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
Date: 2013-06-26
Institutions: European Commission
Subjects: administrative cooperation, administrative formalities, digitisation, electronic government, exchange of information, invoicing, public contract, single market, type of business

EUROPEAN 
COMMISSION 

Brussels, 26.6.2013  
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 

{COM(2013) 449 final} 
{SWD(2013) 223 final} 
{SWD(2013) 225 final} 

EN 

   EN 

 
 
 
 
  
 
Table of Contents 

Introduction .............................................................................................................................. 6 

1. 

1.1. 

1.2. 

Procedural Issues and Consultation of Interested Parties ............................................ 7 

Procedural issues.......................................................................................................... 7 

External expertise and consultation of interested parties............................................. 8 

1.2.1.  Summary of the public consultation ............................................................................ 8 

2. 

Policy context, Problem definition and Subsidiarity.................................................... 9 

2.1. 

Background and context............................................................................................... 9 

2.1.1.  Key concepts ................................................................................................................ 9 

2.1.2.  Benefits of e-invoicing............................................................................................... 12 

2.1.3.  Policy context............................................................................................................. 13 

2.1.4.  Nature and size of the public procurement market .................................................... 15 

2.1.5.  Main stakeholders concerned..................................................................................... 17 

2.2. 

Problem definition...................................................................................................... 18 

2.2.1.  Problem driver (D0) ................................................................................................... 20 

2.2.2.  Problem (P1) – excessive complexity and legal uncertainty for firms ...................... 22 

2.2.3.  Problem (P2) – higher costs for firms ........................................................................ 24 

2.2.4.  Consequences (C1, C2).............................................................................................. 25 

2.3. 

2.4. 

Developing a baseline scenario.................................................................................. 27 

The EU's right to act and justification........................................................................ 29 

2.4.1.  Legal basis.................................................................................................................. 29 

2.4.2.  Subsidiarity and proportionality................................................................................. 30 

2.4.3. 

Justification for EU action on e-invoicing in public procurement............................. 31 

3. 

3.1. 

3.2. 

3.3. 

4. 

Objectives................................................................................................................... 32 

General objective ....................................................................................................... 32 

Specific objectives ..................................................................................................... 32 

Operational objective ................................................................................................. 32 

Policy Options............................................................................................................ 32 

4.1. 

The choice of coercive or non-coercive instruments ................................................. 35 

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5. 

5.1. 

5.2. 

Analysis of Impacts.................................................................................................... 35 

The expected common impacts.................................................................................. 36 

Primary impacts ......................................................................................................... 36 

5.2.1. 

Impacts on firms......................................................................................................... 36 

5.2.2. 

Impacts on contracting authorities ............................................................................. 38 

5.3. 

Secondary impacts ..................................................................................................... 40 

5.3.1.  Economic, social, and environmental impacts........................................................... 40 

5.3.2.  Reduction of administrative burden ........................................................................... 41 

5.3.3.  The scale of secondary impacts.................................................................................. 41 

5.4. 

Impacts of defined options ......................................................................................... 41 

5.4.1.  Option (1):  No new EU action .................................................................................. 42 

5.4.2.  Option (2): Free-choice approach .............................................................................. 42 

5.4.3.  Option (3): Selective conversion to e-invoicing ........................................................ 43 

5.4.4.  Option (4): Obligatory acceptance ............................................................................. 44 

5.4.5.  Option (5): Full harmonisation................................................................................... 45 

6. 

6.1. 

6.2. 

Comparing the Options .............................................................................................. 46 

Comparing the options against the operational objective .......................................... 46 

Comparison of options across all stakeholder groups................................................ 50 

6.2.1.  Member States / contracting authorities..................................................................... 51 

6.2.2.  Firms (including SMEs)............................................................................................. 52 

6.2.3.  Service providers........................................................................................................ 53 

6.3. 

The preferred option................................................................................................... 53 

6.3.1.  Timeframe .................................................................................................................. 54 

6.3.2.  Participation of microenterprises ............................................................................... 55 

6.3.3.  Regulatory form ......................................................................................................... 56 

6.3.4.  Development of the new standard.............................................................................. 56 

7. 

7.1. 

7.2. 

8. 

Overall impacts of the chosen option......................................................................... 57 

Primary impacts ......................................................................................................... 57 

Secondary impacts ..................................................................................................... 57 

Monitoring and Evaluation ........................................................................................ 57 

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1. 

Annexes...................................................................................................................... 60 

1.1. 

Modifications following the IAB opinion of 22 March 2013 .................................... 60 

1.1.1.  Strengthen the problem definition.............................................................................. 60 

1.1.2.  Strengthen the subsidiarity and proportionality analysis ........................................... 60 

1.1.3. 

Improve analysis of the impacts................................................................................. 60 

1.1.4.  Better present stakeholder views................................................................................ 60 

1.1.5.  Procedure and presentation ........................................................................................ 60 

1.2. 

1.3. 

Modifications following the IAB opinion of 8 May 2013 ......................................... 61 

Benefits and costs of e-invoicing in public procurement........................................... 61 

1.3.1.  Benefits ...................................................................................................................... 62 

1.3.2.  Costs........................................................................................................................... 65 

1.4.  Why start with e-invoicing? ....................................................................................... 66 

1.5. 

1.6. 

1.7. 

1.8. 

1.9. 

Structured e-invoicing - efficiencies of higher levels of automation......................... 67 

Overview of e-invoicing uptake in EU Member States ............................................. 68 

Projects to facilitate the roll-out of e-invoicing in the EU ......................................... 73 

E-invoicing data exchange models............................................................................. 73 

Choice of technical solution to ensure interoperability.............................................. 75 

1.10.  CEN standardisation process...................................................................................... 76 

1.10.1.  Developing a European Standard............................................................................... 76 

1.11. 

Summary of stakeholder views .................................................................................. 77 

1.11.1.  Conclusions from bilateral meetings with stakeholders............................................. 77 

1.11.2.  Replies from IPM survey ........................................................................................... 78 

2. 

3. 

Glossary ..................................................................................................................... 95 

References .................................................................................................................. 96 

4 

 
 
 
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 

5 

 
 
Introduction  

A  shift  towards  paperless  public  administration  is  an  important  objective  for  the  European 
Union and the Member States. The Digital Agenda for Europe1 includes a call to increase the 
use  of  e-Government  by  EU  citizens  and  businesses.  The  Annual  Growth  Survey  for  20132 
also  calls  on  Member  States  to  give  priority  to  ensuring  that  exchanges  between 
administrations and enterprises can be done digitally, with a view to increasing administrative 
efficiency.  In  order  to  stimulate  the  transition  to  e-government,  the  European  Union  has 
undertaken  a  variety  of  initiatives,  one  of  which  aims  to  make  the  use  of  electronic 
procurement mandatory across the EU.  

Another particularly promising area to help achieve these objectives is e-invoicing, which the 
Commission has called for to become the predominant invoicing mode in the EU by 20203. In 
addition to its potential contribution to the digitisation of public administration across the EU, 
e-invoicing holds the promise of significant economic and environmental benefits. Increased 
use of e-invoicing by Member State governments would make the broadly understood public 
procurement process more efficient, cheaper, and more transparent for the parties involved as 
well as for the taxpayer. A preliminary estimate indicates that savings of approximately EUR 
1.5  to  2.3  billion  per  year  could  potentially  be  achieved  if  all  public  procurement  invoices 
were submitted in electronic format. E-invoicing is also expected to reduce the administrative 
burden for firms, as well as the use of paper, waste, and CO2 emissions from transport.  

The  widely-acknowledged  benefits  of  e-invoicing  have  incited  several  EU  Member  States 
(Denmark,  Austria,  Sweden,  and  Finland)  to  require  the  submission  of  e-invoices  in  public 
procurement  in  all  or part  of the public sector. However, these bottom-up initiatives are for 
the most part based on national standards, most of which are not interoperable. As such, they 
lead  to  an  increase  in  complexity  and  costs  for  firms  wishing  to  participate  in  cross-border 
procurement,  and  thereby  generate  market  access  barriers.  The  overall  result  is  that  the 
adoption of e-invoicing in Europe is still very limited, accounting for 4 to 15%4 of all invoices 
exchanged.  A  possible  initiative  in  the  area  of  e-invoicing  in  public  procurement  would 
prevent  the  further  fragmentation  of  the  Internal  Market  and  facilitate  the  uptake  of  e-
invoicing. Considering the fact that public procurement covered by the Directives represents 
roughly 3.7% of EU GDP5, the implementation of an initiative which would eliminate market 
access  barriers  in  e-invoicing  in  public  procurement  would  make  the  public  sector  a  'lead 
market' in this area and spearhead its wider use in the economy.  

Over  the  last  couple  of  years,  a  significant  number  of  actors  have  called  for  action  at  the 
European level to stimulate the e-invoicing market across the EU, especially with regards to 
invoices  submitted  to  public  bodies.  The  occasion  therefore  seems  ripe  to  undertake  the 
proposed  initiative  on  e-invoicing  in  public  procurement  and  effectively  remove  the  market 
access  barriers  caused  by  insufficient  e-invoicing  interoperability.  As  such,  action  on 
promoting the uptake of e-invoicing in public procurement is now seen by the Commission as 

1 
2 
3 

4 
5 

"A Digital Agenda for Europe", European Commission Communication, COM(2010) 245. 
“Annual Growth Survey 2013”, Communication from the Commission, COM(2012) 750 final. 
"Reaping the benefits of e-invoicing for Europe", European Commission Communication, COM(2010) 
712. 
Detailed explanations provided in Section 2.1.4.2. 
„Public Procurement Indicators 2010”, European Commission, Brussels, 4 November 2011. 

6 

 
 
                                                 
a  priority.  This  is  reflected  in  the  inclusion  of  an  initiative  on  e-invoicing  in  public 
procurement in the “Single Market Act II” as one of its Key Actions6. 

A potential proposal in this area would also complement the on-going modernisation of EU 
public  procurement  rules7,  a  key  action  under  the  “Single  Market  Act  I”8,  in  particular  with 
regards to the proposal on a full transition to e-procurement.  

The current impact assessment therefore looks at the effects of a possible EU initiative which 
would  enhance  e-invoicing  interoperability  in  public  procurement9  across  the  European 
Union,  in  order  to  eliminate  the  fragmentation  of  the  Internal  Market  and  remove  existing 
obstacles to the broader use of e-invoicing. 

1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Procedural issues 

The project is led by Directorate C of the Directorate General Internal Market and Services.  

Action  on  promoting  the  uptake  of  e-invoicing  in  public  procurement  is  seen  by  the 
Commission as a priority for the near future. This is reflected in the inclusion of an initiative 
on e-invoicing in public procurement in the recently-published “Single Market Act II” as one 
of its Key Actions. The initiative has therefore also been included in the “Commission Work 
Programme for 2013”, which was announced on 23 October 201210.  

This Impact Assessment was preceded by the publication of a Roadmap, which was published 
as part of the Commission Work Programme for 2013.  

The Steering Group for this Impact Assessment was formed by representatives of a number of 
services  of  the  European  Commission,  namely  the  Directorate  General  Internal  Market  and 
Services, the Secretariat General, the Directorate-General for Economic and Financial Affairs, 
the  Directorate  General  Regional  Policy,  the  Directorate  General  for  Communications 
Networks,  Content  and  Technology,  the  Directorate  General  Environment,  the  Directorate 
General  for  Employment,  Social  Affairs  and  Inclusion  the  Directorate  General  for 
Informatics, the Directorate General for Justice, the Legal Service, the Directorate General for 
Taxation and Customs Union and the Directorate General Enterprise and Industry.  

This Group met four times: on 14 September 2012, 19 December 2012, 6 February 2013 and 
18 February 2013. 

6 

7 

8 

9 

10 

“Single Market Act II - Together for new growth”, Communication from the Commission, COM(2012) 
573 final. 
Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  on  public  procurement, 
COM/2011/896 final, and Proposal for a Directive of the European Parliament and of the Council on 
procurement  by  entities  operating  in  the  water,  energy,  transport  and  postal  services  sectors, 
COM(2011) 895 final I. 
“Single  Market  Act  -  Twelve  levers  to  boost  growth  and  strengthen  confidence,  Working  together  to 
create new growth", Communication from the Commission, COM(2011) 206 final of April 2011 
This initiative would only concern public procurement covered by Directives 2004/17/EC, 2004/18/EC, 
and 2009/81/EC. 
“Commission Work Programme 2013”, Communication from the Commission, COM(2012) 629 final.  

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The  first  meeting  of  the  Impact  Assessment  Board  (IAB)  took  place  on  20  March  2013. 
During this meeting, the IAB raised a number of issues which in the board’s opinion would 
need  to  be  addressed  further,  and  requested  a  resubmission  of  the  Impact  Assessment.  The 
second  –  positive  –  opinion  on  the  revised  Impact  Assessment  was  issued  on  8  May  2013. 
The main modifications in response to the first and second opinions of the IAB are presented 
in Annexes 1.1 and 1.2. 

1.2. 

External expertise and consultation of interested parties 

This  Impact  Assessment  builds  on  the  analysis  of  external  research  and  consultations  with 
stakeholders.  

Two meetings of the European Multi Stakeholder Forum on e-invoicing (EMSF)11 were held 
in Brussels (on 26 September 2012 and 7 March 2013) and provided an important forum for 
discussing  the  building  blocks  of  the  potential  EU  initiative  on  e-invoicing  in  public 
procurement. The discussion papers of four Activity Groups of the EMSF12 provided practical 
feedback from the representatives of national multi-stakeholder forums and practitioners, such 
as  service  providers  and  firms.  Additionally,  a  questionnaire  was  circulated  among  the 
members of  the EMSF  which  attempted to gather data on existing e-invoicing systems,  and 
their effectiveness, costs and benefits. The 20 replies which were received (19 from national 
fora  and  one  from  a  standard-setting  body)  were  also  extensively  used  in  this  Impact 
Assessment.  

The  content  of  the  initiative  was  presented  and  discussed  with  the  Advisory  Committee  for 
Public Contracts (ACPC), comprising of Member State representatives, during a meeting on 
19 September 2012. More informal bilateral meetings also took place with representatives of 
various  industry  associations,  including  the  European  E-invoicing  Service  Providers 
Association  (EESPA),  Business  Europe  and  the  European  Association  of  Craft,  Small  and 
Medium-sized Enterprises (UEAPME). 

Finally,  an  on-line  consultation  via  the  Interactive  Policy  Making  tool  (IPM)  was  held 
between 22 October 2012 and 14 January 2013 to gather information on current usage of e-
invoicing and opinions concerning a potential EU initiative in this area. The public response 
to the consultation was very positive, with more than 700 replies submitted. 

The  various  consultations  with  stakeholders  provided  the  Commission  with  a  good  cross-
section of the views held by the different stakeholders. 

1.2.1. 

Summary of the public consultation 

707  replies  to  the  public  consultation  were  received,  with  a  very  good  geographical  and 
sectoral  spread  of  participants:  every  Member  State  and  every  group  of  stakeholders  was 
represented13.  The  questionnaire  asked  participants  about  their  experience  with  using 
electronic  invoicing  and  their  opinions  concerning  a  possible  EU  initiative  to  promote  the 

11 
12 

13 

interim  reports  of  Activity  Groups  1 

http://ec.europa.eu/internal_market/payments/einvoicing/index_en.htm  
The 
invoicing/benefits/invoicing_forum_en.htm). 
The  following  groups  of  stakeholders  were  represented:  policy  makers,  contracting  authorities,  firms 
(large  companies  /  SMEs),  IT  service  providers, business/industry  associations  (industry  consultants), 
other associations (e.g. associations of regional or local government), private individuals / citizens.  

to  4:  (http://ec.europa.eu/enterprise/sectors/ict/e-

8 

 
 
                                                 
uptake of e-invoicing and enhance interoperability between existing systems. The responses 
reveal broad support for EU action in e-invoicing in public procurement; no single category of 
stakeholder or nationality was outright opposed to EU action in this field. Support for an EU 
initiative to promote the uptake of e-invoicing in the EU by making governments act as the 
front-runners is overwhelming – almost 9 in 10 respondents are in favour. There is also strong 
support  for  increasing  the  interoperability  of  e-invoicing  systems,  with  more  than  4  out  of 
every 5 stakeholders supporting EU action to achieve this objective. Finally, the vast majority 
of  respondents  wish  to  see  a  rapid  EU  intervention  in  the  area  of  e-invoicing  in  public 
procurement: 90% of stakeholders call for making it mandatory before the end of 2017. 

When looking individually at the different groups of stakeholders, the greatest supporters of 
EU  action  in  e-invoicing  in  public  procurement  are  the  e-invoicing  service  providers, 
followed  by  Member  States,  contracting  authorities,  and  finally,  enterprises.  Yet  even  for 
enterprises, support hovers around 80%.  

The full synthesis report of the responses can be found in Annex 1.11.  

2. 

POLICY CONTEXT, PROBLEM DEFINITION AND SUBSIDIARITY 

2.1. 

Background and context 

2.1.1.  Key concepts 

This Impact Assessment refers to a possible initiative that lies at the intersection of two policy 
areas:  the  public  procurement  policy  and  the  use  of  electronic  means  of  communication  for 
invoicing. These two concepts are presented below. 

2.1.1.1.  Public procurement 

Public  procurement  refers  to  the  acquisition  of  goods,  works  or  services  by  government 
institutions and public sector organisations. The EU procurement legislation applies common 
principles  of  transparency,  open  competition  and  sound  procedural  management  to  public 
contract  award  procedures  which  are  likely  to  be  of  interest  to  suppliers  across  the  Internal 
Market. Open and well regulated procurement markets are expected to contribute to a better 
use of public resources14. 

The  procedures  to  be  applied  for  the  award  of  contracts  by  contracting  authorities15  are 
provided in Directive 2004/18/EC. Firms which are active in the utilities markets (contracting 
entities)  are  subject  to  the  provisions  of  Directive  2004/17/EC.  Procurement  in  the  field  of 
security  and  defence  is  regulated  by  the  Defence  and  security  procurement  Directive 
2009/81/EC.  

The three above mentioned legal acts (hereinafter referred to as “the Directives”) regulate the 
organisation of tender procedures for high value contracts (i.e. contracts falling above certain 

14 

15 

“Evaluation  Report  -  Impact  and  Effectiveness  of  EU  Public  Procurement  Legislation”,  Commission 
Staff Working Paper, SEC(2011) 853 final. 
In  this  Impact  Assessment,  the  term  “contracting  authorities”  will  be  used  to  refer  to  contracting 
authorities  or  entities,  within  the  meaning  of  Article  1(9)  of  Directive  2004/18/EC,  Article  2  of 
Directive 2004/17/EC and/or Article 1(17) of Directive 2009/81/EC. 

9 

 
 
                                                 
monetary  thresholds16).  The  Directives  also  contain  a  number  of  exclusions  (e.g.  Directive 
2004/18/EC does not apply to inter alia contracts requiring special security measures, secret 
contracts or to service concessions)17.  

In  line  with  the  general  principles  of  the  Directives,  contracts  of  values  falling  below  the 
monetary  thresholds  set  out  in  the  Directives  (i.e.  national  procurement  not  covered  by  the 
Directives) and contracts excluded from the scope of the Directives will be out of the scope of 
this initiative.  

In  December  2011,  the  European  Commission  adopted  proposals  to  modernise  Directives 
2004/18/EC  and  2004/17/EC,  containing  provisions  that  relate  to  the  transition  towards 
electronic procurement (e-procurement)18. If the Commission's proposals are accepted during 
the legislative process, the vast majority of procurement procedures covered by the proposals 
will be carried out using electronic means of communication by mid-2016.  

While the rules of the Directives do not go beyond the award stage, the public procurement 
process  or  cycle19  is  a  broader  concept.  It  consists  of  a  number  of  steps  which  take  place 
before and after a successful bidder has been selected: tendering, award, ordering, invoicing, 
payment  and  archiving  of  the  procurement  documentation.  The  key  elements  of  public 
procurement process are presented below (Figure 1). 

Figure 1): The scope of the Directives and public procurement process 

Source: DG Internal Market and Services 

16 
17 
18 

19 

Commission Regulation (EU) No 1251/2011 of 30 November 2011. 
Articles 13 to 18 of Directive 2004/18/EC. 
These  provisions  foresee  a  phased  introduction  of  the  mandatory  use  of  electronic  means  of 
communication in public procurement, covering the electronic notification of procurement notices (e-
notification), the electronic access to tender documents (e-access) and the electronic submission of bids 
(e-submission). 
The term “procurement cycle” is used by OECD in its Procurement Toolbox: “The procurement cycle 
describes the entirety of the process through which public organisations identify, prepare and execute 
the acquisition of goods, services and works. The procurement cycle comprises of three main phases: 
pre-tendering  (including  needs  assessment,  planning  and  budgeting,  definition  of  requirements  and 
choice of procedures); tendering (including the invitation to tender, evaluation and award); and post-
payment)”; 
(including 
award 
(http://www.oecd.org/governance/procurement/toolbox/keyterminology.htm ). 

contract  management, 

post-tendering 

order 

and 

or 

10 

 
 
 
                                                 
This  initiative  takes  into  account  the  complete  public  procurement  process  and  analyses  the 
interactions between its components. Such a broad approach addresses the recently observed 
integration  of  procurement  process  which  has  been  driven  by  IT  developments.  It  is  also  in 
line  with  the  scope  of  various  other  initiatives  concerning  electronic  procurement,  which 
acknowledge that all elements of the procurement cycle have become much more integrated. 
For example, the PEPPOL project defines e-procurement as a process encompassing all steps 
from e-sourcing to e-payment20. The Commission’s 2004 “Action Plan on e-procurement”21 
also referred to the entire procurement chain, including the pre-award and post-award phases. 
The  Commission  Communication  “A  strategy  for  e-procurement”22  from  2012  recognises 
that: "[t]he ultimate goal is 'straight through e-procurement' with all phases of the procedure 
from  notification  (e-notification)  to  payment  (e-payment)  being  conducted  electronically." 
Finally,  the  on-going  revision  of  the  public  procurement  Directives  addresses,  among  other 
elements,  e-catalogues,  which  is  also  an  important  element  of  the  post-award  procurement 
process. 

2.1.1.2.  E-invoicing 

An  invoice  is  a  document  certifying  the  delivery  of  a  product  or the  provision  of  a  service, 
showing the date of accrual and the amount payable in consideration for the product or service 
provided. It is the central element of a procurement process once a contract has been awarded, 
and  its  creation  is  a  prerequisite  for  the  supplier  to  receive  payment  for  supplied  goods  or 
services.23 In Europe, invoicing rules are governed by Directive 2006/112/CE, as amended by 
Directive  2010/45/EU24,  which  establishes  equal  treatment  between  paper  and  electronic 
invoices. 

E-invoicing  is  the  electronic  transfer  of  invoicing  information  between  business  partners 
(supplier and buyer). It is an essential part of an efficient financial supply chain and it links 
the internal processes of enterprises to their payment systems25.  

Several  competing  definitions  of  electronic  invoicing  coexist.  In  its  broadest  sense,  e-
invoicing  is  understood  as  any  method  of  invoice  submission  which  does  not  include  the 
physical  presence  of  paper.  This  implies  that  any  form  of  invoice  sent  by  electronic  means 
(e.g.  email  with  a  scanned  invoice  as  an  attachment)  constitutes  e-invoicing26.  However,  in 
recent  years  a  more  restrictive  definition  appears to  be  gaining broad  support. According to 
this  view,  e-invoicing  can  only  truly  be  referred  to  as  such  if  the  message  containing  the 
invoice is structured in such a way that its receipt and processing does not require any human 

20 
21 

22 
23  

24 

25 
26 

http://www.peppol.eu/peppol_components 
“Action  plan  for  the  implementation  of  the  legal  framework  for  electronic  public  procurement”, 
Communication from the Commission, Brussels, 13.12.2004.  
“A strategy for e-procurement”, Communication from the Commission, COM(2012) 179 final. 
This is one of the reasons why the proposed initiative will address e-invoicing and not any of the other 
of  the post-award processes.  It  should  be noted, however,  that  some  of  these  processes  have  to  some 
extent already been addressed by other Commission initiatives. More detailed information is provided 
in Annex 0.  
Council  Directive  2010/45/EU  of  13  July  2010  amending  Directive  2006/112/EC  on  the  common 
system of value added tax as regards the rules on invoicing. 
(http://ec.europa.eu/internal_market/payments/einvoicing/index_en.htm) 
Unstructured  e-invoices  are  essentially  an  electronic  image  of  the  paper  invoice,  which  implies  that 
their  further  processing  in  the  recipient's  IT  systems  can  only  take  place  after  they  are  encoded 
manually or using an alternative process, which is generally costly and not fully automated. 

11 

 
 
                                                 
intervention27. The view that only structured invoices can be seen as full e-invoices is shared 
by  many  stakeholders  (e.g.  the  results  of  the  EMSF  consultation  confirm  that  neither  PDFs 
nor unstructured invoices are seen as full e-invoices28). Structured e-invoicing offers greater 
opportunities for the full automation of invoicing procedures and allows other elements of the 
post-award supply chain process to be automated29 (e-ordering, e-payment, and e-archiving, 
etc.).  Although  the  existence  of  non-structured  invoice  documents  cannot  be  ignored,  their 
role (and that of various hybrid solutions30) is generally perceived as temporary31, or as a step 
towards full automation.  

In  summary,  the  definition  which  sees  e-invoicing  as  fully-structured  electronic  invoicing 
messages seems by far the most appropriate and this Impact Assessment will only consider 
structured invoices as e-invoices.  

In  terms  of  the  stakeholders  involved,  e-invoicing  can  take  place  between  two  businesses 
(B2B), between business and government (B2G), between business and the consumer (B2C), 
and  finally  between  government  and  the  consumer  (G2C).  By  its  very  nature,  public 
procurement  transactions  concern  invoices  submitted  by  businesses  (suppliers)  to  public 
authorities  (buyers),  i.e.  B2G  invoicing.  The  other  sectors  (B2B,  B2C  and  G2C)  therefore 
fall outside the direct scope of this Impact Assessment, except insofar as the introduction of e-
invoicing in the B2G sector may generate spill-over effects to these sectors. 

2.1.2.  Benefits of e-invoicing 

The  benefits  of  e-invoicing  when  compared  with  paper-based  invoicing  are  numerous  and 
widely acknowledged. Electronic processing of invoices generates operational savings due to 
less complex processes and shorter processing times; it increases transparency, improves the 
security and auditability of data; and it can reduce administrative burden for enterprises. It is 
also better for the environment. 

These benefits are among the main drivers for the adoption of e-invoicing. For example, the 
Austrian  government,  in  announcing  its  plans  to  mandate  e-invoicing  in  the  public  sector 
transactions,  argued  that  paperless  invoicing  offers  numerous  advantages  such  as  time  and 
cost  savings,  transparency,  traceability,  error  reduction,  as  well  as  positive  environmental 
impacts32.  In  launching  their  pilot  projects,  both  Belgium  and  Ireland  stressed  the  savings 
opportunities  presented  by  e-invoicing.33  In  Greece,  it  was  estimated  that  both  the  state  and 
enterprises  were  losing  more  than  EUR  4  billion  annually  from  illegal  invoicing  practices; 
electronic  invoicing  is  expected  to  effectively  combat  such  practices34.  Finally,  savings  and 

27 

28 

29 
30 
31 

32 

33  

34 

The  invoice  would  need  to  adhere  to  strict  semantic  and  syntactic  standards  which  allows  the  fully 
automatic processing of the invoice data by the sender’s and recipient’s computer systems. 
“Good  practices  in  the  adoption  and  promotion  of  e-invoicing  in  Europe:  Results  of  the  EMSF  good 
practices  consultation”  -  ACCA  Discussion  Paper  prepared  for  Activity  Group  2  of  the  European 
Multi-stakeholder Forum on e-invoicing, London, August 2012.  
The benefits of structured invoicing are analysed in Annex 1.3.1. 
E.g. certain unstructured document formats may partially contain structured information. 
With  the  exception  of  business  to  consumer  (B2C)  sector,  where  invoices  send  as  PDFs  may  be  the 
most appropriate solution. 
http://project.peppol.eu/news/austria-mandates-einvoicing-to-the-public-sector-fostering-peppol-
adoption 
http://presscenter.org/nl/pressrelease/20121213/einde-van-het-tijdperk-van-de-papieren-facturen-in-
zicht?lang=fr; http://www.oneposting.com/PEPPOL-Ireland.aspx 
http://www.athensnews.gr/portal/8/45720 

12 

 
 
                                                 
transparency  motives  were  also  referred  to  as  reasons  for  the  adoption  of  mandatory  e-
invoicing by the federal administration in the United States35  

The  principal  operational  gains  of  e-invoicing  come  from  less  complex  procedures  and 
therefore shorter processing times. The invoice-to-pay cycle time in paper-based invoicing 
may take between 30 and 100 days36. By automating some of the processes and eliminating 
the need for human intervention, it is estimated that this period can be shortened to around 10 
days  when  invoices  are  processed  electronically37.  The  shortened  invoice-to-pay  cycle  also 
means that payment delays would be less frequent, and that contracting authorities could save 
on late payment interests. E-invoicing could therefore contribute to attaining the objectives of 
the late payments Directive 2011/7/EU38. 

