EU on the Internal Market and on the uptake of electronic invoicing in public procurement - Main contents

Please note

This page contains a limited version of this dossier in the EU Monitor.

dossier	COM(2024)72 - Effects of Directive 2014/55/EU on the Internal Market and on the uptake of electronic invoicing in public procurement.
document	COM(2024)72
date	February 19, 2024

agreements between service and solution providers generally include a clause that requires the safeguarding of client data and forbids its use for anything other than what is explicitly necessary and agreed upon. However, its use is not systematic.

In summary, the Directive remains relevant in addressing the challenges identified in 2014, which persist. However, the latest developments of eInvoicing created new challenges to be tackled in view of enhanced efficiency and harmonisation of electronic invoicing rules within the EU.

Impact of the Directive on the Internal Market, eInvoicing uptake and stakeholders

The implementation of the Directive and the adoption of the European eInvoicing standard have significantly contributed to the harmonisation and interoperability of electronic invoicing in Europe and to its uptake, as explained below. However, the Directive has been partially effective in fulfilling its objectives. Its two direct objectives are (i) the removal of market barriers and obstacles to trade deriving from the existence of differing national rules and standards and (ii) ensuring interoperability. In achieving these two objectives, the adoption of the European eInvoicing standard was a key element.

Regarding the first objective, the harmonisation of eInvoicing rules and standards in Europe was achieved to a certain extent by establishing a European standard for eInvoicing developed by CEN and endorsed by the Commission ¹⁹ in October 2017, and by creating the conditions for an Internal Market in public procurement. The European eInvoicing standard encompasses two interoperability levels, semantic and syntax, which were identified as challenges to intra-EU interoperability in 2014.

In regards to the second objective, the Directive imposed an obligation on Member States and their public authorities by requiring the public sector in the EU to accept and process eInvoices issued for contracts under EU Public Procurement Directives, if they are compliant with the European eInvoicing standard. In order to achieve this objective and, hence, ensure interoperability, the Directive required Member States to either establish systems for Business-to-Government (B2G) eInvoicing incorporating the European eInvoicing standard or to adapt their existing systems to accept electronic invoices compliant with the standard. For the central level, the capabilities are in place in 25 Member States and two Member States, Cyprus and Slovakia are still developing their national central platforms. For the sub-central level, it is not possible at this stage to fully check the implementation of the Directive, as only few Member States have created mechanisms to monitor eInvoicing implementation within their countries. Typically, these are Member States that have mandated their suppliers to send eInvoices to the public sector and have central monitoring tools in place, such as France, Italy and Spain.

One of Directive’s expected impacts on the Internal Market was to increase adoption of eInvoicing in a harmonised way throughout the EU. For the adoption of eInvoicing in general, the percentage of EU enterprises sending eInvoices (in general, not exclusively in B2G) has grown from approximately 10.3% in 2013 to 32.2% in 2020, based on a Eurostat survey of companies with more than 10 employees. Although the analysis faced limitations in terms of data availability and consistency since there is no reporting obligation for the Member States applicable under the Directive, data from Eurostat ²⁰, desk research and interviews with stakeholders have compensated for the shortcomings ²¹.

For the uptake in public procurement, the analysis revealed that B2G eInvoicing adoption has increased mainly in the Member States that introduced suppliers’ obligation to send eInvoices to the public sector, showing that voluntary adoption by the private sector can be challenging. In France, for example, where an obligation was introduced gradually between 2017 and 2020, 34 000 electronic invoices were received in 2013 versus 4.3 million in 2022 by the national authorities and 66.74 million by the sub-central authorities; in Spain, where the obligation was introduced in 2015, data gathered from the national platform showed an increase from 884 000 eInvoices in 2014 to 9.5 million in 2017 and 15.9 million in 2022 – data refer only to the central level. Mandating eInvoicing, which is the obligation for suppliers in B2G (only) to send exclusively electronic invoices to their national authorities has proved to have an effect on the general rate of adoption, including B2B, as the Eurostat data show that the number of enterprises using eInvoicing in Italy, Slovenia and Spain significantly increased in correlation to the time the obligations entered into force in each country, respectively in 2014 and 2015, reflected in 2016 Eurostat figures.

