SMEs and Private Sector onboarding - electronic invoices
Introduction and overview of the current state-of-play on eInvoicing onboarding of SMEs and Private Sector in the EU market
The twin transition to a green and digital economy are key priorities for the European Commission. This will mean a more resilient economy through which Europe can recover from the COVID-19 pandemic. The adoption and widespread use of electronic public procurement and electronic invoicing (eInvoicing) will play a major role in realising these ambitions. eInvoicing enables trading counterparties to send and receive eInvoices, based on a robust European standard on eInvoicing for the semantic elements of a core eInvoice (EN 16931). eInvoicing already shows important benefits for the public sector. In recent months, the CEF eInvoicing team launched a series of activities related to SME and private sector onboarding to nourish policy discussions taking stakeholder suggestions and market needs into account. Based on previous input from stakeholders on this topic, the Commission organised an open session on eInvoicing in November 2021. This article brings together the conclusions of this session, including the views of the co-authors, from both the public and private sectors.
This article will:
- Define some key terms and concepts;
- Address the current issues faced within supply chains operating within and across Member States and in particular those relating to the inclusion of small and medium-sized enterprises (SMEs) in onboarding processes and the dissemination of the usage of structured eInvoices (as opposed to paper or electronic images such as PDF);
- Provide a state of play and examples of onboarding initiatives taken at a country level or by the private sector in some EU countries;
- Present the benefits of eInvoicing and the important role played by private businesses in its mass-adoption.
The widespread adoption of eInvoicing and related onboarding efficiency strategies will:
- Optimise growing eInvoicing volumes and make the exchange of invoices among economic operators across the EU, based on the use of common practices, standards and interoperable delivery networks;
- Minimise one-off processes and workarounds used by economic operators to cope with the absence of well-established onboarding strategies that often create additional administrative burdens for all parties;
- Reduce the usage of unstructured (non-digital) document exchanges via multiple channels, which currently cause processing inefficiency;
- Encourage eProcurement life cycle automation in both the private and public sector by including other digital supply chain documents such as purchase orders;
- Enable the utilisation of established technologies and newer emerging technologies.
This article is focused on SMEs and their onboarding into an eInvoicing environment based on digitally structured eInvoicing standards and interoperable networks. So far, larger private economic operators have led the adoption of eInvoicing. There is scope to include SMEs.
There is currently relatively low penetration of eInvoicing into such companies except in a few EU Member States. Where eInvoicing has been adopted it is often based on PDFs rather than structured data capable of being automatically processed .
In relation to eInvoicing, accounting and related payments, SMEs operate a variety of systems and approaches. SMEs are likely to have systems similar to larger enterprises based on the use of ERP (Enterprise Resource Planning) systems capable of meeting the requirements for the majority of accounting and billing processes; they are more likely to be able to receive and transfer data to eInvoicing service platforms and networks in digital form.
Small and micro-enterprises are likely to use more basic accounting software often in conjunction with manual processes. They may not be able to generate invoices or invoice data in digital form and will either resist adoption of eInvoicing or expect to be offered easy-to-use solutions that are secure and reliable and involve no expensive investments in technology.
For example, there are various models for eInvoicing activation and ongoing operation by SMEs acting as a supplier:
- an SME is directly connected to the system of a buyer, who provides the facilities for presenting and managing eInvoices without the intervention of another party. A number of public sector entities operate through a government portal for such a model. In some cases, a service provider may be employed to onboard the SME supplier into such a solution;
- an SME uses a service provider solution or platform to which the SME is connected and through which invoices are presented to a buyer or buyers that use the same platform (three-corner model);
- an SME uses a service provider/network access solution to which the SME is connected and through which invoices are presented to a buyer, which is reachable on another platform by means of interoperable networks such as Peppol (four-corner model). This may allow a supplier to connect with a range of buyers because of the interoperable connections created by a service provider with other platforms.
