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eInvoicing Documentation

Compliance with eInvoicing Directive


Article 7 of Directive 2014/55 on electronic invoicing in public procurement states that:

"Member States shall ensure that contracting authorities and contracting entities receive and process electronic invoices which comply with the European standard on electronic invoicing whose reference has been published pursuant to Article 3(2) and with any of the syntaxes on the list published pursuant to Article 3(2)."

The key points included in this Article may be clarified as follows.


Key points in Article 7Clarification

The Member States shall ensure ...

Member State authorities are required to adopt, publish and apply the laws, regulations and administrative provisions necessary to comply with this Directive ... (Art. 11(1)).

The obligation to receive and process electronic invoices is thus placed on the contracting authorities and contracting entities in different Members States and must be defined by their respective national legislation. The national legislation may restrict the options defined as compliant with the European eInvoicing standard (EN 16931). The national legislation may also impose additional requirements in eInvoicing-related matters that are not within the scope of the Directive. These issues can include transmission of invoices, sending requirements to suppliers, scope, etc.

Information on the adoption of the Directive in different Member States can be found in the Country Factsheets.

... that contracting authorities and contracting entities ...

The scope of Directive 2014/55/EU (Article 1) specifies that the Directive applies to electronic invoices issued as a result of the performance of contracts to which: Directive 2009/81/EC on the coordination of procedures for the award of certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, Directive 2014/23/EU on the award of concession contracts, Directive 2014/24/EU on public procurement or Directive 2014/25/EU on procurement by entities operating in the water, energy, transport and postal services, apply.

... receive and ...

The requirement to receive and process means that the receiver shall do so when a supplier sends an electronic invoice. In other words, the suppliers will have the option to send electronic invoices to the receivers and, if they do so, they are ensured that the invoice will be received and processed, resulting in a payment or another response (questions or rejection) from the receivers to the buyers. The Directive does not require senders to send electronic invoices, but the Member States or individual receivers can impose such requirements as part of the adoption of the Directive.

The reception of electronic invoices requires the adoption of one or more Message transmission solutions. Neither the Directive nor the European eInvoicing standard specifies how electronic invoices shall be transmitted but the standard provides guidelines on interoperability of electronic invoices at the transmission level, identifying options and making recommendations. The accepted transmission options may be restricted in the Member States as part of the national transposition of the Directive.

... process ...

How invoices are processed is not specified by the Directive. EN 16931 part 1 specifies what business processes are supported by the standard, which means that a receiver who has unrestricted compliance with the EN shall receive and process all invoices that require any of the supported processes. The European eInvoicing standard does not specify how the invoices shall be processed, which leaves it up to the receivers to decide on the level of automation they wish to adopt.

... electronic invoices which comply with the European standard on electronic invoicing ...

The electronic invoice must comply with the European Standard on electronic invoicing, which is the European eInvoicing standard.

For clarification, note 7 of the Directive states that "... only machine-readable invoices which can be processed automatically and digitally by the recipient should be considered to be compliant with the European standard on electronic invoicing. A mere image file should not be considered to be an electronic invoice for the purpose of this Directive."

... whose reference has been published pursuant to Article 3(2) and ...

Article 3 of the Directive required the establishment of a European eInvoicing standard and, once this standard was published, to connect the Directive and the standard through a reference in the Official Journal of the European Union. It is the date of the publication of this reference that, according to Article 11, sets the deadlines by which the contracting authorities and entities in scope must be able to receive and process electronic invoices complying with the European eInvoicing standard.

... with any of the syntaxes on the list published pursuant to Article 3(2).

A contracting authority and entity must be able to receive and process electronic invoices using either of two syntaxes specified in the list of syntaxes (EN 16931 part 2) that comply with the eInvoicing standard.


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