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
Date: 2010-12-02
Institutions: European Commission
Subjects: VAT, distributive trades, provision of services, tax exemption, tax harmonisation, tax on consumption, tax relief

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EUROPEAN COMMISSION 

Brussels, 2.12.2010 
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 

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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 

1. 

INTRODUCTION 

The Europe 2020 strategy1 sets out a vision of a highly competitive European social market 
economy for the 21st century and emphasises that it is crucial to reap the full economic and 
social benefits of a digital society. To this end, electronic invoicing (e-invoicing) is part of the 
European  Commission’s  flagship  initiative  A  Digital  Agenda  for  Europe2  which  gives 
prominence to achieving a  single digital  market  and  calls  for  removal  of  the  regulatory  and 
technical barriers that prevent mass adoption of e-invoicing. 

To the detriment of consumers and enterprises alike, the existing rules that govern e-invoicing 
in Europe are still fragmented along national lines and most of the potential of e-invoicing is 
still  untapped.  What  is  more,  exchanging  e-invoices  is  still  too  complex  and  costly,  in 
particular  for  SMEs.  While  42 %  of  large  enterprises  say  they  receive  or  send  e-invoices, 
adoption rate among SMEs remain at a lower level (22 %)3.  As  a  result  the  average  market 
penetration of e-invoicing remains rather low in Europe and is currently estimated at around 
5 % of all invoices annually exchanged4 for Business to Business relations. 

This  creates  important  opportunities  for  improvement.  The  mass  adoption  of  e-invoicing 
within  the  EU  would  lead  to  significant  economic  benefits  and  it  is  estimated  that  moving 
from  paper  to  e-invoices  will  generate  savings  of  around  EUR 240 billion  over  a  six-year 
period5.  Furthermore,  due  to  the  close  link  between  invoicing  and  payment  processes,  the 
creation  of  the  Single  Euro  Payments  Area  (SEPA)  offers  a  launch  pad  for  interoperable 
European e-invoicing schemes. 

The  Commission  wants  to  see  e-invoicing  become  the  predominant  method  of  invoicing  by 
2020  in  Europe.  The  Commission  is  committed  to  working  in  close  cooperation  with  the 
Member States  and  all  other  stakeholders  who  will  need  to  play  their  part  to  achieve  this 
target and create the right environment for the widespread deployment of e-invoicing. 

Accordingly, this Communication addresses the following priorities: 

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to ensure legal certainty and a clear technical environment for e-invoices to facilitate 
mass adoption 

COM(2010) 2020, http://ec.europa.eu/eu2020/index_en.htm. 
COM(2010) 245, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM: 2010:0245:FIN:EN:PDF. 
Enterprises sending and/or receiving e-invoices, Eurostat, 2009. 
E-invoicing – E-billing in Europe, Billentis, 2009. 
SEPA potential benefits at stake, Capgemini, 
http://ec.europa.eu/internal_market/payments/docs/sepa/sepa-capgemini_study-final_report_en.pdf. 

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– 

– 

to  encourage  and  promote  the  development  of  open  and  interoperable  e-invoicing 
solutions  based  on  a  common  standard,  paying  particular  attention  to  the  needs  of 
SMEs 

to support the uptake of e-invoicing by setting up organisational structures, such as 
national e-Invoicing fora and a European Multi-Stakeholder Forum. 

2. 

BENEFITS FROM ELECTRONIC INVOICING 

Unlike  paper-based  invoices,  e-invoices  provide  all  data  in  digital  format.  Such  e-invoicing 
offers  substantial  benefits  over  paper  invoicing. It  allows  for  shorter  payment  delays,  fewer 
errors, reduced printing and postage costs and, most importantly, fully integrated processing. 
One distinctive feature of the e-invoice is therefore its potential for automation, especially if 
the  invoice  is  sent  in  a  structured  format:  e-invoices  can  be  generated  and  transferred 
automatically  and  directly  from  the  issuer’s  or  service  provider’s  financial  supply  chain 
systems to those of the recipient. Most of the economic benefits therefore do not arise from 
savings  in  printing  and  postage  costs  but  rather  from  the  full  process  automation  and 
integration from order to payment between trading parties. 

Furthermore, applying equal VAT rules on electronic and paper invoices is expected to reduce 
administrative burden on enterprises by up to a maximum of EUR 18 billion in the medium 
term as pointed out by the High Level Group on Administrative Burden6. 

