(A.) Policy and legislation

(A.1) Policy objectives

Electronic invoicing (eInvoicing), as defined in Directive 2014/55/EU, is the process through which an invoice is issued, sent and received in a structured electronic format which allows for its automatic and electronic processing; it brings numerous benefits to all users (senders, and recipients, service providers, tax authorities, etc). By automating the relevant business processes, eInvoicing 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. Electronic invoicing can improve tax compliance and is an effective tool to reduce tax frauds, in fact its adoption also in the private sector transactions (B2B) is increasing worldwide, often by legal obligation and with proprietary formats.

eInvoicing is evolving rapidly and innovative applications of eInvoicing and uses are developing, based on Blockchain, AI, RPA, etc. and this evolution will shape policy developments in the coming years. The main objectives for the coming period are to achieve broad take-up of eInvoicing in Europe, extension of the use of the European Standard and the EU-model for eInvoicing to B2B, B2C and at an international level, and making the European standard fit for use according to all upcoming Commission e-Invoicing related policies, such as VAT reporting.

For electronic invoices related to ICT services addressing end users, attention will be paid to Human Factors such as universal accessibility, consistency and use of understandable language. Aspects such as clarity and ability to perceive of information structures and content, use of unambiguous, harmonised terminologies and standardised formats and information attributes and details must 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, international standards bodies and consortia 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).

(A.2) EC perspective and progress report

By specifying the semantic data model of the core elements of an electronic invoice, the published European standard EN 16931-1 and its list of syntaxes in Annex is intended to tackle the fragmentation that is a side effect of the vast number of eInvoicing 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 facilitate interoperability while respecting different sector needs and practices. On the same basis, it should also be possible, by new standardisation activities, to support the adoption of e-Invoicing for B2B and B2C (e-receipts) and at an international level while ensuring the use of eInvoicing and the European Standard for VAT reporting obligations, as foreseen in the upcoming Commission legislation on this topic.

The Commission has addressed the issues around eInvoicing also on the political and legal level:

• Directive 2014/55/EU obliges public authorities and bodies of the Member States, in public procurement above EU thresholds, to accept electronic invoices compliant with the European Standard.
• On 8 December 2022, the European Commission published a legislative package composed of several pieces of legislation, around the “Proposal for a Council Directive amending Directive 2006/112/EC as regards VAT rules in the Digital Age”. This Commission proposal makes eInvoicing by default the rule in the EU starting 2028 and contains provisions on VAT reporting based on electronic invoicing for intra-community transactions and below - on decision by each Member State.
• In 2023, the European Commission has evaluated the effects of Directive 2014/55/EU on the internal market and uptake of e-Invoicing in public procurement. As foreseen in article 12 of Directive 2014/55/EU, the report was submitted to the European Parliament and to the European Council.

(A.3) References

• Directive 2014/55/EU of the European Parliament and of the Council on electronic invoicing in public procurement. Since April 2020, this Directive obliges public authorities and bodies of the Member States of the European Union to accept electronic invoices in public procurement, contracts above EU thresholds. These electronic invoices must comply with the European standard on electronic invoicing (EN 16931-1), and with any of the syntaxes on a limited list specified in CEN/TS 16931-2.
• Proposal for a Council Directive amending Directive 2006/112/EC as regards VAT rules in the Digital Age.
• 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) 223 — 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.
• 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
• Commission work programme 2022, Annex II, includes the “VAT in the digital age” initiative, which aims to modernise the current VAT rules, taking into account the opportunities offered by digital technologies. The initiative covers 1) VAT reporting obligations and e-Invoicing 2) VAT treatment of the platform economy and 3) single EU VAT registration.

Several European countries already introduced rules whereby public authorities only accept electronic invoices from suppliers, and all these initiatives will need to align with the standardisation activities carried out by CEN/TC 434 according to the Annex of the Standardisation Mandate M/528.

(B.) Requested actions and progress in standardisation

(B.1) Requested actions

The deliverables defined in Standardisation Mandate M/528 have been published. The European Standard EN16931-1 and its complementary technical specifications and reports are available. CEN/TC 434 should pursue work on ensuring that the European Standard is aligned with the most recent Commission policies, as the 2022 legislative proposals on VAT digital Reporting and discuss further follow up activities leading to wider adoption and implementation of eInvoicing / automated processes.