In a more technical way, onboarding involves public authorities, service providers and end-users (acting along with the national eInvoicing legislation and the European standard on eInvoicing) and refers to a practical set of actions such as:
- Establishing the business relationship and performing “know your customer” routines, including identity and operational information;
- Creating a secure technical connection ranging from onboarding into a portal to allowing data file transfer (e.g. Peppol networks);
- Making available digital processes often in the ‘cloud’ and minimising the need for installed software;
- Establishing service level expectations and agreements based on transparency and established data protection procedures;
- Agreeing on the format or data be used in creating the eInvoice, which can be done by the sender, or the provider based on data submitted and will need to reflect the requirements of the buyer. This will also apply to the management of other documents types and response messages;
- Deployment of customer service capabilities/tools and additional value-added services as required;
- In some cases, larger enterprises may choose to be their own ‘self-service’ provider for onboarding.
Successful onboarding strategies must be easy to replicate, accessible, and adaptable (however, as systematic as possible for efficiency purposes). It is a practical issue requiring investment and expertise in management processes and technology which need to generate high levels of customer satisfaction.
Existing eInvoicing onboarding challenges within the Single Market
Directive 2014/55/EU mandates the implementation of eInvoicing in public procurement, based on a receiving capability of invoices presented in the European standard in each EU Member State. All public contracting authorities must be able to receive and process eInvoices conforming to the standard from domestic and intra-EU senders. However, the Directive does not stipulate any obligation for the suppliers to public contracting authorities to send invoices in a structured and electronic format. As a result, many contracting authorities are capable of managing eInvoicing, but due to a low take-up on the supplier side, eInvoices still represent a very low percentage of the invoices exchanged . This under-performance in eInvoicing adoption can be explained by various factors such as:
- The lack of a mandate and an obligation to issue eInvoices. Despite the economic benefits, smaller economic operators' willingness to invest in digital solutions remains low. However, an obligation does not remove the need to offer easy-to-use eInvoicing solutions;
- Inefficient communication about eInvoicing benefits and insufficient general information on eInvoicing provided to suppliers, which then must apply additional efforts to search for approaches and guidelines on eInvoicing practices;
- Lack of resources within both the public and private sector to focus on the implementation of eInvoicing, which requires time, expertise, human resources, and a willingness to change;
- Unduly heterogeneous business practices across the eInvoicing environment resulting in large variety and complexity experienced across business sectors and various supply chains. This complicates invoice process standardisation, which aims at more uniform business practices, the usage of the ‘just right’ amount of data, a closer alignment across EU Member States in terms of legal requirements, and more concerted change management strategies.
- Insufficient focus on the practical onboarding and the lack of engagement from qualified stakeholders involving policy-makers, technical provider, eInvoicing experts and the end-user community;
All these issues prevent the mass-adoption of eInvoicing and generate reluctance on some SMEs toward the adoption of eInvoicing. This is often due to the fact that SMEs’ resources are promptly allocated to primary business activities and therefore not dedicated to system implementation.
Consequences for businesses often turn into increasing operating costs and administrative burdens caused by human error and diversified business practices and exchange methods of trading partners. These administrative burdens also generate inefficient processing and barriers to trade.
Onboarding initiatives among the EU countries
There are initiatives led by EU governments and/or projects from the private sector. The selection presented below aims at raising awareness about stakeholders about lessons learned and potential solutions to build on and contribute to the mass-adoption of B2G and B2B eInvoicing.
Initiatives by the EU Member States
Presented by Lars Engberg - country representative for eInvoicing in Sweden
In Sweden, eInvoicing was already well-known among B2G and B2B stakeholders. eInvoicing users have been working with a local format based on a Edifact/XML since the 90´s and Swedish central government agencies and almost all municipalities have used eInvoicing for many years. Consequently, the public sector was well prepared for the transposition of the eInvoicing Directive into Swedish law.
The Act (2018:1277) on eInvoicing in public procurement entered into force on 1 April 2020. However, the requirement to send and receive eInvoices applies to all public procurement since 1 April 2019, including direct procurement. This means that every supplier to public contracting authorities must send eInvoices that comply with the European standard (unless they have agreed preliminarily on another standard), and all public sector entities must be able to receive and process these eInvoices. The requirement to send eInvoices applies to all suppliers within and outside of the EU. PDF invoices or scanned paper invoices are not considered as eInvoices.
