Last updated: 27 October 2026. Legislation keeps moving: every date below links to a source, and you should re-check it against the official text (Official Journal, EUR-Lex, the national tax authority) before launching any workstream.
At the end of October 2026, a CIO or CFO at a European mid-sized company faces a wall of deadlines that runs from e-invoicing to sustainability, by way of cybersecurity and cloud. Each one has its own article, its own reference vendor, its own consultant. None of them tells you in which order to act, or what the ERP must absorb first.
This article is a cross-cutting hub. It does not detail each regulation: it places them on one calendar, shows what touches the ERP, and points to the in-depth analysis on this blog.
Why You Need a Single Calendar
In most organisations, regulatory monitoring is fragmented. Finance follows VAT and e-invoicing, the CISO follows NIS2 and the Cyber Resilience Act, the sustainability team follows CSRD. Each opens its own project with the ERP vendor, and nobody sees the collisions.
Yet the ERP is the common crossing point. The same master data setup (customer identifiers, VAT codes, bills of materials, suppliers) feeds the structured invoice, carbon reporting and the register of processors. The same vendor has to deliver the changes: if it receives ten conflicting requests in the same quarter, yours will rank behind those of its largest customers.
A single calendar does three things: it lets you balance the load on the project team, negotiate one batch of fixes with the vendor instead of ten tickets, and document for leadership why one workstream comes before another.
Invoicing and Reporting: France, Germany, Belgium, Poland, ViDA
This is the busiest domain, and the one where the ERP is most directly affected (format, transmission, statuses, archiving).
France. According to the reform calendar published by the tax authority, data transmission to the administration has been effective since 1 September 2026. According to summaries of the official calendar (Cegid, Previssima), all taxable businesses must be able to receive e-invoices through an accredited platform from that date, large companies and mid-caps must issue them, and issuance for SMEs and micro-businesses is expected on 1 September 2027. If you are an SME, that is the date to retain for 2027. Details: France roadmap, PDPs, directory and e-reporting.
Germany. Issuing structured e-invoices becomes mandatory from 1 January 2027 for businesses above the turnover threshold set by law (€800,000 the previous year), then for everyone from 1 January 2028: see the Federal Ministry of Finance FAQ and the Sovos calendar. Our guide: mandatory E-Rechnung and ERP compliance 2025-2027. The French-language 2026 ERP action plan goes further.
Poland. KSeF was rolled out in stages: 1 February 2026 for large taxpayers, 1 April 2026 for other taxable persons, and 1 January 2027 for micro-businesses, the date from which penalties also apply, according to EY. If you have a Polish subsidiary, the penalty-free period therefore ends with the year. See KSeF Poland and ERP impact.
Belgium. The B2B Peppol mandate has been in force since early 2026. The 2027 issue is no longer initial compliance but operations (statuses, rejections, penalties). See our Belgium guide.
ViDA. According to the European Commission page, the “VAT in the Digital Age” package entered into force on 14 April 2025, minor adjustments to the One-Stop Shop (OSS) and IOSS apply from 1 January 2027, digital cross-border reporting obligations start on 1 July 2030, and the final alignment of national systems is set for 1 January 2035. For 2027, the ERP impact is therefore limited; the challenge is to anticipate data modelling. See the ViDA roadmap (in French) and our ViDA action plan 2026-2030.
Tax: SAF-T, Pillar Two, DAC7
SAF-T. There is no single European calendar: each country imposes its own schema. In Norway, for example, SAF-T Financial version 1.40 becomes the only valid one from 1 January 2027 (versions 1.20 and 1.30 remain usable only for financial year 2026 and earlier), according to Fiscal Requirements. Check, country by country, which version your vendor supports: SAF-T and digital tax compliance overview.
Pillar Two. The first GloBE Information Return (GIR) for financial year 2024 was due on 30 June 2026, and the first information exchanges between Member States under DAC9 cannot take place before 1 December 2026, according to PwC Belgium. For an in-scope group, 2027 is the year the process must become recurring, with entity-level accounting data collection that comes out of the ERP. See OECD Pillar Two and ERP compliance.
DAC7. If you operate a platform (marketplace, rental, services), annual reporting obligations continue to apply. They are already in steady state, but require a clean seller master file. See DAC7 and ERP.
Data and Cybersecurity: Data Act, Cyber Resilience Act, NIS2
Data Act. The regulation has applied since 12 September 2025. From 12 January 2027, providers of data processing services (cloud, SaaS) must entirely remove data transfer and switching charges, according to the European Commission. For a CIO, this is a direct negotiating lever: exit fees on your cloud ERP should no longer work as a lock-in argument. See Data Act and cloud ERP (in French).