Benefits from e-invoicing are also expected to affect consumers, in particular with regard to 
the convenience aspects of e-invoices in comparison with paper invoices. It should however 
be ensured that consumers with limited or no access to the internet should not be left behind 
and that consumers  should always  be allowed to ask for a paper invoice. In addition and in 
accordance with the EU Charter on Fundamental rights, e-invoicing should comply with the 
protection of personal data and the right of private life. 

Finally, the environmental benefits of e-invoicing in terms of reducing paper consumption and 
energy  costs  for  transportation  are  also  significant,  generating  carbon  savings  which  could 
amount to reductions in CO2 emissions of 1 million tonnes per annum7 for the EU. 

3. 

INVOLVING STAKEHOLDERS 

Responding to market needs and the calls of stakeholders, the European Commission set up 
an Expert Group on e-invoicing to look at the barriers impeding a faster uptake of e-invoicing 
within  the  EU.  At  the  end  of  2009,  the  Expert  Group  published  its  final  report,  including 
a proposal for a European Electronic Invoicing (EEI) Framework8. 

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COM(2009) 15, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2009:0015:FIN:EN:PDF. 
This is an extrapolation based on a study from the Department of Environmental Strategies research at 
the  Royal  Institute  of  Technology  in  Sweden,  estimating  the  total  effect  of  replacing  paper  with 
electronic invoices would lead to annual carbon reductions corresponding to 39°000 tot 41°000 tons of 
CO2-equivalents per year. 
Final Report of the Expert Group on Electronic Invoicing, 
http://ec.europa.eu/internal_market/consultations/docs/2009/e-invoicing/report_en.pdf. 

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Their main recommendations can be summarised as follows: 

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Meeting  the  needs  of  SMEs  as  a  priority  focus,  by  concentrating  on  a  number  of 
specific business requirements. 

The harmonisation of and the provision of clarity for the legal and VAT framework 
across  the  EU  on  the  basis  of  equal  treatment  between  paper  and  e-invoices  and 
supported by a Code of Practice prepared by the Expert Group. 

The  creation  of  an  e-invoicing  eco-system  that  provides  maximum  interoperability 
and reach. 

The  adoption  by  all  actors  within  both  the  private  and  public  sector  of  a  common 
invoice content standard and data model – the UN/CEFACT Cross-Industry Invoice 
(CII) v.2. 

The  establishment  of  an  organisational  process  for  implementation  of  the  EEI 
Framework at Member State and EU level. 

The  report  was  subject  to  a  public  consultation9  enabling  all  stakeholders  to  react  to  the 
proposed  recommendations.  The  majority  of  respondents  agreed  with  the  report’s  main 
messages, recommendations and conclusions. 

The stakeholder consultation process was concluded with a major conference on the topic of 
e-invoicing in Europe10 held under the auspices of the Spanish Presidency of the Council on 
27 and 28 April 2010 in Madrid. The conference also validated the recommendations of the 
Expert Group whose proposals were globally supported. 

4. 

LANDSCAPE OF ELECTRONIC INVOICING IN THE EUROPEAN UNION 

4.1. 

Adoption rate of electronic invoices 

To  date,  adoption  rates  of  e-invoices  are  relatively  low  and  vary  widely  among 
Member States. While 23 % of enterprises say they receive or send e-invoices11 (ranging from 
8 %  to  41 %  in  EU27),  the  number  of  exchanged  structured  e-invoices  still  remains  low, 
particularly among SMEs. 

On the supply side, the e-invoicing market is largely fragmented. More than 400 e-invoicing 
service  providers  are  active  in  the  EU  mainly  at  domestic  level,  offering  a  wide  variety  of 
e-invoicing business models. 

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11 

The summary of responses to the public consultation, 
http://ec.europa.eu/enterprise/newsroom/cf/document.cfm?action=display&doc_id=5814&userservice_i
d=1&request.id=0. 
http://ec.europa.eu/enterprise/sectors/ict/e-invoicing/benefits/conference_electronic_invoicing_en.htm 
Enterprises sending and/or receiving e-invoices, Eurostat, 2009, 
http://epp.eurostat.ec.europa.eu/tgm/graph.do?tab=graph&plugin=0&language=en&pcode=tin00114. 