The Swedish government went beyond the Directive minimum requirements when transposing it in the national law.
The Agency for Digital Government (DIGG) made mandatory the submission of structured-eInvoice from suppliers to contracting public authorities. A supplier that, after repeated reminders, does not send invoices that meet the legal requirements may be fined. However, this never happened as the Swedish strategy promotes information sharing and dialogues with counterparties rather than restrictions and penalties.
As the DIGG's regulation states, contracting entities in the public sector must be registered in Peppol for a minimum of Peppol BIS Billing 3.0. This means that all suppliers to the public sector could focus exclusively on using Peppol eInvoices and send them through a service provider/access point on the Peppol network. This strategy goes along with the eInvoicing law including additional regulation. The goal is to provide clear guidelines to suppliers, this enabling them to invoice public entities in a systematic way and avoid ad-hoc cases. Recommending Peppol as a transmission system lifts the end-users' confusion when facing the diversity of systems present in the EU market. Peppol also ensures secured exchanges among stakeholders' solutions by being platform agnostic. Lastly, the use of Peppol does not require technical skills for end-users (i.e. business partners/ suppliers) and provide additional functionalities such as eOrdering also significantly considered in Sweden.
In Sweden, the Single Face To Industry (SFTI) aims at promoting and facilitating public eProcurement by recommending eProcurement standards. The SFTI is a joint initiative in the Swedish public sector that involved different actors such as public sector entities, suppliers and IT-providers. Leaders and coordinators of SFTI are the Swedish Association of Local Authorities and Regions (SKL), the Agency for Digital Government (DIGG) and the Legal, Financial and Administrative Services Agency (Upphandlingsmyndigheten). The digitalisation of eProcurement and eInvoicing strongly benefit from different counterparties' cooperation. "We see this project as a cooperative ecosystem where service providers of infrastructures (based on standard technical components) have to work very closely with end-users to deliver efficient onboarding campaigns on user-friendly services" stated Lars Engberg during the CEF eInvoicing Open Session in November 2020. In Sweden, the DIGG also works on upgrading the Edifact/XML format to Peppol Bis Billing 3. Until now, this Swedish national format remains used mainly for B2B transactions (out of scope for the eInvoicing Directive).
Surely, onboarding initiatives often come with challenges. In Sweden, stakeholders often find it difficult to benefit from the right resources for both incoming and outgoing eInvoices. The lack of know-how and expertise can be time-consuming and expensive for end-users. Consequently, they rely on the community of access points and service providers. Additionally, other issues can appear such as the lock-in effect towards specific service providers selling complex systems, or the usage of too technical solutions involving data conversion and a high risk to data-loss for end-users.
To cope with these challenges, SFTI suggested:
- considering eInvoice solutions together with adapted onboarding strategies as a whole. This should avoid the lack of awareness and information experienced by suppliers to the public sector which do not receive information.
- avoiding talking about too technical specificities and solutions to end-users but rather focus on standard eInvoice format processing and production.
- promoting the benefits of eInvoicing adoption to all stakeholders.
- providing users with a secure and traceable network as the Peppol network does.
Presented by Cyrille Sautereau - country representative for eInvoicing in France
Pursuant to article 153 of the "Loi de Finance 2020", mandatory B2B eInvoicing implementation will take place from 2023 to 2025, together with a clearance mechanism implying additional tax digital reporting requirements. Mandating B2B eInvoicing is certainly the most efficient method to ensure a fast adoption when applicable to most B2B business cases. Nevertheless, a mandate is not enough itself and requires a solid onboarding and change management strategy to involve stakeholders and make it a win-win sustainable project. The onboarding approach in France is based on the statement that 100% of end-users, and especially SMEs, can necessarily process PDF files and 100% of machines can extract XML data from a PDF.
