MD 168/2026 — Accreditation of e-invoicing service providers

Factual summary

Sets the eligibility criteria and the accreditation procedure for service providers under the Electronic Invoicing System: Peppol certification and PINT AE support, information-security requirements for the product, a self-declaration that includes 100 free e-invoice exchange and reporting services per year to each End User, accreditation testing with the FTA, two-year validity, renewal, termination and objection. It repeals Ministerial Decision No. 64 of 2025 and gives pre-approved providers 30 days from 1 October 2026 to complete accreditation.

What it means in practice Professional insight

Who: e-invoicing service providers, and the businesses that appoint them. What to check: that a provider is on the Ministry's list of Accredited Service Providers on the day you sign and again before go-live, and how its offer applies the 100 free services per year under Art. 9(4).

Key provisions

• Art. 4 Eligibility: among other conditions, an active Peppol-certified Service Provider that has passed the OpenPeppol conformance tests.
• Art. 8 Information security of the product: multi-factor authentication, encryption, security monitoring, ISO/IEC 27001 for the product, and End-User hosting, storage and residency requirements.
• Art. 9(4), Sch. 1 The provider declares a commitment to 100 free e-invoice exchange and reporting services per year to each End User, from the signature of each End-User agreement.
• Art. 13 The Ministry grants accreditation and publishes the provider's details; accreditation is valid for two years.
• Arts. 15–17 Renewal, termination and objection procedures; a terminated provider is delisted and must notify its End Users.
• Art. 18 Repeals Ministerial Decision No. 64 of 2025 and its amendments.
• Art. 19 A provider pre-approved under MD 64/2025 must complete accreditation within 30 days of 1 October 2026, or its pre-approval is terminated.
• Art. 20 Published in the Official Gazette; effective from 1 October 2026.