In the absence of a mandate for sending electronic invoices (either in B2G or B2B), the adoption level has increased slowly. According to the SMEs targeted consultation, the most efficient measure to increase adoption by businesses that are already using ERP and accounting software is to ensure that these solutions also include an eInvoicing functionality. This means that they can immediately be enabled to send and receive an eInvoice from their existing system without having to manually enter data, ensuring automation. This was already suggested by SMEs in the 2013 Impact Assessment ²² of the Directive, which shows that it is a critical factor for adoption of eInvoicing by SMEs. This is the policy chosen by Denmark, for example, with their recent Bookkeeping Act ²³.

For the Directive’s underlying objectives enshrined in its recitals and in the 2013 Impact assessment, they were partially fulfilled. The Directive aimed at fostering the Internal Market by addressing interoperability, increasing legal certainty, reducing legal complexity, and lowering the costs for economic operators. This was complemented by an operational objective: creating the conditions for the emergence of technical solutions for eInvoicing in public procurement to ensure interoperability.

The Directive primarily focused on addressing interoperability challenges related to semantic and syntax levels, but it did not tackle all four interoperability layers, including transmission and governance. The development of the European eInvoicing standard effectively tackled the semantic and syntax interoperability layers. Evidence of this is that, since the publication of the European standard in October 2017, the Directive has fostered the Internal Market by preventing the introduction of new national eInvoicing formats for the public sector (B2G), thus avoiding further fragmentation. Three Member States - Estonia, Finland and Sweden, have been gradually replacing their national standard with the European Standard. Other Member States, which mandated the use of a national standard before the introduction of the European eInvoicing standard, simply allow for the use of the European Standard. It is important to stress that, while transmission and governance have not been addressed by the Directive, in practice, interoperability across borders has been ensured by the implementation of Peppol-based solutions in 23 Member States. The Directive fostered the Internal Market by increasing legal certainty and reducing technical complexity for eInvoicing: it established a clear legal basis and set the European eInvoicing standard as the common standard to be supported by the entire EU public sector. Fourteen Member States out of the 21 that responded to the targeted survey, reported that the intervention had a positive impact on increasing legal certainty and reducing technical complexity ²⁴. About 80% of SMEs in the targeted survey perceived that national legal requirements for eInvoicing are clear and accessible and these requirements are mainly the result of the transposition of the Directive into national law.

The Directive, in its Article 2, established the definition of an electronic invoice which ensured legal clarity: “electronic invoice means an invoice that has been issued, transmitted and received in a structured electronic format which allows for its automatic and electronic processing”. Only structured invoices fit for automation are covered. The Directive also sets the requirements for the European eInvoicing standard, including technological neutrality, compatibility with international standards, suitability for commercial transactions between enterprises and support for the needs of SMEs, consistency with the relevant provisions of Directive 2006/112/EC ²⁵, etc.

Moreover, by addressing interoperability at the semantic and syntax level with the European standard, the Directive contributed further to reducing technical complexity. This is particularly true for public procurement, where suppliers have the opportunity to use the same standard for eInvoicing for all their public procurement procedures into the scope of EU public procurement in their own country and most importantly in all other EU countries.

The majority (66%) of the SMEs surveyed in the targeted stakeholder consultation for the evaluation view the European eInvoicing standard as a means of significantly simplifying intra-EU trade. In Finland, technical complexity is offset by improved automation and higher data quality provided by the use of the European eInvoicing standard which replaced the national eInvoicing format. However, as regards technical complexity, 41% of SMEs surveyed still experience technical challenges when using eInvoicing, while the others declare not facing challenges. These challenges include: Support for multiple eInvoicing formats, archiving for audit purposes, integration with service providers, data security and privacy concerns, interoperability with trading partners, infrastructure, and connectivity.

The Directive focused on addressing interoperability issues and providing the conditions for widespread use of eInvoicing compliant with the European standard but did not require its use by suppliers. As a result, enterprises must support multiple eInvoicing formats in Member States where a national standard is required for B2G transactions while using other formats for B2B transactions. The public sector essentially acts as a large buyer, imposing its requirements on suppliers.

