The purpose of this page is to collect your inputs related to eInvoicing technical topics. Here, you can share your questions, experiences and future projects about eInvoicing take-up, standard implementation and expectations toward the CEF support and help desk. 



How to contribute?

  1. Scroll down to reach the "comment section" of the page
  2. Click on the square "Write a comment" (written in English or in the language selected in your setting)
  3. Write your comment and click on "Save"
  4. Your comment will appear automatically in the list  


How to reply to a comment?

  1. Scroll down to reach the "comment section" of the page to see the other members' comments appearing 
  2. Click on the "Reply" button (written in English or in the language selected in your setting) corresponding to the comment to which you would like to react 
  3. Write your comment and click on "Save"
  4. Your comment will appear automatically in the list and the author of the initial comment will receive a notification 





    

11 Comments

  1. Paul SIMONS

    Given the already widely implemented use of the Peppol network in the EU (and mandatory use to send invoices to public authorities), it should be an option to promote (or mandate) the use of this network. The open model is similar to the mobile network that guaranteed the success and easy access and low cost for all participants. 

    1. Solene DRUGEOT

      Even if the usage of a single network would ensure an optimal homogeneity, the European Commission can not appear as supporting on specific provider rather than other. This supports unequal competition. We can only advise on the decision and bring neutral guidelines. 

      1. Serge LIBERT

        1. This discussion is not technical, It is a policy discussion. It should be moved there.
        2. Paul is right that Peppol is a kind of network. But narrowing Peppol down to only a network, is a misunderstanding.
          1. In the first place, Peppol is an application of the European Interoperability Framework (EIF).
          2. Peppol is platform agnostic, that is what gives Peppol the potential to overcome commercial barriers, which is the condition sinequanone for generalizing eInvoicing (unless going monopolistic). 
          3. If it is a network, then it is
            1. an internet rather than a (closed) network, or
            2. a network in the social sense: a collaboration area between people willing to go borderless - whatever the border can be.
        3. Your answer to Paul suggests that the countries that decide to support the Peppol model, in particular the ones who appointed a Peppol Authority, wouldn't be market-neutral. That is quite rude, isn't it? In my opinion, that is the contrary: Peppol is the only way for policy-makers to (a) promote generalization of eInvoicing an (b) NOT confiscate this market (like the LATAM model does, installing a monopoly in the place).  

        In conclusion, I see here a series of misunderstanding that lead to unfortunate policy statements, and an opportunity to work them away.

        The elaboration of the Peppol cooperation framework costed  32  millions to the European taxpayer. Now is time to pay him back this investment.

        Let's break the discussion open!

        1. Solene DRUGEOT

          Thank you Serge for the clarifications. I come back on a few points to clarify: 

          • The European Commission cannot mandate the use of any network. The choice of a solution to use is a country decision.
          • The European Commission (and CEF) mentions Peppol's existence. It is also widely used and demonstrated in our workshops and success stories.
          • Lastly, I didn’t say that the countries who choose Peppol are not market neutral, as mentioned it is solution-agnostic.


          More information and discussions about the Peppol interoperability framework available on the Policy page. 

          1. Ger CLANCY

            • The European Commission cannot mandate the use of any network. The choice of a solution to use is a country decision.
              I dont think there needs to be an exclusive mandate of a network eg Peppol, but there should be a recognition of and recommendation of minimum technical standards to meet.

            • The European Commission (and CEF) mentions Peppol's existence. It is also widely used and demonstrated in our workshops and success stories.
              There is a big difference between mentioning the existence of and encouraging the use of whichever network.
              Certain readers could interpret the lack of recommendation as a negative signal

            • Lastly, I didn’t say that the countries who choose Peppol are not market neutral, as mentioned it is solution-agnostic.
              I would say Peppol is the only market-neutral way to do it. And Peppol is (can be) solution-agnostic in the eyes of an end-user.

              How I deliver services, technically, commercially, support, access to other related value-added capabilities is fundamentally different from any / every other provider.
              It should be stressed that while the Peppol document payload must be generic, the Peppol client experience is where providers of Peppol services compete and innovate.
              What other alternative offers that degree of competitive + business benefit?

  2. Tadeusz RUDNICKI

    see also Policy: 'real time tax reporting & e-invoicing'

    In order to achieve the results of the automatic tax reporting process, it should be possible to integrate reporting with the e-invoicing process. Both of these processes have different actors, different choreography and different data (and e-documents) standards.

    The following actions are needed:

    1. removal of the gaps between OECD SAF-T and UBL / UN CEFACT e-invoice semantic models
    2. developing applications and services that convert e-invoice data from the UBL / UN CEFACT standard(s) to SAF-T

    or

    1. transition to a common standard for both processes.