The simpler and shorter processes result in savings. For example, the Finnish State Treasury 
and  some  Finnish  companies  have  estimated  that  an  incoming  paper  invoice  incurs  costs 
amounting to EUR 30-50 to the receiving company. By moving to electronic invoicing, these 
costs can be lowered to EUR 10 by semi-automating the invoice process, and to  EUR  1 by 
fully  automating  the  process39.  Some  service  providers  estimate  that  processing  of  paper 
invoices  is  around  60%  to  80%  more  expensive  than  electronic  invoices40.  The  European 
Association  of  Corporate  Treasurers  has  reached  similar  results,  estimating  that  companies 
could  save  up  to  80%  of  their  current  costs  by  processing  invoice  data  automatically,  i.e. 
removing paper and manual efforts41. 

The  electronic  processing  of  invoices  positively  influences  the  transparency  of  the 
procurement process. When a tax audit occurs, e-invoices can be more easily made available 
to  tax  authorities  than  paper  invoices,  allowing  them  to  check  for  compliance  more  easily. 
Industry  publications  underline  that  e-invoicing  significantly  reduces  operational  risk  of 
fraudulent invoices and duplicate payments42. If e-invoicing is integrated with tax reporting, it 
can reduce administrative burden, as tax declarations can be generated automatically. 

Finally, e-invoicing is more environmental friendly, as it reduces the use of paper and the 
amount of waste generated by public buyers and firms, as well as the CO2 footprint caused by 
transportation.  

More detailed information about the benefits of e-invoicing is provided in Annex 1.3. 

2.1.3.  Policy context 

The potential benefits from the use of e-invoicing are perceived as an opportunity by a wide 
range of actors, chief among them: 

35 
36 

37 
38 
39 

40 
41 
42 

http://www.treasury.gov/press-center/press-releases/Pages/tg1238.aspx 
The differences concern the best case/worst case scenario respectively - “E-invoicing 2010, European 
market guide”, Euro Banking Association (EBA) and Innopay, page 15, quoting Celent. 
“Financing Innovations”, Sarah Jones, Bottomline Technologies, April 2010. 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:048:0001:0010:EN:PDF 
"Electronic Invoicing Initiatives in Finland and in the European Union – Taking steps towards the Real 
Time Economy", Helsinki School of Economics, B-95. 
http://www.einvoicingbasics.co.uk/benefits-of-einvoicing/buyer-benefits/ 
“European E-Invoicing Guide for SMEs”, The European e-Business Lab, November 2009. 
“European E-Invoicing Guide for SMEs”, The European e-Business Lab, November 2009. 

13 

 
 
                                                 
•  Member  States,  who  have  called  for  measures  to  promote  e-invoicing  at  the 
Informal Competitiveness Council of February 2012 and in the European Council 
Conclusions of June 201243. 

•  The  European  Parliament,  which  called  for  making  e-invoicing  compulsory  in 

public procurement by 2016 in a resolution adopted in April 201244. 

•  Stakeholders  (chiefly  economic  actors  and  NGOs),  which  in  various  fora 
(conferences, studies, and reports) have highlighted the benefits which e-invoicing 
could bring with respect to cost savings, increased efficiency, simpler and faster 
payment processes, or a reduced environmental impact. 

An  initiative  facilitating  the  use  of  e-invoicing  in  public  procurement  would  contribute  to 
achieving the objectives of several existing Commission initiatives, both legislative and non-
legislative. These are discussed below. 

2.1.3.1.  Legislative initiatives 

While at present, no EU legislation specific to e-invoicing in public procurement exists, some 
related  legislative  acts  do  address  e-invoicing  directly  or  indirectly.  Council  Directive 
2010/45/EU45, on the common system of value added tax revises and simplifies the rules for 
the submission of electronic invoices vis-à-vis traditional invoices, setting both methods on an 
equal  footing  with  a  view  to  promoting  its  usage  in  the  context  of  tax  rules.  E-invoicing  is 
also  indirectly  related  to  objectives  of  the  late  payments  Directive  2011/7/EU46,  as  it  could 
contribute to shortening the payment processing times. The present initiative would be fully in 
line  with  the  objectives  of  both  of  these  Directives.  Additionally,  the  Commission  has 
recently  proposed  to  modernise  Directives  2004/17/EC  and  2004/18/EC,  one  element  of 
which  is  the  introduction  of  mandatory  e-procurement.  The  initiative  on  e-invoicing  would 
build on these efforts in order to achieve the objective of “straight through e-procurement” as 
defined  in  the  recent  communication  “A  strategy  for  e-procurement”  (see:  section  2.1.3.2 
below). 

Finally, e-invoicing is embedded in a patchwork of legal requirements, which cover rules on 
accounting,  auditing,  protection  of  personal  data47,  archiving  and  customs  issues.  The 
proposed initiative would fully respect all of these requirements. 

2.1.3.2.  Non-legislative initiatives 

A  number  of  non-legislative  initiatives  dealing  specifically  with  e-invoicing  have  been 
adopted, in particular: 

43 
44 

45 
46 
47 

EUROPEAN COUNCIL 28/29 JUNE 2012 CONCLUSIONS, Brussels, 29 June 2012.  
“E-Government  as  a  spearhead”,  European  Parliament  resolution  of  20  April  2012  on  a  competitive 
digital single market (2011/2178(INI)), T7-0140/2012.  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:189:0001:0008:EN:PDF  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:048:0001:0010:EN:PDF 
As far the data protection legislation is concerned, such requirements are set out in Directive 95/46/EC 
on the protection of individuals with regard to the processing of personal data and on the free movement 
of such data. The said Directive specifies inter alia when processing of personal data is legitimate, what 
principles  apply  to  data  processing  operations  and  confers  various  rights  on  the  data  subjects.  These 
provisions  and  in  particular  the  national  provisions  adopted  in  the  implementation  of  Directive 
95/46/EC will be fully applicable to processing of personal data in the context of e-invoicing. 

14 

 
 
                                                 
•  The  Communication  from  the  Commission  "Reaping  the  benefits  of  electronic 
invoicing  for  Europe",  COM(2010)71,  which  outlines  the  benefits  which  e-
invoicing can bring the Single Market and sets out a plan for increasing its uptake 
across  the  EU.  It  has  set  as  an  objective  that  "e-invoicing  becomes  the 
predominant method of invoicing by 2020 in Europe".  

•  The  Communication  from  the  Commission  “A  strategy  for  e-procurement”, 
COM(2012) 179 final, which 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.  

•  The  European  Commission's 

for  Europe", 
COM(2010)  245,  which  gives  a  prominent  role  to  achieving  a  single  digital 
market and calls for removing the regulatory and technical barriers which prevent 
mass adoption of e-invoicing; and 

initiative  "A  Digital  Agenda 

•  The  Commission  proposal  for  a  Connecting  Europe  Facility  (CEF),  which 
foresees  support  to  digital  services  infrastructures  (which  will  also  enable  e-
invoices). 

As  mentioned  previously,  the  European  Commission  has  also  established  the  EMSF  on  e-
invoicing,  composed  of  delegates  from  national  e-invoicing  fora  and  key  stakeholders  from 
the user side of the market, which could be leveraged in the context of a possible initiative on 
e-invoicing in public procurement48. Finally, the Commission has supported and implemented 
a number of projects to facilitate the roll-out of e-invoicing in the EU, namely: PEPPOL, e-
SENS,  and  e-PRIOR  (more  information  about  the  scope  and  objectives  of  these  projects  is 
provided in Annex 1.7). 

2.1.4.  Nature and size of the public procurement market 

Public buyers are traditionally the largest consumer in the economy. In 2010, the public sector 
spent over EUR 2 406 billion on goods, services and works – amounting to around 19.7% of 
EU  GDP.  As  mentioned  in  Section  2.1.1.1,  the  majority  of  public  expenditure  on  goods, 
works and services is not covered by the Directives – this includes various exemptions, below 
threshold  procurement  or  large  amounts  of  public  expenditure  on  goods  and  services  to 
provide health, education and social services. In fact, only 1/5 of total public expenditure on 
goods and services is covered by the Directives. In 2010, over 160 000 invitations to tender 
were  published  in  conformity  with  the  Directives  in  the  OJ/TED49  website.  The  estimated 
value  for  these  contracts  was  EUR  447  billion  (see:  Figure  2),  representing  approximately     
3.7 % of the EU GDP. 

48 

49 

It is worth noting, however, that the scope of the 2010 e-invoicing Communication and the EMSF is e-
invoicing in general (i.e. broader than B2G e-invoicing). 
Tenders  Electronic  Daily  (OJ/TED)  –  the  Supplement  to  the  Official  Journal  of  the  European  Union 
where notices are published for public procurement contracts covered by the Directives. 

15 

 
 
                                                 
Figure 2): The size of public procurement market above EU threshold 

Source: DG Internal Market and Services, based on OJ/TED data 

Within  the  procurement  covered  by  the  Directives,  only  a  relatively  small  proportion  of 
contracts are awarded to firms from another Member State. Direct cross-border procurement 
accounted for 1.6% of awards or roughly 3.5% of the total value of contract awards published 
in  OJ/TED  during  2006-2009.  In  addition  to  direct  cross-border  procurement,  there  is  a 
considerable  volume  of  indirect  cross-border  procurement.  For  example  firms  can  bid  for 
contracts through their foreign affiliates or subsidiaries. This channel accounted for 11.4% of 
awards published in OJ/TED and 13.4% by value during 2006-200950. 

2.1.4.1.  Nature and size of e-invoicing in public procurement 

Governments are among the principal recipients of invoices. The public sector is listed as one 
of top three industries with the highest inbound invoice volumes, estimated at 9-15% of the 
share of all invoices (other industries mentioned are: retail 10%, healthcare 5-13%)51.  

The  above  data  refers  to  all  invoices.  As  far  as  e-invoices  are  concerned,  there  are  some 
limitations  in  the  available  data,  but  a  rough  outline  of  the  usage  of  e-invoicing  by 
governments in the EU is beginning to emerge. For example, Eurostat provides detailed data 
on the percentage of enterprises sending/receiving e-invoices in a standard structure suitable 
for automatic processing and electronic data to/from public authorities, which may be used as 
a good proxy of structured e-invoicing in public procurement.  

50 
51 

„Cross-border public procurement above EU thresholds”, Rambøll Management, May 2011.  
"Global development of Electronic Invoicing" Karri Lehtonen, Basware, 2012. 

16 

 
 
 
                                                 
Figure  3):  Enterprises  sending  /  receiving  e-invoices  in  a  standard  structure  suitable  for  automatic 
processing and electronic data to/from public authorities in 2011 [%] 

Source: Eurostat, E_INV2_ADEGOV  

The  EU  average  of  12%  confirms  that,  for  enterprises,  exchanging  e-invoices  with  public 
authorities in Europe is still more an exception rather than a rule. 

Looking at the data from a different perspective, namely the share of e-invoices in all invoices 
received  (i.e.  e-invoicing  market  penetration),  a  similar  picture  emerges.  According  to  a 
number  of  recent  studies,  e-invoicing  makes  up  approximately  4  -  15%  of  invoicing 
procedures in the EU52. This is in line with the Eurostat data, and there is therefore no reason 
to  assume  that  the  percentage  of  e-invoicing  penetration  would  be  significantly  higher  in 
public procurement.  

2.1.5.  Main stakeholders concerned 

The main groups of stakeholders that may be affected by the EU initiative on e-invoicing in 
public procurement are: 

•  Member States (understood as policymakers at all levels), who would implement 

the new initiative (including possibly the transposition of legislation). 

•  Contracting authorities, as purchasers of goods, works and services, who apply the 

provisions of the Directives; 

•  Firms,  including  SMEs53  (i.e.  suppliers),  who  sell  works,  goods  and  services  to 

contracting authorities (i.e. are active on public procurement markets); 

•  Enterprises providing e-invoicing services (e-invoicing service providers). 

52 

53 

For  example:  "E-invoicing  2010  –  Current  status  of  e-invoicing  in  Europe",  EBA/Innopay,  page  25, 
refers  to  the  e-invoicing  adoption  rate  of  4-15%  (2008);  "E-invoicing/E-billing,  International  Market 
Overview & Forecast", Bruno Koch, Billentis, February 2012 refers to the B2B/ B2G/G2B electronic 
share of 6-14% (2008 to 2011). 
In 2006-08 the SMEs’ share of public procurement contracts above EU thresholds was estimated to be 
60% of the number of contracts awarded, and 34% in terms of total value. 

17 

 
 
 
                                                 
2.2. 

Problem definition 

Based upon research of the e-invoicing market and the results of the public consultation, the 
existence  of  multiple  non-interoperable  (national  and  proprietary)  e-invoicing  standards 
across the EU has been identified as the main problem driver with regards to the exchange of 
invoices in public procurement. This driver results in an excessive level of complexity, legal 
uncertainty and additional operating costs for firms when issuing invoices across the EU. As a 
consequence, firms encounter market access barriers that deter them from bidding on public 
procurement  in  other  Member  States,  which  in  turn  translates  into  inefficiencies  in  the 
functioning of the Internal Market. 

However,  the  identified  problems  must  also  be  placed  in  a  broader  context,  where  despite 
efforts to stimulate and promote the use of e-invoicing across the EU, and despite the broad 
acknowledgment  of  the  economic,  environmental,  and  other  benefits  of  its  use,  the  public 
sector  across  the  EU  has  been  quite  unresponsive.  As  mentioned  earlier  in  this  Impact 
Assessment,  the  use  of  e-invoicing  in  the  EU  remains  limited,  particularly  in  public 
procurement. This appears to be to some extent a case of market failure, where market forces 
have  not  been  sufficient  to  drive  forward  changes  in  public  procurement  processes  which 
offer significant potential benefits to all stakeholders. The reasons for this can only be guessed 
at, but most likely include a mixture of bureaucratic inertia, the difficulties of process change, 
and the effects of the short-term nature of the political cycle.  

The  above  situation  results  in  the  continued  predominance  of  inefficient  paper-based 
invoicing  processes  in  EU  public  procurement,  with  all  the  negative  side-effects  which  this 
implies.  The  scale  of  these  inefficiencies  corresponds  to  the  potential  benefits  which  are 
foregone due to the fact that e-invoicing is not being used54.  

The  problem  tree  which  summarises  the  above  finding  is  presented  in  Figure  4),  where 
problem drivers, problems, and their consequences are presented together with the context of 
the low uptake of e-invoicing in public procurement.  

54 

These benefits are presented in Annex 1.3. 

18 

 
 
                                                 
Figure 4): Problem tree 

19 

 
 
 
2.2.1.  Problem driver (D0) 

The  e-invoicing  market  in  Europe  is  characterised  by  the  existence  of  many  (national  and 
proprietary)  standards.  Examples  of  e-invoicing  standards  used  in  the  EU  are  provided  in 
Table 1) below. 

Table 1): Examples of e-invoicing standards 

Industry specific standards 

National standards 

ODETTE 

PIDX 

CIDX 

Facturae (Spain) 

ebInterface (Austria) 

OIOUBL (Denmark) 

Svefaktura (Sweden) 

ZUGFeRD (Germany) 

Common global and regional 
standards 

UN/CEFACT Cross Industry Invoice 
(CII) version 2 

UN/EDIFACT 

ANSI X12 

eCOM (includes GS1 EANCOM and 
GS1 XML) 

ebXML 

UBL 

RosettaNet 

Source: "European e-invoicing guide for SMEs"  
European e-business lab, pages 54-56 and DG Internal Market and Services research. 

These and probably quite a few more global, regional, and industry-specific standards coexist 
in  the  EU.  Most  of  these  standards  are  not  interoperable  and  none  of  them  appear  to  be 
dominant. 

Paradoxically, the multiplicity of standards and lack of a dominant technical solution creates a 
“vicious circle” situation, where even more new standards appear on the market. As one of the 
e-invoicing service providers has pointed out, “lack  of information about existing standards 
has resulted in the re-invention of dozens of niche standards (domestic or industry focus)”55. 

Despite  the  co-existence  of  many  non-interoperable  standards  on  the  market,  a  number  of 
Member States, who have recognised the economic benefits of e-invoicing, have decided to 
make  it  mandatory  (de  facto  or  de  jure)  in  public  procurement  within  their  national 
administrations56. However, in a situation where no clear indication exists on which standard 
to use, when making the decision to facilitate or mandate the use of e-invoicing, governments 
(both  national  and  local)  frequently  decide  to  come  up  with  their  own  technical  solutions, 
based on a separate national standard.  

For example, e-invoicing is currently mandatory in Denmark and Sweden, and it will become 
mandatory  in  Austria  as  of  2014.  In  these  three  countries  only,  three  different  technical 
solutions  have  been  chosen:  Denmark  requires  the  use  of  OIOUBL  (based  on  UBL  2.0), 

55 
56 

"Global development of Electronic Invoicing" Karri Lehtonen, Basware, 2012. 
An overview of the implementation of e-invoicing in the EU is provided in Annex 1.6. 

20 

 
 
                                                 
Sweden  recommends  the  use  of  the  Svefaktura,  while  Austria  has  opted  for  PEPPOL 
solutions. 

This  process  of  fragmentation  is  continuing,  as  even  more  standards  are  appearing  or  will 
soon appear on the market driven by government initiatives:  

• 

• 

• 

• 

• 

• 

Spain  currently  makes  it  possible  for  the  central  government  to  accept  electronic 
invoices on a voluntary basis, and has established a national standard to facilitate the 
exercise (known as Facturae).  

Italy  has  passed  basic  laws  on  mandatory  e-invoicing,  and  is  planning  to  introduce 
mandatory  e-invoicing  “in  the  near  future”  on  the  basis  of  an  XML-based  national 
standard.  

The Czech Republic allows their governmental departments to mandate e-invoicing 
if  they  so  choose  and  a  non-mandatory  national  standard  exists  (ISDOC  based  on 
UBL 2.0).  

The  German  national  e-invoicing 
(Forum  elektronische  Rechnung 
Deutschland  or  FeRD),  supported  by  the  German  Ministry  of  Economy  and 
Technology,  has  recently  unveiled  a  German  national  standard,  known  as 
ZUGFeRD.  

forum 

Belgium is preparing a pilot project, allowing the submission of e-invoices to certain 
departments and/or regions. A UBL-based standard will be mandatory.  

The Netherlands has established an e-invoicing portal (Digipoort) and obliges central 
government bodies to accept e-invoices if they are submitted via this portal. One of 
two specific standards (UBL and a Dutch version of an XML-based standard) must 
be used to do so. 

Additionally,  e-invoicing  is  being  used  by  some  government  departments,  public  sector 
organisations, and localities across the EU, although no specific laws regulating the practice 
currently exist. 

The  above  clearly  highlights  the  problem:  if  at  some  point  in  the  future  all  Member  States 
decide to switch to e-invoicing and each of them choses its own e-invoicing standard, a huge 
number  of  combinations  of  standards  would  be  possible  when  sending  and  receiving  e-
invoices (e.g. even if only the 15 e-invoicing standards mentioned in Table 1 are considered, 
this  results  in  more  than  100  different  combinations).  To  combat  the  problem  of  these 
multiple  matches,  translation  between  the  standards  is  necessary  –  a  process  known  as 
‘mapping’. In theory, the mapping can be carried out by any market operator, but in practice, 
most of this work has been delegated to service providers. 

The multiplicity of e-invoicing standards and the need to map them has resulted in a number 
of  models  which  are  applied  to  the  exchange  e-invoices.  These  are  usually  categorised  as: 
bilateral exchange, 3-corner models, and 4-corner models57. Due to the fact that it allows each 
of the parties  to  an e-invoicing transaction  to work through its own service provider,  the 4-

57 

More detailed description of the e-invoicing models is provided in Annex 0. 

21 

 
 
                                                 
corner  model  is  generally  considered  to  be  the  most  efficient  and  flexible  system  for 
exchanging e-invoices. However, such a system is still based on a bilateral exchange (in this 
case between two service providers) and it therefore still requires a large number of bilateral 
agreements on the method of communication to be used between them.  

A  report  by  EBA/Innopay  summarises  the  difficulties  of  the  current  organisation  of  the  e-
invoicing  market  based  on  the  above  data  exchange  models,  stating  that  “these  market 
developments  have  resulted  in  a  tendency  towards  separation  and  segmentation,  often 
described as “silos”58. A similar diagnosis of the current situation can be found in a Deutsche 
Bank Research document, which stresses that “e-invoicing providers who offer their services 
as external contractors have not established a market standard to date. Also the high number 
of  more  than  400  e-invoicing  providers  in  Europe  has  contributed  to  the  existing  siloed 
solutions.  […]  sending  invoices  electronically  between  clients  of  different  providers  is 
frequently impossible because of technical disparities.”59 

The  proliferation  of  e-invoicing  standards  therefore  requires  significant  investments  from 
service providers to be able to support them and elevated operating costs in order to perform 
the mappings. The degree of difficulty – and therefore of the associated costs – to a significant 
extent  depends  on  the  service  providers’  ability  to  sign  interoperability  agreements.  Several 
attempts have recently been made to simplify this process; however, due to the fact that all of 
these efforts have focused on a bilateral approach, none of them have resolved the problem of 
the  multiplicity  of  potential  combinations  of  standards.  Even  where  interoperability  can  be 
ensured  by  means  of  a  bilateral  agreement,  considering  the  number  of  such  players  on  the 
market  (in  excess  of  400)  and  the  number  of  different  standards,  several  thousand  different 
agreements  would  be  required  in  order  to  ensure  full  general  interoperability.  This  is,  for 
obvious reasons, very resource-intensive and, until now, has not been feasible.  

Concluding,  the  multiplicity  of  non-interoperable  standards  (D0)  dominates  the  EU  e-
invoicing  landscape.  Member  States  are  co-responsible  for  the  observed  spur  of  e-invoicing 
solutions, as several of them have required that invoices submitted to the public sector must 
comply with specific – frequently national and non-interoperable – standards.  

2.2.2.  Problem (P1) – excessive complexity and legal uncertainty for firms 

The existence of many different e-invoicing requirements and standards across the EU results 
in  an  excessive  level  of  complexity  and  legal  uncertainty  (P1)  for  firms  when  issuing 
invoices  to  another  Member  State.  This  situation  is  not  only  burdensome  for  suppliers,  but 
presents a risk that their e-invoices might not be accepted by buyers in other Member States. 
The fact that cross-border e-invoicing is problematic is confirmed in various publications. For 
example,  the  Euro  Banking  Association  underlines  the  fact  that  barriers  to  adoption  of  e-
invoicing persist, especially in the area of legal/tax rules and a lack of EU-wide harmonisation 
and clarity, which complicates intra EU–invoicing60.  

Similar views have been collected within the PEPPOL project, where a representative of an 
enterprise  currently  using  e-invoicing  in  public  procurement  has  stated  the  following:  “We 
currently support many different standards, versions of standards and formats and this is not 

58 
59 
60 

“E-invoicing 2010, European market guide”, Euro Banking Association (EBA) and Innopay.  
”E-invoicing - Final step of an efficient invoicing process”, Deutsche Bank Research, May 3, 2010.  
“E-invoicing 2010, European market guide”, Euro Banking Association (EBA) and Innopay. 

22 

 
 
                                                 
sustainable  anymore.  If  you  look  at  the  cost  benefits  of  automation,  supporting  4  different 
standards represents a break-even point for us […]. Every new format or standard requires 
training, learning the codes, developing and testing new code, and then maintaining it. It is a 
serious investment and maintenance cost.”61 

In the public consultation concerning this initiative, the multiplicity of standards/requirements 
in  e-invoicing  was  identified  as  one  of  the  main  barriers  to  the  adoption  of  e-invoicing  by 
firms. 

Figure 5): Reasons for not using e-invoicing – public consultation results 

Source: DG Internal Market and Services 

The  results  of  the  above-mentioned  consultation  also  show  that  a  lack  of  clarity  concerning 
applicable  laws  and  regulations  is  the  third  most  frequently  mentioned  reason  which 
discourages firms from e-invoicing (see: Figure 5). 

Complexity  and  legal  uncertainty  concerning  the  acceptance  of  an  invoice  in  different 
Member  States  was  also  mentioned  by  SMEs  in  a  survey  on  the  use  of  e-invoicing  in 
Europe62. For example, the fear of lack of acceptance of invoices abroad was mentioned by as 
many as 47% of firms from Austria and 21% from Italy. In Spain and Finland this concern 
was mentioned less frequently, but around one in ten firms still perceived it as a problem (see: 
Table 2). 

61 

62 

“Supplier  perspectives  on  the  challenges  of  eInvoicing  with  the  public  sector”  by  Roman  Weber, 
PEPPOL. 
The  survey  was  conducted  in  2008  by  PricewaterhouseCoopers  (PwC)  in  Finland,  Austria,  Italy  and 
Spain.  The number  of replies  received: 694  (FI), 126 (AT), 60  (IT)  and 34 (ES);  source:  Annex 2 of 
„European E-Invoicing Guide for SMEs”. 

23 

 
 
 
                                                 
Table 2): Survey of SMEs – problems of e-invoicing 

What  do  you  regard  as  potential  problems  of 
electronic invoicing? [in %] 

AU 

FI 

IT 

ES 

Complexity 

27,0  

18,9  

23,9 

21,4 

Expensive/high investment required  

12,3  

17,5  

15,6  

11,1 

Concerns over return on investment  

14,2  

9,2  

13,9  

14,8 

Readiness/compatibility of internal systems  

30,4  

34,6  

36,0  

20,0 

Customer compatibility/readiness  

36,0 

51,8  

23,9  

20,7 

Legal uncertainty concerning the acceptance of the invoice in 
different Member States 

46,8  

9,4  

21,4  

12,0 

There are no barriers  

10,3  

11,6  

20,8  

15,0 

Other 

23,7  

10,3  

0,0 

15,4 

Source: "European e-invoicing guide for SMEs"  

In practice, the risk of non-acceptance abroad is typically driven by the existence of different 
technical standards. This is also confirmed by the fact that a lack of “customer compatibility” 
scores  high  on  the  list  of  problematic  issues  for  SMEs  (e.g.  mentioned  by  51%  firms  in 
Finland).  Uniform  technical  requirements  would  undoubtedly  simplify  the  e-invoicing 
processes as compatibility between buyers and sellers would be ensured. 

2.2.3.  Problem (P2) – higher costs for firms  

As  mentioned  above,  the  existence  of  multiple  requirements,  standards,  solutions,  and 
networks/platforms across the EU results in a very complex situation.  Since these standards 
and  systems  are  not  interoperable,  and  as  no  common  standard  is  available  on  the  market, 
firms  which  want  to  carry  out  cross-border  procurement  activities  are  often  required  to 
support, in one way or another, a new invoicing standard each time they access a new market. 
This  in  turn  generates  additional  costs,  irrespective  of  whether  the  invoices  are  submitted 
directly  (which  requires  additional  expenditure  on  creating  new  mapping  possibilities)  or 
through service providers (which will charge higher fees). Whether done via service providers 
or directly, the need to introduce new interoperability requirements increases operating costs 
for economic operators (P2), i.e. the costs of doing business cross-border. 

