COMMISSION STAFF WORKING DOCUMENT Implementation Plan Accompanying the document Directive of the European parliament and of the Council on electronic invoicing in public procurement
Date: 2013-06-26
Institutions: European Commission
Subjects: European standard, European standardisation body, Internet access provider, electronic government, invoicing, public contract

EUROPEAN 
COMMISSION 

Brussels, 26.6.2013  
SWD(2013) 225 final 

COMMISSION STAFF WORKING DOCUMENT 

Implementation Plan 

Accompanying the document 

Directive of the European parliament and of the Council on electronic invoicing in 
public procurement 

{COM(2013) 449 final} 
{SWD(2013) 222 final} 
{SWD(2013) 223 final} 

EN 

   EN 

 
 
 
 
  
 
Implementation Plan1 

1. Title of the document for the proposed act: Implementation plan for the Directive of the 
European Parliament and of the Council on electronic invoicing in public procurement 
(hereinafter referred to as “the Directive”). 

2. Contact point:  

•  KILJANSKI Kamil (MARKT), telephone 66166, e-mail: Kamil.Kiljanski@ec.europa.eu;  

•  TOADER Maria-Magdalena (MARKT), telephone 80298, e-mail: Maria-

Magdalena.Toader@ec.europa.eu  

3. Deliverables and implementation challenges 

The  Directive  introduces  an  obligation  on  the  contracting  authorities  and  entities  to  accept 
electronic  invoices  compliant  with  the  European  standard  on  electronic  invoices.  The 
Directive covers the invoices issued as a result of the performance of contracts subject to the 
EU public procurement legislation. 

The  European  standard  on  electronic  invoices  will  be  drawn  up  by  a  [or  “the  relevant”] 
European Standardisation Body on the basis of a mandate form the Commission. 

Contracting  authorities  and  contracting  entities  may  also  accept  electronic  invoices  which 
comply with standards other than the common European standard, as well as paper invoices 
unless  otherwise  provided  in  national  legislation.  Consequently,  this  Directive  does  not 
impose  any  obligations  on  the  economic  operator  –  they  are  free  to  take  up  electronic 
invoices at their own pace. 

Currently  electronic  invoicing  is  used  by  contracting  authorities  and  entities  in  certain 
Member  States,  either  de  facto  or  de  jure.  Consequently  challenges  related  to  the 
implementation of this Directive will be different in magnitude for Member States/contracting 
authorities and entities which have introduced electronic invoices and for those which have 
not yet done so. 

Challenges 

1.  Technical challenges:  

This is a rather simple  and straightforward Directive; therefore the transposition into 
national  law  is  unlikely  to  pose  problems.  Member  States  which  might  face  some 
transposition difficulties are those where electronic invoicing is not mandated or used. 
In any case a series of support actions  may be put in place by the Commission, as 
specified below with a view to support Member States during the transposition period. 

1 This  Implementation  Plan  is  provided  for  information  purposes  only.  It  does  not  legally  bind  the 
Commission  on  whether  the  identified  actions  will  be  pursued  or  on  the  form  in  which  they  will  be 
pursued. 

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2.  Compliance challenges  

The  most  significant  challenges  that  could  be  envisaged  at  this  stage  are  the 
difficulties  in  the  actual  introduction  of  electronic  invoicing  by  the  contracting 
authorities and entities which never used this system before and in particular by those 
which  are  smaller  in  size.  However,  it  should  be  noted  that  the  services  related  to 
electronic  invoicing  can  be  outsourced  to  an  external  service  provider.  To  facilitate 
the  take  up  of  electronic  invoicing,  some  support  actions  could  be  put  in  place, 
especially at national level. 

3.  Timing challenges 

No  such  problems  are  envisaged  at  the  moment.  The  transposition  period  of  24 
months  should  be  sufficient  to  allow  Member  States  to  adopt  national  rules  to 
implement this Directive into their domestic law.  
Furthermore,  the  contracting  authorities  and  entities  are  required  to  apply  the 
provisions  set  out  in  this  Directive  by  48  months  after  its  entering  into  force.  This 
interval  is  considered  sufficient  to  allow  these  authorities  to  take  the  necessary 
measures to accept electronic invoices in the European standard. 

4.  Support Actions: 

In  order  to  monitor  risks  and  take  the  necessary  mitigation  measures,  the  Commission  will 
schedule  a  number  of  activities,  in  order  to  identify  common  difficulties  and  also  national 
specific problems, during the transposition period and afterwards. 

The Commission intends to: 

•  use  the  meetings  of  the  Advisory  Committee  for  Public  Contracts  as  a  forum  for 
monitoring of the transposition process and as a platform for best practice sharing. 
•  ask Member States to identify the appropriate liaison contacts to take part in further 

technical discussions with the Commission. 

•  organise  multilateral  and/or  bilateral  meetings  with  Member  States  to  discuss  and 
solve general and/or specific issues related to transposition or to the implementation 
process. 
to set up a web-page in order to provide information on the implementation process to 
Member  States  and  stakeholders,  to  be  used  also  as  a  platform  for  best  practice 
sharing in the form of case studies, FAQs, etc. 

• 

Example of Possible Member State Actions: 

•  Develop and implement detailed strategies for the introduction of e-invoicing in public 

procurement in their administrations and monitor its use. 

•  Organize  training  programmes  addressed  to  contracting  authorities  and  entities,  to 
inform them about the possibilities at their disposal and to facilitate the setup of their 
electronic invoicing systems. 

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•  Set up dedicated web-pages in the national language disseminate to the stakeholders 
general information on the electronic invoicing, to be used as a platform for exchange 
of best practices, FAQs, and information on electronic invoicing service providers. 

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