E-INVOICING

(A.) Policy and legislation

(A.1) Policy objectives

Electronic invoicing (e-Invoicing)28, i.e. an invoice that has been issued, sent and received in a structured electronic format which allows for its automatic and electronic processing, brings numerous benefits to all users (senders and recipients). By automating the relevant business processes, e-Invoicing leads to cost savings, increased efficiency, faster payments, and a reduced environmental impact especially if other business documents like order and dispatch advice are also available in electronic format.  Its deployment is a strong tool in support of enterprise and financial policies as it makes enterprises more efficient and generates potentially significant savings for Member States’ governments. Therefore, e-Invoicing is highlighted in the EU’s digital agenda as one of the key actions of its first pillar (“A vibrant digital single market”). Additionally, it contributes significantly to the EU’s digital agenda by promoting the development of eGovernment, and ready accessibility to users with disabilities (see the separate section on accessibility of ICT products and services and web accessibility).

(A.2) EC perspective and progress report

In the last decade or so, many e-invoicing standards/formats have been developed, based mostly on different versions of XML syntaxes. Many of these are proprietary formats and are only used by specific communities (for example a country, one multinational company and its suppliers, etc) or embed proprietary unique identifiers that may require licensing from a single source. As Member States developed their own national standards, some of these also differed from anything already on the market, resulting in further divergence and a lack of interoperability. As a consequence, market players, such as companies or financial and IT service providers need to support multiple formats, requiring substantial mapping and conversion exercises to cope with data expressed in different syntaxes.

By specifying the semantic data model of the core elements of an electronic invoice, the published European standard EN 16931-1 is intended to tackle the semantic fragmentation that is a side effect of the vast number of e-invoicing standards, data formats, and usage requirements that exists across the EU and globally. The standard model preserves the necessary flexibility through Core Invoice Usage Specifications (CIUS) and extensions. It is important to promote the standards in order to promote interoperability while respecting different sector needs and practices.

The Commission has addressed the issues around e-Invoicing also on the political and legal level:

• Communication COM(2012)573  identified 12 key actions, one of which is to “adopt legislation to make e-invoicing standard billing mode in public procurement”.
• Directive 2014/55/EU obliges central government bodies of the Member States to accept electronic invoices in public procurement.

A European Multi-stakeholder Forum on e-Invoicing (EMSFEI) was set up by the Commission with Commission Decision C(2010)8467. The EMSFEI was renewed in October 2017 for a 3-year mandate and closed in 2020. On 1 October 2013, EMSFEI unanimously adopted and endorsed the Recommendation on the use of a Semantic Data Model to support Interoperability for Electronic Invoicing that has been taken up by the European Commission and is a central focal point for Directive 2014/55/EU. The EMSFEI published also a number of recommendation in support of the implementation of Directive 2014/55/EU and the electronic invoicing standard EN 16931.

(A.3) References

• Directive 2014/55/EU of the European Parliament and of the Council on electronic invoicing in public procurement. This Directive obliges central government bodies of the Member States of the European Union to accept electronic invoices in public procurement from 18 April 2019 onwards; and Member States were able to postpone the obligation for local authorities until 18 April 2020. These electronic invoices must comply with the European standard on electronic invoicing (EN 16931-1), and with one of the syntaxes on a limited list specified in CEN/TS 16931-2.
• Council Directive 2010/45/EU amending Directive 2006/112/EC on the common system of value added tax as regards the rules on invoicing.
• SWD(2013) 222 — Impact Assessment accompanying the document `Proposal for a Directive of the European Parliament and of the Council on electronic invoicing in public procurement´
• COM(2013) 453 final on end-to-end e-Procurement to modernise public administration
• Explanatory Notes on VAT-invoicing rules (Council Directive 2010/45/EU).
• Council Directive 2006/112/EC on the common system of value added tax.
• COM(2010)712 “Reaping the benefits of electronic invoicing for Europe” describes a number of actions in different areas, including standardisation, needed to facilitate the deployment of e-invoicing in Europe.
• Member States called for measures to promote e-invoicing at the Informal competitiveness Council of February 2012 and in the European Council Conclusions of June 2012.
• The European Parliament called for making e-invoicing compulsory in public procurement by 2016 in a resolution adopted in April 2012.
• COM(2012)179 “A strategy for e-procurement” states that the ultimate goal is “straight through e-procurement” with all phases of the procedure from notification (e-notification) to payment (e-payment) being conducted electronically.
• Commission Implementing Decision (EU) 2017/1870 of 16 October 2017 on the publication of the reference of the European standard on electronic invoicing and the list of its syntaxes pursuant to Directive 2014/55/EU
• Several European countries already introduced rules whereby public authorities could only accept electronic invoices from suppliers, and all these initiatives will need to align with the ongoing standardisation activities carried out by CEN/TC 434 according to the Annex of the standardisation request M/528.