The  problems  of  these  excessive  costs  are  also  recognised  by  firms  participating  in  public 
procurement:  “There  are  several  fee  structures  that  service  providers  typically  use  for  e-
Invoicing:  from  free  for  suppliers,  a  fixed  subscription  fee,  a  fixed  fee  per  invoice  to  a 
percentage fee on the amount of the invoice. So, in addition to the technical complexities we 
also have to evaluate the fee structure when deciding to support a customer’s request for e-
Invoicing or not. Some service providers have acceptable fee structures but there are others 
that for example charge a percentage of the amount of the invoice, so the exchange of a large 
invoice could cost us 1.500 Euro or more, even though it is exactly the same process whether 
you  exchange  a  100  Euro  or  a  1  million  Euro  invoice.  This  simply  does  not  make  sense 

24 

 
 
economically. In such case we will contact the customer and revert back to a 100% manual 
process for a large invoice. This obviously defeats the whole purpose of automation for both 
customer and supplier but it allows us to save a significant amount of money.”63 

The  exact  amount  of  additional  costs  for  firms  generated  by  the  need  to  adapt  to  multiple 
standards  is  difficult  to  quantify,  since  as  mentioned  above,  service  providers  use  various 
business  models  and  pricing  schemes,  which  typically  depend  on  the  volume  of  invoices 
generated by the supplier. It is evident, however, that the need to support each additional e-
invoicing standard leads to additional operating costs for firms. In passing, it should be noted 
that these higher operating costs may be especially burdensome for SMEs, and in particular 
for microenterprises.  

Finally,  it  is  important  to  note  that  it  is  not  only  suppliers  that  are  faced  with  the  problems 
stemming from the multiplicity of e-invoicing standards across the EU. The higher operating 
costs  for  these  firms,  which  result  from  the  need  to  support  several  different  standards, 
indirectly also have a negative effect on the buyers. In order for the firms to make the same 
level of profit, higher prices need to be charged for their products or services, and these higher 
prices are ultimately paid by the contracting authorities. This aspect links the problems with 
the contextual aspects, such as the suboptimal use of resources in public procurement. 

2.2.4.  Consequences (C1, C2) 

The  need  to  adapt  to  multiple  interoperability  requirements  generates  excessive  complexity 
and  legal  uncertainty  (P1)  and  increases  the  operating  costs  (P2)  for  firms  doing  business 
cross-border.  

The divergent legal or technical requirements, which are either “non-standardised” or adopted 
in  the  form  of  national  standards,  can  constitute  market  access  barriers  in  cross-border 
public  procurement  (C1)  -  in  the  same  way  as  any  other  unknown  legal  or  administrative 
requirements. These divergent requirements could be perceived as technical barriers to trade64 
and generate investment risk. In the worst-case scenario, the two above-mentioned problems 
might deter firms from bidding in public procurement in other Member States, meaning that 
enterprises  would  pass  up  on  potential  business  opportunities  due  to  specific  e-invoicing 
requirements which they cannot support (or which they judge too expensive to support)65. 

According  to  a  survey  held  in  2011  by  Rambøll  Management66,  for  71.5%  of  firms,  legal 
requirements  leading  to  market  entry  barriers  in  the  awarding  country  are  perceived  as 
relevant or highly relevant obstacles to cross-border bidding in public procurement (i.e. high 
relevance  for  47.6%  and  medium  relevance  for  23.9%  respondents).  “Unfamiliar  formal 

63 

64 

65 

66 

“Supplier  perspectives  on  the  challenges  of  eInvoicing  with  the  public  sector”  by  Roman  Weber, 
PEPPOL. 
The World Trade Organisation recognises that regulations and product standards, if set arbitrarily, could 
be used as an excuse for protectionism (source: http://www.wto.org/english/tratop_e/tbt_e/tbt_e.htm). 
“[A]s long as it is unclear which e-invoicing standard will establish itself in the market some companies 
will shy away from making any long-term investments. After all, with specific investments it is not only 
the direct expenditure but also indirect costs that play a part. The company decides on a particular e-
invoicing solution. This could rule out business associates who do not adopt this system and this may 
raise  the  barriers  when  looking  for  new  suppliers  or  customers.  These  indirect  costs  would  not  be 
incurred  if  interoperability  between  e-invoicing  providers  were  to  be  achieved.”  “E-invoicing  -  Final 
step of an efficient invoicing process”, Deutsche Bank Research, May 3, 2010. 
"Cross-border procurement above EU thresholds”, Rambøll Management, May 2011. 

25 

 
 
                                                 
requirements demanded” were important or very important for 63.1% of firms. The detailed 
results of the survey are provided in Figure 6.  

Figure 6): Businesses' views on several possible obstacles to cross-border bidding 

Source: "Cross- border procurement above EU thresholds”, Ramboll Management, May 2011 

If the above examined legal uncertainty (P1) and higher costs  (P2) resulting from different e-
invoicing  requirements  were  to  be  classified  respectively  under  the  headings  “legal 
requirements” and “unfamiliar formal requirements” in the above survey, its findings would 
then show that the persistence of these obstacles discourages firms from participating in cross-
border public procurement. 

Similarly,  the  connection  between  e-invoicing  and  cross-border  public  procurement  is 
confirmed  by  the  results  of  the  public  consultation,  where  72%  of  661  respondents  either 
agreed or strongly agreed with the statement: "If the EU established a common standard for e-
invoicing 
transactions  would  be 
facilitated". Only 10% disagreed or strongly disagreed. The proportion was almost identical 
for  enterprises,  i.e.  the  stakeholders  most  directly  concerned:  71%  either  agreed  or  strongly 
agreed with the statement while a mere 8% disagreed or strongly disagreed (out of 122 firms 
which replied).  

in  public  procurement,  cross-border  procurement 

26 

 
 
 
Figure 7): Impact of EU common standard for e-invoicing on cross-border procurement  

Source: DG Internal Market and Services – results of the IPM public consultation, Dec 2012 – Jan 2013 

Finally, the risk of emergence of market entry barriers in cross-border public procurement due 
to  functional  as  well  as  technical  IT  characteristics  was  identified  as  early  as  2004  in  the 
Commission Communication “The Action plan for the implementation of the legal framework 
for  e-procurement”.  This  Communication  recognises  that  “barriers  for  businesses  may 
emerge  in  cross-border  tendering,  if  design  of  IT  standards  is  incompatible.  Diversity  and 
incompatibility of technical solutions can render suppliers’ access to e-procurement systems 
impossible  or  discourage  their  participation  because  of  additional  difficulties  or  increased 
costs”67. 

To  summarise,  both  the  higher  operating  costs  for  enterprises  and  the  excessive 
complexity/legal  uncertainty  generated  by  the  need  to  acquire  and  maintain  interoperability 
between various invoicing systems are a potential source of market access barriers in cross-
border procurement (C1), which ultimately leads to a situation where e-invoicing regimes 
are still delineated along national borders. Where it does take place in the EU, e-invoicing is 
for  the  most  part  limited  to  separate  –  often  national  –  networks,  creating  'islands  of  e-
invoicing' in the Internal Market. The domination of national e-invoicing regimes and national 
lower  cross-border  bidding,  fewer  participating 
technical  solutions/standards  means 
companies,  and  therefore  lower  competition,  which  in  turn  translates  into  an  inefficient 
functioning of the Internal Market (C2).  

2.3. 

Developing a baseline scenario 

The baseline scenario consists of the EU undertaking no additional measures with regards to 
e-invoicing in public procurement beyond those which have already been implemented. 

67 

“Action  plan  for  the  implementation  of  the  legal  framework  for  electronic  public  procurement”, 
Communication from the Commission, Brussels, 13.12.2004. 

27 

 
 
 
                                                 
The  EU's  policy  towards  e-invoicing  is  currently  set-out  in  the  2010  e-invoicing 
Communication68, in which the use of e-invoicing was recommended and self-regulation on 
the basis of a number of guidelines was urged. This Communication recognises that if the full 
benefits  of  e-invoicing  are  to  be  realised,  public  sector  initiatives  in  the  Member  States  are 
critical  to  accelerate  its  uptake  and  market  penetration.  In  order  to  achieve  this,  the 
Commission recommends that Member States should develop national strategies "to promote 
e-invoicing  at  national  level,  including  by  setting  targets  for  the  adoption  level  of  e-
invoicing". 

The  Communication  also  recognises  the  drawbacks  of  the  multiplicity  of  standards  for  e-
invoicing. In particular, it points out that "the diversity of data and usage requirements, and 
very different approaches to their implementation, have led to market fragmentation" and that 
"as  a  consequence,  market  players,  such  as  enterprises,  software  companies  and  financial 
service  providers  nowadays  need  to  support  multiple  formats,  necessitating  the  need  for 
substantial  mapping  and  conversion  exercises  to  cope  with  data  expressed  in  different 
syntaxes." 

In  order  to  overcome  this  fragmentation,  the  2010  e-invoicing  Communication  asked 
international  and  European  standard-setting  bodies  to  undertake  efforts  to  facilitate 
convergence on and implementation of the chosen data model. However, the Communication 
stated  that  it  should  be  left  to  the  market  to  define  how  this  data  model  is  subsequently 
adapted to suit specific business needs. In line with this approach, the Commission has also 
implemented  or  funded  projects  of  its  own  to  promote  the  use  and  interoperability  of  e-
invoicing at European level, with a particular focus on the B2G/public procurement domain 
(e.g. the e-PRIOR and PEPPOL projects; see Annex 1.7 for details).  

Three years on from the publication of the 2010 e-invoicing Communication, the situation is 
less than optimal. Although a small number of Member States have taken some steps towards 
implementing  e-invoicing  in  public  procurement  and  a  few  others  are  considering  action  in 
this direction, these initiatives are uncoordinated and inconsistent.  

As  mentioned  previously,  Denmark,  Finland,  and  Sweden  had  already  required  the 
submission  of  e-invoices  before  the  2010  e-invoicing  Communication  was  adopted,  and  a 
number  of  other  Member  States  have  recently  launched  projects  (e.g.  Austria,  Ireland, 
Belgium, the Czech Republic, Germany) to introduce e-invoicing in the public sector, which 
could be considered as their response to the recommendations published in 2010.  

However, this gradual and uncoordinated progress in the adoption of e-invoicing by Member 
States  (including  via  a  mandatory  approach)  only  aggravates  the  interoperability  problem 
described  in  Section  2.2,  as  ever  more  technical  standards  and  requirements  need  to  be 
supported  by  suppliers  in  order  to  be  able  to  send  e-invoices  to  Member  States’  public 
administrations across the EU. These initiatives are therefore bringing further complexity and 
fragmentation  to  the  Internal  Market.  So  far,  only  three  EU  Member  States  have  opted  to 
implement inter-operable solutions based on EU co-funded projects: PEPPOL in Austria and 
foreseen  in  Ireland,  and  e-PRIOR,  currently  being  implemented  by  the  Belgian  Federal 
administration.  

68 

http://ec.europa.eu/internal_market/payments/docs/einvoicing/com712_en.pdf  

28 

 
 
                                                 
In  undertaking  no  new  EU  action,  it  can  be  expected  that  in  the  foreseeable  future,  the 
adoption of e-invoicing in public procurement in the EU would continue at a slow and steady 
pace, with more and more national standards appearing on the market. Even if some Member 
States  opt  for  interoperable  solutions,  there  is  no  guarantee  that  this  will  be  the  case 
everywhere. Indeed, recent experience suggests otherwise.  

As  a  consequence,  achieving  EU-wide  interoperability  of  e-invoicing  systems  in  public 
procurement  risks becoming increasingly complex and costly,  despite the Commission's on-
going  support  for  this  objective.  Service  providers  (or  buyers  and  suppliers  that  choose  to 
communicate  directly)  would  have  to  cater  for  a  growing  number  of  national  requirements 
and standards. The associated costs would ultimately be borne by suppliers – either directly in 
peer-to-peer  transactions  or  in  the  way  of  fees,  if  service  providers  handle  the  format 
conversions. In other words, market access barriers would not only continue to exist but could 
in fact increase, preventing the Internal Market from functioning correctly.  

2.4. 

The EU's right to act and justification  

2.4.1.  Legal basis 

The  EU’s  right  to  take  action  to  ensure  the  functioning  of  the  Internal  Market  stems  from 
Article 114 of the Treaty on the Functioning of the European Union (TFEU), which provides 
the tools for achieving the objectives set out in Article 26 TFEU. 

Article 114 TFEU would therefore constitute the legal basis for a potential EU initiative on e-
invoicing in public procurement.  

As mentioned in Section 2.1.3, no specific legislation at EU level has until now dealt with the 
post-award  part  of  procurement.  The  current  approach  to  address  the  post  award  stage  is 
clearly driven by IT developments in the area of public procurement. For a long time and until 
recently, invoicing could easily be thought of simply as one of the consequences/outcomes of 
public procurement rather than an integral part thereof, with very little impact on the actual 
procurement itself. As such, it was simply not relevant enough to figure significantly in public 
procurement  policy.  However,  the  recently  observed  adoption  of  electronic  procurement 
methods and tools has significantly changed the procurement processes, which have become 
much  more  integrated  and  the  digitalisation  of  all  elements  of  the  procurement  cycle  is 
nowadays  a  reality69.  The  above  IT-driven  changes  in  the  public  procurement  process  have 
necessitated a reassessment of the pre-award / post award division.  

The fact that a number of Member States have introduced electronic tools and processes into 
invoicing and that several of them have made it mandatory, means that these practices are the 
source of new market access barriers in cross-border public procurement. As has been shown 
in  Section  2.2.1,  the  existing  or  planned  national  rules  are  based  on  different  national 
standards  which  are  not  interoperable.  There  is  now  a  real  risk  of  an  enterprise  not 
participating  in  cross-border  public  procurement  due  to  the  inability  to  meet  e-invoicing 
requirements  of  a  particular  Member  State70;  hence  the  introduction  of  electronic  invoicing 

69 

70 

For  example  the  PEPPOL  project  targeted  both  the  pre-award  and  post-award  stages  of  procurement 
process  (in  the  pre-award  phase:  e-signatures,  a  Virtual  Company  Dossier,  e-catalogues;  in  the  post-
award phase: e-catalogues, e-orders and e-invoicing). 
Put differently, if a public contract requires electronic invoicing in a particular format, and an enterprise 
in another Member State interested in participating does not currently support that standard, it is faced 

29 

 
 
                                                 
has  recently  started  to  have  a  direct  impact  on  public  procurement.  As  has  been  argued  in 
Section  2.2.4,  these  new  technological  market  access  barriers  (unknown  e-invoicing 
standards, non-interoperable functional requirements, etc.) hinder the efficient functioning of 
the Internal Market.  

There is therefore an urgent need to address the emerging problem of market access barriers 
before additional Member States enact their own unique national standards for e-invoicing in 
public  procurement.  Article  114  TFEU  provides  the  most  appropriate  legal  basis  for  a 
legislative act harmonising the de facto and de jure actions undertaken by Member States in 
the area of e-invoicing.  

2.4.2. 

Subsidiarity and proportionality  

EU  action  in  the  area  of  e-invoicing  in  public  procurement  is  justified  on  grounds  of 
subsidiarity and proportionality.  

(1) 

Necessity Test  

As  described  in  Section  2.2,  the  number  of  existing  standards,  requirements,  and  solutions 
remains very large and e-invoicing networks appear to be growing more, not less, entrenched 
along national boundaries. The bottom-up initiatives from Member States have aggravated the 
interoperability problem, as more e-invoicing standards have emerged on the market, further 
increasing the costs and complexity of ensuring interoperability. The fact that uncoordinated 
standardisation activities at Member State level can lead to conflicting national standards and 
impediments  to  the  functioning  of  the  Internal  Market  has  already  been  recognised  in  the 
acquis71. European standards therefore play a very important role within the internal market72, 
and such standardisation by nature requires coordination at the EU level.  

In the particular context of public procurement, actions undertaken by Members States, which 
frequently  involve  the  introduction  of  national  standards,  are  not  sufficient  to  ensure  e-
invoicing interoperability in cross-border procurement.  

(2) 

EU added value  

The  rationale  for  an  EU  action  stems  from  the  transnational  nature  of  the  problem  of 
insufficient interoperability between national (and proprietary) e-invoicing systems. Given the 
cross-border nature of public procurement transactions covered by the Directives and the lack 
of  any  meaningful  efforts  on  the  part  of  the  Member  States  to  resolve  the  interoperability 
issues,  an  EU  action  on  e-invoicing  in  public  procurement  seems  to  be  the  only  solution 
available  to  co-ordinate  their  actions  and  to  prevent  further  fragmentation  of  the  Internal 
Market.  Furthermore,  only  the  EU  can  act  as  an  unbiased  arbiter  in  the  discussion  on 
interoperability and objectively recommend the best approach to eliminating market barriers. 

with two choices: either it undertakes an investment which will allow it to invoice using that particular 
standard, or it passes on bidding on the public contract in question. Either way, a barrier to cross-border 
public procurement is created.  
Recital  (14)  of  Regulation  (EU)  1025/2012:  “Within  the  Union,  national  standards  are  adopted  by 
national standardisation bodies which could lead to conflicting standards and technical impediments in 
the internal market.“ 
Recital (5) of Regulation (EU) 1025/2012. 

71 

72 

30 

 
 
                                                                                                                                                         
There is little indication that, without EU action, the current situation concerning e-invoicing 
in public procurement will change or improve in the foreseeable future. 

(3) 

Proportionality 

Under  the  principle  of  proportionality  (Article  5(4)  TEU),  the  content  and  the  form  of  EU 
action  shall  not  exceed  what  is  necessary  to  achieve  the  objectives  of  the  Treaties.  The 
potential  EU  initiative  considered  in  this  Impact  Assessment  will  be  limited  only  to  those 
aspects of e-invoicing in public procurement that Member States cannot achieve satisfactorily 
on  their  own,  with  the  aim  of  respecting  the  heterogeneity  of  requirements  and  invoicing 
traditions among industries, geographies and jurisdictions, as well as the existence of legacy 
IT systems currently used by some Member States. The proportionality of the different policy 
options has been assessed and the result of this assessment is described in the relevant part of 
this Impact Assessment (see, in particular, Sections 5 and 6.1).  

2.4.3. 

Justification for EU action on e-invoicing in public procurement 

The existence of the problems and consequences described in sections 2.2.1 to 2.2.4 is widely 
recognised  by  stakeholders,  as  has  been  shown  in  these  sections  by  quoting  their  views  or 
citing  the  results  of  various  surveys.  The  majority  of  the  stakeholders  share  the  view  that 
action at EU level should be undertaken to facilitate interoperability in e-invoicing (e.g. 85% 
of  respondents  to  the  IPM  consultation  support  a  possible  EU  initiative  to  enhance 
interoperability  in  e-invoicing)73.  For  many  –  especially  firms  which  consider  using  e-
invoicing – “government policy emerges as the most important determinant of progress in e-
invoicing adoption”74. The latter statement also links the problem definition with the context 
of  the  low  uptake  of  e-invoicing  in  the  public  sector,  as  stakeholders  would  very  much 
appreciate seeing governments as front-runners in this area. 

EU  intervention  concerning  e-invoicing  in  public  procurement  is  also  justified  despite  the 
relatively low level of cross-border procurement in the EU75, as market access barriers driven 
by  insufficient  e-invoicing  interoperability  can  influence  firms’  propensity  to  bid  on  public 
procurement  in  other  Member  States.  As  a  result,  it  can  be  argued  that  this  low  level  is 
actually  a  result  of  the  existing  barriers.  Such  an  assessment  is  also  in  line  with  WTO 
practice76:  where  differences  in  technical  regulation  and  standards  may  be  recognised  as 
potential  unnecessary  obstacles  to  trade,  the  volume  of  the  cross-border  procurement  is 
incidental, since any potential barrier to trade may have an impact on the market. Therefore 
theoretically, if barriers to cross-border e-invoicing were removed, the volume of cross-border 
procurement could rise significantly.  

73 
74 

75 

76  

Summary of stakeholders views are presented in Annex 1.11.  
“Good  practices  in  the  adoption  and  promotion  of  e-invoicing  in  Europe:  Results  of  the  EMSF  good 
practices  consultation”  -  ACCA  Discussion  Paper  prepared  for  Activity  Group  2  of  the  European 
Multi-stakeholder Forum on e-invoicing, London, August 2012.  
In  2006-2009  direct  cross-border procurement  accounted  for  around  1.6%  of  the  number of  contracts 
awarded and around 3.5% of their value, see: section 2.1.4 
World Trade Organisation, http://www.wto.org/english/tratop_e/tbt_e/tbt_e.htm. 

31 

 
 
                                                 
3. 

OBJECTIVES 

3.1. 

General objective 

The  primary  objective  of  this  initiative  would  be  to  improve  the  functioning  of  the  Internal 
Market  by  introducing  mechanisms  that  would  diminish  market  access  barriers  in  cross-
border public procurement, generated by insufficient interoperability of e-invoicing technical 
requirements or standards. 

3.2. 

Specific objectives 

The specific objectives contributing to the achievement of the general objective would be the 
following: 

–  Reduce  complexity  and  improve  clarity  and  legal  certainty  for  economic 
operators  (to  combat  problem  P1),  by  enabling  firms  to  send  invoices  in 
standards with which they are familiar and which will be widely accepted; 

–  Lower  operating  costs  for  economic  operators  participating  in  cross-border 
public procurement (to combat problem P2), such as cost of supporting multiple 
e-invoicing standards and systems. 

3.3. 

Operational objective 

Considering  the  main  problem  driver  highlighted  in  Section  2.2,  as  well  as  the  general  and 
specific objectives described above, the following operational objective has been identified:  

–  Create  conditions  for  the  emergence  of  (a)  technical  solution(s)  for  e-
invoicing 
in  public  procurement  which  would  ensure  cross-border 
interoperability – in other words, create conditions in which communication and 
mapping  between  e-invoicing  systems  will  be  less  resource-intensive,  allowing 
buyers and sellers to exchange invoices in public procurement at the lowest cost 
and with minimal complexity.  

It is proposed to implement this initiative within as short a period of time as possible for all 
contracting authorities which award public procurement contracts covered by the Directives. 
Taking into consideration the necessity of developing a common standard and the time which 
this requires, the most realistic deadline for the introduction of a technical solution that would 
ensure  cross-border  interoperability  appears  to  be  between  2017  and  2018.  Such  a  deadline 
would be coherent with the 2010 e-invoicing Communication77, which called for e-invoicing 
to become the predominant method of invoicing in Europe by 2020. 

4. 

POLICY OPTIONS 

With  a  view  to  achieving  the  above-stated  objectives  in  the  most  effective  and  efficient 
manner, the following policy options are proposed:  

77 

"Reaping 
COM(2010)712. 

the  benefits  of  e-invoicing 

for  Europe",  European  Commission  Communication, 

32 

 
 
                                                 
–  Option  (1)  -  No  new  EU  action  (“no  change”):  no  new  action  would  be 
undertaken  at  the  EU  level;  the  Commission  would  continue  to  monitor  the 
implementation of the 2010 e-invoicing Communication, expecting self-regulation 
among  stakeholders  or  the  conclusion  of  multilateral  agreements  between  e-
invoicing service providers; 

–  Option  (2)  -  Free-choice  approach:  the  EU  would  propose  a  European  e-
invoicing standard to the market, but its use would not be obligatory (i.e. the EU 
would recommend it, but the final decision would be left to the stakeholders); 

–  Option  (3)  –  Selective  conversion  to  e-invoicing:  the  EU  would  propose  a 
European  e-invoicing  standard  to  the  market;  the  Member  States  or  contracting 
authorities  which  have  already  made  or  which  subsequently  make  e-invoicing 
mandatory  would  be  obliged  to  accept  invoices  submitted  in  this  standard; 
exchanging e-invoices in other standards would still be allowed if both parties of 
the transaction so agree; 

–  Option  (4)  -  Obligatory  acceptance:  the  EU  would  propose  a  European  e-
invoicing  standard  to  the  market;  the  acceptance  of  invoices  submitted  in  this 
standard would be obligatory for all contacting authorities; exchanging e-invoices 
in other standards would still be allowed if both parties of the transaction so agree;  

–  Option (5) - Full harmonisation: the EU would propose a European e-invoicing 
standard  to  the  market,  which  would  become  the  only  means  of  exchanging 
invoices  in  public  procurement;  exchanging  e-invoices  in  other  standards  would 
no longer be allowed. 

As  explained  in  Section  2.1.1,  the  above  proposals  would  apply  to  public  procurement 
covered  by  the  Directives.  In  all  Options,  firms  would  be  allowed  to  send  paper  invoices 
unless  the  Member  State  or  the  contracting  authority  decides  to  ban  paper  invoicing;  the 
introduction of mandatory sending of e-invoices is not considered in the Options analysed in 
this Impact Assessment.  

33 

 
 
An overview of key differences between the above proposed Options is presented in Table 3). 

Table 3): Key differences between Options 

A new European 
standard is proposed 
to the market 

Member States must 
accept invoices 
compliant with the 
new European 
standard 

Only the new 
European standard is 
allowed 

Option (1): No new 
EU action 

Option (2): Free-
choice approach 

Option (3): Selective 
conversion to e-
invoicing 

Option (4): 
Obligatory 
acceptance 

Option (5): Full 
harmonisation 

NO 

YES 

YES 

YES 

YES 

NO 

NO 

NO/YES 
(YES - only if a Member 
State or a contracting 
authority mandates the 
use of e-invoicing) 

YES 

YES 

NO 

NO 

NO 

NO 

YES 

With  the  exception  of  the  baseline  scenario  (i.e.  Option  (1)  “No  new  EU  action”)  which 
follows  the  recommendations  of  the  2010  e-invoicing  Communication78,  the  remaining 
Options  foresee  that  a  specific  instrument  (a  European  e-invoicing  standard)  would  be 
proposed to the market to facilitate interoperability.  

The  above  raises  a  key  question,  namely  which  technical  solution  should  be  chosen  as  the 
backbone  of  the  new  interoperability  framework.  Theoretically,  the  operational  objective 
defined in this Impact Assessment could be achieved in one of two ways: 

(a) 

choosing one of the existing standards and proposing it to the market, or  

(b)  developing  a  new  standard  and  proposing  it  to  the  market,  e.g.  a  European 

standard (EN).  

These  alternatives  could  constitute  sub-options  of  each  of  the  four  above-mentioned  main 
Options (i.e. the five Options less the baseline scenario). However, for a number of technical 
and practical reasons, such an approach has not been used. The principal reason is that there is 
currently  no  adequate  solution  available  on  the  market  which  could  ensure  cross-border 

78 

http://ec.europa.eu/internal_market/payments/docs/einvoicing/com712_en.pdf 

34 

 
 
 
                                                 
interoperability at the EU level. As such, the development of a European standard remains the 
only  viable  solution.  The  justification  for  the  above  decision  is  presented  in  more  detail  in 
Annex 1.9. 

Finally,  the  proposed  new  European  standard  should  cover  only  the  elements  that  are 
necessary  to  ensure  cross-border  interoperability  in  e-invoicing.  The  exact  scope  of  the  EN 
should  be  left  to  the  relevant  European  Standardisation  organisation  and  follow  the 
standardisation process as defined in Regulation (EU) No 1025/2012. However, at this stage 
of analysis it seems that the new European standard should above all focus on the semantic 
alignment79 of various national standards / technological solutions used in e-invoicing across 
the EU.  

4.1. 

The choice of coercive or non-coercive instruments 

The proposed menu of options ranges from options which would be implemented using soft 
law  measures,  to  options  where  legal  instruments  would  be  necessary.  A  question  arises  if 
coercive instruments should be at all considered in this Impact Assessment, knowing that in 
the public consultation the majority of respondents (52%) preferred voluntary instruments to 
be used in order to enhance interoperability, while 42% chose mandatory and 6% voted for 
both.  

Firstly, the majority in favour of voluntary instruments only slightly outweighs the number of 
supporters  of  mandatory  actions  at  the  EU  level.  Secondly,  the  options  proposed  in  this 
Impact Assessment that envisage some mandatory enforcement of common rules to facilitate 
e-invoicing interoperability in public procurement are actually a mixture of coercive and non-
coercive measures. For example Option (3) foresees coercive measures only with regards to 
the Member States or contracting authorities which have mandated or will mandate the use of 
e-invoicing.  For  the  remaining  stakeholders,  the  use  of  e-invoicing  would  be  voluntary. 
Similarly, Option (4) would contain certain mandatory elements (i.e. an obligation to accept 
invoices if compliant with the new European standard), but the uptake of e-invoicing would 
depend on the decisions made by firms participating in public procurement, and therefore it 
would have a partially non-coercive character. 