For the specific objective of lowering operating costs for economic operators, the evaluation concluded that this depends mainly on the take-up of eInvoicing and its mass-adoption in two dimensions: firstly, on the prices of eInvoicing services and secondly, on the network effects, as the possibility to make use of these services with all business partners and for many other applications of eInvoicing. On the one hand, in general, companies have to acquire eInvoicing services or software, and the prices for the eInvoicing services are still relatively high. The results from the consultation activities targeting SMEs show that pricing per eInvoice transaction ranges from EUR 0.05 (when a EUR 2 500 set-up fee was part of the package) to EUR 0.30 (when an annual fee of EUR 550 was part of the package). It should be noted however that there is a considerable difference in pricing models or SMEs, in particular for those with very low invoicing models – in some exceptional cases, the price per eInvoice can be up to 10 euros. Operating costs for economic operators depend on the availability of cost-effective solutions and services. These are influenced by the number of eInvoicing transactions, formats supported, transmission protocols, number of countries in which the businesses operate as specialised support is required in each Member State that has defined specific formats and requirements.

On the other hand, the SMEs survey revealed that even when they acquired the respective software/service, a company fully reaps the benefits of its investment when it is able to profit from the network effects and use electronic invoicing with all its business partners, which is far from being the case. In addition, companies pointed out that they would maximise their benefits, also in terms of simplification or streamlining of reporting obligations, if they were able to use eInvoicing for further applications, as the VAT reporting introduced by the current ViDA legislative proposals or fulfilling their administrative obligations such as customs declaration, sustainability reporting, and when integrating other processes like electronic orders and despatch advice.

Mass adoption of eInvoicing would both allow lowering of fees for eInvoicing services, by creating competition between the numerous service and solutions providers in each Member State and maximising the benefits from using eInvoicing by default and for further applications.

As regards the operational objective of creating the conditions for the emergence of technical solutions for eInvoicing in public procurement, this was achieved in two manners. First of all, the Directive created the conditions directly by imposing an obligation on public authorities who either created systems or adapted their systems in order to be able to accept the European Standard, therefore, equipping themselves with the capabilities for interoperable eInvoicing. Despite the positive impact, challenges remain. The different implementation of the European standard in national eInvoicing platforms has led to compatibility issues, which are exacerbated by a lack of interoperability at the transmission level. An important challenge related to having more than one national eInvoicing platform mandated by the government (a platform for B2G and another one for B2B) remains in certain Member States. Monitoring technical developments and adoption of eInvoicing at the EU level also poses challenges due to the heterogeneity of procedures and requirements across EU Member States and to the absence of a monitoring obligation for Member States.

Secondly, since its adoption, the Directive facilitated and gave an impetus to the use of Peppol as a technical interoperable solution and network for eInvoicing between EU countries. Peppol is used in 23 Member States with common specifications, legal agreements, and a governance model.

Looking at the impact of the Directive on stakeholders, it appears that the different categories of stakeholders incurred different types of costs; national authorities, economic operators - amongst which service and solutions providers, SMEs or large corporations have been addressed separately. However, the reliability of the findings is contingent on the limited availability of data. The analysis of the efficiency of the Directive presented several limitations related to lack of data availability. As there is no obligation for Member States to report on eInvoicing transactions, only a few national authorities provided detailed information, and even fewer at the cross-border level. The evaluation thus relies primarily on stakeholder-reported data and data published on national authorities' portals.

Regarding the efficiency for public authorities the analysis of the costs and benefits shows a very varied situation from Member State to Member State. The benefits include operational efficiencies, improved transparency, and environmental benefits. Process automation is perceived as the main driver, followed by the use of the common standard, faster processing, and less complexity.

The costs associated with implementing the Directive's obligation for contracting authorities to receive and process eInvoices compliant with the European standard largely depend on the IT maturity level of the public sector: the higher the digital maturity, the lower the costs, as revealed by the targeted consultation of the national authorities. The costs specifically linked to the implementation of European standard vary depending on the existence of a national standard or technical specifications and the requirement to ensure interoperability with the European eInvoicing standard, but the highest costs are related to the establishment and maintenance of the national eInvoicing infrastructure.