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In  some  Member States12,  public  sector  initiatives  have  emerged  or  are  emerging,  to  make 
e-invoicing  mandatory  for  public  procurement.  These  projects  are  critical  to  accelerate  the 
market  penetration  of  e-invoicing.  At  European  level,  the  Commission  has  launched  the 
PEPPOL  project13  (Pan-European  Public  Procurement  On-line)  which  aims  to  make 
electronic  communication  between  enterprises  (including  SMEs)  and  government  bodies 
possible throughout the EU for all procurement processes, including the exchange of invoices. 
The  developed  interoperable  e-invoicing  solution  could  be  reused  also  beyond  public 
procurement in the business to business context. 

4.2. 

E-invoicing in the Single Euro Payments Area (SEPA14) 

Invoices  represent  just  one  step  in  the  overall  purchase-to-pay  financial  supply  chain.  In 
particular by virtue of the close link between invoices and payments, it is important to embed 
e-invoicing in the wider context of an integrated electronic payments market. The creation of 
a single integrated euro payments area which has been strongly supported by the Commission 
from the outset facilitates the linking of invoicing and payment processes. 

While SEPA and e-invoicing are distinct projects, they are nevertheless mutually beneficial. 
SEPA could create a launching path for a successful e-invoicing initiative by promoting full 
process integration across the financial supply chain and mass adoption of e-invoicing could 
benefit SEPA migration due to the close link between payments and invoices. 

SEPA aims at end-to-end straight-through-processing of payments. This eliminates the need 
thereby  creating  substantial  economic  benefits.  Therefore, 
for  manual 
an e-invoice  standard  should  be  coherent  with  the  ISO  20022  financial  services  messaging 
standard, which is being used in the context of SEPA. 

intervention, 

4.3. 

Current  legal  and  technical  environment  for  electronic  invoices  and  potential 
burdens for adoption 

4.3.1.  Legal aspects 

4.3.1.1.  VAT and rules on electronic invoicing 

Through  the  options  available  to  Member States,  the  legal  provisions  currently  in  force  on 
VAT  regarding  e-invoicing  within  the  EU  have  produced  a  disjointed  set  of  requirements. 
This  has  created  complexity  for  trading  parties  wishing  to  use  e-invoicing  solutions, 
especially for enterprises which operate across borders. 

However,  on  13  July  2010  the  Council  adopted  Directive  2010/45/EU  amending  Directive 
2006/112/EC on the common system of value added tax as regards the rules on invoicing15. 
This  Directive,  which  will  be  transposed  by  1  January  2013,  sets  out  new  VAT  rules  as 
regards e-invoicing and removes the obstacles to the uptake of e-invoicing by creating equal 
treatment between paper and e-invoices, while also ensuring that no additional requirements 

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Initiatives have emerged in Denmark, Finland, Italy, Spain, Sweden to make e-invoicing mandatory for 
public  authorities  under  distinct  timeframes.  Final  Report  of  the  Expert  Group  on  e-Invoicing,  2009, 
pp. 15-16, http://ec.europa.eu/internal_market/consultations/docs/2009/e-invoicing/report_en.pdf. 
Further information on this initiative on www.peppol.eu. 
http://ec.europa.eu/internal_market/payments/sepa/index_en.htm 
Directive 2010/45/EU, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:189:0001:0008:EN:PDF. 

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are imposed on paper invoices. According to the new Article 233 of the Directive, businesses 
will be free to send and receive e-invoices providing they maintain "business controls which 
create a reliable audit trail between an invoice and a supply of goods or services" in the same 
way as is currently done for paper invoices. 

4.3.1.2.  Other legal aspects 

Apart from legislation on VAT, e-invoicing is embedded in a patchwork of legal requirements 
which cover rules on accounting, auditing, protection of personal data, archiving and customs. 
While VAT is generally considered a key hurdle, it is necessary to identify if these other legal 
rules constitute further barriers to the uptake of e-invoicing within the EU. 

Some  e-invoicing  solutions  make  use  of  electronic  signatures  (e-signatures).  However,  the 
diversity of legal requirements among Member States for e-signatures have led to cross border 
interoperability  problems  which  contributed  to  slow  down  the  uptake  of  cross-border 
e-invoicing solutions in so far as they make use of e-signatures. Despite the positive impact of 
existing legal provisions on the use of e-signatures and the political commitments taken by the 
Member States  and  the  Commission,  a  more  coordinated  and  comprehensive  approach  is 
needed to facilitate the EU-wide cross-border interoperability of e-signatures. To this end in 
the  framework  of  the  Digital  Agenda,  the  Commission  proposed  to  revise  the  current 
Directive 1999/93/EC 16 on e-signatures. 