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

• ensure the EU standard is “fit for purpose” to serve a coherent eInvoicing policy in the EU, especially in line with the new requirements coming from the EU legislation for tax reporting based on eInvoicing
• maintenance activities
• preparation of the Amendment to the European Standard
• development of standardisation documents and tools 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
• development of a standard supporting e-receipts, based on the European Standard on electronic invoicing.
• following the market and technological evolution in eInvoicing, ensure an active link with the work on Blockchain, in liaison with CEN/CENELEC/JTC 19 on Blockchain and Distributed Ledger Technologies.

(C.) Activities and additional information

(C.1) Related standardisation activities

CEN

CEN/TC 434 — “Electronic Invoicing” — 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.

CEN/TC 445 — This CEN Technical Committee on Financial Services has published CEN/TS17901:2023, a standard for the electronic invoicing of insurance premiums, based on the European Norm16931-1. CEN/TC445 is also working on a standard for the digital portability of personal data in the insurance industry. This covers general data (e.g. name, birthdate, address, telephone, email, bank account, occupation) and business-specific data (e.g. those relevant to motor insurance, such as vehicle make/model, plate number, VIN, registration date etc.).”

“Digital information Interchange in the Insurance Industry” — has finalized the development of a new standard for the electronic invoice of the insurance premium, based on the standard invoice of EN16931-1. This standard FprCEN/TS 17901:2023 - Electronic Premium Invoice - Mapping to Electronic Invoice EN 16931-1 will be published at the beginning of 2024.

OASIS

The OASIS Universal Business Language (UBL) TC defines a common XML library of business document types supporting digitization of commercial and logistical processes for domestic and international supply chains. UBL includes document schemata that support eInvoicing. This also includes service location (BDXL 1.0) and capability lookup (SMP 2.0) that can be used together with a message protocol like AS4 (as used in the European Commission’s eDelivery Building Block and in OpenPeppol) and an Exchange Header Envelope schema (XHE 1.0).

UBL version 2.4 was published as OASIS standard in June 2024, and has been submitted to ISO/IEC JTC1 to be published as ISO/IEC standard. UBL versions 2.4, 2.3, 2.2 and 2.1 are backwards compatible. OASIS currently works on UBL version 2.5. UBL version 2.1 is used in OpenPEPPOL (see section C.2) and various member states, and is also published as ISO/IEC 19845:2015.

The Code List Representation (genericode) final v1.0 standard is a semantic model of code lists and accompanying XML serialization that can encode a broad range of lists of information elements such as country codes, abbreviations and lookup tables. This serialization, originally designed for e-invoicing message assembly and used (among other things) by UBL tools, enables automatic interchange or distribution of machine-readable code list information between systems, and so wider re-use of existing normalised categories and code tables.

The OASIS UBL TC also launched a Commodities subcommittee in 2024 to respond to demand for embedded sustainability and circularity data. See 3.4.13 Circular economy and sustainability (Section C.1). 

UNECE

The United Nations Centre 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.

ETSI

The ETSI Industry Specification Group on permissioned Distributed Ledgers and Distributed Ledger technology (SG PDL) has published Group Reports (GR) and Group Specifications (GS) for Smart Contracts and a Group Specification for Distributed Autonomous Organisations (DAO), among other subjects such as non-repudiation, redactability, digitial identity, etc… These address security and integrity related matters and may become relevant for e-invoicing, although this has not been specified yet. One of the publications potentially relevant for e-Invoicing is DGS/PDL-0026 ‘PDL in Settlement of Usage-Based Services’.

IEEE

IEEE Std 2142.1 - Recommended Practice for E-Invoice Business Using Blockchain Technology.

ITU

In 2022, ITU-T SG16 published Recommendation F.751.4 which provides a framework for electronic invoices based on distributed ledger technology (DLT).

(C.2) Other activities related to standardisation

OpenPeppol

OpenPeppol is an open non-profit organisation that provides specifications, practices and implementations for exchanging e-Invoicing documents. It builds on the specifications that were created by the European Large Scale Pilot (LSP) Peppol, which ran from 2008 until 2012. OpenPeppol does not only provide specifications, it also governs the Peppol network and implementations. Service Providers that are members of OpenPeppol provide standards-based networking services, which are overseen by National Peppol Authorities.

OpenPeppol aligns with the CEN standards for e-Invoicing wherever possible. This results in a Peppol network which is largely compatible with CEN standards. The Peppol Business Interoperability Standards (BIS) for eInvoicing is a Core Invoice Usage Specification (CIUS) of the European Norm 16931 for eInvoicing published by CEN/TC434.

Peppol is now supported by hundreds of service providers throughout Europe, servicing thousands of public and private organisations.