To fulfil their obligations stemming from the Directive, some Member States had to create new systems, in certain cases national central systems, for eInvoicing in public procurement, ensuring that the implementation is fully covered at the central level. At the same time, they built their systems in order to support the European standard. Other Member States, those whose IT maturity level was higher, or they had a system for eInvoicing in place, had to modify their system/systems in order to make sure these were able to accept European standard-compliant electronic invoices. It happened either at the central level system or in the decentralised set-ups; all eInvoicing solutions for public procurement had to be adapted.

The costs for aligning with the European standard varied depending on whether a national standard already exists, as it needed to be adapted to comply with the European standard. Nine Member States incurred costs to ensure compliance of their existing national formats with the European standard, and three of them (Sweden, Finland, and Estonia) opted to completely replace their legacy formats with the European standard. The costs associated with ensuring national format compliance with the European standard vary per Member State, ranging from EUR 250 000 in Finland to approximately EUR 1.5 million in Poland and EUR 2.5 million in Italy (funded to a certain extent, in all cases, through CEF Telecom eInvoicing projects).

As mentioned above, the most significant costs are related to establishing and maintaining a national eInvoicing infrastructure, mainly involving software and hardware expenses, testing costs, training costs and administrative costs, which include: legal and solution analysis, publicity, user guides, support, security, audit, etc.

CEF funding, through the mechanism of grants managed by the EU, allowed Member States to cover their costs partially. Twenty-four Member States received a budget of 28.9 million for over 40 projects during the CEF telecom programme 2015-2020. These projects supported the creation of a central system or the adaptation to the European standard.

As regards the efficiency analysis for economic operators, the results of the consultation activities targeting SMEs show that costs vary depending on the eInvoice service package they selected and the volumes of eInvoices handled: 97% of the SMEs surveyed have purchased eInvoice packages at fixed yearly costs, while 3% SMEs purchased eInvoice packages with fixed costs and variable fees depending on transaction volumes. For companies, the lower the number of invoices, the higher the costs.

Free-of-charge packages for SMEs with basic eInvoicing functionalities are available in most of the Member States analysed. Nine Member States provide a free central system for sending eInvoices directly to public bodies.

However, according to SMEUnited, which responded to the targeted consultation, there are difficulties for SMEs inherent to their size and a lack of expertise on the subject. Therefore, these stakeholders make a plea that the deployment of the eInvoicing obligation needs to be gradual to allow meeting the obligations in the best conditions. As eInvoicing is considered to be quite expensive for SMEs, they need time to adapt their accounting system.

Multinational corporations surveyed in the targeted stakeholder consultation underpinning the evaluation of the Directive reported significantly high set-up costs for establishing eInvoicing in different EU Member States for both B2G and B2B. These costs are correlated to the need to use different service providers to cover specific national requirements. Recurring costs vary considerably.

Quantitative benefits from automating the invoicing process are estimated at around EUR 5.28 per eInvoice issued and EUR 8.4 per eInvoice received, considering the cost of labour per hour at EUR 46 ²⁶. Moreover, greater savings are achieved when automating the entire order-to-pay cycle, including orders, transport documents, invoices, and payment notices. Automating these processes allows for consistent electronic document exchange and enables automated reconciliation, resulting in benefits estimated between EUR 25 and EUR 65 per purchase-to-pay cycle ²⁷.

Coherence with other EU policies and EU added value

To support the creation of the Digital Single Market for eInvoicing, the Directive needed to be coherent with all other EU policies, mainly those targeting digitisation. The coherence of the Directive has been evaluated on two main levels: internal and external coherence. Internal coherence examines how the different components of the EU intervention work together, while under external coherence, the analysis looks into how the Directive is aligned with a few EU policy initiatives, legislative and non-legislative: 2014 Public Procurement Directives ²⁸, Late Payment Directive ²⁹ and 2023 proposal for a Regulation repealing the current Late Payment Directive ³⁰, 2022 VAT in the Digital Age (ViDA) legislative proposals, European Interoperability Framework (EIF)³¹, Connecting Europe Facility (CEF) eInvoicing and eDelivery Building Block ³² and the Commission policy work on the global dimension of eInvoicing and the promotion of the EU model.