4.3.2. 

Interoperability and reach 

Interoperability of e-invoicing solutions provides trading parties with the ability in practice to 
exchange  e-invoices  across  multiple  technologies  and  organisational  boundaries,  based  on 
common legal requirements, business processes and technical standards. 

The  lack  of  interoperability  between  distinct  business  models  and  solutions  entails  the  risk 
that  enterprises  and  especially  SMEs  may  need  to  invest  in  multiple  systems  and  solutions 
when  exchanging  e-invoices.  This  leads  to  unnecessary  costs  and  further  hampers  mass 
adoption.  By  means  of  interoperable  e-invoicing solutions, it will be possible to create over 
time  a  number  of  interconnected  and  interoperable  networks  where  a  maximum  number  of 
trading parties can be reached. 

4.3.3. 

Standards 

In the current environment, there is no globally used standard for e-invoicing. The diversity of 
data and usage requirements, and very different approaches to their implementation, have led 
to market fragmentation. 

None  of  the  existing  formats  has  so  far  achieved  dominance.  Electronic  Data  Interchange 
(EDI17) which is still used by many multinational companies is often impractical for the mass 
of  SMEs.  Likewise  many  proprietary  formats  are  only  used  by  one  multinational  company 
and its suppliers. As a consequence, market players, such as enterprises, software companies 
and financial service providers nowadays need to support multiple formats, necessitating the 

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Directive 1999/93/EC, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:013:0012:0020:EN:PDF. 
Commission Recommendation 1994/820/EC, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31994H0820:EN:HTML. 

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need  for  substantial  mapping  and  conversion  exercises  to  cope  with  data  expressed  in 
different syntaxes. 

Several  international  and  European  standardisation  organisations  are  currently  working  on 
e-invoicing  standardisation.  At  international  level,  the  United  Nations  Centre  for  Trade 
Facilitation  and  Electronic  Business  (UN/CEFACT)  has  developed  and  is  maintaining  the 
Cross-Industry  Invoice  (CII)  standard  and  data  model,  and  has  cooperated  with  the 
Organisation  for  the  Advancement  of  Structured  Information  Standards  (OASIS),  for  the 
convergence between the Universal Business Language (UBL) invoice and the CII standard. 
Moreover,  UN/CEFACT 
for 
Standardisation) for the integration of the CII data model in the ISO 20022 Invoice message. 
At European level, the European Committee for Standardization (CEN) is running a number 
of workshops on specific e-invoicing implementation issues18. 

(International  Organisation 

is  cooperating  with 

ISO 

5. 

A STRATEGY TO FOSTER THE UPTAKE OF ELECTRONIC INVOICING 

5.1. 

Key priorities to promote e-invoicing within the EU 

On the basis of the recommendations of the Expert Group and the conclusions of the public 
consultation, the Commission proposes to support the mass uptake of e-invoicing by focusing 
on the following four key priorities. 

5.1.1.  Ensure a consistent legal environment for e-invoicing 

As  of  1  January  2013,  new  VAT  rules  on  e-invoicing  provided  for  by  Council  Directive 
2010/45/EU will require Member States to adhere to the principle of equal treatment between 
paper and e-invoices. Member States will no longer be allowed to add specific requirements 
such as insisting that e-invoices be based on advanced electronic signatures or EDI. Instead 
these  technological  choices  will  become  options  which  can  still  be  used,  as  can  business 
controls,  by  businesses  to  guarantee  the  'authenticity  of  the  origin'  and  the  'integrity  of  the 
content' of e-invoices. 

Any  differences  in  the  interpretation  and  subsequent  transposition  of  the  rules  by 
Member States  could  present  practical  difficulties  for  the  use  of  e-invoices.  This  could 
increase  burdens  and  compliance  costs  on  business,  thereby  restricting  the  uptake  of 
e-invoicing. Therefore, the Commission will work closely with the Member States to ensure 
a common  understanding  of  the  new  e-invoicing  rules  to  help  achieve  a  consistent  and 
coherent transposition of the Directive 2010/45/EU. 

