SABIS vs Peppol in Lithuania: How to Send Invoices Right

What Do You Check First: The Buyer or Your Accounting Software?

When you’re about to invoice a Lithuanian public-sector buyer, the first decision isn’t SABIS versus Peppol — they do different jobs entirely. SABIS, short for Sąskaitų administravimo bendroji informacinė sistema (Lithuania’s national invoice-receiving portal), was created on 1 September 2024 out of a reorganisation of the former “E. sąskaita” system, and it’s run by the National Common Services Centre, known as NBFC. Peppol, meanwhile, is the mandatory default delivery channel set out in Government Resolution No. 405, through which structured invoices have had to travel since 1 January 2025. Manual entry into the SABIS portal is the exception — reserved for suppliers who lack the technical means to send an invoice automatically through Peppol. That relationship got harder to overlook from April 2026, when SABIS added clearer checks that flag invoices arriving via Peppol whose data doesn’t match the contract, buyer code or supplier code on file.

What matters isn’t whether your company is VAT-registered or where it’s incorporated — it’s who receives the invoice. Resolution No. 405 applies to “viešojo sektoriaus subjektams ir kitiems subjektams, kurie yra perkančiosios organizacijos”: public-sector bodies and other contracting authorities, regardless of their corporate form, according to the text of the resolution. Lithuania’s Ministry of Finance has been explicit about this: if a buyer is required to accept invoices that meet the EN 16931 standard — the European e-invoice standard, a shared machine-readable data model — through SABIS, then suppliers doing business with that buyer must also submit invoices through the same system for that buyer. There’s no such obligation for private-sector customers — more on that below.

Are SABIS and Peppol Competing Channels?

Think of it as a post office and a postal carrier. SABIS is the post office: every Lithuanian public-sector buyer receives and processes invoices there, and nowhere else. Peppol is the carrier that delivers structured invoice data straight from your accounting software into SABIS’s inbox, without either side retyping anything by hand.

Since 1 January 2025, sending invoices via Peppol has been the default, mandatory way for EN 16931-compliant financial documents to reach a public-sector buyer, under Resolution No. 405. Manual entry in the SABIS portal, or importing an XML file (a structured data-file format), is intended only for suppliers who don’t have the technical capability to send invoices automatically over the Peppol network. In other words, Peppol isn’t an extra option sitting alongside SABIS — it’s the main route, and the portal is the fallback, not an alternative you get to freely pick.

The consolidated version of this resolution has been in force since 12 December 2023; the government adopted the original version on 27 April 2022, but the Peppol obligation for technical suppliers only took effect at the start of 2025.

What Are the Three Technical Routes Data Can Take Into SABIS?

SABIS’s current help material lists exactly three ways invoice data reaches the system: manual entry or XML file import in the portal, a universal interface connecting directly from your accounting software, and the Peppol network for those who are members of it, according to SABIS’s FAQ page. All three routes use the same formats — Peppol BIS Billing 3.0 eInvoice and Peppol BIS Billing 3.0 Credit Note — which are Lithuania’s implementation of the European e-invoice standard EN 16931, per the same source.

One common misunderstanding: you can’t upload a PDF invoice to the portal and have it treated as the official invoice. The data has to be entered manually or imported as an XML file; a PDF or other document can only be attached as a supplement, according to SABIS’s guidance.

Which Route Fits Your Business?

RouteBest forWhat it requires
SABIS portal (manual/XML)occasional invoices, rare work with the public sectorlogin via VIISP (Lithuania’s national e-identity gateway), manual entry
Universal interface from your ERPmedium-to-high invoice volume, existing accounting softwaretechnical setup following the interface specification
Peppol networkongoing work, multiple buyers, cross-border businessjoining through a certified Access Point (a certified connection point to the network)

The more invoices you send, and the more buyers you deal with, the faster Peppol pays off — because the same Access Point lets you reach any other member of the Peppol network, not just SABIS users, according to SABIS’s explanation.

Does a Delivered Peppol Invoice Mean It’s Accepted?

This is where suppliers trip up most often. A delivery confirmation from the Peppol network only shows that your message arrived. It does not mean SABIS accepted the invoice. Since the April 2026 update, SABIS won’t confirm an invoice received via Peppol if there’s no matching contract registered in the system, or if the buyer code, supplier code or contract number on the invoice don’t match what’s on file, according to NBFC’s announcement.

What Does SABIS Check Now?

For an invoice submitted via Peppol under a written contract, three things have to line up: the contract must be registered in SABIS and linked to the supplier issuing the invoice; the contract number on the invoice must match the number registered in the system; and the buyer and supplier codes must correspond, per SABIS’s FAQ explanation. If any of these don’t match, the invoice lands in a status called “Neapdorotos PEPPOL sąskaitos” — unprocessed Peppol invoices — and both the supplier and the buyer now see this flagged in the system, according to NBFC’s update announcement. Over 3.8 million invoices moved through SABIS in 2025, and by January 2026 the system counted more than 71,000 organisational accounts and 114,000 active users, per NBFC’s statistics — at that volume, automated checks like this were bound to arrive. In practice, a Peppol delivery receipt doesn’t replace checking SABIS’s status. You need to do that separately, every time.