(B.) Requested actions

The deliverables defined in the standardisation request M/528 have been published. EN16931-1 and its complementary technical specifications and reports are available.  TC/434 should discuss further follow up activities leading to wider adoption and implementation of e-Invoices / automated processes.

Action 1 Continue the work in CEN TC/434, which includes the following aspects and standardisation deliverables, currently under development:

• investigation of future activities (the TC has already agreed on the topics to be addressed on a short and medium term
• maintenance activities
• development of standardisation documents that support and encourage the uptake of the European Standard and its ancillary deliverables
• communication activities (Capacity building) also addressing third countries at global level
• deliverables that describe the governance and rules framework for Core Invoice Usage Specifications (CIUS) and extensions to the core invoice management a specification to the creation and management of a registry in support to use of CIUS, extensions, code lists and any other similar need

Action 2 For industry specific purposes sector specific extensions in addition to the generic EN 16931-1 model might be devised and standardised at a European and global level: for example for energy, e-health, insurance and human resources management purposes in line with  CEN/TC 434 deliverables. There needs to be a registry for such standardised extensions whose development should be in line with centrally defined rules (see Action 1).

Action 3 For e-Invoices related to ICT services addressing end users, attention should be paid to the relevant Human Factors requirements (e.g. language understandability and consistency and accessibility). Aspects such as clarity and ability to perceive of information structures and content, use of unambiguous, harmonized terminologies and standardised formats and information attributes and details should be considered for current and upcoming ICT services. ETSI has already addressed certain aspects related to the usability and accessibility of the basic elements (e.g. in Smart City environments) and on the general level;  the ESOs, MSP, consortia and standards bodies should coordinate and initiate work to develop recommendations addressing the requirements and user experience of e-invoicing in digitised environments (covering applicable usability and accessibility aspects related to those attributes and context of use).

General remark: Overall, the actions should be part of an agreed standardisation strategy shared by the Commission, the ESOs, MSP, consortia and standards bodies supplying specifications in use, and Member States,which actively implement them.  The Commission may launch further broad, neutral fact-finding inquiries (perhaps via the MSP) to identify appropriate shared needs and goals.

(C.) Activities and additional information

(C.1) Related standardisation activities

CEN

CEN/TC 434 was established to provide standardisation for e-Invoicing and to undertake the standardisation activities required by the Directive 2014/55/EU

CEN/TC 440 —   “Electronic public procurement” — was established in order to provide standardisation in the field of e-procurement including post-award processes.

OASIS

The OASIS Universal Business Language (UBL) TC defines a common XML library of business document types supporting digitization of the commercial and logistical processes for domestic and international supply chains. Version 2.1 (UBL v2.1), used in several Member States and in OpenPEPPOL, was adopted as ISO/IEC 19845:2015. An updated version 2.3 is under development.

The OASIS Business Document Exchange (BDXR) TC defining specifications for a federated document transport infrastructure for business document exchange. It provides standards for service location, capability lookup that can be used together with a message protocol like AS4 (as in CEF eDelivery and in OpenPEPPOL) and an Exchange Header Envelop schema.

UNECE

The United Nations Center for Trade Facilitation and Electronic Business (UN/CEFACT) Cross Industry Invoice version 16A is a maximum data set invoice model which aims to cover all potential needs of any industry and any transaction. Each implementation is therefore a subset of the overall standard, but extensions should not be necessary as every aspect is intended to be covered by the standard. This standard is re-released twice a year, but always backwards compatible with the official 16A version.

This standard is based on an overall Reference Data Model which brings direct links to electronic messages for all other supply chain operations.

See: https://www.unece.org/uncefact/mainstandards.html#ui-accordion-jfmulticontent_c66359-panel-1

ETSI

ETSI TC Human Factors is responsible for all Human Factors matters related to the usability and accessibility of ICT products, applications and services. Special care is paid to all aspects related to interfaces and interaction with the user. Human Factors is the scientific application of knowledge about human capacities and limitations in order to make products, systems, services and environments effective, efficient and easy for everyone to use.