Actions: 

1.1 

To  ensure  a  consistent  and  timely  transposition  of  the  new  VAT  Directive,  the 
Commission  will  organise  a  Fiscalis19  seminar,  involving  all  Member States’  tax 

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The CEN Workshop on e-Invoicing set up the E-Invoice Gateway (http://www.e-invoice-gateway.net), 
an independent portal that provides guidance and country-related information on e-invoicing. 
Fiscalis  2013  is  an  EU  cooperation  programme  enabling  national  tax  administrations  to  create  and 
exchange information and expertise, for more information: 
http://ec.europa.eu/taxation_customs/taxation/tax_cooperation/fiscalis_programme/fiscalis2013/index_e
n.htm. 

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administrations in February 2011. After this, the Commission will assess the need for 
further guidance to Member States and businesses. 

1.2 

1.3 

1.4 

To  anticipate  the  principle  of  equal  treatment  as  laid  down  in  the  new  VAT 
Directive;  Member States  are  called  upon  to  allow  invoices  to  be  sent  and  made 
available  by  'other  electronic  means'  as  provided  for  in  Article  233  of  the  current 
VAT Directive (2006/112/EC). 

An  external  study  for  the  Commission  is  looking  at  alternative  VAT  collection 
methods  including  the  role  of  e-invoicing.  The  Commission  will  present  these 
findings and publish before the end of 2010 a Green Paper on the future of VAT to 
stimulate  debate  on  issues  such  as  how  the  new  developments  in  IT  technologies 
could facilitate VAT collection. 

The Commission will propose in 2011 a revision of the Directive (1999/93/EC) on 
e-signatures with a view to providing a legal framework for cross-border recognition 
and interoperability of secure e-authentication systems. 

5.1.2.  Achieve mass market adoption by reaching Small and Medium-sized Enterprises 

The  objective  of  fostering  the  uptake  of  e-invoicing  in  the  EU  cannot  be  achieved  without 
SMEs which represent more than 99 % of European businesses. While many large enterprises 
already  use  e-invoices,  the  adoption  level  by  SMEs  remains  relatively  low.  The  Small 
Business Act20 committed the EU to the 'Think Small First' principle, i.e. to focus on the needs 
of SMEs. This should also apply to the e-invoicing market, which should offer simple, cheap, 
reliable and VAT-compliant solutions to SMEs. 

Small  enterprises  work  with  many  different  trading  parties  (large  enterprises,  consumers, 
public  authorities,  other  SMEs)  who  may  require  them  to  use  e-invoicing  according  to 
different technical solutions. The development of interoperable processes and standards along 
the supply chains, including e-invoicing, will facilitate mass adoption by SMEs. To increase 
the  participation  of  SMEs  in  digital  supply  chains,  the  Commission  supports  large-scale 
demonstration  actions  in  industry  and  service  sectors  (fashion,  automotive,  transports  and 
logistics). These projects aim to improve business transactions and contribute to the increase 
of innovation capacity and competitiveness of enterprises. 

Therefore, it is not only important that small businesses are prepared internally (in terms of 
knowledge  and  infrastructure)  for  this  transition  but  also  that,  externally,  the  e-invoicing 
service  providers  develop  services  and  solutions  that  require  a  low  investment  in 
infrastructure  and  skills  so  that  e-invoicing  enables  SMEs  to  improve  efficiency  and  create 
operational savings. 

The Commission considers that the following actions will help SMEs to reap the full benefits 
of the dematerialisation of invoices. 

Actions: 

20 

COM(2008) 394, 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0394:FIN:EN:PDF. 

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2.1 

2.2 

2.3 

The Commission will thoroughly assess the effect of any future technical and legal 
requirements for e-invoicing on SMEs by applying the 'Think Small First' principle 
and  the  'SME  test'  and  expects  Member States  and  standardisation  organisations  to 
do the same. 

The  Commission  will  organise  and  participate  in  awareness-raising  activities  to 
inform SMEs about the potential of e-invoicing. Synergies with existing promotional 
activities (e.g. the European SME week, E-skills week) and networks (e.g. European 
e-Business Support Network, European Enterprise Network) will be explored. 

The Commission will continue and expand initiatives that promote the participation 
of SMEs in digital supply chains. In 2011, two new actions will be launched in the 
framework of the Competitiveness and Innovation Programme (CIP). 

5.1.3. 