Taking into account the fact that the results of the public consultation do not show a clear or 
overwhelming opposition to mandatory action at the EU level and that the proposed initiatives 
to facilitate e-invoicing interoperability in public procurement contain in practice a mixture of 
voluntary and mandatory elements, the proposed menu of options is fully justified and should 
be maintained.  

5. 

ANALYSIS OF IMPACTS 

A specificity of a potential initiative on e-invoicing in public procurement is that most, if not 
all,  of  its  impacts  would  be  observed  irrespective  of  the  Option  chosen,  the  only  difference 
being their size and the speed with which they would materialise. For this reason, before the 
impacts of each Option are analysed, an overview of the common impacts is presented below.  

79 

As defined in European Interoperability Framework (EIF) for European public services, Annex 2 to the 
Communication from the Commission “Towards interoperability for European public services”. 

35 

 
 
                                                 
5.1. 

The expected common impacts 

The  removal  of  market  access  barriers  is  expected  to  generate  impacts  that  are  mainly 
economic in nature, both in terms of the costs and the benefits. The economic costs for both 
firms and public bodies will be limited to the expenditures necessary for the introduction of e-
invoicing  systems  (e.g.  acquisition  of  relevant  software  and/or  hardware).  The  economic 
benefits, on the other hand, will primarily consist of (i) lower operating costs, as well as more 
clarity  and  legal  certainty  for  firms  active  in  public  procurement;  and  (ii)  lower  processing 
costs and lower prices for contracting authorities due to more intense competition (i.e. more 
bids submitted in part due to increased participation of firms from other Member States). Any 
social  and  environmental  costs  would  be  limited.  These  impacts  will  be  referred  to  in  this 
Impact Assessment as ‘primary impacts’. 

The  above  primary  impacts  will  be  supplemented  by  additional  ‘secondary’  or  ’side  effect’ 
impacts, as improved interoperability would most probably translate into increased uptake of 
e-invoicing by both contracting authorities and firms. The secondary impacts of the initiative 
will  be  economic,  social,  and  environmental.  In  some  Options,  these  secondary  impacts  are 
highly  probable,  since  the  availability  of  an  interoperable  European  standard  in  e-invoicing 
could encourage many market players – which until now have been hesitant – to switch to e-
invoicing. Although the wider adoption of e-invoicing is not an objective of this initiative, the 
secondary impacts will nevertheless be analysed for each Option, as they may be significant.   

The  division  into  primary  and  secondary  impacts  to  a  significant  extent  reflects  the  split 
between the key problems and the context identified in section 2.2 (i.e. primary impacts relate 
to the key problems, while the secondary ones to the context of the low e-invoicing uptake by 
the  public  sector).  An  overview  of  these  common  impacts  is  provided  below.  The  extent  to 
which they would materialise will depend on the Option chosen (as analysed in section 5.4). 

5.2. 

Primary impacts 

As mentioned in the previous section, the removal of market access barriers to cross-border e-
invoicing would have mainly economic impacts. The main stakeholders concerned would be 
firms  active  in  public  procurement  and  contracting  authorities.  The  scale  of  these  impacts 
would  depend  on  the  Option  chosen  -  the  more  users  align  to  a  single  solution,  the  fewer 
market access barriers would remain. 

5.2.1. 

Impacts on firms 

The establishment of a common standard would solve the interoperability problem for firms 
dealing with contracting authorities which adhere to the new rules (voluntarily or due to the 
mandatory  nature  of  the  new  provisions).  Specifically,  the  availability  of  one  interoperable 
and  commonly  acceptable  standard  would  attenuate  the  complexity  of  doing  business 
abroad  and  provide  more  legal certainty for enterprises.  It  would  also  reduce  costs  for 
firms which result from the need to support many different e-invoicing standards.  

The availability of a single standard would be beneficial for both large enterprises and SMEs. 
These  expected  benefits  are  also  recognised  by  the  firms  themselves  –  according  to  one 
supplier active in public procurement, “dealing with 2 or 3 standards would put us in a very 
good position, but having to support one single standard would result in huge savings, as we 
would  realise  the  real  benefits  of  business  automation  with  minimal  setup  and  maintenance 

36 

 
 
costs”80.  Similar  views  were  shared  by  the  contributors  to  the  European  Committee  for 
Standardisation  (CEN)  workshop  agreement  (CWA  16461)81,  who  pointed  out  that”  since a 
large number of different formats are in use, a reduction to a small number of common format 
specifications (if not one), i.e. standards, could make it much easier for an SME to get started 
with structured data exchange and to address the majority of their customers (especially the 
large enterprises) with one common format.”  

SMEs also confirm that they would appreciate the resolution of the interoperability problem 
by the emergence of a common standard. Their opinions were collected in a survey conducted 
within the third Working Group of the EMSF82 and are provided below. 

Table 4): SME adoption drivers (1=least helpful; 5 = most helpful) 

Models  

Mean  

Median 

Integration with SMEs’ accounting software  

Affordability  

A common national standard for invoice content  

Peace of mind on VAT compliance  

A common EU standard for invoice content 

4.01  

3.99  

3.93  

3.75  

3.67 

4.00 

4.00 

4.00 

4.00 

4.00 

Source: “Good practices in the adoption and promotion of e-invoicing in Europe” ACCA Discussion Paper 

As  presented  in  Table  4),  the  availability  of  a  common  e-invoicing  standard  is  mentioned 
among the most helpful drivers for the adoption of e-invoicing in SMEs. 

The introduction of a new European standard could potentially be the source of some costs of 
adoption.  These  could  include  the  cost  of  purchase  of  new  software  and  IT  equipment, 
business  disruption  due  to  process  change,  the  costs  of  retraining  staff,  or  potential  service 
provider  fees  for  suppliers.83  However,  considering  recent  developments  in  information 
technology  and  the  nature  of  the  software  required,  heavy  investments  should  not  be 
necessary. The availability of cloud-based and ‘software-as-a-service’ solutions mean that in 
many cases, no installation of software would even be necessary, and users could be charged 
on a per-use basis.  

Furthermore, it is important to note that any such costs would be borne only once, as only one 
new standard would need to be introduced. The risk of suppliers having to bear such costs a 
number of times due to the need to support numerous other e-invoicing standards would be 
eliminated. The ‘avoided costs’ can effectively be considered as an overall cost reduction or 

80 

81 

82 
83 

„Supplier  perspectives  on  the  challenges  of  eInvoicing  with  the  public  sector”  by  Roman  Weber, 
PEPPOL. 
“Electronic  invoice  processes  in  Europe  and  enablement  of  SMEs  to  use  them  efficiently”,  CEN 
Workshop Agreement (CWA) 16461. 
“Good practices in the adoption and promotion of e-invoicing in Europe” ACCA Discussion Paper. 
The service providers use different pricing models, from those who charge a fixed fee per invoice or a 
monthly rate dependant on the average number of invoices exchanged, to the recently emerging cases 
where the service itself is provided free of charge. 

37 

 
 
                                                 
as potential savings. The scale of the potential savings can vary greatly depending on, among 
other factors, the type of solution chosen, the business model and pricing schemes of service 
providers,  and  the  volume  of  invoices  generated  by  the  supplier.  The  huge  variety  of  e-
invoicing business models84 and cost structures85 that exists on the market makes any attempt 
to provide a precise aggregate figure difficult.  

Finally,  further  potential  savings  for  firms  may  come  from  some  adaptations  of  the  pricing 
schemes  and  market  structures  for  e-invoicing  transmission,  since  the  e-invoicing  service 
providers  would  have  to  modify  their  business  models  to  support  the  new  interoperable 
standard. The availability of a common solution may for example reduce the roaming (i.e. e-
invoice  transfer)  fees.  This  observation  is  shared  by  stakeholders:  during  discussions  in  the 
EMSF,  the  opinion  was  voiced  that  a  common  standard  would  simplify  communications 
between  service  providers  by  removing  the  need  for  them  to  constantly  agree  on  which 
standard  is  to  be  used.  Similarly,  according  to  Deutsche  Bank  Research,  “Interoperability 
would  […]  further  expand  and  promote  the  existing  competition  between  providers  with  its 
positive impact on innovation activity and the value for money offered”. This should help to 
reduce the operating costs for suppliers even further.  

Summarising,  the  introduction  of  a  single  interoperable  solution  would  be  beneficial  for 
enterprises, both large and SMEs: they would need to invest only once in the adaptation to the 
common EU e-invoicing standard, whereby their costs would be proportionately reduced. 

5.2.2. 

Impacts on contracting authorities 

Any measure requiring the use of a new European e-invoicing standard would impact the way 
contracting authorities carry out procurement, and would therefore generate operational costs 
for  contacting  authorities  and/or  Member  States.  Depending  on  whether  Member  States 
and/or contracting authorities react positively, a recommendation to take up the new standard 
could have a similar effect. As mentioned in section 5.2.1 above, however, it seems that that 
these  costs  would  not  be  excessive  and  would  in  any  case  be  outweighed  by  the  expected 
benefits (i.e. operational savings from e-invoicing and lower prices in public procurement due 
to enhanced competition).  

Several examples of estimated costs to public administrations – based on existing projects to 
introduce e-invoicing in the public sector – are provided below. Although the available data 
do not allow to distinguish between the savings from operational enhancements and savings 
due to increased competition in all cases, the figures for estimated savings are provided as an 
indication of the possible economic benefits resulting from the take up of e-invoicing86. They 
all show a positive cost-benefit ratio. 

•  Estimates  made  in  2004  by  officials  in  the  Scottish  Executive  showed  that  the 
introduction  of  e-invoicing  would  reduce  administrative  costs  by  around  £5.4 
million  during  the  first  four  years  of  implementation.  The  total  cost  of 

84 

85 

86  

For example buyer’s own platform, value-added network run by a service provider, four-corner model, 
web portal for SMEs, etc. 
For example free for recipients, free for senders, cost per invoice, monthly fee, initial implementation 
fee, etc. 
Additional information concerning the potential benefits of e-invoicing is provided in Annex 0. 

38 

 
 
                                                 
implementing  such  a  project  were  estimated  at  around  £600  000  during  the  first 
two years87. 

•  Belgium estimates that the costs of implementation of its e-invoicing pilot project 
in the  federal government  will amount to  approximately 370 000  EUR for basic 
infrastructure  and  support  services,  while  yearly  savings  in  excess  of  3  million 
EUR will be generated (not including the judicial sector)88.  

•  In  Spain  the  costs  and  benefits  of  an  introduction  of  e-invoicing  in  the  central 
government  administration  and  related  bodies  (excluding  the  social  security 
agency) are estimated to be about 100 000 EUR per annum, based on the creation 
of a central management model/platform to receive all e-invoices submitted to the 
central  government  administration.  Savings  to  the  central  government  from  the 
move towards e-invoicing are estimated to be about 2.5 million EUR per annum89. 

•  Norwegian municipalities estimated that a requirement to switch to structured e-
invoicing based on a common standard for all incoming invoices would generate 
costs for  suppliers peaking  at some  NOK  400  million  (about  54  million  EUR  at 
current  exchange  rate)  per  annum  3  years  after  the  introduction  of  the  scheme. 
Then  costs  would  steadily  decrease  and  savings  accruing  to  suppliers  would 
exceed  their  costs  by  the  4th  year.  The  total  NPV  of  the  benefits  accruing  to 
suppliers  were  estimated  to  be  NOK  2077  million  over  a  10  year  period  (about 
280  million  EUR).  A  similar  assessment  of  the  introduction  of  mandatory  e-
invoicing in the Norwegian central government administration made in 2008 also 
concluded that there would be a net present value for suppliers, estimated at 178 
million NOK (about 24 million EUR at current exchange rates)90. 

The available data thus indicates that the cost-benefit balance of the adoption of e-invoicing 
by  public  administrations  is  generally  positive.  In  other  words,  the  costs  generated  by  any 
measure where the contracting authorities or Member States would be asked either to align to 
a new European standard or to adapt to e-invoicing more broadly would be outweighed by its 
expected benefits.  

Additionally,  the  removal  of  market  access  barriers  should  also  result  in  more  cross-border 
bids  submitted  by  firms  and  therefore  lead  to  increased  competition  (or  at  least  increased 
competitive pressure) in public procurement. 

As  explained  in  section  2.2.4,  currently  some  potential  suppliers  wishing  to  bid  on  a  public 
procurement  contract  in  another  Member  State  might  decide  not  to  do  so  if  the  contract 
requires  the  subsequent  submission  of  e-invoices  in  a  standard  which  they  do  not  support. 
However,  if  such  barriers  were  removed,  these  suppliers  may  decide  to  participate.  This 
would result in more bids (more competition) and should in principle lower the prices paid by 
contracting authorities for goods, works and services that they purchase.  

87 

88 
89 
90 

Efficient 

Benefits”, 

“e-Invoicing 
http://www.scotland.gov.uk/Publications/2005/07/1292532/25341.  
Internal document form the Belgian Government. 
Information provided by the Spanish administration. 
„AGFA  -  vurderinger  og  anbefalinger  om  elektronisk  faktura  i  staten”  Rapport  fra  arbeidsgruppe  for 
elektronisk faktura (2008). 

Government 

expression 

interest, 

Fund 

of 

- 

39 

 
 
                                                 
As  presented  in  Figure  8)  below,  based  on  aggregated  data  available  for  2011,  a  positive 
relationship  can  be  observed  between  the  number  of  tenders  received  and  the  extent  of 
savings:  the  higher  the  number  of  bids  received  on  a  given  public  procurement  tender,  the 
greater the savings realised. For example, if a contracting authority receives two bids instead 
of one, the typical saving per contract raises from 3% to 8%. 

Figure 8): Relationship between the number of tenders received and savings over expected expenditure 

Source: 2011 average saving (as % of estimated price) on public procurement contracts in the EU compared with the 
number of bids received, estimates by DG Internal Market and Services based on OJ/TED data. 

The  above  example  shows  that  increased  competition  induced  by  the  removal  of  market 
access barriers in public procurement is likely to translate into tangible savings for contracting 
authorities. 

5.3. 

Secondary impacts 

As  mentioned  in  the  introduction  to  the  impacts  chapter,  the  adoption  of  a  new  EU  e-
invoicing  standard  may  generate  secondary  impacts  through  the  increased  uptake  of  e-
invoicing  in  public  procurement.  This  increase  in  the  use  of  e-invoicing  (which  is  highly 
probable  in  some  Options)  would  be  the  source  of  certain  economic,  social,  and 
environmental impacts. 

5.3.1.  Economic, social, and environmental impacts 

The  economic  impacts  of  an  increased  uptake  of  e-invoicing  would  be  basically  linked  to 
savings to the economy generated by the expected savings in the public procurement  cycle, 
i.e. reduction of operating costs for buyers and sellers, increased transparency, faster payment 
processing times. However, as far as secondary impacts on firms are concerned, it is assumed 
that these impacts are more positive if firms are allowed to switch to e-invoicing at their own 
speed.91  

91 

Since firms are exposed to market forces, it is assumed that they would switch to e-invoicing as soon as 
they see that such decision produces benefits. 

40 

 
 
 
                                                 
The  social  impacts  are  expected  to  be  neutral  –  they  may  involve  some  reassignments  or 
redundancies in selected sectors (e.g. public administration, postal services, paper production) 
but these should be marginal and would most likely be counterbalanced by job creation due to 
the  identified  savings.  The  environmental  impacts  are  expected  to  be  positive  –  they  would 
above  all  translate  into  a  reduced  use  of  paper  and  lower  CO2  emissions.  A  more  detailed 
analysis of economic, social and environmental impacts of increased uptake of e-invoicing is 
provided in Annex 1.3. 

5.3.2.  Reduction of administrative burden 

The  broader  uptake  of  e-invoicing  would  also  contribute  to  the  reduction  of  administrative 
burden through the automation of invoicing procedures, including validation and processing 
of invoice data. By definition, this will reduce the burden of dealing with invoices on both the 
sender’s and the recipient’s side. Additionally, the availability of invoice data electronically 
would simplify auditing and tax collection by the Member States’ tax authorities, as well as 
the preparation of any reports which need to be provided by the company. This would in turn 
reduce  the  administrative  burden  on  enterprises.  Importantly,  due  to  the  fact  that  such 
administrative requirements usually weigh more heavily on smaller enterprises, the reduction 
of  administrative  burden  resulting  from  the  introduction  of  electronic  invoicing  would  be 
particularly beneficial to SMEs.  

Due  to  the  high  potential  of  e-invoicing  in  public  procurement  to  reduce  administrative 
burdens,  the  initiative  has  been  included  on  the  list  of  actions  with  a  potentially  significant 
positive impact on administrative burden reduction, contained in Annex II of the Commission 
Work  Programme  for  201392.  The  recent  Communication  “Entrepreneurship  2020  Action 
Plan – Reigniting the entrepreneurial spirit in Europe”93 also mentions this initiative.  

5.3.3.  The scale of secondary impacts  

The overall secondary impacts of each Option would to a large extent depend on the expected 
scope  of  e-invoicing  adoption  –  the  extent  to  which  the  appearance  of  an  interoperable  e-
invoicing  solution  influences  a  wider  adoption  of  e-invoicing  across  the  EU  will  have  the 
greatest impact on the macro scale. Clearly, the wider the adoption, the greater the economic 
and environmental benefits from e-invoicing (the more significant the impacts). Similarly, the 
faster  the  adoption,  the  sooner  the  secondary  impacts  of  wider  e-invoicing  uptake  would 
emerge. 

The expected scale of secondary impacts will be analysed separately for each Option.  

5.4. 

Impacts of defined options 

As  mentioned  in  the  introduction  to  Section  5,  the  common  impacts  are  expected  to 
materialise in all Options, but to a varying degree depending on the case. In order to discuss 
these differences, the impacts of each Option will be compared using the following grid: 

•  Primary  impacts  –  generated  by  the  removal  of  market  access  barriers  in  cross-

border public procurement / enhanced interoperability (economic); 

92 

93 

Commission  Work  Programme  2013,  Annex  II  “Simplification  and  Regulatory  Burden  Reduction” 
http://ec.europa.eu/atwork/pdf/cwp2013_en.pdf  
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2012:0795:FIN:en:PDF 

41 

 
 
                                                 
•  Secondary impacts – generated by potential ‘side effects’ of the availability of an 
interoperable technical solution in e-invoicing, which may lead to an increase in 
the uptake of e-invoicing (economic, social, and environmental). 

5.4.1.  Option (1): No new EU action 

The  baseline  scenario  was  described  in  section  2.3.  The  current  situation  confirms  that  the 
objectives of this initiative would not be fully met if Option (1) were retained. 

Table 5): Impacts of Option (1) 

Primary 
improved interoperability) 

impacts 

(related 

to 

Interoperability  would  not  be  ensured  –  market  access  barriers  would 
most probably remain and/or worsen. 

Secondary 
impacts 
increased  uptake of e-invoicing) 

(related 

to 

Some  secondary  impacts  may  appear,  but  because  of  the  voluntary 
nature of this Option, the scale of these impacts is uncertain.  

5.4.2.  Option (2): Free-choice approach 

The second Option would be similar to the “no EU action” approach, as market users would 
retain their freedom to choose any technical solution that they find best suited to their needs. 
However, a new (interoperable) European e-invoicing standard would be developed and made 
available to the market, with a recommendation (but without any obligation) to use it in public 
procurement. 

With the introduction of the new e-invoicing standard merely recommended and not required, 
several  significant  risks  remain  which  may  prevent  the  objective  of  interoperability  from 
being achieved. The acceptance of e-invoices in the European standard would remain at the 
discretion of each Member State and/or contracting authority, who may decide not to accept 
it.  This  could  lead  to  the  continued  co-existence  of  several  e-invoicing  standards  across  the 
EU, or even within an individual Member State. There is therefore a high likelihood that the 
cost burden on enterprises would not decrease, as they would be forced to maintain numerous 
e-invoicing  standards  at  the  same  time  in  order  to  be  able  to  meet  various  technical 
requirements of other Member States  (especially if mandatory e-invoicing is required by the 
public  buyer).  Should  they  choose  not  to  do  so,  potential  business  opportunities  would  be 
foregone. 

As  far  as  the  objective  of  this  initiative  is  concerned,  it  would  not  be  achieved,  as 
interoperability  would  remain  problematic.  An  impediment  to  the  effective  operation  of  the 
Internal Market would remain.  

Due  to  the  very  large  number  of  agreements  required  between  invoicing  parties  in  order  to 
ensure a satisfactory level of interoperability, the self-regulation process is practically certain 
to be much more time consuming and more costly than standardisation by CEN. 

Secondary impacts would be observed only to the extent to which a switchover to e-invoicing 
occurs. It can be expected that the availability of a common standard might encourage some 
market players to make this decision (presumably more than would be the case if no common 
standard  were  available),  but  due  to  the  voluntary  nature  of  this  Option,  the  scale  of  this 
process is difficult to predict. 

42 

 
 
Table 6): Impacts of Option (2) 

Primary 
improved interoperability) 

impacts 

(related 

to  

Interoperability  would  be  only  partially  facilitated  (depending  on  the 
scale  of  uptake  of  the  new  European  standard);  numerous  e-invoicing 
standards  would  still  co-exist  on  the  market,  so  the  cost  burden  on 
enterprises would remain. 

The self-regulation approach is more costly that the CEN process and its 
results are uncertain. 

impacts 
Secondary 
increased  uptake of e-invoicing) 

(related 

to 

Some  secondary  impacts  may  appear,  but  because  of  the  voluntary 
nature of this Option, the scale of these impacts is uncertain.  

5.4.3.  Option (3): Selective conversion to e-invoicing 

In  this  Option,  contracting  authorities  and/or  Member  States  which  on  their  own  initiative 
mandate  the  submission  of  e-invoicing  in  public  procurement,  would  be  required  to  accept 
electronic  invoices  in  the  agreed  European  standard  as  of  that  point  in  time.  While  not 
imposing  the  use  of  a  new  European  e-invoicing  standard  in  public  procurement  on  all 
contracting  authorities,  this  Option  would  nevertheless  have  some  positive  impacts:  among 
those  Member  States  /  contracting  authorities  which  have  made  (or  will  make)  e-invoicing 
mandatory,  the  interoperability  issues  would  effectively  be  resolved.  Nevertheless,  the 
possibility of different legal interpretations of the future e-invoicing provisions may become a 
source of complexity and legal uncertainty, which undermines the achievement of one of the 
two specific objectives. On the other hand, for Member States / contracting authorities which 
do not make e-invoicing mandatory, the effects of this Option would be identical to those of 
Option (2) – i.e. there is no guarantee that the objective of the initiative would be achieved. 

Overall, the main benefit of this Option would be that interoperability would be facilitated: its 
implementation  would  lower  the  costs  and  complexity  of  e-invoicing  for  enterprises,  which 
could now expect to be able to send electronic invoices in a single standard to any contracting 
authority which mandates e-invoicing. However, two risks would remain that it would not be 
ensured  entirely:  firstly,  if  some  Member  States  delay  the  introduction  of  mandatory  e-
invoicing  (perhaps  as  a  result  of  the  implementation  of  this  Option);  secondly,  when  e-
invoicing  is  required  de  facto,  but  not  mandated  in  the  legal  sense  (de  jure).  The 
implementation of this Option may therefore involve legal uncertainty for firms.  

As far as the broader policy context is concerned, this Option might have some negative side-
effects. On the one hand, Member States / contracting authorities which have already required 
the transition towards e-invoicing in public procurement would be negatively affected because 
the  obligation  to  adapt  to  the  new  standard  would  at  first  only  concern  them.  On  the  other 
hand,  Member  States  /  contracting  authorities  which  have  no  plan  to  switch  to  e-invoicing 
would not face any specific new obligations. This ‘asymmetric’ treatment of Member States 
(obligation  put  only  on  the  front-runners  vs.  lenient  treatment  of  laggards)  might  act  as  a 
disincentive:  since  any  such  move  would  require  the  (additional)  introduction  of  the  new 
European  standard,  it could  discourage those Member States which have  not yet  adopted e-
invoicing from doing so quickly. . Moreover, leaving the option to "do nothing" to Member 
States  that  currently  do  not  use  e-invoicing  in  public  procurement  also  calls  into  question 
whether this option constitutes a real harmonisation measure. 

43 

 
 
The scale of the secondary impacts of this Option is difficult to predict. Even if all Member 
States do eventually decide to opt for e-invoicing the process might take a very long time. As 
a  result,  the  potential  benefits  of  greater  cost  efficiency  in  public  procurement  would  not 
materialise or would do so only very slowly. Nonetheless, even if only some Member States 
introduce mandatory e-invoicing and therefore take up the EU standard, this would generate 
net savings for all stakeholders. 

Table 7): Impacts of Option (3) – summary 

Primary 
improved interoperability) 

impacts 

(related 

to 

Interoperability  would  be  facilitated  as  invoices  sent  in  the  European 
standard would have to be accepted by all public buyers which mandate 
e-invoicing,  but  the  implementation  of  this  Option  may  involve  some 
legal uncertainty.  

The costs of the process would be proportionate as existing e-invoicing 
systems would not be replaced by the new solution. 

impacts 
Secondary 
increased  uptake of e-invoicing) 

(related 

to 

The  asymmetric  treatment  of  contracting  authorities  /  Member  States 
may deter some potential ‘candidates’ from switching to e-invoicing. 

As  the  overall  balance  of  indirect/secondary  impacts  is  positive,  these 
benefits will materialise, but probably at lower speed than with the two 
following Options.  

5.4.4.  Option (4): Obligatory acceptance 

In Option (4), a new, European standard would be developed and made available for use by 
all market operators. In this scenario, acceptance by all contracting authorities of e-invoices 
compliant  with  this  standard  would  be  required  in  public  procurement,  without  however 
replacing  other  existing  technical  solutions  (i.e.  the  invoice  could  still  be  sent  in  another 
standard if both parties so choose).  

This Option would ensure that the operational objective of the initiative would be met rapidly: 
the requirement to accept e-invoices compliant with the European standard would effectively 
ensure  interoperability  and  hence  remove  market  access  barriers  as  of  the  day  when  the 
provisions  enter  into  force.  The  actual  uptake  of  the  proposed  measures  would  depend  on 
firms’  decisions  to  use  e-invoicing  and  adhere  to  the  new  European  standard.  It  is  however 
expected that their response would be satisfactory, as the new standard would be the only one 
that involves the additional incentive of technical acceptance in public procurement across the 
EU.  Additionally,  the  availability  of  a  single  technical  solution  /  standard  was  frequently 
mentioned  by  firms  as  a  prerequisite  for  the  adoption  of  e-invoicing94,  therefore  the 
appearance  of  the  European  standard  on  the  market  is  expected  to  prompt  the  hesitant 
economic operators to switch to e-invoicing.  

Option (4) may provide a ready-made solution and guidance for those Member States which 
have not yet implemented e-invoicing but are considering doing so. This Option could act as a 
stimulus  for  Member  States  to  prepare  the  necessary  systems  early  on.  The  fact  that  they 
could also keep using their own national systems should minimise any potential transitional 
costs  in  Member  States  which  have  already  developed  national  e-invoicing  systems  (for 
example, firms which never enter into cross-border contracts could continue to use existing, 

94 

See: Table 4) in section 5.2.1. 

44 

 
 
                                                 
familiar solutions for all their business with the public sector). Other Member States could use 
the  common  standard  as  a  basis  for  developing  their  national  e-invoicing  systems,  taking  a 
significant proportion of the risk and cost out of developing national solutions.  

For  enterprises,  this  option  would  create  the  certainty  that  any  necessary  efforts  and  initial 
expenditures will not go to waste and will be amortised within a fairly short period of time. 
Finally, the knowledge that an investment into one single solution will allow the sending of e-
invoices  to  any  contracting  authority  in  any  Member  State  should  prove  to  be  a  convincing 
factor  for  enterprises  –  including  SMEs  –  to  launch  the  process  of  switching  over  to  e-
invoicing.  

Furthermore, the fact that i) only one (additional) standard would need to be supported both 
by  firms  and  by  contracting  authorities/contracting  entities,  and  ii)  the  existing  e-invoicing 
systems/standards would not be replaced by the new European standard, but could continue to 
be  used  if  the  parties  agree,  means  that  the  costs  of  implementing  this  option  would  not  be 
excessive, especially considering the expected benefits.   

