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Need for a lasting and common European Standard on eInvoicing (EN)

The eInvoicing Directive mandates the national and sub-national contracting authorities to receive and process eInvoices compliant with the European standard on eInvoicing. This EU standard was created and published by CEN TC434 to provide the eInvoicing stakeholders with the essential elements that an electronic invoice should consider to comply with the relevant legal provisions. 

Among the online contributions received by eInvoicing actors states the example of Sweden where the unchanged national standard on eInvoicing (for four years) enabled the eInvoicing adoption in most of the municipalities. According to some eInvoicing stakeholders, too frequent releases of the standard would lead to a difficult adoption at the regional level and a reluctance from the service providers to comply with the EU standard on eInvoicing.

Based on the stakeholders' online inputs, there may be a trade-off to find between the need of standard's durability and its constant improvement. 

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Interoperability and Transport Infrastructure

The eInvoicing Directive does not impose the eInvoicing solution, infrastructure and network when exchanging eInvoicing.

Some stakeholders highlight the risk of the EU market fragmentation due to the lack of uniformity among the eInvoicing system implemented. To cope with this challenge and enhance the alignment among the Member States and economical players (i.e. B2B and service providers), some contributors suggests the possible take-up of a unique transmission framework. To do so, these same experts state that the eInvoicing framework should be formally supported by policy makers while other opinions state that this take-up should happen via onboarding activities and "softer measures". 

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SMEs and private sector onboarding

The eInvoicing Directive scope is limited to business to government exchanges (B2G). 

In some eInvoicing stakeholder's opinion, the next step is to enhance the eInvoicing adoption among the private sector (e.g. B2B and service providers). According to the inputs received via the online consultation, respondents state that a rapid SMEs and service providers' mass-adoption of eInvoicing is critical. The eInvoicing democratisation would lead to shorter payment terms, eProcurement automation and reduce processing costs. 

Other eInvoicing experts emphasize that onboarding activities are key to raising awareness and making the private sector aware of the benefits of eInvoicing.  

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Further legislative support for adopting and monitoring eInvoicing

Some eInvoicing experts state that policy guidance is needed to enable the national governments to have common indicators for evaluating the eInvoicing take-up among the public and private sectors. These indicators could then serve as a reference for encouraging B2B eInvoicing transmissions and show the benefits of eInvoicing.

In addition, eInvoicing stakeholders shared via their online contributions that policy recommendations would help having standardised data and common best-practices when pushing for the companies' eInvoicing adoption. Especially during the current period, companies aim to find applicable eInvoicing solutions to their businesses to cope with the remote work. To avoid a proliferation of ad-hoc eInvoicing solutions, experts call for policy support to ensure interoperability and efficiency.  

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Ensure cooperation on eInvoicing and VAT, Continuous Transaction Control (CTC) and Clearance (alignment with eTax)

The European standard on eInvoicing and the SAF-T standard used by national tax authorities differs. The SAF-T is mandatory for VAT payers and therefore impacts invoicing processes and vice versa. In the online consultation, some eInvoicing stakeholders state that  the usage of two different standards generates additional operational costs and decrease efficiency. Some eInvoicing experts are in favour of a standard harmonisation and mention the technical benefits and innovation resulting of the eInvoicing standard and SAF-T's merger. 

Other eInvoicing experts pointed out the necessary alignment of eInvoicing with CTC and EU clearance obligations. Ideally, the transmission of eInvoicing including tax information should be reported in real-time to tax administrations.  

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Ensure increased security due to process digitalisation

eInvoicing generates digital innovations and opens the door to IT improvement in eProcurement (article:"eInvoicing: Making public procurement more attractive to businesses within the EU").

At the EU level, the Cyber security Act published by the National Cybersecurity Agency of France (ANSSI) in June 2019 reinforces the importance of cyber security to face up the challenges brought by the digitalisation of processes (e.g. users' data protection, IT system protection). 

Among the expected benefits of the implementation of eInvoicing, there are the reduction of human intervention and automation of IT systems. The service providers and users should keep into account the data, infrastructure and their own protection/ safety and fraud identification.

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Fully integrate eInvoicing in an automated eProcurement process

The homogenised structure of eInvoice enables a reduction of human intervention when processing eInvoices. In this sense, eInvoicing leads to process automation and the reduction of manual processing. This is an opportunity to lower the risk of human mistake and operational costs. 

Based on the online contributions received, some eInvoicing stakeholders are in favour of automating fully the eInvoicing process and to link eInvoicing work to Robo-Process-Automation (RPA).