    1. Ger CLANCY

      Tadeusz RUDNICKI Do you think the new Peppol approach to CTC is solving in a appropriate fashion?


      1. Tadeusz RUDNICKI

        As far as I know, Peppol is starting its new activity called CTC project, declaring that cit. "OpenPeppol have an ambition to support different methods for tax reporting and clearance through the Peppol eDelivery Network". So Peppol didn't define its approach to the tax reporting process implementation yet. Despite the 5C model (of data exchange) seems to be in the air, it still doesn't eliminate different process scenarios.

  3. Lars Engberg

    Technology is a tool to achieve set goals, not the goal itself. The technology should support the business process, important that it is anchored and delivered in agreement with, for example, systemsuppliers. Focusing primarily on what we want to achieve (Policy) and secondly on what technology (Technical) is appropriate. 

    I see this as a market in collaboration. Public sector, suppliers of IT systems/services and operators, as well as end-users (B2G, B2B?) must see the benefits of the entire, or at least parts, of the valuechain and point in the same direction.


  4. Kerstin WISS HOLMDAHL

    E invoicing works well from a technical point of view. So far we have had one standard in Sweden that has ben dominating , it is from 2004,  the "svefaktura,"It is  in XML format, UBL standard and it is mainly used in public sector with their suppliers but also B2B. Now we are  recommending the European standard/ EN and the format that fulfil the requirements of the EN and that we recommend in Sweden is Peppol BIS Billing 3 (via SFTI, which is cooperation between the governmental sector and the regional and local sector). And also we recommend Peppol infrastructure as the communication and it is also mandatory for the contracting authorities and regions to be registered as a receiver of e-invoicees in the Peppol Registry. We give from SFTI information and support to both the end users and the system providers that implement Peppol BIS Billing 3 and also regarding the usage of Peppol as infrastructure.

    My experience from meeting many end users from the municipalities and the regions is that the knowledge of e-invoicing is very good. After the mandatory e-invoicing law also almost all municipalities and all regions are receiving e-invoices. The format Svefaktura has not been updated since it was developed in 2004. It works and it is used very broad. But now, the new European standard/ Peppol BIS Billing 3 is mandated and beeing implemented by most of the systemproviders and VAN operators.  We have had many information events and education regarding the new law and the European standard. And I get the impression that the contracting authorities and regions can rely on it, that it is a well functioning standard.

    I am aware of the proposal from CEN TC 434 to update the European standard, even if I have not seen any standardization request from the European commission to do it. To update the EN can challenge the ongoing implementation of the e-invoicing directive and the implementation of e-invoicing. To have a stable standard is crucial and to trust of not updates too often, which both takes time and is not costeffective.  There must really be a documented need for an update, There are big information efforts of reaching both all contracting authorities and entities and their suppliers. And of course the system providers and VAN operators that shall  implement and provide this, so that the end users can rely on that it is implemented. It is of most importance both on national level but also for the crossborder trade that the standard is stable and not new versions coming very soon. New standards and emerging technologies will and has to come, but first it is crucial to take advantage of well functioning standard and infrastructure and get as many as possible “on board “ with e-invoicing.


  5. Declan MCCORMACK

    While the EN must be kept relevant and updated accordingly, a stable standard is important. As noted by other commentators, eInvoicing Stakeholders operate in an extremely complex landscape with often many external and competing demands made of them to update their systems (e.g. EN, national requirements, eDelivery network changes). A roadmap of proposed changes to the EN may help provide a compromise of stability with managed adaptation.

    It would be helpful to have a greater awareness within eProcurement policy community of the European roadmap/vision for CEF Delivery blocks such as AS4, and its potential relevance and application to eProcurement, in particular beyond eInvoicing.

    Considering how to make support for the EN and the CEF Delivery build blocks ubiquitous in the main Financial applications in the market could help drive uptake of support for the EU eInvoicing standard.

    The work on emerging technologies is a very good initative. In that space, there have been a number of developments in a range of EU regulations and initiatives that might be relevant for further consideration from an eInvoicing technical and operational perspective.

    • Progress on eDelivery infrastructure (e.g. CEF Building blocks; interoperability; Peppol)
    • Cloud – code of conduct
    • Cyber security Act (& EINSA)
    • eSignatures / eIDAS
    • RPA - Robotic Process Automation


    Shared experiences and learnings in terms of eInvoicing solution functional and technical specifications would be useful at this stage, to help prepare for the next iteration of solutions in coming years.