Social and environmental impacts would be observed only to the extent to which a switchover 
to  e-invoicing  occurs.  Nevertheless,  it  can  be  expected  that  the  availability  of  a  European 
standard  would  encourage  more  market  players  to  make  this  decision  than  if  no  common 
standard were available. Although the scale of this process is difficult to predict, it would be 
most probably be more significant that in the previous Option. The secondary impacts would 
therefore very likely materialise to a large extent. 

Table 8): Impacts of Option (4) – summary 

Primary 
improved interoperability) 

impacts 

(related 

to 

Interoperability  would  be  ensured  as  invoices  sent  in  the  European 
standard would have to be accepted by all public buyers. For firms, the 
costs and complexity of interoperability would decrease.  

Secondary 
impacts 
increased  uptake of e-invoicing) 

(related 

to 

The costs of the process would be proportionate as existing e-invoicing 
systems would not be replaced by the new solution. 

The availability of an interoperable European standard and obligation to 
accept  invoices  sent  in  such  a  standard  if  a  successful  firm  opts  for  it, 
may  significantly  increase  the  uptake  of  e-invoicing.  As  the  overall 
balance  of  secondary  impacts  is  positive,  the  implementation  of  this 
Option would allow these benefits to materialise.  

The speed of adoption of e-invoicing would be at the discretion of firms, 
so no excessive costs are expected.  

5.4.5.  Option (5): Full harmonisation 

This last option differs from the previous one in the sense that invoices in currently existing 
formats/standards  would  no  longer  be  permitted.  In  practice,  this  would  mean  that  the 
standardisation efforts would need to go beyond the semantic level and would address also the 
syntax  level.  This  approach  would  therefore  result  in  a  full  harmonisation  of  e-invoicing 
within  above-threshold  procurement  in  the  EU,  and  would  therefore  reduce  the  associated 
complexity and  costs as of the day when the provisions enter into  force. All  of the  primary 
impacts would therefore be certain to materialise. 

45 

 
 
As the uptake of e-invoicing would almost certainly increase due to the great simplification 
and  reduced  cost  of  its  use,  the  secondary  impacts  can  be  expected  to  materialise  to  an 
important  extent.  However,  this  approach  would  also  mean  significant  additional  effort  and 
expenditure to implement the new standard in those Member States which have already made 
large investments to develop functioning e-invoicing systems, as existing systems would need 
to be replaced. Any such previous investments in these Member States would effectively have 
been  wasted.  Such  an  approach  would  to  a  large  extent  negate  the  economic  benefits  of 
greater uptake and meet strong political opposition from Member States which already have 
e-invoicing systems in place.  

For  economic  reasons,  this  approach  would  also  be  highly  disruptive  and  costly  for  the 
service providers, as they would have to entirely redesign their systems.  

Considering that in implementing this option a significant amount of resources will have been 
wasted, such an approach would not be in agreement with the principle of proportionality, as 
the same goals could clearly be achieved by less intrusive means. 

Table 9): Impacts of Option (5) – summary 

Primary 
improved interoperability) 

impacts 

(related 

to 

Interoperability  would  be  ensured  as  invoices  sent  in  the  European 
standard would have to be accepted by all public buyers. Interoperability 
costs  and  complexity  for  firms  would decrease,  but  the  implementation 
costs  for  Member  States  and  contracting  authorities  who  currently  use 
other e-invoicing systems/standards would be disproportionately high.  

This Option raises concerns with regards to the proportionality principle. 

Secondary 
impacts 
increased  uptake of e-invoicing) 

(related 

to 

The  obligation  to  exclusively  accept  e-invoices  sent  in  the  European 
standard would most probably increase the uptake of e-invoicing, but the 
benefits of broader use of e-invoicing would be counterbalanced by the 
expected cost of this option.  

6. 

COMPARING THE OPTIONS 

An analysis of the options identified in Section 4 is presented below in terms of achieving the 
stated objective and in terms of their impacts on the different groups of stakeholders. 

6.1. 

Comparing the options against the operational objective 

In order to select the most appropriate approach, the different Options will be compared using 
the criteria of effectiveness, efficiency and coherence. The evaluation of the effectiveness of 
the  Options  will  be  analysed  taking  into  account  the  extent  to  which  they  solve  the 
interoperability  problem  (i.e.  whether  or  not  market  access  barriers  to  cross-border 
procurement are effectively removed), as this is the main objective of this initiative.  

Within the comparison of the efficiency aspects of the analysed Options, the cost-benefit ratio 
of the proposed implementation methods will be analysed. As explained in section 5.4.4, it is 
proposed  to  develop  a  new  European  e-invoicing  standard  to  facilitate  interoperability.  In 
order to ensure the technological neutrality of this new standard and the transparency of the 

46 

 
 
standardisation  process95,  the  European  Standards  Organisations  appear  to  be  the  most 
appropriate  bodies  to  implement  this  task  at  the  EU-level.  Considering  the  content  of  the 
future European standard (and the work which has already been undertaken within its working 
groups to facilitate e-invoicing interoperability96), the issuing of a mandate to CEN to draw up 
a  new  European  standard  on  e-invoicing  is  proposed  as  the  optimal  way  to  proceed.  As 
mentioned  in  Annex  1.9,  it  seems  that  the  only  alternative  approach  that  might  possibly  be 
considered is self-regulation by stakeholders. Self-regulation is the essence of Option (1) and 
it constitutes one of two parallel processes in Option (2) – the other being standardisation by 
CEN with the voluntary adoption of the results by stakeholders. 

As far as the third criterion is concerned, coherence will be evaluated above all with regards 
to  the  expected  secondary  impacts  of  the  increased  uptake  of  e-invoicing,  which  are  in  line 
with  the  objectives  of  the  "Digital  Agenda  for  Europe"97  and  the  2010  e-invoicing 
Communication98 from the Commission. Additionally, it is assumed that the broader adoption 
of  e-invoicing  would  also  be  coherent  with  the  Commission  policies  concerning  e-
procurement, especially the Commission proposal on the revision of public procurement rules 
from 201199 and the objectives of the late payment Directive (2011/7/EU)100. 

95 
96  

97 
98 

99 
100 

The CEN standardisation process is described in Annex 0. 
More information on the options for standardisation and the CEN standardisation process is provided in 
Annexes 0 and 0. 
"A Digital Agenda for Europe", European Commission Communication, COM(2010) 245. 
"Reaping 
COM(2010)712. 
http://ec.europa.eu/internal_market/publicprocurement/modernising_rules/reform_proposals_en.htm 
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:048:0001:0010:EN:PDF 

for  Europe",  European  Commission  Communication, 

the  benefits  of  e-invoicing 

47 

 
 
                                                 
Table 10): Comparing the options against the operational objective 

Objective - improve/facilitate e-invoicing interoperability in public procurement  

Policy 
options  

Option (1): No 
new EU action  

Option (2): 
Free-choice 
approach 

Option (3): 
Selective 
conversion to 
e-invoicing 

Option (4): 
Obligatory 

EFFECTIVENESS 

EFFICIENCY 

COHERENCE101 

0 

(+ / ?) 

0 

(≈) 

0 

(?) 

Interoperability would be facilitated only 
partially (depending on the scale and timing of 
the adoption of the new European standard). 

The self-regulation approach is more costly that the CEN 
process and its results are uncertain. 

Timely achievement of the objective cannot be ensured. 

Some secondary impacts may appear, but their scale 
and timing is uncertain because of the voluntary 
nature of this approach. 

(+) 

(+) 

(- / ?) 

Interoperability would be facilitated, as invoices 
sent in the European standard would have to be 
accepted by all public buyers which mandated e-
invoicing, but the implementation of this Option 
may involve some legal uncertainty.  

The CEN process to establish a standard is the optimal way 
to achieve the objective (the costs of the introduction of the 
new standard are proportionate).  

Timely achievement of the objective can be expected. 

The asymmetric treatment of contracting 
authorities / Member States may deter “candidates” 
from switching to e-invoicing (hence some 
potential benefits could be lost). Some secondary 
impacts may appear, but their scale is uncertain.  

It is not clear whether or not this Option constitutes 
a harmonisation measure. 

(+ +) 

(+) 

(+ / ?) 

Interoperability would be ensured as invoices 

The CEN process to establish a standard is the optimal way 

Positive secondary impacts of e-invoicing would 

101 

Coherence is evaluated by taking into account also the secondary impacts (i.e. impacts generated by the increased uptake of e-invoicing) and the extent to which the Options 
are coherent with other EU policies (especially the e-procurement initiative and the objectives of the late payment Directive). 

48 

 
 
 
                                                 
acceptance  

sent in the European standard would have to be 
accepted by all public buyers. 

to achieve the objective (the costs of the introduction of the 
new standard are proportionate).  

materialize to the extent to which the switchover 
occurs.  

Timely achievement of the objective can be expected. 

The adoption of e-invoicing would be at firms’ 
own speed, so no excessive costs expected.  

Option (5): 
Full 
harmonisation 

(+ +) 

(- -) 

(≈) 

Interoperability would be ensured as invoices 
sent in the European standard would have to be 
accepted by all public buyers.  

The CEN process to establish a standard is the optimal way 
to achieve the objective (the costs of the introduction of the 
new standard are proportionate).   

Positive secondary impacts of e-invoicing would 
materialise to the extent to which the switchover 
occurs. 

Disproportionately high implementation costs for Member 
States and contracting authorities who use other e-invoicing 
systems which would have to be abandoned. 

The above benefits would be counter-balanced by 
concerns with regards to the proportionality principles. 

Timely achievement of the objective can be expected. 

Magnitude of impact as compared with the baseline scenario (the baseline is indicated as 0): ++ strongly positive; + positive; – – strongly negative; – negative; ≈ marginal/neutral; 
? uncertain; n.a. not applicable  

49 

 
 
From  the  table  above,  it  becomes  evident  that,  when  compared  with  the  baseline  scenario, 
Option (4) appears to be the most effective and efficient in achieving the operational objective 
of  this  initiative.  It  is  also  coherent  with  other  objectives  of  EU  policy  and  its  overall  cost-
benefit balance is the most favourable. 

The effects of Option (3) would be slightly less effective and efficient in terms of achieving 
the  operational  objective  of  this  initiative  (facilitating  interoperability).  However,  its 
coherence remains negative to uncertain (-/?), since the proposed provisions could be contrary 
to  the  objectives  of  other  EU  policies,  as  they  might  discourage  Member  States  from 
switching  to  e-invoicing  in  the  future.  Finally,  this  Option  may  be  too  selective  to  be 
classified as a harmonisation measure. 

The net balance of scores allotted to the remaining Options for all elements under the analysis 
is less favourable than the baseline scenario. 

6.2. 

Comparison of options across all stakeholder groups 

The different options presented above will have different impacts on the different groups of 
stakeholders. With the exception of the baseline scenario, which implies the continuation of 
current policy, these are summarised in Table 11) and analysed below.  

Table 11): Comparison of options across stakeholder groups 

        Stakeholders 

Policy options  

Option (1): No new 
EU action  

Option (2): Free-
choice approach 

Option (3): Selective 
conversion to e-
invoicing 

Option (4): 
Obligatory 
acceptance  

Option (5): Full 
harmonisation 

Firms(including 
SMEs) 

Service 
providers 

Member States 
and / or 
contracting 
authorities 
WITHOUT 
mandatory e-
invoicing 

Member States 
and / or 
contracting 
authorities 
WITH 
mandatory e-
invoicing 

0 

(?) 

(?)  

(+) 

(+) 

0 

(?) 

(≈ / -) 

0 

(-) 

(+) 

0 

(? / +) 

(≈ /  +) 

(≈ / -) 

(+ +) 

(≈ /  +) 

(- -) 

(- -) 

(- -) 

Magnitude  of  impact  as  compared  with  the  baseline  scenario  (the  baseline  is  indicated  as  0):  ++  strongly 
positive; + positive; – – strongly negative; – negative; ≈ marginal/neutral; ? uncertain; n.a. not applicable 

50 

 
 
 
 
6.2.1.  Member States / contracting authorities 

The impacts of the different Options on Member States (understood here as the policymakers) 
are analysed together with contracting authorities directly involved in public procurement, as 
the initial analysis has shown that the emerging patterns for these two groups of stakeholders 
are  very  similar.  Instead,  a  different  distinction  has  been  made,  namely  between  those 
Member States / contracting authorities which have already introduced mandatory e-invoicing 
and those which have not (yet) done so.  

6.2.1.1.  Member States / contracting authorities WITHOUT mandatory e-invoicing 

For those Member States / contracting authorities which have not yet mandated e-invoicing, 
all  the  Options  where  the  introduction  of  a  common  standard  is  expected  to  broaden  the 
uptake  of  e-invoicing  receive  a  positive  score.  The  implementation  of  e-invoicing  systems 
would  imply  some  costs,  but  it  would  also  mean  that  savings  could  be  generated  through 
operational efficiencies in the procurement cycle, simplification of tax collection and auditing, 
and reduced environmental impacts.  

The  voluntary  nature  of  Option  (2)  would  not  guarantee  that  an  invoice  in  the  European 
standard  is  accepted  by  the  recipient.  This  means  that  the  impacts  for  Member  States  or 
contracting authorities are uncertain, as the decision to support the new standard would be at 
their discretion.  

As Option (3) leaves room for manoeuvre for Member States / contracting authorities which 
do not yet have mandatory e-invoicing, the effect of this Option is difficult to assess due to 
the  uncertainty  of  the  progress  of  implementation  of  the  new  standard  (they  will  not  be 
obliged to implement it, but may do so on a voluntary basis). Overall, the impacts of Option 
(3) for those Member States are marked as uncertain.  

Options (4) would be efficient for the Member States / contracting authorities which have not 
yet  mandated  e-invoicing,  as  they  would  not  require  investments  in  parallel  e-invoicing 
standards – they would be only obliged to ensure that invoices compliant with one standard 
(i.e. the European standard) are accepted / read by their IT systems. 

Options  (4)  and  (5)  score  better  than  Option  (3)  due  to  a  greater  certainty  that  the  benefits 
would be realised, and a significant possibility that they would be larger due to the additional 
efficiency and savings resulting from the adoption of e-invoicing (secondary impacts). 

6.2.1.2.  Member States / contracting authorities WITH mandatory e-invoicing 

Option  (2)  would  leave  the  decision  on  whether  or  not  to  support  the  new  standard  to  the 
Member States / contracting authorities. The ultimate uptake of the standard by stakeholders 
who have their own e-invoicing systems in place is difficult to predict – if they adopt the new 
standard,  there  is  no  way  of  knowing  whether  they  would  abandon  their  own  technical 
solution  entirely  or  expand  the  functionalities  of  their  IT  systems  to  read  both  standards  in 
parallel. Therefore the impacts of this Option for Member States or contracting authorities are 
marked as uncertain.  

For  Member  States  /  contracting  authorities  which  currently  have  mandatory  e-invoicing  in 
place, Options where the introduction of a common standard could broaden the uptake of e-

51 

 
 
invoicing would effectively have no impact, since they already have a functioning e-invoicing 
system  in  place.  In  other  words,  the  benefits  of  e-invoicing  are  not  considered  in  case  of 
Member  States  with  mandatory  e-invoicing,  as  the  benefits  which  would  be  generated  are 
already  present  in  these  countries  (i.e.  Options  (3),  (4)  and  (5)).  The  need  to  implement 
technical  solutions  to  enable  the  acceptance  of  the  new  European  standard  in  parallel  to  its 
own national standard (e.g. Options (3) and (4)) would generate some implementation costs. 
However,  as  demonstrated  in  section  5.5.2.,  it  is  expected  that  the  benefits  from  increased 
competition in public procurement would outweigh the additional costs of the introduction of 
the new European standard. 

Strongly negative impacts appear only when these Member States would be forced to entirely 
switch to the new European standard (Option (5)) for all above-threshold procurement. This 
Option  would  imply  significant  additional  expenditures  in  order  to  replace  the  current  e-
invoicing systems with the new European standard. Any legislative efforts and expenditures 
already undertaken will effectively have been wasted. 

6.2.2.  Firms (including SMEs) 

The selection of Option (2) would be negative for firms, as it would mean that there would be 
no assurance that an interoperability framework would allow them to use – and therefore to 
invest in – a single standard for all of their invoicing activities. While the recommendation of 
a  common  standard  could  convince  Member  States  take  it  up,  there  would  be  no  guarantee 
that  this  would  be  the  case.  This  implies  a  high  risk  that  enterprises  would  in  one  way  or 
another need to support the many different standards used by their customers, which means 
that the complexity and higher costs of taking part in cross-border public procurement would 
continue. 

The impacts of Options (3) and (4) on enterprises would overall be positive, as they would no 
longer  need  to  support  several  e-invoicing  standards  while  remaining  free  to  make  the 
decision at their convenience on whether or when to introduce e-invoicing capabilities. Firms 
would  also  be  certain  that  the  introduction  of  the  ability  to  invoice  electronically  using  the 
common  standard  would  mean  that  they  could  seamlessly  send  invoices  to  any  contracting 
authority  throughout  the  EU  –  in  Member  States  which  made  e-invoicing  mandatory  for 
Option (3) and all contracting authorities in Option (4). This could potentially open a number 
of new business opportunities which they would not have considered before. In addition, the 
mandatory  acceptance  of  e-invoices  across  the  EU  would  mean  that  any  initial  investments 
would be more quickly amortised by the potential savings, meaning that Option (4) would be 
slightly more positive.  

Finally, Option (5) would bring certain benefits to enterprises, since even though they would 
need  to  bear  the  investment  costs  associated  with  the  introduction  of  the  new  standard, 
potential  costs  of  using  multiple  e-invoicing  standards  would  have  been  avoided.  However, 
those enterprises which have already introduced e-invoicing on the basis of existing national 
and  or  proprietary  standards  would  need  to  replace  these  with  the  new,  common  standard. 
This  would  mean  that  any  investments  undertaken  previously  would  have  been  wasted. 
Although  the  uncertainties  of  insufficient  interoperability  would  be  remedied,  the  coercive 
nature of Option (5) in terms of the exclusive use of one only solution may result in excessive 
burden, especially for SMEs and microenterprises, who may not be technologically ready to 
adapt to “across the board” solutions. As a result, this Option generates significant additional 
costs without creating any new benefits and is scored as a strongly negative choice.  

52 

 
 
6.2.3. 

Service providers 

The impact of Option (2) on service providers is expected to be uncertain to positive. On the 
one  hand,  a  recommendation  to  use  the  new  European  standard  might  over  time  lead  to  a 
greater uptake of e-invoicing across the EU, and therefore to increased business opportunities 
for  service  providers.  If  the  recommendation  of a  common  standard  results  in  at  least  some 
Member States taking it up, this would mean that a lower number of standards would need to 
be supported and mapped to, and that the need to constantly agree on a common standard to 
use  in  exchanging  invoices  would  be  eliminated.  The  result  would  be  lower  operating  and 
investment costs on the one hand, but potentially also lower income due to a reduced need for 
mapping on the other. On the contrary, if the voluntary uptake of a common standard ends up 
having  a  limited  impact  on  the  market  and  a  proliferation  of  national  standards,  this  would 
potentially  be  a  source  of  more  investments  for  service  providers,  but  equally  a  potential 
source  of  additional  income.  Since  the  aspect  of  potential  use  of  the  new  standard  and  a 
consequent increase in e-invoicing uptake is very difficult to assess in advance, the impacts of 
this Option cannot be easily predicted, hence the (? / +) score.  

Theoretically,  any  Option  that  increases  the  probability  of  a  wider  uptake  of  e-invoicing  in 
public  procurement  would  potentially  be  positive  for  service  providers  as  it  would  increase 
their business. Following this approach, the impact on service providers of Options (3) and (4) 
should  be  judged  as  positive.  However,  while  on  the  one  hand  business  can  be  expected  to 
increase  due  to  increased  uptake  of  e-invoicing  which  these  Options  may  trigger,  there  is  a 
potential  that  some  market  operators  will  stop  using  the  services  offered  by  the  service 
providers as they could opt for bilateral models based on the common standard. Additionally, 
while  the  availability  of  one  common  standard  would  reduce  the  investments  which  would 
need to be undertaken by the service providers, the threat of enterprises sending their invoices 
either directly to contracting authorities or through other service providers (of which the great 
majority would certainly wish to support the new standard) would drive down the fees which 
would  be  charged  for  the  mapping.  As  a  result,  Options  (3)  to  (4)  would  most  probably  be 
only slightly beneficial to the service providers.  

Finally,  the  full  harmonisation  proposed  in  Option  (5)  would  have  a  significantly  negative 
effect  on  service  providers.  As  all  standards  with  the  exception  of  the  new,  common  one 
would  disappear,  so  would  the  need  for  mapping  between  different  standards.  This  implies 
that  the  service  providers  would  lose  a  significant  portion  of  their  business.  Although  there 
would  still  be  some  demand  for  their  services  by  those  market  operators  which  prefer  not 
process invoices directly, there is a risk that a significant proportion of the currently over 400 
- 500 service providers might go out of business altogether.  

6.3. 

The preferred option 

From  Table  10  in  section  6.1,  it  is  possible  to  see  that  Options  (4)  and  (5)  ensure  that  the 
objective of the initiative will be met (i.e. they are fully and equally effective).  All  Options 
would  require  some  cost  and  effort  to  develop  the  new  standard,  but  Option  (5)  has  the 
additional  significant  drawback  of  requiring  that  all  work  already  undertaken  at  a  national 
level  would  need  to  be  abandoned.  The  score  of  Option  (2)  is  relatively  low,  even  on  the 
effectiveness criterion. Option (3) could constitute a viable solution, as its score is positive for 
the effectiveness and efficiency criteria, but its coherence remains problematic.  

53 

 
 
As far as the impacts on stakeholders are concerned, Option (4) is the most advantageous for 
enterprises, and consistently rates as one of the two most favourable Options for all remaining 
stakeholders.  

Therefore, overall the most appropriate solution appears to be Option (4):  

•  firstly,  it  would  require  that  all  contracting  authorities  must  accept  electronic 
invoices  if  they  are  sent  in  a  new,  common  EU  invoicing  standard  as  of  a 
particular  date,  thus  overcoming  the  fragmentation  inherent  in  the  current 
patchwork  of  national  e-invoicing  systems  and  guaranteeing  the  integrity  of  the 
Single Market; 

•  secondly, the transition to e-invoicing would occur on a firm’s initiative, thus not 
generating unnecessary costs, especially for SMEs; the non-intrusive (‘at market 
speed’)  nature  of  such  provisions  would  also  respect  the  subsidiarity  and 
proportionality  principles;  it  is  expected  that  actual  uptake  of  the  proposed 
measures would be satisfactory, as the new European standard would be the only 
one  that  involves  the  additional  incentive  of  technical  acceptance  in  public 
procurement across the EU; 

•  thirdly,  there  is  a  high  probability  that  this  Option  would  induce  a  broader 
transition to e-invoicing for contracts covered by the Directives, thus capturing the 
full efficiency gains and economic savings offered by e-invoicing; 

•  finally,  it  would  allow  both  firms  and  contracting  authorities  to  continue  using 
existing  national  invoicing  systems,  thus  reducing  the  cost  and  disruption  of  the 
transition for both groups. 

The  chosen  approach  would  combine  the  strong  stimulus  of  an  obligation  to  ensure 
interoperability in e-invoicing in public procurement with a more flexible approach as to the 
most appropriate means of ensuring the use of e-invoicing as such. The recipients of invoices 
would have full flexibility as to how they would ensure their acceptance – directly, or using a 
three-corner or a four-corner model. The introduction of the new standard and the requirement 
to  accept  all  invoices  which  use  it  would  reduce  the  compliance  costs,  thereby  greatly 
improving  the  chances  for  a  broad  take-up  and  spill-overs  into  other  sectors  (B2B,  below-
threshold procurement, etc.).  

6.3.1.  Timeframe 

In line with the calls by the Member States and by the European Parliament (Section 2.1.3) as 
well as by stakeholders (results of public consultation presented in section 1.2.1 and Annex 
1.11), it is proposed to implement this initiative for all contracting authorities within as short a 
deadline  as  possible.  Taking  into  consideration  the  necessity  of  developing  a  common 
standard  and  the  time  which  this  requires  (see:  Section  6.3.3  below),  the  most  realistic 
deadline for the introduction of an obligation to accept the new European e-invoicing standard 
appears  to  be  between  2017  and  2018.  This  timeframe  is  also  consistent  with  the  2010  e-
invoicing Communication, which called for e-invoicing to become the predominant method of 
invoicing  by  2020  in  Europe,  and  with  the  expected  date  of  the  launch  of  mandatory 
electronic  public  procurement,  which  is  contained  in  the  draft  revised  public  procurement 
directives currently under discussion in the European Parliament and the Council. Linking the 

54 

 
 
implementation timelines of these two closely related initiatives would multiply the benefits 
identified in both by further streamlining the entire public procurement process and increasing 
the level of digitalisation of Member States’ public authorities. 

The  approach  presented  above  would  be  closely  aligned  with  the  views  of  stakeholders 
presented during the public consultation. The obligation for contracting authorities to accept 
e-invoices reflects the wish of stakeholders to see mandatory steps undertaken to increase the 
use  of  e-invoicing  in  public  procurement.  While  the  provision  of  a  common  European 
standard would lower the costs and complexity for suppliers and contracting authorities (the 
main expected benefits identified in the consultation), the ability to continue to submit paper 
invoices and e-invoices in existing formats as long as this is permitted by the Member States 
reflects  the  wish  of  stakeholders  for  voluntary  instruments  to  enhance  interoperability.  The 
goal of implementation within the 2017-2018 timeframe reflects the wish of stakeholders to 
move forward quickly, while taking into consideration the restrictions imposed by the need to 
develop a new standard. Finally, the application of the initiative to contracting authorities at 
all levels and the inclusion of invoices in all relevant sectors but stemming only from above-
threshold public procurement are once again reflective of the opinion of the majority of the 
stakeholders.  

6.3.2.  Participation of microenterprises 

The  Impact  Assessment  has  brought  to  light  a  couple  of  elements  related  to  the  use  of  e-
invoicing by microenterprises. Microenterprises represent only a small fraction of firms which 
participate  successfully  in  public  procurement102.  In  light  of  the  above,  the  question  arises 
whether 
in  public  procurement  should  also  cover 
microenterprises. 

initiative  on  e-invoicing 

the 

After  an  analysis  of  the  potential  costs  and  benefits  to  microenterprises  of  the  current 
initiative, it is proposed to include them in its scope. This decision is based primarily on the 
consideration of the impact of the chosen Option on those microenterprises which do wish to 
take up e-invoicing. In a case where they would be excluded, microenterprises would be the 
only firms (contrary to all larger firms) without guarantee that contracting authorities would 
have  to  accept  their  e-invoices.  Additionally,  by  including  microenterprises  in  the  scope  of 
this  initiative,  they  would  gain  access  to  new  business  opportunities  by  ensuring  that  they 
would  not  be  excluded  from  participating  in  cross-border  public  procurement  only  due  to 
different e-invoicing requirements.  

On the other hand, there would be no negative impacts on microenterprises which do not wish 
to use e-invoicing. If Option (4) is implemented, the decision whether or not to send e-would 
be up to each firm. As such, those microenterprises which wish to remain with paper would 
not be negatively impacted in any way. 

An  exclusion  of  microenterprises  from  this  initiative  would  also  place  additional  burden  on 
contracting authorities, which would need to monitor the size of enterprises with which they 
are dealing. This would not only increase costs and complexity, but might lead to errors and a 
risk of legal challenges. These risks are even more significant considering that the size of a 
company can change through time – sometimes quite rapidly. Finally, there do not appear to 

102 

The  share  of  micro  enterprises  winning  public  procurement  contracts  above  EU  thresholds  was 
estimated at 18% in terms of the number of contracts and 6% in terms of value (2006-2009 data). 

55 

 
 
                                                 
be any clear benefits for contracting authorities from the exclusion of microenterprises from 
the current initiative. 

6.3.3.  Regulatory form 

As  to  the  form  of  a  possible  legislative  act  which  would  implement  the  chosen  option,  a 
directive appears to be the most appropriate choice. The proposal envisaged under Option (4) 
only  imposes  on  the  Member  States  an  obligation  to  achieve  certain  results,  while  leaving 
them  the  choice  of  how  to  do  so  (e.g.  regarding  the  governance  arrangements  or  technical 
infrastructures  that  will  be  used  to  implement  the  new  e-invoicing  standard  in  public 
procurement). These choices may need to be developed in national legislation transposing the 
legislative proposal (draft directive) envisaged under the preferred Option. 

