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Legislation

According to the law of 20 December 2017 amending the Public Procurement Law 2012 to include Directive 2014/55/EU, the implementation deadline for B2G eInvoicing for all public authorities in the Netherlands was 18 April 2019.

The Dutch government had already implemented part of the Directive 2010/45/EU in national law in 2012 (Implementation of the Billing rules Directive of 15 March 2012), simplifying rules in the field of billing regarding the levying of VAT and harmonising the requirements for the invoicing and electronic invoicing (eInvoicing).

eInvoicing platform and eInvoicing management solutions

In the Netherlands, the implementation of eInvoicing as required by Directive 2014/55/EU and the Dutch Procurement Law has been executed by adopting the Peppol framework for setting up an interoperable exchange infrastructure. Currently, all government agencies are direct or indirect connected to the Peppol infrastructure.

As of 1 October 2020, the Dutch government is the Peppol Authority in the Netherlands. The new organisation is called the Netherlands Peppol Authority (NPa). This follows the decision of the Dutch Ministry of the Interior and Kingdom Relations (BZK), at the end of 2019, to move the Peppol Authority into the public domain.

To implement the tasks associated with the NPa, the BZK is working with:

• the Netherlands Enterprise Agency (RVO), an executive organisation within the central government, whose role is to assist Dutch entrepreneurs and policy officers to progress in the fields of sustainability, international business, agrarian entrepreneurship and innovation;
• Logius is the digital government service which supports all providers with facilities and standards to provide digital services (such as Digipoort).
• RDI for the enforcement of the compliancy to the agreements in the Peppol framework

Furthermore, two communities have been created to support the NPa in its decision-making:

• the Peppol community consists of the contracted service providers. This community will be consulted on a regular basis and various topics will be discussed, such as developments within OpenPeppol, proposed amendments, compliance, etc. These consultations would also be used to advise the NPa on potential amendments;
• the Stakeholder community gathers representatives of authorities, businesses, software packages and other stakeholders and aims to guarantee that both the services provided by the infrastructure and the trust framework meet their needs.

In 2023, the Netherlands introduced e-orders via Peppol for the Central Government Procurement sector. 

Using this pilot, suppliers can convert electronic orders received from the government to an eInvoice and submit it back; increasing efficiency, decreasing costs, and eliminating invoice errors. This process allows government services to exchange purchasing messages with suppliers easier and faster. Such messages can be eInvoices or electronic orders, but also contract data or status reports.

Approach for receiving and processing eInvoices

All government organisations (such as Ministries, municipalities, provinces and non-departmental public bodies) are obliged to be able to receive and process eInvoicing

eInvoices can be submitted to the centralised government in the following ways:

• via the secure Peppol network. Most administration software that Dutch companies use is suitable for sending eInvoices via the Peppol network. The Access Point of the national government automatically converts the Peppol invoice into an eInvoice in the government format. The invoice will then be sent via Digipoort to the relevant National Service. Peppol is the preferable channel for exchanging e-invoices, the other options are temporarily or meant as a backup;
• via the Central Government eInvoicing portal. It is suitable for suppliers who send a limited number of invoices, have no objection to manual entry into a portal, do not want to incur extra costs for sending an eInvoice, and who do not have the (technical) possibilities for an extensive ICT infrastructure;
• via Digipoort, which is the ICT center where message traffic for the government is handled. eInvoicing via a direct link with Digipoort is suitable for suppliers who send large volumes of invoices (approximately more than 50 per week), want to fully automate eInvoicing; want a direct connection with Digipoort; have an extensive automated ICT infrastructure, or the ability to set it up.

No electronic signature is required for eInvoices and the archiving period amounts to 7 years, with the exception of invoices related to Immovable Property whose archiving period is 10 years.

eInvoicing implementation in sub-central level contracting authorities 

The Netherlands transposed the eInvoicing Directive into law through its National Procurement Act and it did not need the Directive’s extended deadline for sub-central authorities. The capability for contracting authorities to be included in the address network (i.e. Peppol SMP) was not included in the regulation, but it was provided in an additional memorandum. 