Verbal Agreements: The €1,000 Threshold Is History

The rule for invoices issued under a verbal public-procurement agreement got simpler — and, at the same time, stricter. Until 31 December 2024, the obligation to submit through SABIS for verbal agreements only kicked in for invoices exceeding €1,000 excluding VAT, according to SABIS’s explanation. From 1 January 2025, that obligation applies to every invoice issued under a verbal agreement, regardless of amount.

The good news: verbal-agreement invoices don’t need to be linked to a contract in SABIS the way written-contract invoices do. The simplified process is meant for smaller purchases made without a formal contract in place. Since 7 January 2025, publication data for accepted verbal-agreement invoices transfers automatically into CVP IS, Lithuania’s public procurement information system, according to SABIS’s guidance — so suppliers don’t need to report the same information separately anywhere else.

Do Foreign Suppliers and Private B2B Customers Follow the Same Rules?

Two questions get mixed up constantly, and the answers are entirely different.

What Happens If the Supplier Is Outside Lithuania?

Foreign suppliers of goods, services or works currently can’t log into the SABIS portal at all, according to SABIS’s FAQ page. That doesn’t shut them out of doing business with Lithuania’s public sector — they can submit invoices via the Peppol network, choosing a suitable certified Access Point as their service provider. If that route doesn’t suit the buyer, the buyer can use another acceptable method, such as email, per the same source. For written contracts, the same requirement applies to foreign suppliers as to domestic ones: the contract must be registered and linked in SABIS, and the contract number on the invoice must match it exactly.

Do the Same Rules Apply to Lithuania’s Private Sector?

The SABIS and Peppol obligation applies only to public-sector bodies and contracting authorities. According to the European Commission’s Lithuania 2025 eInvoicing Country Sheet, published on 18 March 2026, Lithuania runs a mandatory B2G regime but currently has no general B2B or B2C e-invoicing mandate. Two private companies can agree between themselves to exchange structured e-invoices, but the law doesn’t require it.

That changes at EU level, not within Lithuania itself: from 1 July 2030, ViDA — VAT in the Digital Age, the EU’s package to modernise VAT reporting, brings a cross-border B2B digital reporting requirement built on mandatory e-invoicing. That’s an EU-wide milestone for cross-border VAT reporting — not an expansion of Lithuania’s own SABIS obligation. The two are easy to confuse, and worth keeping separate.

What to Check Before You Send an Invoice

Before your invoice goes out, run through five checkpoints:

  • Check the buyer. Is this a public-sector body or another contracting authority? If yes, the SABIS/Peppol obligation applies; if it’s a private company, it doesn’t.
  • Identify the right process. Is this based on a written contract (which needs to be linked in SABIS) or a verbal agreement (mandatory since 2025, regardless of amount)?
  • Use the right format. Invoices sent via Peppol must comply with the Peppol BIS Billing 3.0 eInvoice standard.
  • Check that the codes match. The buyer code, supplier code and contract number on the invoice must exactly match what’s registered in SABIS.
  • Check SABIS’s status, not the Peppol delivery receipt. Only the status tells you whether the invoice was actually accepted, or whether it’s stuck as “Neapdorotos PEPPOL sąskaitos.”

Get all five right, and the invoice reaches the buyer through SABIS without delay — and without a contract or code mismatch to chase down later.

Kas tarnija peab valima esmalt SABIS’i või Peppol’i?

Leedu avaliku sektori ostjale ei saa valida kanalit “SABIS või Peppol”, sest need täidavad erinevat rolli. SABIS on ostja vastuvõtukeskkond, Peppol on kohustuslik edastustee, mille kaudu struktureeritud e-arve peab jõudma alates 1. jaanuarist 2025.

Kas Peppol’i saatmiskinnitus tähendab, et SABIS võttis arve vastu?

Ei. Peppol’i edastuskinnitus näitab, et sõnum jõudis kohale, kuid SABIS võib arve jätta töötlemata, kui leping, lepingu number või ostja/tarnija koodid ei klapi. Alates 2026. aasta aprillist kontrollib SABIS senisest selgemalt kattuvust.

Millised on kolm tehnilist viisi, kuidas arve andmed SABIS’sse jõuavad?

SABIS’sse saab andmed saata (1) käsitsi sisestuse või XML-faili importiga portaali, (2) universaalse liidese kaudu ERP-ist ning (3) Peppol-võrgu kaudu, kui tarnija on liikmeks. Kõigil teedel kasutatakse Peppol BIS Billing 3.0 eInvoice ja Credit Note vormingut koos EN 16931 rakendusega.

Kas suulise kokkuleppe arvetele kehtis varem 1000 euro piir?

Jah, kuid reegel muutus. Kuni 31. detsembrini 2024 kehtis SABIS’i kaudu esitamise kohustus suuliste kokkulepete arvetele ainult siis, kui arve ületas 1000 eurot käibemaksuta. Alates 1. jaanuarist 2025 kehtib kohustus kõigile suulise kokkuleppe alusel esitatud arvetele.