For the internal coherence, the Directive is coherent with the subsequent work on the European eInvoicing standard as all the requirements of the Directive have been satisfied. First, the Directive called for the creation of a European standard for the semantic data model of core elements in an electronic invoice and listed a list of mandatory elements to be included. Secondly, it required a limited number of syntaxes and only two syntaxes were identified by CEN and published in 2017 together with the standard. Additionally, non-binding guidelines for eInvoicing transmission were created together with the European standard to ensure further interoperability. These requirements have been successfully reflected in CEN deliverables, confirming the coherence between legislative objectives and standard development. Furthermore, consistency is also ensured with the standardisation work that CEN TC434 is undertaking as regards e-Receipt. As to the establishment and the work of the European Multi-Stakeholder Forum on eInvoicing (EMSFEI) to support EU policy work on eInvoicing, between 2014 and 2020, all EMSFEI's deliverables complemented and supported the implementation of European standard, addressing potential interoperability challenges.

In terms of external coherence, the Directive is well-aligned with various EU policies promoting the digitisation of public procurement and related activities. The Directive is aligned with the 2014 Public Procurement Directives, being an integrated part of the legislative package in pursuing the same objective of digitisation of public administration in a harmonised way, and it is also aligned with public procurement standardisation objectives.

There is a strong link between the Directive and the 2022 Commission VAT in the Digital Age (ViDA) legislative proposals ³³ as regards the role of eInvoicing. The proposal aims to modernise the EU VAT system, addressing challenges related to the platform economy and introducing a single VAT registration to avoid multiple registrations within the EU. Furthermore, it will implement a reporting system for VAT for EU cross-border transactions, which will be based on eInvoicing and on the European eInvoicing standard, while requiring Member States that want to put in place a VAT reporting system for domestic transactions to also base it on eInvoicing. As part of the proposal, eInvoicing is set to become the default invoicing method by January 2028.

The coherence between the Directive and ViDA is ensured with the current draft legislative proposals, which are, however, subject to evolution during the adoption process. The ViDA proposals are an opportunity to ensure alignment on the EU definition of electronic invoicing in the VAT legislation and in the Directive. The ViDA’s new definition of electronic invoicing is consistent with the one included in the Directive. This alignment ensures coherence across various EU policies and facilitates the smooth implementation of eInvoicing initiatives within the EU.

Furthermore, the Directive focuses specifically on B2G eInvoicing and aligns in its current main lines with the ViDA proposal, which targets B2B eInvoicing. Ultimately, the ViDA proposals complement the eInvoicing Directive, especially in ensuring harmonisation and interoperability in cross-border eInvoicing in B2G and B2B transactions, allowing the reduction of administrative burden, and fostering convergence towards the European eInvoicing standard, as also stressed in the 2023 Rolling Plan for ICT standardisation ³⁴.

The implementation of eInvoicing and the Directive is coherent with the provisions of the revised the Late Payment Directive and 2023 proposal for a Regulation repealing the current Late Payment Directive, as it automates the approval process for eInvoices, streamlining payment procedures and ensuring timely payments.

As regards the European Interoperability Framework (EIF), the eInvoicing Directive effectively addresses interoperability at both the semantic and syntax layers, as the EIF foresees. It has not addressed, however, all four layers of interoperability, including transmission and governance, which would have further facilitated interoperability.

The eDelivery Building Block was developed in parallel and in a consistent manner with the eInvoicing Building Block package of services under CEF. While the eInvoicing Building Block provided essential tools to facilitate and validate compliant implementations of the European eInvoicing standard in IT systems and services, the eDelivery Building Block provided technical specifications and standards, installable software, and ancillary services to create a network of nodes for the exchange of eInvoices, as well as other secure digital data exchanges. Some eInvoicing solutions used eDelivery as a transmission method.

