eInvoicing in Sweden

Legislation

In Sweden, the following laws mandate the use of eInvoicing for public entities:

1. Ordinance for accounting(Förordning (2000:606) om myndigheters bokföring §21f).
2. Ordinance for electronic information exchange(Förordning (2003:770) om statliga myndigheters elektroniska informationsutbyte § 3). The law has been amended multiple times, with the latest amendment in 2021. It also includes the mandated use of eProcurement in the procurement processes.
3. Act on electronic invoicing in public procurement (Lag (2018:1277) om elektroniska fakturor till följd av offentlig upphandling). The law implemented the EU eInvoicing directive into national law. More information regarding the Act is provided below. 

The Act on eInvoicing in public procurement:

• Entered into force on 1 April 2019;
• The Act covers all public procurement transactions (B2G), including those below the EU public procurement thresholds. More information about EU’s public procurement thresholds can be accessed on the European Commission’s website;
• The Act makes it mandatory for public sector suppliers to send eInvoices for all contracts signed after 1 April 2019; 
• Public sector contracting authorities must be able to receive and process eInvoices according to the European standard, EN 16931. However, there are some exceptions which includes national security, specific privacy situations, etc.;
• Digg (Swedish Agency for Digital Government) can impose fines to suppliers that do not comply with the law;
• The Act permits the use of other/older formats, which may be set out in bilateral agreements;
• Digg has issued an accompanying regulation, which mandates all public entities to be registered in Peppol.

In February 2023, the Digg, along with the Swedish Companies Registration Office (Bolagsverket) and the Swedish Tax Agency, have submitted a formal request to the Swedish government to evaluate the conditions for adopting mandatory eInvoicing in B2B and G2B (to be added to the current B2G eInvoicing mandate). The request put a focus on relevance of mandatory eInvoicing, especially in the EU regulatory landscape of the Value Added Tax (VAT) in the Digital Age proposal. There are no specific timelines yet. However, according to the proposal, the evaluation of the conditions for adopting mandatory eInvoicing in B2B and G2B shall be done as soon as possible.

eInvoicing platform and eInvoicing management solutions

Sweden encourages the use of Peppol for electronic procurement, enabling connected public entities and economic operators to communicate with each other. Legacy eProcurement solutions based on EDIFACT (GS1 EANCOM) are still supported by the central, regional and municipalities.

Approach for receiving and processing eInvoices

Solution providers, on behalf of public sector organisations, operate the access point to receive eInvoices from economic operators. For the central government, the Legal, Financial and Administrative Services Agency manages framework agreements for the provision of a common infrastructure for central government organisations. 

Several platforms are in use by the public sector. In Sweden, the solutions used are based on the recommendations by Single Face To Industry (SFTI) regarding standards for both messages and other infrastructure. SFTI recommends Peppol for the Swedish public sector and its suppliers. For more information on SFTI, please read the  section on ‘additional information’.

No electronic signature is required for eInvoices and the archiving period amounts to 7 years[1].

eInvoicing implementation in sub-central level contracting authorities 

Beginning 1 April 2019 all central and sub-central public procurement contracting authorities and suppliers (above and below EU threshold and including direct procurement) must comply with the EN 16931 using the (CIUS) Peppol BIS Billing 3. Implementation of eInvoicing at sub-central level is close to be fully completed as there are old legacy formats (Svefaktura version 1 and SFTI Fulltextfaktura) still in use.

The main identified benefits of implementing eInvoicing at sub-central level are cost and operational savings, the reduction of administrative burden, optimisation of time-to-payment and contribution to process automation. 

Status on the implementation of the European Standard on eInvoicing (EN)

In Sweden, the EN is implemented through the use of Peppol and efforts are being made to increase the use of its compliant CIUS, the Peppol BIS Billing 3. Sweden plays an active role in OpenPeppol where support for the implementation of the EN is considered. The Peppol specification is used as-is without any national blends. For more info on Peppol see: The Future Is Open - OpenPeppol.

Digital reporting requirements

The VAT return may be submitted either electronically or on paper. The Swedish Tax Agency however encourages companies to use its e-service for filling a VAT return (Lämna momsdeklaration) [2].

In 2022, the Swedish Tax Agency confirmed it initiated a project to establish the future of VAT reporting in Sweden and started evaluating the alternatives of eInvoicing and digital reporting solutions. No specific solution or timeline has been communicated yet. Nevertheless, the Swedish Tax Agency aims to keep discussing further the options including Periodic Transaction Control (PTC), i.e., VAT listings and SAF-T, Continuous Transaction Controls (CTC), such as real-time invoice reporting and mandatory eInvoicing.

As part of Sweden’s Environment, Social and Governance (ESG) policy to digitalise environmental data, the Swedish Transport Administration now requires its digital reporting for certain procured contracts over 50 million SEK from 15 March 2024. Contracted suppliers will have to follow the BEAst supply 4.0 industry standard and report environmental data using Peppol Advanced Despatch Advice to the Swedish Transport Administration [3].

Additional information

Single Face To Industry (SFTI). SFTI is led by the Swedish Association for Local Authorities & Regions (SALAR), Digg, the National Procurement Agency and The Legal, Financial and Administrative Services Agency. SFTI is represented by the public sector, economic operators and IT providers. Its aim is to recommend standards for eProcurement in the public sector and to support its use. It offers a service desk free of charge, publishes guidance on its website and organises a wide range of courses and seminars related to eProcurement. It is active in international standardisation in CEN, OASIS and similar organisations.

SFTI has been, and are still, one of the stakeholders responsible for the communication regarding the use of Peppol BIS Billing 3 both within central and sub-central entities.

Digg is commissioned by the government to facilitate the use of eProcurement (post award) in Swedish central government agencies. Digg is a sponsor of the work in SFTI. It also has the role of the Swedish Peppol Authority. In this regard, it is responsible for the registration of companies that wish to become an Access Point (AP) or a Service Metadata Publisher (SMP) within the Swedish jurisdiction.

[1] (Skatteverket, 2024), [2] (Filling a VAT return, 2024), [3] (Requirements regarding digital delivery notes (In Swedish))

Last updated:  Jun 13, 2024 13:21