In practice, the cooperation between "Forum National de la Facture Eléctronique" (FNFE-MPE) for France and "Forum elektronische Rechnung Deutschland" (FeRD, Germany) cooperation resulted in the creation of the Factur-X format/ZUGFeRD (aligned with the European standard on eInvoicing). This format is the set of specifications for the usage of "hybrid eInvoices" fulfilling the three following criteria: standardised, readable, flexible. Concretely, a single hybrid invoice is composed of:
- structured invoice data, compliant with the European standard on eInvoicing - UN/CEFACT SCRDM CII XML syntax (standardised);
- a readable presentation of the invoice information for SME employees, thus facilitating the invoice processing for SMEs often not equipped to process XML files in an automated way (readable);
- the ability to use five sets of invoice data organised as “profiles”: the EN16931 profile and three subsets with less invoice data to take in account the ability of the sender to provide only a part of invoice information as structured data, and a quite rich "extended" profile, which is an extension of the EN16931, this to address most of business case diversity and complexity (flexible).
The B2G mandate in France is organised through ChorusPro, the national platform and the community of service and solution providers that support it. ChorusPro has always proposed a hybrid format as a partial UBL set of invoice data embedding a full PDF presentation, digitally signed or not. The portal also enables users to upload PDF invoices and to complete and approve manually a minimum data set to build a hybrid invoice. Since May 2018, ChorusPro has implemented Factur-X as a standard hybrid format compliant to the EN16931. Additionally, Chorus Pro provides end-users with eInvoice process status functionalities (via status management and response messages available through direct EDI connection or API). It appears that more than 60% of invoices received from suppliers on B2G transactions are hybrid, and this rate becomes more than 90% for SMEs, in 2020 . The Factur-x/ZUGFeRD 2.1 standard is seen as an "onboarding tool" involving all businesses. In fact, it is adapted to SMEs' capabilities when creating and reading eInvoices and implementing an accounting solution to process structured sets of invoice data.
In addition to the technical aspects, France communicates about the eInvoicing benefits for economic operators (i.e. process efficiency, cash flow acceleration and fight against fraud) including tax digital reporting purposes. As of 2023, in addition to the B2B mandate under a clearance mechanism orchestrated around a National Platform (ChorusPro new generation), France aims to implement a real-time reporting mechanism of tax and invoice data to the "Direction Générale des Finances Publiques" (DGFiP – Ministry of Economy and Finance) acting as the tax authority.  The goal for DGFiP is to be able to prepare a prefilled VAT-return including B2C sales and to control VAT deductibility against VAT collection. From an end-user perspective, this digital requirement is an opportunity to reduce administrative burdens by automating invoice data extraction (in ChorusPro or through certified Service Providers) and its integration in VAT reporting processes. From a tax authority view, a mass-adoption of B2B eInvoicing with a core set of structured invoice data linked to tax control processes would help reduce VAT gap, tax fraud and improve tax collection efficiency, thus lifting the pressure on public financing and contribute to the EU recovery.
Initiatives from the private sector and reflecting the role of service providers and the accountancy profession by making the link with the end-users
Presented by Jurgen Soetaert - Founder of DigiCrowd eInvoicing community
These four companies are accounting software, eInvoicing service and solution providers. Today, 80% of Belgian SMEs use a solution or a set of solutions provided by one of these four entities. Based on their years of experience working with private businesses, Digicrowd members aim to solve the paradox often encountered in which senders do not dare submitting eInvoices via the Peppol network and SMEs (receivers) not perceiving the eInvoicing benefits, are reluctant toward digital solutions or ignore how to register to Peppol. Consequently, only 5% of all invoices in Belgium are structured eInvoices compliant with the Belgian government guidance .
To mobilise SMEs and provide an efficient onboarding to small economic operators in Belgium, DigiCrowd adopted this three-objective approach:
- Taking away the doubt for senders to send eInvoices through Peppol by using the "Guaranteed Delivery" model;
- Enhance convenience by offering a simple solution integrated into end-user's software;
- Increasing the volume so that receivers (SMEs and their accountants) can process their purchases invoices with automated systems.
Objective 1 - Take away the doubt with the "Guaranteed delivery" principle
The "Guaranteed delivery" principle emerged from conversations between DigiCrowd members and SME senders being reluctant to send their eInvoices through the Peppol network. Although in Belgium, the Peppol infrastructure is available for B2G and B2B transactions, its usage remains mostly limited to B2G eInvoicing.