Stimulate an environment that creates maximum reach 

It  is  vital  to  create  an  environment  that  enables  a  maximum  number  of  trading  parties  to 
exchange  invoices  to  ensure  the  mass  uptake  of  e-invoicing.  While  actions  currently  under 
way  will  improve  interoperability  of  e-invoices,  the  Commission  sees  the  need  for  further 
actions at the organisational and technical level21. Major progress on these recommendations 
should be achieved before the transposition deadline of the VAT Directive (1 January 2013). 

First, clear roles and responsibilities of trading parties and service providers as regards inter-
operability  at  organisational  level  should  be  defined  and  adopted  by  market  participants 
through  a  Code  of  Practice.  Furthermore,  the  adoption  and  use  of  unambiguous  and  widely 
recognised  identifiers  and/or  addresses  of  trading  parties  and  service  providers  would 
facilitate the processing of e-invoices. 

In  addition,  to  ensure  that  e-invoicing  models  are  able  to  interconnect,  trading  parties  and 
service  providers  should  search  alignment  on  matters  such  as  risk  management,  addressing 
and  routing,  roaming  agreements,  standards,  communication  workflows  and  security 
requirements. 

The following actions are required to ensure that over time, trading parties can interconnect 
and create an EU or even wider network delivering mass adoption of e-invoicing. 

Actions: 

3.1 

3.2 

21 

CEN should develop by end of 2011, a Code of Practice taking into account the work 
of the Expert Group on e-invoicing. This Code of Practice, to be adopted by trading 
parties,  services  providers  and  public  authorities,  should  include  a  consistent 
terminology and a definition of roles and responsibilities of the distinct actors within 
the e-invoicing process. 

CEN should analyse by end of 2011 the need and propose actions for the adoption of 
interoperable  addressing  and  routing  procedures  by  the  e-invoicing  industry 
participants. 

Along the lines of the forthcoming European Interoperability Framework (EIF) for public services, four 
layers of inter-operability can be distinguished: legal, organisational, semantic and technical. 

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5.1.4.  Promote an e-invoice standard data model 

One of the key challenges for e-invoicing deployment is to define a single and clear semantic 
data  model  describing  the  information  elements  required  for  e-invoices.  One  common  data 
model  will  facilitate  semantic  interoperability  and  ensure  technology  neutrality.  As  per  the 
recommendations  of  the  Expert  Group,  "the  UN/CEFACT  Cross-Industry  Invoice  (CII)  v.2 
should be adopted as the common reference semantic data model upon which future e-invoice 
content standard solutions are based". It should be left to the market to define how this data 
model is subsequently adapted to suit it to specific business needs. All market actors within 
both the private and public sectors are encouraged to develop and implement, or to converge 
on, solutions that are compliant with the CII v.2 data model. 

In  addition,  the  implementation  of  this  data  model  should  be  supported  by  international 
standards organisations to ensure accessibility and stability in terms of ongoing governance, 
maintenance and quality. In Europe, CEN, through its technical committees and workshops, 
should  act  as  a  facilitator  to  drive  forward  the  implementation  of  relevant  standards  and 
supporting  implementation  guidelines,  and  to  ensure  international  standards  bodies  support 
the European requirements. However, in the short term, the convergence to a single standard 
should  not  prevent  existing  e-invoicing  solutions  from  being  used,  provided  those  solutions 
conform, or converge towards, the requirements of the common e-invoice data model. 

Actions: 

4.1 

4.2 

4.3 

In  2011,  CEN  will  design  implementation  guidelines  for  the  CII  v.2  data  model. 
These guidelines should be based on the core invoice data set proposed by the Expert 
Group  on  e-invoicing  and  take  into  account  the  ISO  20022  Invoice  message,  the 
work of the CEN e-Invoicing, BII and EBES workshops, and other initiatives such as 
the PEPPOL project. 

Depending on market demand, the development of further guidelines covering other 
domains/business processes should be envisaged. 

CEN will work with international standards organisations, such as UN/CEFACT and 
ISO, and communicate specific requirements for further development of the CII data 
model. 

UN/CEFACT is invited to pursue the fast development of e-business messages that 
are complementary to the e-invoice, and will improve the ability of businesses, trade 
and  administrative  organisations  to  exchange  products  and  relevant  services 
effectively. 

5.2. 