The choice of legal form for the Commission's legislative proposal is determined both by the 
chosen legal basis and by the content of the proposal. As mentioned previously, Article 114 
TFEU is the appropriate legal basis for this proposal. In principle, this article leaves open the 
choice of either a directive or a regulation as the legal form of a proposal. However, since the 
scope  of  the  proposal  envisaged  under  the  preferred  Option  would  match  that  of  the 
Directives, it may also be necessary to use the other legal bases of the Directives (i.e. Articles 
54.1 and 62 TFEU). This would imply that the only possible legal form would be a directive. 
This point will be explored further during the preparation of the proposal. 

6.3.4.  Development of the new standard 

As  far  as  the  development  of  the  new  technical  standard  is  concerned,  substantial  work  has 
already  been  done  to  develop  specifications  and  a  multilateral  inter-operability  framework, 
within the context of CEN BII103 and UN/CEFACT (the latter at an international level).The 
PEPPOL  project  has  also  contributed  by  developing  a  number  of  specifications  (based  on 
CEN BII) and open-source software components for cross-border e-invoicing. Moreover, the 
EMSF on e-invoicing is also making progress in developing an architecture that supports the 
adoption  of  e-invoicing  in  'communities'  (whether  in  the  public  or  private  sectors)  and  the 
underlying  business  requirements,  while  allowing  for  the  electronic  exchange  of  invoice 
information  between  communities  where  relevant.  The  EMSF  is  also  expected  to  provide 
recommendations  about  the  elements  of  this  architecture  which  should  be  developed  into 
formal European standards (ENs) in order to allow for optimal adoption and implementation. 
Discussions  with  stakeholders  (i.e.  in  the  EMSF  and  in  the  CEN  Workshop  BII)  show  that 
there  is  a  growing  consensus  and  that  this  is  both  necessary  and  feasible  in  the  short-term. 
Moreover,  the  possible  Commission  proposal  would  build  on  the  recommendations  of  the 
EMSF and the future mandate would list a number of minimum requirements which the new 
standard would need to fulfil. The proposal would also set dates by which the EN would need 
to  be  developed.  Thus  a  clear  framework  would  be  provided,  and  Member  States  would  be 
given  sufficient  time  to  introduce  the  new  standard  into  their  e-invoicing  systems  once  it  is 
published. 

103 

CEN/ISSS Business Interoperability Interfaces for Public procurement in Europe. 

56 

 
 
                                                 
7. 

OVERALL IMPACTS OF THE CHOSEN OPTION 

The expected impacts of the proposed Option have already been touched upon in several parts 
of  this  Impact  Assessment.  In  order  to  provide  a  conclusion,  the  scenario  is  once  again 
presented below. 

7.1. 

Primary impacts 

In  the  preferred  Option  (4),  a  new  European  standard  for  e-invoicing  would  be  introduced 
and,  by  a  certain  date,  all  contracting  authorities  which  award  public  procurement  contracts 
according to the provisions of the Directives would have to accept e-invoices complying with 
this  common  standard.  Several  results  can  then  be  expected.  Firstly,  for  enterprises  the 
introduction  of  a  common  standard  would  lower  the  costs  and  complexity  generated  by  the 
need  to  support  several  different  e-invoicing  systems.  Market  access  barriers  inhibiting  the 
proper  functioning  of  the  Internal  Market  would  effectively  be  removed  as  firms  active  in 
public  procurement  would  be  able  to  send  electronic  invoices  in  a  single  standard  to  any 
contracting authority in any Member State. This would be particularly beneficial to SMEs, for 
whom  the  initial  investment  to  support  many  e-invoicing  standards  is  relatively  speaking 
more significant. In time, if sufficient numbers of enterprises and Member States take up the 
new  standard,  it  may  become  the  preferred  one  across  the  EU,  potentially  also  in  the  B2B 
sector. 

7.2. 

Secondary impacts 

As the availability of a common interoperable standard may provide a potential solution and 
guidance  for  those  Member  States  which  have  not  yet  implemented  e-invoicing  but  are 
considering doing so, the e-invoicing uptake is expected to increase across the EU.  

The  gradual  uptake  of  e-invoicing  by  ever  greater  number  of  market  actors,  induced  by  the 
emergence  of  the  new  standard,  might  generate  some  secondary  impacts.  As  explained  in 
previous  sections,  Option  (4)  may  ultimately  lead  to  the  hoped-for  situation,  where  e-
invoicing interoperability in public procurement would be achieved in parallel with a broader 
uptake of e-invoicing. The latter is in turn expected to be a source of multiple benefits, such as 
operational  savings,  faster  payments,  environmental  gains,  improved  transparency,  the 
reduction  of  administrative  burden,  etc.  However,  it  should  be  mentioned  that  the  level  of 
potential  benefits  depends  to  a  significant  extent  on  the  level  of  e-invoicing  uptake,  an 
increase of which is highly probable but not certain under the preferred Option. 

8. 

MONITORING AND EVALUATION 

The  Commission  should  review  the  implementation  of  any  (legislative  or  non-legislative) 
proposal  on  e-invoicing  in  public  procurement  with  regards  to  the  achievement  of  policy 
objectives identified in this Impact Assessment. It shall evaluate in particular whether, and to 
what extent, the above objectives have contributed to the improvement of the functioning of 
the Internal Market. A commitment to evaluating the impacts of a legislative act, if proposed, 
should be included in the draft text. 

The  indicators  proposed  to  monitor  the  achievement  of  policy  objectives  identified  in  this 
Impact Assessment are presented below. 

57 

 
 
Table 12): Monitoring of specific objectives 

SPECIFIC 
OBJECTIVES 

MONITORING 
INDICATORS 

SOURCES OF DATA 
AND/OR DATA 
COLLECTION METHODS 

DATA 
COLLECTED  
ALREADY? 

Lower costs 
for firms 

Procurement operating 
costs borne by 
contracting authorities 
and enterprises 

Reduce 
complexity for 
firms 

Perceptions of 
complexity and 
willingness to bid cross-
border among firms 
active in public 
procurement above EU 
thresholds 

A study needs to be 
launched (a follow up of a 
survey implemented 
within “Cost-
effectiveness” study in 
2011104; data from the 
survey will be used as a 
benchmark ) 

A study needs to be 
launched on perceptions 
of complexity in cross-
border procurement due 
to invoicing requirements 

ACTORS 
RESPONSIBLE 
FOR DATA 
COLLECTION 

The 
Commission 

NO but 
benchmark 
exists 

NO 

The 
Commission 

Table 13): Monitoring of operational objectives 

OPERATIONAL 
OBJECTIVES 

MONITORING 
INDICATORS 

SOURCES OF DATA 
AND/OR DATA 
COLLECTION METHODS 

DATA 
COLLECTED  
ALREADY? 

Enhance 
interoperability 
in e-invoicing 

The number and value 
of invoices exchanged 
cross border in public 
procurement 

A study needs to be 
launched (e.g. to access 
data processed in 
invoicing systems) 

NO 

The  number  and  value 
of  cross-border  awards 
in public procurement  

OJ/TED  database 
collected 
developments 
monitored) 

(data 
already, 
be 
to 

YES 

ACTORS 
RESPONSIBLE 
FOR DATA 
COLLECTION 

The 
Commission 

The 
Commission 

To  avoid  putting  any  additional  administrative  burden  on  contracting  authorities,  firms  or 
Member  States  due  to  the  collection  of  information  used  for  monitoring,  the  proposed 
indicators  mainly  rely  on  the  existing  data  sources  (e.g.  OJ/TED,  Eurostat)  or  data  already 
collected by stakeholders (e.g. e-invoicing service providers) in their business activities. 

104  

„Public Procurement in Europe : Cost and effectiveness”, PricewaterhouseCoopers, London 
Economics, and Ecorys, 2011. 

58 

 
 
                                                 
However,  there  are  some  data  gaps  which  will  require  additional  research.  This  should  be 
done  by  conducting  a  targeted  study105.  The  costs  of  such  a  study  should  be  borne  by  the 
Directorate General for Internal Market and Services within its operational expenditure (e.g. 
as  support  expenditure  for  operations  of  the  Internal  Market  policy  area).  As  a  result,  the 
proposed  monitoring  arrangements  would  not  generate  additional  administrative  burden 
(reporting obligations) for firms, including SMEs. 

105  

It is expected that all of the above indicators can be collected within one single research project. 

59 

 
 
                                                 
1. 

ANNEXES  

1.1.  Modifications following the IAB opinion of 22 March 2013 

Further to the negative opinion of the IAB following the meeting 20 March 2013, a number of 
modifications were introduced into the Impact Assessment report. The changes corresponding 
to the main recommendations for improvement are presented below: 

1.1.1. 

Strengthen the problem definition 

Significant  modifications  have  been  made  to  the  problem  definition.  The  problem  tree  has 
been revised in order to focus the assessment more on the principal problem of market access 
barriers. As a result, the problem drivers, problems, and consequences have been reworked.  
The  reasons  why  current  non-legislative  efforts  have  failed  and  why  existing  technical 
solutions are insufficient to resolve the problem have been presented more clearly. The link 
between the proposed initiative and existing initiative in related fields has been strengthened. 
It is important to note that the new approach has rendered irrelevant a number of the Board’s 
initial  concerns  (impact  on  employment,  impact  on  microenterprises,  proportionality,  some 
elements of the cost analysis, etc).  

1.1.2. 

Strengthen the subsidiarity and proportionality analysis 

The arguments supporting the necessity for EU action have been reinforced, and the reasons 
why Member State’s current efforts have not resolved the problem have been presented more 
clearly. The revised approach has made irrelevant the comment concerning the limited impact 
of the initiative due to the small size of cross-border public procurement – the initiative now 
focuses much more on the legal aspects of eliminating market access barriers. 

1.1.3. 

Improve analysis of the impacts 

An important  part  of the comments in this  section are no longer relevant due to the revised 
structure  of  the  Impact  Assessment.  However,  additional  information  has  been  included 
concerning the process and timing of the introduction of a new standard, the data on potential 
costs  for  contracting  authorities  has  been  highlighted,  and  the  assessment  of  the  potential 
impacts has been broken down into two parts: one concerning Member States which already 
have a mandatory e-invoicing system in place and those which do not. A justification for the 
inclusion of microenterprises has been added. 

1.1.4.  Better present stakeholder views 

The sections presenting the views of the different stakeholders on the problem definition and 
the different options have been revised and improved. 

1.1.5.  Procedure and presentation 

The report has been shortened, and a significant amount of information has been moved to the 
annex. The presentation of the options was revised and strengthened, and an annex with key 
definitions has been added.  

60 

 
 
1.2.  Modifications following the IAB opinion of 8 May 2013 

The following changes have been introduced to the Impact Assessment report to address the 
comments included in the second opinion of the IAB: 

•  the need for an EU action has been analysed in the context of the relatively small scale of 
cross-border procurement and the stakeholders’ views expressed in the public consultation; 

•  the proportionality of the proposed EU intervention has been further elaborated; 

•  the  choice  between  a  mandatory  or  voluntary  instrument  and  the  nature  of  the  proposed 

menu of Options have been explained in more detail; 

•  the potential risk of higher cost to contacting authorities arising from the need to accept e-

invoices in different formats has been discussed; 

•  the likelihood of a low uptake of e-invoicing due to the voluntary nature of the proposed 

measures has been analysed.  

1.3. 

Benefits and costs of e-invoicing in public procurement  

Multiple sources have identified a broad range of drivers for the adoption of e-invoicing. The 
most frequently mentioned are time-gains, cuts in operating costs, environmental impacts, as 
well  as  improved  transparency,  security,  and  auditability  of  data.  The  broader  use  of  e-
invoicing  across  the  EU  would  therefore  have  positive  economic  impacts  resulting  mainly 
from savings to the economy. Finally, an initiative in this area would also help to reduce the 
administrative burden on enterprises. 

In a recent survey, respondents (CFOs and other financial professionals, 13% of which came 
from  the  public  sector)  were  asked  to  evaluate  current  practices  surrounding  e-invoicing 
processes.  In  a  question  about  the  extent  to  which  e-invoicing  can  be  associated  with 
achieving overall business goals, the following aspects of e-invoicing were mentioned as the 
most efficient: improvements of operational efficiency (67%), improvement of environmental 
practices (e.g. paperless office, 58%) and improved auditing/compliance (34%)106. In paper-
based environment all these potential benefits are lost and turn into persisting inefficiencies of 
purchasing processes.  

Inevitably, the switch to e-invoicing would also generate some costs. Contrary to the benefits, 
these  would  be  almost  exclusively  economic  (monetary)  in  nature,  but  some  limited  social 
and  environmental  costs  are  nonetheless  hypothetically  possible.  However,  a  comparison  of 
the  costs  with  the  potential  benefits  of  e-invoicing  clearly  shows  that  the  former  are 
significantly exceeded by the latter. 

All of these aspects are discussed below in detail. Due to the specificity of the available data 
on the economic impacts of e-invoicing, the information on economic benefits is presented for 
the  most  part  in  terms  of  net  benefits  (i.e.  including  implementation  and  operational  costs). 
An effort is then made to present the economic costs of implementation based on the available 

106 

“2012  Global  E-Invoicing  Study  -  A  shift  toward  e-invoicing  ecosystems”,  The  Institute  of  Financial 
Operations & Basware, (http://www.basware.co.uk/einvoicing-survey-2012). 

61 

 
 
                                                 
data.  The  data  concerning  the  social,  transparency,  and  environmental  impacts  can  more 
easily be separated into gross costs and benefits, and is therefore presented as such. 

1.3.1.  Benefits 

The benefits of e-invoicing can be broken down into the (net) economic impacts, as well as 
the  environmental,  social,  and  transparency  improvement  impacts.  The  economic  benefits 
would in practice be the result of operational efficiencies at both micro and macro level. 

1.3.1.1.  Operational efficiencies – micro level 

The use of e-invoicing in public procurement could lead to improved operational performance 
through  more  efficient  sending,  reception,  and  processing  of  incoming  invoices,  and  could 
also  affect  various  directly  related  processes,  such  as  the  preparation  of  payments  or 
storage/archiving.  When  fully  automated,  all  of  these  require  significantly  fewer  resources 
and are therefore less costly than in the case of traditional paper-based processes.  

The  principal  evidence  for  the  observed  operational  savings  comes  from  the  comparison  of 
costs between automated and paper based invoicing. For example, the Finnish State Treasury 
and  some  Finnish  companies  have  estimated  that  an  incoming  paper  invoice  incurs  costs 
accounting to EUR 30-50 to the receiver company. By moving to electronic invoicing, these 
costs  can  be  lowered  to  EUR  10  by  semi-automating  the  invoice  process  and  to  1  EUR  by 
fully  automating  the  process.  Some  service  providers  estimate  that  processing  of  paper 
invoices  is  around  60%  to  80%  more  expensive  than  electronic  invoices.  According  to 
Politecnico  di  Milano  the  switch  from  paper  based  to  automated  invoicing  may  generate 
benefits of up to EUR 65 per invoice in the case of full integration of the trade process. The 
European  Associations  of  Corporate  Treasurers  has  reached  similar  results,  estimating  that 
companies  could  save  up  to  80%  of  their  current  costs  by  processing  invoice  data 
automatically, removing paper and manual efforts.  

It  should  be  noted  that  the  additional  costs  of  manual  processing  of  invoices  are  shared 
asymmetrically between senders and recipients of invoices, with the latter being more affected 
by the excessive costs. As a consequence, public authorities’ losses due to higher transaction 
costs are more significant than those of firms participating in public procurement. 

However,  the  operational  inefficiencies  generated  by  paper-based  invoicing  do  not  concern 
only the cost associated with this process but also the amount of time which it requires. The 
most  time-consuming  parts  of  the  manual  processes  are  invoice  processing  and  query 
handling.  As  a  result,  the  invoice-to-pay  cycle  time  in  paper-based  invoicing  may  take 
between  30  and  100  days  (in  the  best-case/worst-case  scenario  respectively).  According  to 
another source, it is estimated that payment processing times can be shortened from 4 weeks’ 
time to around 10 days when invoices are processed electronically. If the assumptions from 
the  two  above  data  sources  were  combined,  then  the  net  gain  from  the  switchover  to  e-
invoicing  would  be  between  20  to  90  days  (i.e.  paper  invoice  processing  time  of  30  to  100 
days, less 10 days in case of e-invoicing). The shortened invoice-to-pay cycle also means that 
payment delays would be less frequent and contracting authorities could save on late payment 
interests.  E-invoicing  could  therefore  contribute  to  attaining  the  objectives  of  the  late 
payments Directive 2011/7/EU.  

62 

 
 
1.3.1.2.  Operational efficiencies – macro level 

The  overall  economic  impacts  of  a  broader  introduction  of  e-invoicing  in  the  public  sector 
would  be  positive.  Examples  of  the  scale  of  potential  savings  come  from  the  countries  that 
have  introduced  or  consider  introducing  e-invoicing  in  their  administrations.  The  U.S. 
Department of the Treasury estimates that e-invoicing would save taxpayers as much as 450 
million USD annually, if it was adopted government-wide. The Danish government estimates 
benefits of the conversion to e-invoicing in the public sector at about EUR 30 million a year, 
while the Swedish estimates oscillate around 57 million of yearly net savings. 

The overall net benefits of the introduction of e-invoicing in public procurement are estimated 
at around 1.5 to 2.3 billion EUR annually. This calculation was carried out using two different 
approaches: (i) comparison with Member States’ estimates and (ii) top-down approach.  

Using the top-down approach, the overall savings resulting from the adoption of e-invoicing 
in  public  procurement  can  be  estimated  on  the  basis  of  the  figures  from  the  B2B  sector 
mentioned  in  the  2010  e-invoicing  Communication.    According  to  the  Communication,  the 
mass adoption of e-invoicing within the EU would lead to significant economic benefits and it 
is estimated that moving from paper to electronic invoices would generate savings of around 
EUR  240  billion  over  a  six-year  period.  As  mentioned  in  section  2.1.4,  public  procurement 
above  EU  threshold  constitutes  approximately  3.7%  of  GDP.  Public  procurement  below  the 
thresholds  is  estimated  at  another  2%  of  GDP    If  the  5.7%  share  of  public  procurement  in 
GDP  were used as a proxy of the expected benefits, then the global savings generated by the 
introduction of e-invoicing could be around 2.3 billion EUR per year .  

To complete the picture of the top-down calculation, savings that could be achieved can also 
be extrapolated from data provided by the Member States that either have already introduced 
e-invoicing or plan to do so. As mentioned above, Sweden estimates that the adoption of e-
invoicing  can  generate  savings  of  400  million  EUR  in  7  years  for  government  as  a  whole. 
Denmark  estimates  savings  of  around  30  million  EUR  per  year.  If  these  national  estimates 
were again extrapolated for the EU on basis of the GDP, the global savings for the EU would 
be between 1.57 and 1.86 billion EUR.  

As  indicated  above,  the  two  above  mentioned  calculation  methods  give  a  range  of  annual 
savings  between  1.5  to  2.3  billion  EUR  per  year.  It  is  however  important  to  note,  that  the 
actual impact of a Commission initiative in this area might differ from this estimate. It is also 
important  to  note,  that  the  maximum  level  of  potential  savings  will  only  be  achieved  if 
invoicing  becomes  fully  electronic,  i.e.  if  the  entire  post-award  supply  chain  process  is 
automated. 

It  is  important  to  note  that  the  distribution  of  the  potential  economic  benefits  would  not  be 
evenly  spread  among  the  different  users.  In  particular,  the  costs  and  efforts  of  processing 
invoices are much more significant on the receiving side than on the sending side – whereas 
the  sender  only  needs  to  print  out  the  invoice,  put  in  in  an  envelope  and  send  it  off,  the 
recipient must register it, verify it, transfer it to the Accounts Payable, which must match the 
invoice against an existing purchase order, input the data into the ERP or accounting system, 
archive it, etc. By eliminating the need for these processes, the potential savings are by default 
greater  for  the  recipient  than  for  the  sender.  In  addition,  savings  are  obviously  greater  for 
large  companies  and  public  bodies  who  deal  with  a  significant  volume  of  invoices  than  for 
small companies and localities which process only a few invoices a month or even a year. 

63 

 
 
1.3.1.3.  Environmental gains 

The  predominance  of  paper  based  invoicing  results  in  environmental  inefficiencies,  such  as 
excessive use of paper by public buyers and firms. The obvious environmental benefits of the 
broad introduction of e-invoicing are therefore: a significant reduction in the number of trees 
cut  down  for  the  production  of  paper,  a  reduction  in  the  amount  of  solid  waste  generated, 
reduced  CO2  emissions  due  to  a  lower  need  for  road  and  air  transport,  and  a  reduction  of 
other emissions resulting from the production of paper.  

Multiple examples and case studies are available to confirm this finding. One invoice service 
provider  provides  information  about  one  of  its  clients,  whose  transition  from  paper  to 
electronic  invoices  has  saved  6  million  sheets  of  paper  –  the  equivalent  of  700  trees,  85 
barrels of oil,  173 000 kilowatts  of energy, and more than 2 500 pounds of air pollution107. 
According to the Euro Banking Association, 1 000 000 paper invoices require approximately 
400  trees108.  The  Euro  Banking  Association  estimates  that  a  1%  increased  adoption  of  e-
invoicing in Europe (across all industries) could lead to an annual reduction of tree usage of 
approximately  800  000  trees  and  towards  reduction  of  CO2  emissions.  According  to  yet 
another  source,  sending  out  around  150  000  e-invoices  annually  would  save  14.4  tonnes  of 
carbon, 57.6 trees, 180 000 litres of water or 1872 kg of solid waste109 (to put this number in a 
context,  the  Norwegian  Public  Roads  Administration  receives  about  170  000  invoices  per 
year110).  Finally,  Deutsche  Bank  estimates  that  a  complete  conversion  to  e-invoicing  across 
Europe would save 12 million trees a year111. The latter figure refers to a complete switchover 
in all market segments (B2B, B2C, etc.), but even if the environmental gains were lower in 
the  B2G  sector,  they  would  still  be  significant  and  show  the  scale  of  inefficiencies  of  the 
current paper-based system. 

1.3.1.4.  Improved transparency 

The  electronic  processing  of  invoices  positively  influences  the  transparency  of  the 
procurement  process.  If  e-invoicing  were  widely  adopted,  governments  would  realise 
additional  savings  due  to  lower  auditing  costs  for  trading  parties  and  tax  authorities. 
Transparency motives are frequently referred to when mentioning reasons for the adoption of 
mandatory e-invoicing  by  governments (e.g. Austria, the US). It is estimated that in Greece 
both  the  state  and  enterprises  were  losing  more  than  4  billion  EUR  annually  from  illegal 
invoicing  practices  -  electronic  invoicing  is  expected  to  effectively  combat  such  practices. 
Transparency  aspects  were  also  among  the  major  drivers  for  the  adoption  of  e-invoicing  in 
Latin America. For example, in Argentina the introduction of mandatory invoicing is reported 
to have contributed to a significant reduction in the incidence of VAT fraud. The potential for 
improved  transparency  of  the  process  also  concerns  broadly  understood  business  fraud. 
Industry  publications  underline  that  e-invoicing  reduces  operational  risk  through  automated 
matching  and  approval  processes  that  include  controls  on  the  invoice  data.  Such  processes 
dramatically reduce the risk of fraudulent invoices and duplicate payments. The combination 
of e-invoicing adoption with a well thought out matching process and strict controls on bank 

107 
108 
109 
110 

111 

http://www.environmentalleader.com/2010/09/08/how-e-invoicing-can-save-a-small-forest/ 
E-invoicing 2010, “European market guide”, Euro Banking Association (EBA) and Innopay. 
http://www.accountis.com/green-calculator/ 
„AGFA - vurderinger og anbefalinger om elektronisk faktura i staten”, Rapport fra arbeidsgruppe for 
elektronisk faktura, 25. mars 2008, Fornyings- og administrasjonsdepartementet. 
”E-invoicing - Final step of an efficient invoicing process”, Deutsche Bank Research, May 3, 2010. 

64 

 
 
                                                 
account  entries  are  key  to  eliminating  business  fraud.  In  practical  terms,  when  a  tax  audit 
occurs,  e-invoices  can  be  more  easily  made  available to  tax  authorities  than  paper  invoices, 
allowing them to check for compliancy more easily.  

All  of  the  above  observations  are  equally  valid  when  invoices  are  exchanged  in  public 
procurement. 

1.3.1.5.  Social benefits 

The  main  social  benefits  at  enterprise/public  authority  level  will  be  the  potential  for 
employees currently engaged in low value-added, repetitive tasks to be redirected into more 
productive  and  more  rewarding  work.  In  a  broader  sense  (i.e.  in  terms  of  the  secondary 
impacts),  society  as  a  whole  will  benefit  from  a  reduced  potential  tax  evasion  by  market 
operators, through better control of invoices (less possibility of data tampering) and improved 
auditability.  This  will  result  in  an  improved  financial  situation  of  the  Member  States. 
Additionally,  as  e-invoicing  is  expected  to  induce  the  digitalisation  of  public  seller’s  back 
office,  it  could  also  influence  the  wider  digitalisation  of  government  services  in  general  (e-
Government),  hence  creating  conditions  for  the  provision  of  more  efficient  and  citizen-
friendly public services.    

1.3.2.  Costs 

The costs of the broader use of e-invoicing are primarily economic, but also to some extent 
social and environmental in nature. Contrary to the data on net benefits, the data on costs is 
less  easily  available.  Nevertheless,  a  general  outline  of  the  possible  costs  of  e-invoicing  is 
presented below. 

1.3.2.1.  Economic (implementation) costs 

The  introduction  of  e-invoicing  in  an  enterprise  or  a  public  body  inevitably  has  some 
implementation costs, such as those linked to the purchase of software or hardware, training 
costs,  costs  resulting  from  process  change,  or  fees  paid  to  service  providers.  However,  it  is 
important to keep in mind two considerations. Firstly, the increased availability of software-
as-a-service and cloud-based solutions means that important new IT-related investment are no 
longer necessary, greatly limiting the up-front costs. This is particularly important for SMEs, 
for whom simple, web-based solutions should be fully sufficient. Secondly, there is on-going 
innovation  in  the  e-invoicing  sector,  including  through  the  development  of  new  business 
models.  Some  service  providers  now  offer  basic  e-invoicing  services  sufficient  to  meet  the 
needs of smaller companies, in particular micro-enterprises, free of charge, while others with 
a more traditional business model that charge fees to suppliers tend to provide a free quota of 
invoices  before  fees  are  applied.  Thirdly,  some  Member  States  have  also  implemented 
systems  or  portals  through  which  suppliers  can  submit  electronic  invoices  free  of  charge  to 
contracting  authorities,  e.g.  Denmark,  Spain,  the  Netherlands.  Finally,  even  with  the  use  of 
structured e-invoicing, solutions exist which make it possible for low-volume users (or those 
with  limited  IT  capabilities)  to  participate  in  e-invoicing  –  the  most  obvious  one  is  a  web-
based platform where suppliers can log  on  and type  in their invoice  data directly. Although 
this  would  limit  some  of  the  benefits  for  the  sender,  it  is  a  perfectly  viable  option  if  the 
primary wish is to keep costs to a minimum. The receiver would still be able to profit from all 
the benefits of automation, as the final invoice would nonetheless be sent in a structured data 
format. 

65 

 
 
It  should  be  noted  that  limited  data  is  available  concerning  the  implementation  costs  of  e-
invoicing  systems.  Only  a  few  Member  States  have  made  an  attempt  to  estimate  the  costs, 
such as Belgium (cost of €300,000 for the country’s pilot project), Spain (€100,000 per year), 
or  Scotland  (£500,000  during  the  first  two  years  of  implementation).  As  previously 
mentioned, these estimates are significantly smaller than the expected benefits. 

In summary, although some there are inevitably some start-up costs associated with the use of 
e-invoicing,  methods  exist  to  keep  these  to  a  minimum,  while  the  benefits  of  e-invoicing 
remain  important  (and,  as  explained  in  section  1.6,  are  greater  the  more  fully  the  invoicing 
process  is  automated).  As  a  result,  even  for  smaller  market  operators  the  benefits  of  e-
invoicing clearly outweigh the costs (the latter would even be negligible for companies that 
only submit a small number of invoices using free services already available on the market or 
provided by Member States, e.g. web forms or free software).  