This is due to the fact that business partners are not aware of each other's Peppol practices and technical capacities. In other words, senders are not sure that receivers are also registered to the Peppol network and can receive the eInvoicing in timely and quality manners. This lack of awareness and communication between end-users results in the non-adoption of Peppol and the creation of partner-specific bilateral agreement for eInvoicing.
To cope with this issue, DigiCrowd created the "Guaranteed Delivery" principle being a list of SMEs that explicitly expressed their demand to receive eInvoices through Peppol. The goal is to share this list regularly with the eInvoicing senders. This guarantees the senders that their business partners will receive their invoices via Peppol.
This pragmatic solution enhances trust between the business partners, support the government in the eInvoicing practice dissemination and therefore increases the volume of processed eInvoices.
Objective 2 - Enhance convenience to end-users and maintain competitiveness
Peppol being a platform agnostic solution, end-users are free to choose the solution of any service provider/access point to exchange eInvoices via Peppol. In this sense, each economic operator can select a system fulfilling its business needs and core activities necessities.
Objective 3 - Increase the volume of eInvoicing exchanged to generate system automation
DigiCrowd aims to (i) increase the number of eInvoicing adopters among SMEs and (ii) increase the overall volume of exchanged eInvoices.
As DigiCrowd was founded by four major players in the Belgian accounting industry, the coalition leverages their accountants' network being the main target of the onboarding campaign. Accountants often act as counsellor for SMEs. Therefore, as a trusted person, they become the spokesperson of DigiCrowd and promote eInvoicing and Peppol.
Moreover, DigiCrowd members gather a network of about 12,000 SME-mandates. This important volume helps convince larger B2B suppliers to send their eInvoices via Peppol to SMEs. The strategy is to use these multiple mandates as a proof for suppliers that most SMEs have the capacities to receive Peppol eInvoices, thus lifting doubts on potential late payments caused by the non-reception of eInvoices. Increasing the eInvoicing volumes also means enhancing process automation. In fact, one of the conditions for automation to be efficient and impactful is to select an activity involving a high-volume of systematic interactions. The more eInvoices will be processed, the more profitable will be the implementation of an automated system.
Lastly, DigiCrowd strongly leverages the important role of the service providers. "We are convinced that we need to work together as partners to ensure more eInvoices deliveries to SMEs and their accountants" stated Jurgen Soetaert, founder of DigiCrowd. By connecting different Peppol Access Points, the volume of available eInvoices increases exponentially which is to the benefit of all eInvoicing stakeholders.
Communication is key! Round table events with stakeholders are essential to optimise the impact of these combined efforts.
To communicate about their actions, DigiCrowd members organise round table events. It allows all stakeholders to share their accomplishments and solutions with community members. In 2020, one of the round table events received the full support of Alexander De Croo, the former Minister of Finance and the current Belgian Prime Minister. He publicly supported the DigiCrowd initiative and stated that time has come to think about how eInvoicing can be made available to all SMEs in Belgium. One solution he suggested was to "make eInvoicing sending through the Peppol network mandatory for all companies or SMEs in Belgium".
Presented by Charles Bryant - Secretary-General of EESPA
EESPA is a trade association representing over 80 service providers throughout Europe, which provides a number of services for its membership:
- Representing the industry, engaging in the public policy debate,
- Recommending best practice within European forums and expert groups,
- Promoting interoperability and contribute to the creation of a European Digital Single Market,
- Advocating and supporting the wide adoption of eInvoicing and its benefits.
As part of the provision of eInvoicing and supply chain automation services to millions of customers in both the private and public sector, EESPA members stand as experts when onboarding enterprises and offering a range of platform capabilities and delivery channels. EESPA members also support public policy initiatives to promote eInvoicing adoption including the implementation of mandates and other systematic approaches to the roll-out of eInvoicing solutions.
EESPA is engaged with a global interoperability framework initiative (also called "GIF", described in the "Transmitting eInvoicing" article) that supports the creation of a standardised environment for the transmission of eInvoices. The GIF also facilitates the onboarding of end-users by service providers/access points present in networks. To do so, the GIF states a set of seven guidelines for those that have implemented or plan to implement a GIF-compliant instance. These recommendations containing consistent guidelines for the customer experience in the so-called 'first mile' or ‘last mile’ of the transaction chain and the day-to-day connection to and operation of eInvoicing services and solutions.