In addition, the current activities carried out by the Commission with its international partners are coherent with the Directive, both in the formal negotiations and during bilateral dialogues. The EU-model PINT (Peppol-based) has been adopted in several countries outside of the EU, including Australia, Japan, Malaysia, New Zealand, and Singapore. As regards U.S., the eInvoicing exchange frameworks in the EU and the U.S. have a considerable degree of compatibility. The U.S. profiles of the eInvoice were modelled after the European standard purposefully to ensure a high degree of alignment to support interoperability while meeting U.S. business market requirements. Similarly, Taiwan and the EU started a regulatory dialogue on eInvoicing in July 2023.

Lastly, the Directive aligns with the overall European standardisation policy by supporting the development and maintenance of the European eInvoicing standard, funded by the Commission.

As regards EU added value, there is a broad consensus among EU Member States that the Directive has improved the functioning of the Internal Market since its adoption in 2014.

From the perspective of national authorities, the main EU contribution consists in reducing barriers in cross-border public procurement, by limiting the emergence of various national eInvoicing standards. The Directive required public administrations throughout the European Union to receive and process eInvoices issued under contracts subject to EU Public Procurement directives, provided they comply with the European e-invoicing standard. This Directive-induced action has not only prevented the fragmentation of the internal market but has also fostered EU-wide eInvoicing interoperability.

Beyond its immediate impact within the public procurement sphere, the Directive has played a pivotal role in promoting further harmonisation of eInvoicing solutions and set-ups in the B2B context. By establishing a common foundation for eInvoicing standards and practices within the EU, the Directive has encouraged developments in B2B, where the EU standard will be reused under the ViDA proposals. For this purpose, the European eInvoicing standard is due to evolve to cover all use cases and meet the needs of specific sectors. The CEN Technical Committee TC434 is responsible to make sure that the European standard will be fit for purpose by the end of 2024.

Finally, the Directive is considered to have generated international added value by promoting global interoperability. This is exemplified by the adoption of the Peppol Interoperability Framework outside the EU, including in countries such as Australia, Japan, Malaysia, New Zealand, and Singapore, further extending the positive impacts of the Directive.

CONCLUSIONS

Under the Directive, significant achievements were made towards the removal of Internal Market barriers and obstacles to trade deriving from the existence of differing national eInvoicing rules and standards.

For this reason, the Directive’s impact was assessed as positive considering its effects in terms of cross-border interoperability and uptake of eInvoicing in public procurement. The main expected impact of the Directive - interoperability - was improved, as eInvoices compliant with the European eInvoicing Standard need to be accepted by all public buyers. This, in turn, was led to its second expected effect, namely an increased uptake of eInvoicing.

The EU's intervention in eInvoicing for public procurement supported harmonisation and interoperability across technical requirements and standards, preventing further fragmentation within the Internal Market. Interoperability has been achieved at the semantic and syntax levels through the creation of a European eInvoicing Standard. However, the implementation of the Directive by the Member States showed that addressing interoperability at the transmission level is a critical element for full interoperability.

The increase of eInvoicing uptake in Europe was the expected second impact of the Directive. The availability of a European standard and obligation to accept compliant eInvoices on public authorities were expected to significantly increase the uptake of eInvoicing, depending however on business decisions. For public procurement, the findings showed that 100% eInvoicing adoption is (or is to be) achieved only in the Member States that mandated B2G eInvoicing to their suppliers or in digitally mature Member States. The uptake of eInvoicing in general has increased but it does not yet represent the majority of transactions.

Overall, the Directive on eInvoicing has provided significant value at EU level but challenges still exist. Further efforts to stimulate the uptake of eInvoicing within the EU, and to foster interoperability are therefore needed.

1 SWD(2024)39

2 Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on electronic invoicing in public procurement, OJ L 133, 6.5.2014. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0055

3 Enterprise Resource Planning is a business process management software that allows an organisation to use a system of integrated applications to manage the business and automate many back-office functions such as procurement, production, technology, accounting and support services, and human resources.