1.3.2.2.  Social costs 

There is a potential for some redundancies due to the introduction of e-invoicing, as some of 
the tasks currently carried out by humans will be fully automated. Such redundancies should 
be minimal in the public sector, where internal reassignment is much more common than lay-
offs; they are more probable in enterprises, where such decision depend also on a number of 
other  factors,  e.g.  labour  market  regulation  and  market  conditions.  However,  in  light  of  the 
fact  that  the  current  initiative  would  apply  to  invoices  sent  by  enterprises  to  contracting 
authorities, and considering that, as mentioned in previous sections, e-invoicing has a greater 
impact on the recipient than on the sender (in terms of the resources necessary), the number of 
redundancies in enterprises should not be excessive. 

1.3.2.3.  Environmental costs 

There  do  not  appear  to  be  any  significant  environmental  costs  of  the  initiative.  The  only 
potential impacts worth mentioning are a potential rise in electricity usage due to the need for 
more electronic processing power and data storage space (e.g. server parks) and an increase in 
the long term of electronic waste products. However, it is currently impossible to verify the 
validity  of  these  hypothetic  impacts,  and  it  is  possible  that  the  effects  resulting  from  e-
invoicing  might  be  on  the  order  of  statistical  error  considering  the  general  trend  of  greatly 
increasing  use  –  and  hence  disposal  –  of  energy  and  electronic  equipment.  In  any  case,  it 
appears safe to assume that any such costs would be greatly exceeded by the environmental 
benefits referred to above. 

1.4.  Why start with e-invoicing? 

Invoicing  is  only  one  of  a  number  of  post-award  processes  stemming  from  public 
procurement. Others include ordering, payment, archiving, to name the most important ones 
(see:  Figure  1  in  section  2.1.1.1).  The  benefits  of  automating  the  post-award  public 
procurement  process  are  greater,  the  greater  the  number  of  procurement  steps  which  are 
automated (allowing the elimination of a greater number of inefficient manual processes). The 
question  then  arises  as  to  whether  it  is  sufficient  to  attempt  to  address  only  one  of  these 
processes  (e-invoicing)  in  a  potential  initiative  at  EU  level. There  are  two  principal  reasons 
why  this  question  can  be  answered  in  the  affirmative.  Firstly  –  and  most  importantly  –  a 
number  of  Member  States  have  also  begun  efforts  to  automate  their  national  post-award 
public procurement processes with action on e-invoicing. As has been explained in the Impact 

66 

 
 
Assessment,  these  actions  have  led  to  the  creation  of  market  access  barriers.  As  such,  it  is 
these activities which need to be addressed initially.  

Secondly, most if not all of the remaining processes have in one way or another already been 
the object of action at EU level. Specifically: 

•  the  element  of  e-payments  has,  to  a  large  degree,  been  addressed  in  the  recent 
SEPA  legislation,  and  electronic  payments  are  already  a  fairly  standard  way  of 
doing business in the EU;  

•  electronic archiving of invoices requires the existence of electronic invoices in the 

first place in order to generate many of the benefits112;  

•  e-ordering  is  closely  related  –  and  dependent  on  –  the  existence  of  electronic 
catalogues  (ordering  goods  and  services  electronically  requires  these  goods  and 
services to be listed online, with their relevant codes, parts numbers, descriptions, 
etc.), which are handled by the current reform proposal113.  

Action  on  e-invoicing  is  therefore  the  logical  next  step:  it  is  necessary  in  order  to  remove 
existing and avoid future market access barriers, and it is also the area most likely to generate 
the  expected  spill-over  effects  into  the  remaining  elements  of  the  post-award  public 
procurement process. 

1.5. 

Structured e-invoicing - efficiencies of higher levels of automation 

One  of  the  most  important  factors  influencing  the  level  of  overall  benefits  which  the 
introduction of e-invoicing could generate is the level of automation of the invoicing process 
itself, as well as of any related post-award procurement processes. The key to maximising the 
returns  on  an  investment  in  e-invoicing  is  the  complete  elimination  of  the  need  for  human 
intervention during the entire invoicing process, from preparation to processing and archiving. 
Currently, very often a traditional paper invoice is printed from its electronic version on the 
supplier side, placed in an envelope and sent by post to the recipient. On the receiving side, 
the invoice is then registered, verified, approved, and sent for archiving, all of which is done 
manually  by  accounts  receivable  staff.  Frequently,  the  invoice  data  is  scanned  or  manually 
entered  into  the  buyer’s  electronic  data  storage  system.  Each  of  these  tasks  costs  the  two 
parties a significant amount of time and money, and opens up the possibility for errors. If all 
of them are eliminated, allowing a direct sending of an electronic invoice from the supplier’s 
to the buyer’s computer system, huge savings could be realised. Additionally, if an electronic 
invoice verification system is used, the probability of errors would be virtually eliminated. As 
mentioned in Annex 1.4 above, the extension of digitisation to other parts of the purchase-to-
pay process (e.g. e-ordering, e-payment, e-archiving, etc.) would further increase the potential 
benefits. 

112 

113 

Although paper invoices can certainly be scanned and stored electronically, such an approach implies 
virtually no direct process cost savings and only limited benefits in terms of accessibility of data: while 
it is true that the invoices could be accessed more easily, the data within them would most likely not be 
computer readable.  
http://ec.europa.eu/internal_market/publicprocurement/modernising_rules/reform_proposals_en.htm 

67 

 
 
                                                 
1.6. 

Overview of e-invoicing uptake in EU Member States 

As  part  of  the  broad  consultations,  the  Commission  undertook  a  survey  of  the  national  e-
invoicing  fora  represented  in  the  EMSF  concerning  the  current  usage  of  e-invoicing  in  the 
various  Member  States.  19  replies  were  received  from  Member  States  and  Croatia  -  the 
following  Member  States  did  not  provide  a  response:  Bulgaria,  Estonia,  Finland,  Greece, 
Hungary, Ireland, Latvia, Malta, and Slovenia. 

68 

 
 
Table 14): Summary of a survey of the national e-invoicing fora (via EMSF) 

MS 

mandatory / 
recommended? 

for whom? 

standard 

set-up 

fees 

Austria 

Yes, as of 
1/01/2014 

initially only for 
central bodies, but 
regional and local 
are invited to 
participate 

four options: 
- PEPPOL 
- use of online form 
- upload of XML-files 
- web service 

invoices to federal government 
must be submitted through a 
central platform; businesses 
need to be registered on it 

three options: 
- direct connection to web-
services 
- via service providers 
- web portal 

free if using PEPPOL; standard 
service provider fees otherwise 

free if using web portal or web 
services; otherwise standard 
service provider fees 

Belgium 
Bulgaria 
Croatia 
Cyprus 

N 

N 
N 

n/a 

n/a 
n/a 

UBL-based standard will be 
mandatory; e-Prior will be used 

n/a 
n/a 

n/a 
n/a 

n/a 
n/a 

law allows 
government 
agencies to make 
it obligatory at 
their discretion; 
no obligation 
exists 

Czech 
Republic 

any public body 

- national standard exists, but it 
is not mandated: ISDOC, based 
on UBL 2.0 with electronic 
signatures 
- EDIFACT used in B2B (ODETTE 
or EANSCOM) 
- Min of Finance preparing 
mandatory national standard 

primarily based on 'databoxes' 

in B2G, free for public bodies if 
using databoxes; costs borne by 
the supplier 

69 

 
 
  
  
  
  
  
mandatory for all 
suppliers to the 
public sector to 
send e-invoices 

all public sector 
(central, regional, 
local) 

- OIOUBL, based on UBL 2.0 is 
the mandated national 
standard in p.p. 
- in private sector, UBL and 
EDIFACT used 

- NemHandel, an open source 
and open standards 
- used both in four-corner 
models and in peer-to-peer 
exchanges; 
- longer term, closer integration 
with PEPPOL is foreseen 

Denmark 
Estonia 
Finland 

France 

N 

n/a 

none - guidelines only concern 
security of data etc. 

no data 

- no charge when using 
NemHandel 
- when using four-corner 
models, cost is often borne by 
the buyer 
- no roaming fees between 
service providers when using 
NemHandel 
- increasing number of free-of-
charge solutions/portals aimed 
at SMEs 

no clear data, but it seems large 
organisations shift costs to 
suppliers 

national, open-source standard 
(ZUGFeRD), based on PDF/A-3 
(ISO 15005-3) including 
structured data according to 
UN/CEFACT XML Core CII as 
defined in the CEN MUG CWAs 

any transmission means 
possible 

use of standard will be free; 
transmission costs depend on 
service provider fees 

N 

Germany 
Greece 
Hungary 
Ireland 

70 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
- none for the moment 
- XML-based national standard 
is planned, which will be closely 
linked to the MUG (CEN BII 
profiles) 

- currently wide variety of 
systems in place 
- in future, e-invoices to 
government will be submitted 
via central hub; connections 
can be direct or via service 
provider 

no fees will be charged when 
using the central hub; no 
regulation of service provider 
fee structures is foreseen 

n/a 
n/a 

n/a 
n/a 

n/a 
n/a 

N 

Italy 
Latvia 
Lithuania 
N 
Luxembourg  N 
Malta 

n/a 

n/a 
n/a 

Mandatory to 
receive if sent vie 
Digipoort 
N 

central 
government 
n/a 

Netherlands 
Poland 

- Dutch version of UBL 2.0 
- "SETU", Dutch version of 
SIDES, on basis of hr-XML 
n/a 

Portugal 
Romania 
Slovakia 
Slovenia 

N 
N 
N 

n/a 
n/a 
n/a 

n/a 
n/a 
n/a 

Spain 

N 

n/a 

- Facturae is mandatory 
common standard for central 
government (linked to CEN BII 
profiles) 
- several versions of EDIFACT 
also used in specific sectors 

71 

buyer's own-platform (VAN) 
n/a 

several private platforms exist 
(large enterprises) 
n/a 
n/a 

- free for suppliers if using 
Digipoort 
- government agencies charged 
€0,59 / invoice 
n/a 

n/a 
n/a 
n/a 

- two main approaches: own-
platforms and outsourcing of 
invoice reception to service 
providers 

- no fees charged to the 
senders; government bears the 
costs 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
mandatory for 
central 
government to 
receive and send, 
but not mandatory 
for suppliers to 
send; voluntary for 
local and regional 
authorities 

n/a 

- Svefaktura (UBL 1.0-based) 
- EDIFACT also heavily used, 
especially in localities and 
regions 
- SFTI currently recommending 
standards for e-proc in public 
sector 

no mandatory standards; pdf 
quite common 

- various: 
 - four-corner model for central 
government platforms 
 - EDIFACT for VANs 
 - supplier portals for SMEs 
without EDI capability 
 - etc.  

- pure four-corner model - 
every side pays their service 
provider for services 
- government departments pay 
for implementation, a monthly 
fee, and fees to on-board 
suppliers 
- government striving to 
eliminate roaming fees 
between service providers 

VANS, 3-corner model 

vary 

Sweden 

United 
Kingdom 

Y 

N 

72 

 
 
1.7. 

Projects to facilitate the roll-out of e-invoicing in the EU 

As mentioned in section 2.1.3 the Commission supports and implements a number of projects 
to facilitate the roll-out of e-invoicing in the EU, including the following:  

•  PEPPOL: the Pan European Public Procurement On-Line project is a Large Scale 
Pilot  project  funded  by  the  EU’s  Competitiveness  and  Innovation  Framework 
Programme. It was launched in 2008 and concluded in mid-2012. PEPPOL’s aim 
was  to  promote  the  EU-wide  inter-operability  of  electronic  procurement.  The 
project  developed  a  number  of  specifications,  infrastructure  and  technical 
solutions  covering  both  the  pre-award  and  post-award  phases  of  public 
procurement,  including  e-invoicing.  PEPPOL’s  e-invoicing  component  has  been 
trialled in a dozen Member States. Several platforms enabled for e-invoices refer 
to e-Procurement systems support the use of PEPPOL invoice specification. The 
PEPPOL  project  has  been  completed  in  2012  and  turned  into  a  stand-alone 
initiative, operating without the Commission support as “Open PEPPOL” AISBL.  

•  e-SENS:  a  Large-Scale  Pilot  project  (LSP)  to  be  launched  in  2013.  It  will 
consolidate  and  expand  on  the  work  done  by  the  other  LSPs  with  the  aim  of 
industrialising  the  solutions  and  extending  their  potential  to  more  domains.  e-
SENS will contribute to building a sustainable infrastructure for use by Member 
or  Associated  States  when  delivering  cross-border  public  services  in  any  sector. 
Its  objectives  include  supporting  the  implementation  of  the  proposed  public 
procurement  directive  and  the  continued  standardisation  of  public  procurement 
processes.  As  such,  it  will  develop  specifications  and  services  for  the  pre-award 
part  of  the  procurement  process  and  continue  efforts  to  streamline  the  processes 
for  ordering  and  invoicing  (post-award  procurement).  It  will  support  the 
introduction of e-invoicing as a standard practice in public procurement and thus 
make the public sector a 'lead market' for e-invoicing and spearhead its wider use 
in the economy.  

•  e-PRIOR:  a  service-oriented  platform  developed  by  DG  Informatics  of  the 
European  Commission  under  the  ISA  programme.  It  allows  the  exchange  of  e-
procurement  documents  by  using  web  services,  or  via  a  portal,  or  over  the 
PEPPOL  network  through  its  built-in  gateway.  It  is  an  open-source  software 
which implements the emerging European standards of e-procurement. It is fully 
functional  at  the  European  Commission,  and  is  being  adopted  by  other 
institutions, agencies and Member States administrations. 

1.8. 

E-invoicing data exchange models 

According  to  EBA/Innopay,  the  following  definitions  of  e-invoicing  data  exchange  models 
recognised on the market can be proposed: 

•  Bilateral  exchange  model:  A  model  for  the  exchange  of  information  directly 
between a buyer and a seller in a one-to-one relation. These can be seller-driven or 
buyer-driven. 

73 

 
 
•  3-Corner  model  (3-party  exchange  model):  An  exchange  model  where  senders 
and receivers of invoices are connected to a single hub for the dispatch and receipt 
of messages.  

•  4-Corner  model  (4-party  exchange  model):  An  exchange  model  where  senders 
and  receivers  of  messages  are  supported  by  their  own  consolidator  service 
provider (for the sender) and aggregator service provider (for the receiver), which 
are interconnected. 

These three models are presented in Figure 9) below. 

Figure 9): E-invoicing data exchange models 

Source: DG Internal Market and Services based on EBA/Innopay 

The specificity of the bilateral model is that it requires that both parties use the same standard, 
either by common agreement or by one of the parties effectively forcing its standard onto the 
other.  In  such  cases,  if  a  supplier  deals  with  several  contracting  authorities  in  different 
Member States, it is obliged to support several different standards.  

74 

 
 
The  3-corner  model  theoretically  allows  this  difficulty  to  be  resolved,  in  that  the  service 
provider  is  most  likely  able  to  map  the  invoice  from  the  supplier’s  standard  to  that  of  the 
buyer. However, in a 3-corner model the service provider has by definition been contracted by 
one of the parties to either send or receive e-invoices in that party’s standard. As a result, the 
risk remains that a supplier will need to work with several different (Member State) service 
providers if he wishes to participate in public procurement across the EU. The most effective 
way  to  eliminate  this  difficulty  is  therefore  through  use  of  the  4-corner  model,  where  each 
party has its own service provider, and these exchange e-invoices between themselves, after 
previously agreeing on the standard in which they will communicate. 

1.9. 

Choice of technical solution to ensure interoperability 

As  mentioned  in  section  2.2  of  the  Impact  Assessment,  awareness  clearly  exists  that  the 
multiplicity  of  e-invoicing  standards  causes  problems  with  cross-border  e-invoicing.  While 
several  national  and  a  significant  number  of  proprietary  e-invoicing  standards  have  been 
developed  and  are  used  throughout  the  EU,  these  are  almost  always  designed  with  the 
particular needs of a specific Member State or sector in mind. As such, they are very rarely 
“transferrable” to other Member States and sectors.  

No  appropriate  European  standards  have  been  adopted  to  date  nor  have  any  ICT  technical 
specifications  been  recognised  by  the  Commission  within  the  meaning  of  Regulation  (EU) 
1025/2012 on European standardisation. Despite some initial works which have been carried 
out at the global level to try to develop an international standard (UN/CEFACT CII, which is 
thus far not operational), no other efforts to harmonise standards have taken place. For these 
reasons,  at  present  no  single  national  or  international  e-invoicing  standard  is  robust  and 
flexible  enough  to  cover  all  the  needs  of  cross-border  and  cross-sector  e-invoicing,  and 
therefore  none  of  the  existing  standards  can  satisfactorily  resolve  the  interoperability 
challenge. 

Several  attempts  to  improve  interoperability  have  already  been  made.  For  example,  in  May 
2012  the  European  Standardisation  Committee  (CEN)  agreed  a  so-called  CEN  Workshop 
Agreement  (CWA)  which  proposes  a  model  interoperability  agreement  for  transmitting  and 
processing  e-invoices  and  other  business  documents114.  More  recently,  the  European  E-
invoicing Service Providers Association (EESPA) announced that it has agreed an e-invoicing 
Model Interoperability Agreement115. However, these initiatives all take a bilateral approach 
to inter-operability, which, as mentioned above, does not eliminate the problem of the huge 
number  of  potential  agreements  which  would  need  to  be  signed  in  order  to  ensure  general 
interoperability. 

In  light  of  the  above  situation,  the  Commission  has  also  undertaken  efforts  to  address  the 
problem  of  multilateral  interoperability,  mainly  via  the  e-invoicing  element  of  the  PEPPOL 
project. So far, PEPPOL is the only significant European project that has developed a multi-
lateral  interoperability  model.  However,  since  this  is  a  project  which  has  been  developed 
within a consortium which includes several Member States, and as it offers solutions which 
are  in  direct  competition  with  some  e-invoicing  services  provided  by  private  service 

114 

115 

CEN  CWA  16464-2,  “Electronic  invoicing  -  Part  2:  Model  Interoperability  Agreement  for 
Transmission  and  Processing  of  Electronic 
Invoices  and  other  Business  Documents”, 
ftp://ftp.cen.eu/CEN/Sectors/List/ICT/CWAs/CWA16464-2.pdf 
http://www.eespa.eu/sites/default/files/EESPA-Information%20Release%202013-01-07-EN.pdf 

75 

 
 
                                                 
providers, the current initiative cannot directly recommend the PEPPOL solution as the basis 
of  an  EU-wide  e-invoicing  system,  in  line  with  the  principle  of  “technical  neutrality”.  It  is 
important to add that the PEPPOL solution does not include all the elements which would be 
required to truly consider it as a ‘standard’. 

In  summary,  the  theoretical  possibility  of  focusing  on  a  standard/technical  solution  that  is 
already available on the market must be disregarded at the early stage of this analysis, simply 
because no adequate solution exists that could ensure cross-border interoperability at the EU 
level.  However,  it  is  important  to  note  that  the  works  carried  out  by  the  Member  States  in 
preparing  their  national  standards  would  not  be  completely  disregarded  should  CEN  be 
mandated to develop a new common European standard. The set-up and internal procedures 
of CEN mean that in practice,  any  new  standard uses elements of ones already in existence 
and brings them together into a single, coherent whole. Additionally, the technical committees 
responsible  for  developing  standards  are  composed  of  Member  States’  representatives,  who 
work together towards a common objective. Any such mandate to CEN would therefore not 
imply creating a standard from the beginning, but would be solidly grounded in the existing 
achievements of the Member States.  

1.10.  CEN standardisation process116 

A  European  Standard  (EN)  is  a  standard  is  produced  by  all  interested  parties  through  a 
transparent, open and consensus based process. European Standards are a key component of 
the Single European Market. Although rather technical and often unknown to the public and 
media,  they  represent  one  of  the  most  important  issues  for  businesses.  Often  perceived  as 
boring  and  not  particularly  relevant  to  some  organisations,  they  are  actually  crucial  in 
facilitating  trade  and  hence  have  high  visibility  among  manufacturers  inside  and  outside 
Europe.  A  standard  represents  a  model  specification,  a  technical  solution  against  which  a 
market can trade. It codifies best practice and is usually state of the art. 

1.10.1.  Developing a European Standard 

The  development  of  an  EN  is  governed  by  the  principles  of  consensus,  openness, 
transparency, national commitment and technical coherence (more information is given in the 
BOSS  -  Business  Operation  Support  System  -  Production  processes)  and  follows  several 
steps: 

• 

Proposal to develop an EN: 

Any  interested  party  can  introduce  a  proposal  for  new  work  in  CEN.  Most  standardisation 
work is proposed through the National Standards Bodies. 

• 

Acceptance of the proposal: 

Once a project to develop an EN is accepted by the relevant CEN Technical Body, or by the 
CEN  Technical  Board  (in  case  the  proposal  is  related  to  a  new  field  of  standardisation 
activity), the member countries shall put all national activity within the scope of the project on 
hold.  This  means  that  they  do  not  initiate  new  projects,  nor  revise  existing  standards  at 

116 

section 

This 
(http://www.cen.eu/cen/products/en/pages/default.aspx). 

entirely 

based 

information 

on 

is 

published 

on 

the  CEN  website 

76 

 
 
                                                 
national  level.  This  obligation  is  called  'standstill'  and  allows  efforts  to  be  focused  on  the 
development of the EN. 

• 

Drafting 

The EN is developed by experts within a Technical Body. 

• 

CEN Enquiry – Public comment at national level 

Once the draft  of an  EN is prepared, it is released for public comment, a process  known in 
CEN  as  the  'CEN  Enquiry'.  During  this  public  commenting  stage,  everyone  who  has  an 
interest  (e.g.  manufacturers,  public  authorities,  consumers,  etc.)  may  comment  on  the  draft. 
These views are collated by the CEN national members and analysed by the CEN Technical 
Body. 

• 

Adoption by weighted vote 

Taking into account the comments resulting from the CEN Enquiry, a final version is drafted, 
which is then submitted to the CEN national members for a weighted formal vote. 

• 

Publication of the EN 

After its publication, a European Standard must be given the status of national standard in all 
CEN  member  countries,  which  also  have  the  obligation  to  withdraw  any  national  standards 
that would conflict with it. This guarantees that a manufacturer has easier access to the market 
of  all  these  European  countries  when  applying  European  Standards  and  applies  whether  the 
manufacturer is based in the CEN territory or not. 

• 

Review of the EN 

To  ensure  that  a  European  Standard  is  still  current,  it  is  reviewed  at  least  within  five  years 
from its publication.  

This review results in the confirmation, modification, revision or withdrawal of the EN. 

1.11. 

Summary of stakeholder views 

1.11.1.  Conclusions from bilateral meetings with stakeholders 

Bilateral meetings with stakeholders played an important part of the public consultations, and 
allowed  the  Commission  to  gather  important  information  on  the  position  of  enterprises  and 
service  providers  with  respect  to  e-invoicing  in  public  procurement.  This  information  is 
presented below. 

1.11.1.1. Enterprises 

Generally  speaking,  enterprises  are  some  of  the  biggest  supporters  of  the  broader  use  of  e-
invoicing across the EU. It is important to remember that by many accounts, enterprises are 
currently significantly more advanced than the public sector in using electronic invoices in the 
B2B  sector.  This  is  confirmed  in  the  public  consultation,  where  just  over  one-half  of 
respondents  from  enterprises  indicate  that  they  already  use  e-invoicing  (the  proportion  is 

77 

 
 
visibly  greater  for  large  enterprises  than  for  SMEs  and  microenterprises,  however).  These 
enterprises have already reaped many of the benefits which e-invoicing promises to deliver: 
lower  costs,  faster  payment  processing  times,  more  effective  use  of  capital,  and  better 
business relations, to name some of the more obvious ones. Understandably then, the support 
of business for e-invoicing has been registered in a number of different studies and surveys.  

This broad support was confirmed yet again during the Commission’s meetings with business 
representatives throughout the Impact Assessment process. Favourable opinions expressed by 
business organisations are confirmed in their position papers. For example, Business Europe 
is  very  supportive  of  the  possibility  of  mandatory  e-invoicing  in  public  procurement, 
mentioning  the  potential  savings  and  business  opportunities  which  could  be  generated.  The 
need to ensure as much flexibility as possible for the users was stressed, however, in order to 
avoid any unnecessary costs. UEAPME, the association of small and medium businesses, has 
also  clearly  voiced  its  support,  but  made  it  conditional  on  the  agreement  on  a  common 
standard  throughout  the  EU,  in  order  to  ensure  that  suppliers  were  not  obliged  to  support 
several different national or proprietary standards.  

Asked  about  why  some  enterprises  do  not  yet  use  e-invoicing,  the  concerns  voiced  by 
Business  Europe  and  UEAPME  confirmed  the  two  main  reasons  identified  in  the  public 
consultation: the excessive number of different standards and unclear laws/regulations. As a 
result, it can be assumed that availability of a widely recognised technical solution would be 
broadly  supported  by  enterprises.  Additionally,  it  would  be  particularly  beneficial  to  SMEs, 
for  whom  the  initial  investment  to  start  e-invoicing  would,  relatively  speaking,  be  more 
significant.  

1.11.1.2. Service providers 

The community of service providers has generally appeared to be the most cautious among all 
the stakeholders with respect to a possible EU initiative on e-invoicing in public procurement. 
In the Commission’s meetings with the European e-Invoicing Service Providers Association 
(EESPA)  and  with  individual  market  operators,  as  well  as  from  opinions  voiced  at  various 
conference and fora, a number of concerns have been raised. These concerns focus primarily 
on  the  role  which  service  providers  will  play  in  e-invoicing  in  the  future,  as  well  as  on  the 
additional costs that the addition of a new common standard, which would be obligatory for a 
significant part of the invoice traffic, would generate. Yet despite these concerns, there is in 
principle  support  for  an  increased  use  of  e-invoicing  in  Europe,  since  this  would  create  a 
potentially  significant  business  opportunity  for  the  service  providers.  This  appears  to  be 
confirmed by the results of the pubic consultation, where out of the 92 service providers, all 
indicate support for EU action to increase uptake and 92% agree that the EU should attempt to 
enhance interoperability. 

1.11.2.  Replies from IPM survey 

The public consultation was launched on 22 October 2012 and remained open for 12 weeks, 
until  14  January  2013.  The  survey  was  open  to  all  stakeholders  and  interested  parties: 
policymakers, contracting authorities, enterprises, IT service providers, associations (business 
and governmental), tax authorities, citizens, etc. In addition, participation was not limited to 
the  European  Union  –  interested  parties  from  all  over  the  world  were  welcome  to  provide 
their views.  

78 

 
 
In  all,  707  replies  were  received  by  the  14  January  2013  deadline.  There  was  a  very  good 
representation of the different groups of stakeholders. The geographic spread was also quite 
good,  with  contributions  received  from  all  EU  Member  States  as  well  as  from  a  significant 
number  of  third  countries.  Nevertheless,  some  Member  States  were  underrepresented  in 
relative  terms  to  their  size  (e.g.  United  Kingdom,  Italy,  Romania)  or  to  their  level  of 
advancement  in  terms  of  e-invoicing  use  (e.g.  Finland,  Austria,  Norway).  Despite  this,  the 
number of replies to the public consultation is sufficiently large to allow a thorough analysis 
of the current use of e-invoicing in Europe and the public’s views on a potential EU initiative 
in e-invoicing in public procurement.  

1.11.2.1. General overview 

Before presenting the opinions for each of category of stakeholders, it is important to note that 
support  for  EU  action  in  e-invoicing  in  public  procurement  was  very  high  in  each  of  the 
different categories and in all Member States. No single category of stakeholder or nationality 
was outright opposed to EU action in this field. Out of the 707 replies received in total, 88% 
of the respondents said they would be in favour of the EU undertaking steps to increase the 
use  of  e-invoicing  in  public  procurement.  The  proportion  dropped  only  slightly  (to  85%) 
when  asked  about  support  for  a  possible  EU  initiative  to  enhance  interoperability  in  e-
invoicing. 