IEEE

IEEE  P2142.1 -  Recommended Practice for E-Invoice Business Using Blockchain Technology. For further details please see https://standards.ieee.org/content/dam/ieee-standards/standards/web/documents/other/blockchain.pdf

ITU

Under ITU-T SG3, Recommendation ITU-T D.198, “Principles for a unified format of price/tariffs/rates lists used for exchanging telephone traffic”, recognizes the right of any operator to present price/tariffs/rates charged for telecommunications services in any form deemed convenient for the operator. It additionally recommends that telecommunications companies offering international connections/exchange of traffic make use as far as possible of the same templates/forms/format of data to represent traffic destinations and offered price/tariffs/rates including if required optional clarifying information or quality of service criteria. ITU-T D.198 also identifies the mandatory and optional specifications of price list electronic spreadsheets and advocates for the coordination between parties not only to define QoS information but also to ensure smooth spreadsheet processing.

See: https://www.itu.int/rec/T-REC-D.198-201905-I

Under ITU-T SG16 a new work item to draft a new Recommendation H.DLT-INV “General framework of DLT-based invoices” was approved, aiming to publish it during 2021.

See: https://www.itu.int/ITU-T/workprog/wp_item.aspx?isn=16367

Other activities related to standardisation

OpenPEPPOL

E-Invoice developer community to implement the PEPPOL (and e-SENS) programmes.  The PEPPOL transport infrastructure is today implemented by hundreds of service providers throughout Europe, servicing thousands of public and private entities, specifically in the post-award processes of e-procurement, where e-Invoicing is predominantly used. http://www.peppol.eu/about_peppol/about-openpeppol-1 

(C.2) additional information

The French government devised rules for e-Invoicing. This action is part of a simplification programme for businesses. The goal is to dematerialise invoicing between public bodies and suppliers. E-invoicing will be introduced progressively from 1 January 2017 it will apply to big firms and from 2020 to small and medium businesses. Public bodies must be ready to use e-Invoicing by 2017.

The German Government project “eRechnung” on behalf of the IT Planning Council is directed by the Federal Ministry of the Interior and the IT Standards Coordination Office (KoSIT).  The project has developed a national standard “XRechnung”, which fulfills the requirements of the German public sector and private entities on electronic invoices.   This national standard includes a core invoice usage specification that provides additional explanations and business rules compared to the CEN Semantic Data Model. A second goal is to offer recommendations on infrastructure components for federal, state and local governments

In Italy 100% of the suppliers for central and local authorities have been obliged to issue e-invoices in FatturaPA format since March 31, 2015 semantically aligned with CEN/BII WS core invoice through a centralized government hub. This broad-scale project has led to between 2 and 2.5 million suppliers to send invoices electronically and has enabled the Italian government to reap the benefits of digital invoicing to the full extent. The central hub was extended also to B2B invoices and its use became mandatory as of Jan 1st, 2019: no paper invoices, with few exceptions, are allowed. The central hub was adapted to receive and process electronic invoices compliant with EN 16931-1 expressed in one of the formats identified in EN 16931-2 from April 2019, as part of the transposition of Directive 2014/55/EU and Commission Implementing Decision (EU) 2017/1870.

In the Netherlands, NLCIUS is a specification that has been created for Dutch businesses and public sector organizations to help the implementation of EN16931 in their e-invoicing solutions.  It is compliant with Dutch legislation and in line with the PEPPOL CIUS, and will be implemented through the PEPPOL transport infrastructure. In light of the legal obligation to comply with EN16931 from 18 April 2019 onwards, NLCIUS was created by a joint initiative of Dutch government organizations and the Dutch business community (www.STPE.nl). The use of NLCIUS is mandatory for all public sector organisations and follows ‘comply or explain’ rules.

The emergence of an abundance of internet and mobile based payment services for both online and over-the-counter purchases makes it increasingly important to also standardize formats and delivery methods for business-to-consumer (B2C) e-billing.  Business-to-government (B2G) and business-to-business (B2B) e-invoicing formats are not directly applicable to invoices and receipts issued to consumers. Most importantly, there are privacy issues to be considered with respect to content and delivery. Standardised e-billing for B2C commerce could have a number of benefits including faster and simpler payments and reduced environmental impact for mobile over-the-counter purchases; more readily accessible to users with disabilities; consumers can collect invoices in a single location, easily accessible for warranty and ODR purposes; easily accessible and portable e-invoices may be used to increase trust in relation to second-hand C2C trading. However, e-invoicing in multiple formats, where the consumer would have to register in many different ways with various vendors and/or data mining third-party services to receive invoices in various formats or become embedded in proprietary apps, would be detrimental to the objectives of the digital single market. 

28 This definition is in line with Directive 2014/55/EU and the European standard on electronic invoicing EN 16931-1 that refers to the structured format and automatic processing. This is coherent with the purposes of this document but more restrictive than the general definition of electronic invoice given in the VAT Directive (2006/112/EC).