One of the most confusing aspects of the new e-invoicing requirements for accountants has been how these changes will affect delivery documents starting January 1, 2025. While structured e-invoice requirements don't directly apply to delivery documents, this doesn't mean you can skip creating a structured invoice when shipping goods.
Understanding the Current Situation
Many businesses currently use a combined document – a delivery note-invoice that merges multiple documents into one: supporting documentation, tax invoice, and delivery note. This practice will need to be reconsidered when the new changes take effect, as businesses will need to adapt these documents to meet structured e-invoice requirements while maintaining their overall accounting and document flow.
What's Changing in 2025?
According to the new Accounting Law amendments coming into effect on January 1, 2025:
- Companies registered in Latvia must issue structured e-invoices to other local companies for goods or services
- Initially, these requirements will only apply to transactions with state and municipal institutions
- From 2026, the requirements will extend to all companies registered in Latvia
What is a Structured E-Invoice?
A structured e-invoice is not a PDF file, Word document, digital image, or Excel spreadsheet. Instead, it's a machine-readable XML file that can be automatically processed, following the internationally recognized PEPPOL BIS Billing 3.0 standard.
How Will This Affect Delivery Documents?
The Finance Ministry clarifies that the new requirements don't directly apply to delivery documents. However, when a single document combines both supporting documentation and delivery information (like an invoice-delivery note), the situation needs special consideration.
Your Options Moving Forward:
- Separate Documents: If you currently issue delivery notes separately, you can continue this practice, but your supporting documents must be converted to structured e-invoices.
- Combined Documents: If you use a single document that includes both payment and delivery information, this will need to be transformed into a structured e-invoice. The delivery document can still be printed or prepared electronically if both parties agree.
Practical Recommendations
- For Physical Deliveries: When goods need to be checked upon delivery (quantity, quality, etc.), you can continue using printed delivery documents while sending the structured e-invoice separately.
- For Electronic Processing: You can prepare delivery documents electronically if both parties agree, but make sure to establish clear procedures for document approval.
Important Note About E-Invoice Limitations
The current structured e-invoice standard in Latvia doesn't support detailed information about product batches, which is crucial for industries like food or medical supplies. While this information can be added in text fields like notes, it's important to consider whether your business partner needs to process this information automatically.
Will This Create More Work for Accountants?
Not necessarily. Electronic documents, including e-invoices, are machine-readable, which means:
- Systems can handle data entry and recognition automatically
- This reduces manual work for accountants
- It lowers the risk of errors
However, businesses need to review their processes to prevent duplicate data entry when documents are received in multiple formats and channels.
Key Takeaway
The most important thing to remember is that while delivery documents can remain flexible in format, the supporting documentation (invoice) must be converted to the structured e-invoice format. Both systems can coexist, but proper planning and system integration will be crucial for smooth operations.
Remember: According to the latest clarification from the State Revenue Service, you cannot include delivery notes within the structured e-invoice itself. However, you should include a reference to the delivery note's unique identifier in the e-invoice for transaction traceability and future document analysis.