Organising the deployment of e-invoicing within the EU 

Coordinated  action  is  necessary  both  at  national  and  at  European  level  to  support  the 
deployment  of  e-invoicing.  This  will  promote  compatible  national  solutions  to  improve  the 
functioning of the internal market by making cross-border transactions more efficient and less 
burdensome for consumers, businesses and public authorities. 

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5.2.1.  Promoting e-invoicing at national level 

Member States  are  well-placed  for  advocating,  developing  and  facilitating  the  use  of 
e-invoicing.  They  should  ensure  that  their  national  commercial,  taxation  and  procurement 
practices contribute to the development of an e-invoicing environment with EU-wide reach. 

Action: 

5.1 

– 

– 

– 

5.2 

Member States  should  develop  a  strategy  to  promote  e-invoicing  at  national  level. 
This strategy should have the objective to: 

advocate the use of e-invoicing, in particular by SMEs 

coordinate  at  national  level  existing  and  forthcoming  initiatives  to  promote  the 
uptake  of  e-invoicing,  including  the  legal,  standardisation  and  interoperability 
aspects with a European dimension 

monitor and set targets for the adoption level of e-invoicing. 

To  support  the  realisation  of  these  objectives,  Member States  should  put  in  place 
national  multi-stakeholder  e-invoicing  fora  and  inform  the  Commission  of  their 
establishment by June 2011. National fora should ensure a balanced representation of 
stakeholders,  with  sufficient  participation  of  public  authorities  and  users  of 
e-invoicing services including consumers, SMEs and large businesses. 

5.2.2.  Promoting e-invoicing at European level 

The actions at Member State level should be coordinated to make sure that e-invoices can be 
freely  exchanged  within  the  EU.  Particular  attention  should  be  given  to  facilitating 
cross-border transactions, especially for SMEs. 

Action: 

6.1 

The Commission will establish for 3 years a European multi-stakeholder e-invoicing 
forum,  hereinafter  'the  European  E-invoicing  Forum',  composed  of  delegates  from 
national  fora  and  representatives  of  relevant  European  associations  from  the  users’ 
community,  CEN,  the  European  Central  Bank  (ECB)  and  the  Article  29  Data 
Protection Working Party22.  

The European E-Invoicing Forum’s  main tasks will be to assist the Commission in 
the following areas: 

– 

– 

monitor  the  development  of  the  e-invoicing  market  and  the  e-invoicing  adoption 
level in industry and services sectors across Member States 

bring  about  an  exchange  of  experience  and  good  practice  that  facilitates  the 
emergence of inter-operable e-invoicing solutions 

22 

Directive 95/46/EC, OJ L 281, 23.11.1995, p. 31–50. 

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– 

– 

6.2 

6.3 

point  out  problems  encountered,  in  particular  as  regards  cross-border  transactions, 
and propose appropriate solutions 

support and monitor work leading to the adoption of a e-invoice standard data model 

The  Commission  and  all  the  other  EU  institutions  should  lead  by  example  by 
implementing  e-invoicing  for  their own public  procurement purposes. In particular, 
the Commission will pursue the roll-out of the e-Prior project. 

In  2011,  the  Commission  will  work  towards  better  statistical  monitoring  of 
e-invoicing adoption. 

6. 

CONCLUSION 

The mass adoption of e-invoicing is expected to bring benefits to the EU as a whole and to 
contribute  to  its  competitiveness.  Outside  the  EU,  the  market  penetration  of  e-invoicing  is 
growing substantially and it is critical that the EU is not lagging behind these developments. 

Member States and stakeholders are invited to endorse the proposed key priorities and actions 
to  achieve  the  objective  of  mass  adoption  of  e-invoicing.  The  Commission  will  monitor 
closely all actions and the uptake of e-invoicing and will, by end of 2013, present a progress 
report  to  the  Council  and  the  European  Parliament.  In  case  the  progress  report  shows 
unsatisfactory  progress  of  e-invoicing  adoption  and  ongoing  fragmentation,  further  actions 
and  recommendations  could  be  taken  to  address  those  areas  that  are  preventing  mass 
adoption. 

The deployment of e-invoicing by setting-up governance structures such as the National Fora 
and the European Multi-Stakeholder Forum should help to build a consistent EU approach on 
e-invoicing  and  facilitate  the  emergence  of  an  interoperable  pan-European  e-invoicing 
environment. 

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