4 COM/2012/0179 final, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, A strategy for e-procurement. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=COM:2012:0179:FIN

5 COM(2010)245 final, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, A Digital Agenda for Europe, 19.5.2010. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0245:FIN:EN:PDF

6 COM (2010) 712, final Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Reaping the benefits of electronic invoicing for Europe, 2.12.2010. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0712:FIN:en:PDF

7 https://data.consilium.europa.eu/doc/document/ST-76-2012-INIT/en/pdf

8 https://peppol.org/

9 The European standard on eInvoicing was developed by CEN and published by the European Commission,

It defines the core business terms of an electronic invoice in a semantic data model. https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/Compliance+with+eInvoicing+standard

10 The European standard on eInvoicing addresses the issue of transmitting the eInvoices with a guidelines report. The guidelines support implementers in selecting and designing transmission solutions. https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/Navigating+the+eInvoicing+standard+documentation

11 Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of procedures for the award of certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, and amending Directives 2004/17/EC and 2004/18/EC (Text with EEA relevance), OJ L 216, 20.8.2009, p. 76–136.

12 Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award of concession contracts Text with EEA relevance, OJ L 94, 28.3.2014, p. 1–64.

13 Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC, OJ L 94, 28.3.2014.

14 Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities operating in the water, energy, transport and postal services sectors and repealing Directive 2004/17/EC, OJ L 94, 28.3.2014, p. 243–374.

15 https://taxation-customs.ec.europa.eu/taxation-1/value-added-tax-vat/vat-digital-age_en

16 PINT is the specification that implements the Peppol BIS billing for use in Europe. It describes the use of the invoice and credit note messages in Peppol, and facilitates an efficient implementation and increased use of electronic collaboration. https://test-docs.peppol.eu/pint/pint-eu/pint-eu/bis/

17 The results of the National Authorities survey conducted during the Study preparing the Evaluation, see SWD(2024)39.

18 SWD(2024)39

19 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 of the European Parliament and of the Council (Text with EEA relevance), C/2017/6835, OJ L 266, 17.10.2017, p. 19–21.

20 The data represented in this section are an elaboration of the following Eurostat’s dataset: ISOC_EB_ICS.

21 SWD(2024)39

22 SWD(2013) 222 final, Commission Staff Working Document, Impact Assessment accompanying the document Proposal for a Directive of the European Parliament and of the Council on electronic invoicing in public procurement, 26.6.2013. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2013:0222:FIN:EN:PDF

23 Bill on the Danish Bookkeeping Act (danishbusinessauthority.dk)

The Danish parliament passed the Bookkeeping Act on May 19th, 2022, initially stated to take effect on July 1st, 2022. The Act mandates all companies of all sizes to issue, receive, process, and archive invoices electronically.

24 SWD(2024)39 .

25 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, OJ L 347, 11.12.2006.

26 European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, Ciciriello, C., Gray, E., Preparatory study on the effects of the Directive 2014/55/EU on electronic invoicing in public procurement, Publications Office of the European Union, 2024, https://data.europa.eu/doi/10.2873/27631

27 https://www.corrierecomunicazioni.it/digital-economy/polimi-da-fattura-elettronica-risparmi-per-3-miliardi/

28 Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of procedures for the award of certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, and amending Directives 2004/17/EC and 2004/18/EC

Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award of concession contracts Text with EEA relevance

Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 2004/18/EC

Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities operating in the water, energy, transport and postal services sectors and repealing Directive 2004/17/EC

29 Directive 2011/7/EU of the European Parliament and of the Council of 16 February 2011 on combating late payment in commercial transactions (recast), OJ L 48, 23.2.2011, p. 1–10.

30 Proposal for a regulation of the European Parliament and of the Council on combating late payment in commercial transactions. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52023PC0533(01)

31 https://ec.europa.eu/isa2/eif_en/

32 https://joinup.ec.europa.eu/collection/digital-building-blocks/solution/edelivery/about

33 COM/2022/701 final, Proposal for a COUNCIL DIRECTIVE amending Directive 2006/112/EC as regards VAT rules for the digital age, 8.12.2022. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A701%3AFIN

34 e-Invoicing (RP2023) | Joinup (europa.eu)

EN EN