All Dutch government bodies are connected to the Peppol network– either directly or indirectly. For sub-central contracting bodies, the use of Peppol is recommended but not mandatory.

eInvoices can be sent to local authorities in the following ways[1]:

• via the secure Peppol network (as explained above);
• via e-mail using an XML-attachment;
• eInvoicing manually using the online portal of an ICT service provider (as explained above).

The eInvoicing implementation at the sub-central level is in operation. In November 2019, 95% of sub-central authorities already used eInvoices while eInvoicing was not yet mandated for all municipalities and suppliers. 

The municipalities are not legally required to ask for eInvoices from their suppliers. However, they have the possibility to set a requirement in their procurement contracts based on bilateral agreements.

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

Public entities in the Netherlands can receive eInvoices in several formats:

1. Peppol BIS 3.0 (Preferred format) is a subset of the European Standard EN 16931 for use in Europe. Country-specific rules for the Netherlands apply.
2. UBL-OHNL is a standard that describes the messages for public procurement of all goods and services, except hiring of temporary staff. UBL-OHNL is based on the international standard UBL.
3. SI-UBL 2.0 is the UBL implementation of NLCIUS. Older versions of SI-UBL will eventually be phased out. NLCIUS is a subset of the European Standard EN 16931 for use in the Netherlands.
4. SETU (HR – XML) standard describes the messages (including eInvoices) in the context of data exchange for hiring temporary staff. This is currently the highest volume of invoices to (central) government. 

Monitoring eInvoicing implementation

The monitoring of eInvoicing implementation is not explicitly tackled, however, there are some measures of uptake across different institutions.

While the current approach is more oriented toward a technical perspective, the Netherlands has started focusing on monitoring and communicating the benefits to the broader public. 

In 20202023, the Netherlands Peppol Authority (NPa) published its roadmap which is a multi-year program describing the ambitions of the NPa for the coming years.

There are three focus points of the NPa, defined as tracks in this roadmap:

• improving the Peppol framework: ensure the correctly executed and applied Peppol framework on a national level;
• expanding post-award domain: conduct an analysis of the existing Peppol BIS standard, and possibly country specific additions, and align these developments with the service providers, stakeholders and OpenPeppol;
• communication and marketing: increase the awareness and the use of Peppol.

Use of Core Invoicing Usage Specifications (CIUS) at national level

NLCIUS is a subset of the mandatory European standard on eInvoicing (EN) 16931 for application in the Netherlands. The European standard (EN16931) describes the method of eInvoicing to governments and can also be used by companies. EN16931 and NLCIUS provides clarity to governments and companies about the elements and data that should be used on invoices to government organisations in the Netherlands. For more information go to Forumstandaardisatie. 

Digital reporting requirements

The Netherlands put in place a new tax portal named Mijn Belastingdienst Zakelijkportal. Taxpayers are now required to file Value Added Tax (VAT) returns using compatible software, through a tax services provider, or through the new portal. VAT-registered taxpayers must authenticate their identity using the eHerkenning system. However, some traders are exempt from this identity requirement and may continue to use DigiD[2]. The Mijn Belastingdienst Zakelijkportal allows to submit VAT declaration, view current year VAT return, correct a VAT return, file an objection, etc.

In February 2023, the Dutch Ministry of Finance published a sheet of the working group Assessment (BNC) of the new EU Commission Proposals (VAT in the Digital Age proposal), where a detailed assessment of the proposed VAT regulations was conducted. The government endorses a digital reporting system for intra-community transactions, provided that it eases the administrative burden for entrepreneurs and effectively combats VAT fraud. Moreover, the government favours the suggested framework for voluntary reporting methods for domestic transactions because it enables each Member State to adopt a system that aligns with their objectives.

[1] (Ministry of the Interior and Kingdom Relations , n.d.), [2] (KPMG Global Tracker, 2022Tax Administration, 2024)

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