 continuous hours of outage and submission to the system within 5 working days after restoration. Prepare a simple procedure and an owner in advance.
• Retention and history: the draft refers to retention duties and provides that invoices are available to download through the system for up to two years after the end of their issue year. Do not rely on one place alone for working context and documentation.

Where to start: a calm preparation plan

The best first step is not a mass change to every process. Start with one clear flow, from entry to retention, and agree what must be accurate, visible and on time.

1. 01
   Map one real workflow

   Choose one typical outgoing and incoming invoice. Record who enters, checks, signs, sends, tracks status and responds to refusal.

2. 02
   Clean up key data

   Review master data for partners, tax numbers, tax rates, lines, units and rules for advances or credit notes.

3. 03
   Set roles and cover

   Agree an owner for incoming documents, a signing owner and a person who takes over during absence. Notifications should reach people who can act.

4. 04
   Test before it becomes urgent

   Use the proposed voluntary period, if it remains applicable in the final framework, to walk through a normal document, refusal, correction, cancellation and a system outage.