Cyber Resilience Act. Obligations to report actively exploited vulnerabilities and serious incidents have applied since 11 September 2026, and the full set of requirements (CE marking, technical documentation, SBOM) from 11 December 2027, according to PwC Switzerland. The burden falls first on the vendor; your role is to demand contractual guarantees and to check your own custom developments. See CRA and ERP compliance.
NIS2. The directive should have been transposed before 17 October 2024. In France, the national resilience bill was scheduled in the National Assembly from 7 October 2026, according to Next: do not assume the national entry-into-force date, but prepare using the ANSSI framework. If you have subsidiaries in several Member States, the timetable differs country by country. See NIS2 and ERP.
Sustainability: CSRD and Omnibus, CBAM, Battery Passport
CSRD and Omnibus. The Omnibus I Directive (EU) 2026/470 was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. The scope is narrowed to entities with more than 1,000 employees and €450 million in net turnover, and Member States must transpose it by 19 March 2027, according to DLA Piper and Arthur Cox. Many mid-sized companies drop out of direct scope but are still solicited by their customers. See Omnibus and ERP impact.
CBAM. The definitive period began on 1 January 2026; the sale of certificates starts on 1 February 2027 and the first annual declaration (2026 imports) is due on 30 September 2027, according to BSI. If you import steel, aluminium, fertilisers or cement, import data must be consolidated starting now. See CBAM and ERP (in French).
Battery passport. From 18 February 2027, batteries for electric vehicles, light means of transport and industrial batteries above 2 kWh placed on the market must carry an electronic passport, according to Environment + Energy Leader. It is the only text on this list that concerns only certain manufacturers, but the impact on item and bill-of-materials data is heavy. See Battery Regulation and ERP.
Summary Table
| Deadline | Who is affected | ERP impact | Priority action | Article |
|---|---|---|---|---|
| 1 Sept 2027 (France) | SMEs and micro-businesses (issuance) | Issuance, statuses, e-reporting | Choose the accredited platform | France |
| 1 Jan 2027 (Germany) | Businesses above the threshold | EN 16931 format, archiving | Test XRechnung / ZUGFeRD | Germany |
| 1 Jan 2027 (Poland) | Micro-businesses, penalties | KSeF integration | Validate flows before penalties | KSeF |
| 12 Jan 2027 | Cloud / SaaS providers | Contracts, portability | Renegotiate exit fees | Data Act |
| 1 Jan 2027 (Norway) | Entities required to keep accounts | SAF-T v1.40 export | Confirm the vendor version | SAF-T |
| 1 Feb 2027 | Importers of CBAM goods | Import data, certificates | Map customs codes | CBAM |
| 18 Feb 2027 | Manufacturers of in-scope batteries | Product data, QR code | Launch a passport pilot | Batteries |
| 19 Mar 2027 | Member States (Omnibus I) | CSRD scope | Reassess your scope | Omnibus |
| 11 Dec 2027 | Manufacturers of digital products | CE marking, SBOM | Demand vendor guarantees | CRA |
Method: Prioritise by Risk and Implementation Lead Time
A near deadline is not necessarily the most urgent. Priority depends on two variables: risk (penalty, operational blockage, loss of a customer) and ERP implementation lead time (the time needed to specify, develop, test and deploy).
- Rate each deadline as high, medium or low risk for your legal entity. A text that does not apply to you must not consume budget: confirm the scope in writing.
- Estimate the implementation lead time with the vendor: standard patch delivered, custom development, or a data workstream (which depends on you). A data quality workstream usually takes longer than a vendor patch.
- Separate vendor workload from internal workload. If the vendor delivers the format and transmission, your work is configuration, testing and change management. If the vendor delivers nothing, you have a sourcing decision to make early.
- Escalate first whatever combines high risk and a long lead time: in practice, SME e-invoicing in France and the data workstreams (CBAM, batteries).
Quarterly Action Plan, Q4 2026 to Q2 2027
Q4 2026 (now). Build the list of legal entities and countries concerned; ask the ERP vendor for its written regulatory roadmap; plan the switch to the new SAF-T or KSeF version if you have affected subsidiaries; open the negotiation on cloud exit fees before 12 January.
Q1 2027. Go live with what is required on 1 January (Germany, Poland, SAF-T); start testing the accredited platform for France (SMEs); consolidate CBAM import data before certificate sales open; start a battery passport pilot if you are concerned.
Q2 2027. Reassess your CSRD scope once transposition is known; audit your custom developments against the CRA; finalise acceptance testing of French issuance ahead of September; prepare the first CBAM declaration.
Going Further
To follow changes and receive updates to this calendar, subscribe to our ERP regulatory watch newsletter. To dig deeper: the France roadmap, ViDA, Data Act (in French) and the Cyber Resilience Act.