The Recommended Practices are summarised below:
1. Service providers/access points operating within an interoperable network should ensure that a comprehensive set of business documents is supported and matches other service provider offerings to the maximum feasible extent. This will enable end-users to engage with most of their business partners in a consistent way to ease their daily exchanges. Such services also need to be tailored towards the digital capabilities of a heterogeneous end-user base.
2. Service providers/access points need to support a consistent set of interface methods and protocols. This ranges from an automated file transfer with truly integrated end-users to end-users using portal technologies or other kinds of technical connection. A set of defined minimum services should be supported based on a community understanding of applicable best practices.
3. Service providers/access points should ensure that all their customers have access to an easy-to-use addressing and routing tool. Such tools need to include information about end-user organisational and business hierarchies so that entity and electronic identifiers can be consistently and accurately used and mapped. From the single entity end-user to the global multi-affiliate organisation, consistent use and mapping of identifiers will ensure all end-users can successfully interoperate.
4. Service providers/access points should have the ability to map any data format to the semantic and syntax standards employed in a particular instance of the GIF [or the applicable interoperable framework being used]. This will allow maximum flexibility and differentiation in support of end-users. Service providers/access points need to be able to guide end-users so that data elements are deployed in a standardised manner, this enhancing harmonisation and interoperability about end-user.
5. Service providers/access points should ensure that for each business document transmitted, a corresponding response message is capable of being returned back to the end-user, as required by business circumstances. Not all interoperability models support this yet, and action is required among all relevant stakeholders to enable the implementation of end-to-end response messages like a normal deployment.
6. Service provider/access points should consistently apply error handling processes, triggers and responses to support harmonised end-to-end business process.
7. Service provider/access points should assess their customer’s interoperability capabilities and support them in continuously implementing improvements. Providers should also apply continuous improvements to their own capabilities and carry out bench-marking to assess where they stand against best practices.
For more detail about the GIF set of recommendations about "end-user perspective in delivering interoperability", discover the Global Interoperability Framework and liaise with the CEF Team or EESPA members through the CEF eInvoicing User Community!
Benefits of eInvoicing mass-adoption within the private sector
The large-scale adoption of eInvoicing will be gradual. On one hand, normalising eInvoice submission to public contracting authorities for B2G transactions is necessary. On the other hand, the exchange of eInvoices should become the by-default billing method for B2B transactions. For both aspects, there are three categories of users involved: (i) public authorities/ governments, (ii) eInvoicing solution and service providers and (iii) business partners (i.e. earlier called 'end-users"). It is important to point out that each user type sees different opportunities in eInvoicing, however often targets similar benefits.
Public authorities and EU governments
eInvoicing solution and service providers
End-users (i.e. business partners)
Decrease VAT gap and tax fraud
Creation of a unique flow of eInvoices for a systematic processing
Increase of the eInvoicing volume exchanged through the solution
Ensure safety for business partner authentication
Decrease processing costs and enable resources allocation for core activities
Reduce of administrative burden
Enhance eInvoice transmission between counterparts
Reduce impact on the environment
Facilitate of cross-border trade
Contribute to process automation and emerging technology implementation
In December 2020, the CEF eInvoicing team published the update of the Benefits Analysis of the Directive 2014/55/EU implementation produced in November 2019. This document showed the different type of benefits experienced by public authorities after adopting eInvoicing based on data provided by the EU Member States representatives.
 Reported by the Ireland and Luxembourg country representatives as part of the data collection for the Update of the Benefits Analysis, 2020.
 Direct procurement is the act of acquiring raw materials and goods for production. On the contrary, indirect procurement refers to purchasing services or supplies required to keep the day to day business running.
 Information extracted from ChorusPro monitoring functionalities - numbers reported by Cyrille Sautereau, eInvoicing representative for France.
 CEF-WHITE-PAPER-INPUT, 24 November 2020 (document with authors)
 For more information about interoperability and GIF, "Transmitting eInvoices" article, CEF Digital.
Looking for help? Need more information?