Figure 10): Support for EU action to increase uptake and enhance interoperability in e-invoicing in public 
procurement - general 

Source: DG Internal Market and Services 

In terms of the instruments to be used in order to increase the uptake of e-invoicing, a slim 
majority  of  respondents  to  the  survey  (52%)  chose  mandatory  instruments,  while  41% 
preferred voluntary and 7% voted for both. The attitude to the type of instruments to be used 
in order to enhance interoperability, on the other hand, was almost exactly the reverse: here, 
the  majority  (52%)  prefer  voluntary  instruments  over  mandatory  ones  (42%);  6%  of  the 
respondents wish to see both being used.  

79 

 
 
 
 
 
 
 
 
 
 
Figure 11): Preferences with regards to the type of EU action - general 

Source: DG Internal Market and Services 

Among  those  stakeholders  approving  the  introduction  of  mandatory  e-invoicing  in  public 
procurement,  there  appears  to  be  a  very  strong  preference  to  see  this  happen  rapidly:  more 
than half of this group of respondents (56%) would like to see e-invoicing become mandatory 
before 2016, while just over a third more (36%) prefer a timeframe of 2016 or 2017. Less than 
1  in  10  stakeholders  (8%)  would  rather  have  a  longer  timeline,  in  which  mandatory  e-
invoicing would not be introduced until 2018 or later.  

Figure 12): Preferred timeline of introduction - general  

Source: DG Internal Market and Services 

Out  of  the  364  respondents  supporting  mandatory  instruments  to  increase  the  uptake  of  e-
invoicing in public procurement, virtually all of them (99%) wish for it to apply to the entire 
public sector; only 4 participants indicated that they would wish to restrict use to the central 
government only. Furthermore, 84% of stakeholders voiced a preference to include all types 

80 

 
 
 
 
 
of invoices in the obligation, while 16% wish to see the initiative limited to certain types of 
invoices  only.  The  most  commonly  chosen  restriction  was  that  based  on  the  value  of  the 
invoice (70% of respondents), with the other three types of limitations receiving significantly 
lower and more or less equal support (invoices only in certain sectors and invoices covered by 
the  public  procurement  directives  –  39%  each;  other  criteria  –  34%).  The  other  possible 
limitations  mentioned  include  among  others:  contracts  with  secret  clauses  or  pertaining  to 
national security matters; contracts where the payments are made by way of fixed advances; 
suppliers  which  do  not  have  the  required  IT  capabilities;  in  situations  where  VAT  rules  are 
not clear; small suppliers with a very limited number of invoices, etc. 

The  main  benefits  of  mandatory  e-invoicing  in  public  procurement  expected  by  the 
stakeholders are primarily economic: at least 4 in 5 respondents mentioned cost reduction and 
faster  processing  times  (89%  and  80%  respectively),  while  three-quarters  (74%)  indicated 
process  simplification  (74%).  Other  potential  benefits  expected  by  more  than  half  of  the 
stakeholders include: positive environmental effects (66%), better management of data (63%), 
and a contribution to broader digitalisation of the economy (59%). 

Figure 13): Expected benefits of e-invoicing in public procurement - general  

Source: DG Internal Market and Services 

1.11.2.2. Member States 

In  the  general  public  consultation,  ‘Member  States’  are  understood  as  policymakers  not 
directly involved in public procurement, i.e. who do not fall into the category of contracting 
authorities.  The  respondents  represented  all  levels  of  government,  the  central,  regional,  and 
local. Of the 80 respondents, 86% voiced support for the EU undertaking action to promote 
the use of e-invoicing in public procurement, and 88% want the EU to act to undertake action 
to enhance interoperability. 

81 

 
 
 
Figure 14): Support for EU action to increase uptake and enhance interoperability in e-invoicing in public 
procurement – Member States 

Source: DG Internal Market and Services 

In terms of the instruments to be used for increasing uptake, of the 69 respondents supporting 
EU action, a slight majority (54%) prefer mandatory instruments, 41% voluntary instruments, 
while 6% would like to see both used. The opinion on instruments to be used for enhancing 
interoperability is evenly split, with 47% supporting mandatory instruments, 49% preferring 
voluntary instruments, and 4% choosing both. 

Figure 15): Preferences with regards to the type of EU action – Member States 

Of  those  looking  for  mandatory  instruments,  just  over  half  (51%)  would  like  to  see  e-
invoicing  become  mandatory  before  2016;  the  vast  majority  of  the  remaining  half  of 
respondents  (39%  of  all  replies  received)  would  prefer  it  within  a  2016-17  timeframe,  with 

Source: DG Internal Market and Services 

82 

 
 
 
 
 
 
only  10%  preferring  e-invoicing  to  become  mandatory  between  2018  and  2020.  No 
respondents wished for a longer timetable. 

Figure 16): Preferred timeline of introduction – Member States  

Source: DG Internal Market and Services 

Furthermore, 95% would like the mandatory e-invoicing to apply to all public bodies, while 
only 5% would like it to be restricted to the central government only. Of the former, 72% of 
the former and 50% of the latter would wish all invoices to be covered, while the remainder 
would  prefer  to  restrict  the  use  of  e-invoicing  only  to  certain  types  of  invoices.  From  this 
group, more than 9 out of 10 (91%) respondents would like to include only invoices above a 
certain  monetary  value;  approximately  half  (55%)  would  prefer  to  use  it  only  in  certain 
sectors  or  only  apply  it  to  invoices  covered  by  the  public  procurement  directives;  while  a 
quarter  (27%)  indicated  other  criteria  (e.g.  exemptions  for  contracts  with  secret  clauses  or 
pertaining  to  national  security  matters,  contracts  where  the  payments  are  made  by  way  of 
fixed  advances).  The  main  benefits  expected  by  Member  States  are  cost  reduction  (96%), 
faster processing times (78%), and process simplification (78%). 

83 

 
 
 
 
 
 
 
 
 
 
 
Figure 17): Expected benefits of e-invoicing in public procurement – Member States 

Source: DG Internal Market and Services 

1.11.2.3. Contracting Authorities 

171  replies  were  received  from  contracting  authorities.  Just  over  a  quarter  (27%)  of  the 
respondents currently use e-invoicing. Of these, practically all (96%) agreed that e-invoicing 
had positively impacted their activities, with the remainder either neural or having no opinion. 
The main reasons for not using e-invoicing were: unclear laws/regulations (28%), too many 
different standards (28%), and other reasons (21%), which seemed to focus primarily on lack 
of an existing national framework, on a failure at an earlier attempt to introduce it, or on lack 
of readiness of business partners or resistance to change. More than a quarter of respondents 
(28%) admit that they have simply never considered it before. 

84 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 18): Reasons for not using e-invoicing – contracting authorities 

Source: DG Internal Market and Services 

84%  of  contracting  authorities  support  the  EU  undertaking  action  to  promote  the  use  of  e-
invoicing in public procurement, and 82% want the EU to act to undertake action to enhance 
interoperability. 

Figure 19): Support for EU action to increase uptake and enhance interoperability in e-invoicing in public 
procurement – contracting authorities 

Source: DG Internal Market and Services 

Of  the  144  respondents  approving  of  EU  action  to  increase  use  of  e-invoicing,  a  slight 
plurality would prefer voluntary to mandatory instruments (49% vs. 45%) with the rest (6%) 
opting for both. In order to enhance interoperability, the majority of respondents (60%) would 
prefer voluntary instruments, with 35% opting for mandatory and 5% for both. 

85 

 
 
 
 
 
 
Figure 20): Preferences with regards to the type of EU action – contracting authorities 

Source: DG Internal Market and Services 

In terms of the timeframe, 48% of those preferring mandatory instruments would like to see 
mandatory e-invoicing before 2016, and another 45% in 2016 or 2017. Only 7% would rather 
wait until 2018 or after. 

Figure 21): Preferred timeline of introduction – contracting authorities 

Source: DG Internal Market and Services 

All of the respondents supporting mandatory instruments to increase uptake would wish to see 
it apply to the entire government sector, and less than 1 in 5 (18%) respondents would prefer 
to limit the application to only certain types of invoices. The only limitation which received 
the support of respondents (54%) was by monetary value of invoice; less than a third (31%) 
would prefer to see e-invoicing only in certain sectors, and less than 1 in 6 (15%) would like 
to  restrict  its  use  to  invoices  covered  by  the  public  procurement  directives.  Just  under  half 
(46%)  mentioned  other  selective  criteria,  such  as:  limitation  of  e-invoicing  to  high-volume 
purchases and to simple purchases (goods, simple services, as opposed to works). The main 

86 

 
 
 
 
 
benefits  expected  by  the  contracting  authorities  are  cost  reduction  (89%),  faster  processing 
times (81%), and a reduced environmental impact (75%). 

Figure 22): Expected benefits of e-invoicing in public procurement – contracting authorities 

Source: DG Internal Market and Services 

1.11.2.4. Firms (including SMEs) 

Out the 140 replies received from enterprises, 46 were from large companies, 51 were from 
SMEs, and 43 from microenterprises. Almost exactly half of all enterprises (51%) already use 
e-invoicing;  however,  the  proportion  is  greater  for  large  enterprises  (63%)  than  for  SMEs 
(47%)  and  for  microenterprises  (42%).  On  average,  more  than  4  out  of  5  enterprises  (86%) 
agreed  or  strongly  agreed  that  e-invoicing  has  had  a  positive  impact  on  their  business 
operations;  only  3%  were  of  the  opposite  opinion.  However,  here  too,  the  opinions  varied 
among the different types of enterprises: whereas 100% of large enterprises agreed with the 
statement, the proportion dropped to 88% for SMEs and only 61% for microenterprises. The 
respondents who did not feel that e-invoicing had had a positive impact mentioned the poor 
presentation of the invoice and complexity of dealing with service providers as the reasons. 

The  main  reasons  given  for  not  using  e-invoicing  for  enterprises  as  a  group  were:  never 
considered  using  e-invoicing  (30%),  too  many  different  standards  (28%),  and  unclear 
laws/regulations  (20%).  For  large  enterprises,  the  same  reasons  were  given,  but  their  order 
was reversed: over a third of respondents (35%) mentioned unclear laws/regulations and the 
multiplicity  of  standards  (35%  for  each),  while  a  slightly  lower  number  (29%)  have  simply 
never  considered  it.  Perhaps  unsurprisingly  for  large  enterprises,  the  issues  of  cost  and 
insufficient number of invoices were not mentioned at all. In terms of the SMEs which do not 
use  e-invoicing,  2  out  of  every  5  (41%)  have  never  considered  it,  while  a  quarter  (26%)  is 
concerned  by  the  multiplicity  of  standards.  The  next  two  reasons  mentioned  are  the  lack  of 
clarity in laws/regulations and other reasons (both 19%), such as lack of sufficient knowledge, 
fear  of  dependence  on  a  service  provider,  or  the  lack  of  agreement  from  business  partners. 

87 

 
 
 
The issue of cost and volume of invoices appears, at 7% and 11% of respondents indicating 
these as concerns. Finally, for microenterprises, the situation looks quite different: 40% of the 
respondents indicate the insufficient number of invoices as the main concern, a quarter (24%) 
–  the  multiplicity  of  standards,  while  20%  fear  excessive.  20%  of  microenterprises  have 
simply never considered e-invoicing. 

Figure 23): Reasons for not using e-invoicing - enterprises 

Source: DG Internal Market and Services 

Taking the three groups together, 84% of respondents were in favour of the EU undertaking 
action  to  increase  the  uptake  of  e-invoicing,  and  78%  wished  for  action  to  enhance 
interoperability.  Looked  at  separately,  the  greatest  support  for  the  promotion  of  uptake  was 
among  large  enterprises  (96%),  while  support  among  SMEs  and  microenterprises  was 
somewhat lower and almost identical (78% and 79% respectively). 

88 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 24): Support for EU action to increase uptake and enhance interoperability in e-invoicing in public 
procurement - enterprises 

Source: DG Internal Market and Services 

With regards to the question of enhancing interoperability, support was similar among large 
enterprises  (85%)  and  SMEs  (80%),  but  was  significantly  lower  among  microenterprises 
(67%).  Out  of  all  enterprises  supporting  EU  action  to  increase  uptake,  roughly  2  out  of 
every 5  (38%)  supported  mandatory  instruments,  with  just  over  one-half  (55%)  preferring  a 
voluntary  approach.  The  proportion  was  very  similar 
large  enterprises  and 
microenterprises, but among SMEs there was greater support for voluntary instruments (65% 
vs.  33%  for  mandatory).  As  far  as  enhancing  interoperability  is  concerned,  once  again 
a majority preferred the use of voluntary to mandatory instruments (55% vs. 35%), while 10% 
of  respondents  were  in  favour  of  both.  Once  again,  the  proportion  of  large  enterprises  and 
microenterprises  preferring  mandatory  instruments  is  very  similar  (41%  for  both),  although 
there is greater support among microenterprises for voluntary measures (56% to 46% for large 
enterprises).  The  SMEs  stand  out  in  this  aspect  as  well  –  the  proportion  of  those  preferring 
voluntary  instruments  over  mandatory  ones  is  significantly  greater  than  among  the  other 
groups of enterprises (65% for voluntary vs. 33% for mandatory). 

for 

89 

 
 
 
 
Figure 25): Preferences with regards to the type of EU action - enterprises 

Source: DG Internal Market and Services 

In  terms  of  the  timeline  for  the  introduction  of  mandatory  e-invoicing,  all  enterprises  seem 
very  eager:  almost  3  out  of  5  (58%)  would  prefer  the  deadline  to  be  prior  to  2016,  and  a 
further  40%  prefer  2016-2017.  This  means  that  there  are  practically  no  enterprises  which 
would  wish  to  see  a  longer  transition  period  to  mandatory  e-invoicing  (i.e.  introduction  in 
2018 or later). 

Figure 26): Preferred timeline of introduction - enterprises  

Source: DG Internal Market and Services 

Interestingly,  the  proportion  of  supporters  of  early  introduction  rises  as  the  company  size 
decreases: while only 50% of large enterprises would support the introduction of mandatory 
e-invoicing before 2016, the level of support rises to 54% in SMEs and to as much as 71% in 
microenterprises.  

90 

 
 
 
 
 
All  of  the  firms  in  favour  of  mandatory  instruments  to  increase  the  uptake  of  e-invoicing 
support its use in all government institutions, and 86.8% wish to include all types of invoices 
(the  proportions  are  very  similar  between  the  three  types  of  enterprises,  but  is  inversely 
proportional  to  the  size  of  the  enterprise).  Those  few  enterprises  which  do  wish  to  limit  e-
invoicing  generally  indicate  most  (if  not  all)  of  the  types  of  limitations.  Due  to  the  low 
numbers involved, however, any trends are very difficult to detect.  

The main benefits expected by enterprises, irrespective of whether looked at as a group or by 
size  sector,  are  invariably:  cost  reduction  (86%),  faster  processing  times,  and  process 
simplification (both 76%). 

Figure 27): Expected benefits of e-invoicing in public procurement - enterprises  

Source: DG Internal Market and Services 

The only discernible trend between large enterprises, SMEs, and microenterprises is that the 
economic  benefits  (cost,  processing  time)  weigh  heavier  the  larger  the  enterprise;  for 
microenterprises, issues such as the environment and digitalisation appear to play a relatively 
larger role. 

1.11.2.5. Service providers 

92 IT service providers responded to the public survey, out of which 86% currently provide e-
invoicing  services.  Of  these,  79%  have  signed  one  or  more  bilateral  interoperability 
agreements,  and  almost  exactly  half  (51%)  have  multilateral  agreements.  Among  those 
service  providers  not  currently  providing  e-invoicing  services,  by  far  the  most  commonly 
cited reason was that other services were a priority (38%). 

91 

 
 
 
Figure 28): Reasons for not providing e-invoicing services  

Source: DG Internal Market and Services 

Out  of  the  four  groups  of  stakeholders  discussed  here,  the  service  providers  are  by  far  the 
most  supportive  of  EU  action  in  the  area  of  e-invoicing  of  public  procurement.  Of  the  92 
respondents,  all  support  EU  action  to  increase  uptake  and  92%  agree  that  the  EU  should 
attempt to enhance interoperability. 

Figure 29): Support for EU action to increase uptake and enhance interoperability in e-invoicing in public 
procurement – service providers  

Source: DG Internal Market and Services 

92 

 
 
 
 
 
Two-thirds  (65%)  of  those  service  providers  supporting  EU  action  in  order  to  increase  the 
uptake of e-invoicing are for the use of mandatory instruments, and another 9% would like to 
see both mandatory and voluntary instruments. The opinions are much more balanced when it 
comes to steps to enhance interoperability: 46% support mandatory instruments, 49% prefer 
voluntary instruments, and 5% would opt for both. 

Figure 30): Preferences with regards to the type of EU action – service providers 

Source: DG Internal Market and Services 

Service  providers  wish  to  see  the  broadest  scope  possible  for  e-invoicing:  100%  of  those 
supporting mandatory instrument would like all governmental institutions included and 91% 
all types of invoices covered. Of the respondents wishing to limit the use of e-invoicing, 83% 
wanted to include only invoices above a certain monetary value, exactly half would like it to 
apply only to invoices covered by the public procurement directives, and 1 in 6 (17%) would 
like  to  restrict  it  to  only  certain  sectors.  In  addition,  50%  named  other  criteria,  e.g.  legal 
complexity  of  the  invoice.  They  are  also  eager  to  see  it  soon:  just  over  two-thirds  (68%) 
would like it introduced before 2016 and a further 20% in 2017 or 2018. There is no interest 
in delaying introduction pasts 2020. 

93 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 31): Preferred timeline of introduction – service providers 

Source: DG Internal Market and Services 

Similarly  to  the  other  groups,  the  main  benefits  expected  by  the  service  providers  are  cost 
reduction (95%), faster processing times (87%), and process simplification (83%). 

Figure 32): Expected benefits of e-invoicing in public procurement – service providers 

Source: DG Internal Market and Services 

94 

 
 
 
 
2. 

GLOSSARY 

ACPC: the Advisory Committee for Public Contracts 

CEN: European Standardisation Committee  

CWA: CEN Workshop Agreement 

Directives, the: Directive 2004/17/EC of the European Parliament and of the Council of 31 
March  2004  coordinating  the  procurement  procedures  of  entities  operating  in  the  water, 
energy,  transport  and  postal  services  sectors;  Directive  2004/18/EC  of  the  European 
Parliament  and  of  the  Council  of  31  March  2004  on  the  coordination  of  procedures  for  the 
award  of  public  works  contracts,  public  supply  contracts  and  public  service  contracts;  and 
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. 

Contracting authorities: in this Impact Assessment, the term is used to refer to contracting 
authorities or entities, within the meaning of Article 1(9) of Directive 2004/18/EC, Article 2 
of Directive 2004/17/EC and/or Article 1(17) of Directive 2009/81/EC. 

EESPA: European E-invoicing Service Providers Association (http://www.eespa.eu/) 

EMSF: 
(http://ec.europa.eu/enterprise/sectors/ict/e-invoicing/benefits/invoicing_forum_en.htm) 

European  Multi 

Stakeholder 

Electronic 

Forum 

on 

Invoicing 

EN:  European standard (“norme européenne”) is a standard which has been adopted by one 
of the three recognised European Standardisation Organisations: CEN, CENELEC or ETSI 

e-procurement  (electronic  procurement):  e-procurement  refers  to  the  use  of  electronic 
communications  by  public  sector  organisations  when  buying  supplies  and  services  or 
tendering public works 

IAB: the Impact Assessment Board 

IASG: the Steering Group for this Impact Assessment 

IPM: Interactive Policy Making (http://ec.europa.eu/yourvoice/ipm/index_en.htm) 

OJ/TED:  Tenders  Electronic  Daily  (TED)  –  the  Supplement  to  the  Official  Journal  of  the 
European Union where notices are published for public procurement contracts covered by the 
Directives (http://ted.europa.eu/)  

UEAPME:  European  Association  of  Craft,  Small  and  Medium-sized  Enterprises 
(http://www.ueapme.com/ ) 

95 

 
 
3. 

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• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

REFERENCES  

"A Digital Agenda for Europe", European Commission Communication, COM(2010) 
245 
(http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0245:FIN:EN:HTML)  

“Action  plan  for  the  implementation  of  the  legal  framework  for  electronic  public 
procurement”,  Communication  from 
the  Commission,  Brussels,  13.12.2004, 
(http://ec.europa.eu/internal_market/publicprocurement/docs/eprocurement/actionpla
n/actionplan_en.pdf) 

„AGFA - vurderinger og anbefalinger om elektronisk faktura i staten”, Rapport fra 
(2008) 
for 
arbeidsgruppe 
(http://www.regjeringen.no/upload/FAD/Vedlegg/IKT-
politikk/AGFArapportWEB.pdf ) 

elektronisk 

faktura 

“A strategy for e-procurement”, Communication from the Commission, COM(2012) 
179 
final 
(http://ec.europa.eu/internal_market/publicprocurement/docs/eprocurement/strategy/
COM_2012_en.pdf) 

“Annual Growth Survey 2013”, Communication from the Commission, COM(2012) 
750 final (http://ec.europa.eu/europe2020/pdf/ags2013_en.pdf)  

“Commission  Work  Programme  2013”,  Communication  from  the  Commission, 
COM(2012) 629 final (http://ec.europa.eu/atwork/pdf/cwp2013_annex_en.pdf)   

Commission  Regulation  (EU)  No  1251/2011  of  30  November  2011  amending 
Directives 2004/17/EC, 2004/18/EC and 2009/81/EC of the European Parliament and 
of  the  Council  in  respect  of  their  application  thresholds  for  the  procedures  for  the 
(http://eur-
awards 
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:319:0043:0044:EN:PDF)  

contract 

of 

Council Directive 2010/45/EU of 13 July 2010 amending Directive 2006/112/EC on 
the common system of value added tax as regards the rules on invoicing (http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:189:0001:0008:EN:PDF ) 

„Cross-border  public  procurement  above  EU  thresholds”,  Rambøll  Management, 
2011, 
May 
(http://ec.europa.eu/internal_market/publicprocurement/docs/modernising_rules/cros
s-border-procurement_en.pdf) 

“E-Government  as  a  spearhead”,  European  Parliament  resolution  of  20  April  2012 
on  a  competitive  digital  single  market  –  (2011/2178(INI)),  T7-0140/2012 
(http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference
=P7-TA-2012-140 ) 

“E-invoicing 2010, European market guide”, Euro Banking Association (EBA) and 
Innopay 
(https://www.ebaportal.eu/_Download/commentary/2010/E-
Invoicing_2010-European_Market_Guide.pdf)  

96 

 
 
• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

“E-Invoicing  Benefits”,  Efficient  Government  Fund  -  expression  of  interest 
(http://www.scotland.gov.uk/Resource/Doc/55971/0015406.pdf ) 

”E-invoicing - Final step of an efficient invoicing process”, Deutsche Bank Research, 
(http://www.dbresearch.com/PROD/DBR_INTERNET_EN-
2010 
May 
PROD/PROD0000000000257196/E-
invoicing%3A+Final+step+of+an+efficient+invoicing+process.pdf ) 

3, 

"E-invoicing/E-billing,  International  Market  Overview  &  Forecast",  Bruno  Koch, 
Billentis, 
2012 
(http://www.billentis.com/einvoicing_ebilling_market_overview_2012.pdf ) 

February 

“Electronic  invoice  processes  in  Europe  and  enablement  of  SMEs  to  use  them 
efficiently”,  CEN  Workshop  Agreement 
2012, 
(ftp://ftp.cen.eu/CEN/Sectors/List/ICT/CWAs/CWA16461.pdf)  

16461,  May 

(CWA) 

“Electronic  Invoicing  Initiatives  in  Finland  and  in  the  European  Union  –  Taking 
steps  towards  the  Real  Time  Economy",  Helsinki  School  of  Economics,  B-95  , 
(http://epub.lib.aalto.fi/pdf/hseother/b95.pdf ) 

"Electronic  invoicing:  models,  integration  level  and  benefits"  Alessandro  Perego, 
Politecnico 
2010 
School 
(http://ec.europa.eu/enterprise/sectors/ict/files/23_perego_en.pdf ) 

Management, 

Milano 

of 

di 

EUROPEAN  COUNCIL  28/29  JUNE  2012  CONCLUSIONS,  Brussels,  29  June 
2012 
(http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/ec/131388.pdf) 

“European E-Invoicing Guide for SMEs”, The European e-Business Lab, November 
2009 
(http://celeris-group.eu/public/wp-
content/uploads/2012/01/ebl_guide_final_print-copy.pdf ) 

“European Interoperability Framework (EIF) for European public services”, Annex 
2  to  the  Communication  from  the  Commission  “Towards  interoperability  for 
final 
European  public 
(http://ec.europa.eu/isa/documents/isa_annex_ii_eif_en.pdf ) 

services”,  Brussels,  16.12.2010  COM(2010)  744 

“Evaluation  Report  Impact  and  Effectiveness  of  EU  Public  Procurement 
final 
Legislation”,  Commission  Staff  Working  Paper,  SEC(2011)  853 
(http://ec.europa.eu/internal_market/publicprocurement/docs/modernising_rules/er85
3_1_en.pdf ) 

“Financing Innovations”, Sarah Jones, Bottomline Technologies, April 2010 

"Global  development  of  Electronic  Invoicing"  Karri  Lehtonen,  Basware,  2012 
(http://fr.slideshare.net/ssonetwork/global-development-of-electronic-invoicing ) 

“Good practices in the adoption and promotion of e-invoicing in Europe: Results of 
the  EMSF  good  practices  consultation”  -  ACCA  Discussion  Paper  prepared  for 
Activity Group 2 of the European Multi-stakeholder Forum on e-invoicing, London, 

97 

 
 
August 
(http://ec.europa.eu/enterprise/sectors/ict/files/invoicing/activity_2_consultation_rep
ort_en.pdf ) 

2012 

Proposal  for  a  Directive  of  the  European  Parliament  and  of  the  Council  on  public 
procurement,  COM/2011/896  final,  and  Proposal  for  a  Directive  of  the  European 
Parliament  and  of  the  Council  on  procurement  by  entities  operating  in  the  water, 
energy, transport and postal services sectors, COM(2011) 895 final, a key action of 
I 
the 
(http://ec.europa.eu/internal_market/publicprocurement/modernising_rules/reform_p
roposals_en.htm) 

Market 

Single 

Act 

OECD Procurement Toolbox : 
http://www.oecd.org/governance/procurement/toolbox/ 

„Public  Procurement  Indicators  2010”,  European  Commission,  Brussels,  4 
November 
2011 
(http://ec.europa.eu/internal_market/publicprocurement/docs/indicators2010_en.pdf)  

„Public  Procurement  in  Europe :  Cost  and  effectiveness”,  London  Economics, 
PricewaterhouseCoopers, 
2011 
(http://ec.europa.eu/internal_market/publicprocurement/docs/modernising_rules/cost
-effectiveness_en.pdf) 

Economics, 

London 

Ecorys, 

and 

the  benefits  of  e-invoicing 

"Reaping 
Communication, 
(http://ec.europa.eu/internal_market/payments/docs/einvoicing/com712_en.pdf)  

for  Europe",  European  Commission 
COM(2010)712 

“Single  Market  Act  -  Twelve  levers  to  boost  growth  and  strengthen  confidence, 
Working  together  to  create  new  growth",  Communication  from  the  Commission, 
(http://eur-
COM(2011) 
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0206:FIN:EN:PDF) 

final 

206 

“Single  Market  Act  II  -  Together  for  new  growth”,  Communication  from  the 
final, 
Commission, 
(http://ec.europa.eu/internal_market/smact/docs/single-market-act2_en.pdf) 

COM(2012) 

573 

• 

• 

• 

• 

• 

• 

• 

• 

“Solutions  for  Remaining  Cross‐Border  Issues”,  Interim  Report  Activity  3  v04, 

European  Multi-stakeholder  Forum  on  Electronic 

Invoicing,  26‐09‐2012, 

(http://ec.europa.eu/enterprise/sectors/ict/files/invoicing/activity_3_interim_report_e
n.pdf) 

98 

 
 
• 

“Supplier  perspectives  on  the  challenges  of  eInvoicing  with  the  public  sector”  by 
Roman  Weber,  PEPPOL  (http://project.peppol.eu/news/supplier-perspective-on-the-
challenges-of-einvoicing-with-the-public-sector) 

99