REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the Assessment of the European Standard on electronic invoicing, according to Directive 2014/55/EU
Date: 2017-10-11
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: European Committee for Standardisation, European standard, administrative formalities, electronic document, electronic government, harmonisation of standards, invoicing, public contract, technical specification

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   EUROPEAN COMMISSION  Brussels, 11.10.2017  COM(2017) 590 final   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the Assessment of the European Standard on electronic invoicing, according to Directive 2014/55/EU  
 
1.  Background 

The  Directive  2014/55/EU  on  electronic  invoicing  in  public  procurement1  (the  "Directive") 
has  the objective  of promoting the uptake of electronic invoicing  in  public procurement, by 
ensuring interoperability and improving legal certainty. It was adopted on 16 April 2014 by 
the  European  Parliament  and  Council,  following  a  thorough  preparation  process  led  by  the 
Commission and involving a large number of stakeholders.  

The Directive requires contracting authorities to receive and process electronic invoices which 
comply with a European Standard (EN) for electronic invoicing. The Directive also foresees 
that a process is started by the relevant standardisation organisations to define this standard. 
The obligation only concerns invoices related to public contracts which fall in the scope of the 
EU Directives on Public Procurement. 

As  the  EN  was  not  available  at  the  time  of  adoption,  the  Directive  entrusts  (in  Art.3)  the 
Commission with the responsibility of carrying out an evaluation of the standard as regards its 
practicality,  user  friendliness  and  implementation  costs  for  an  end-user,  before  the  standard 
become  applicable.  The  EN  has  recently  been  adopted  by  CEN  and  this  report  presents  the 
results of the evaluation carried out.  

2.  The development of the European Standard for eInvoicing 

Further  to  the  Directive,  the  Commission  gave  on  10  December  2014  a  mandate2  to  the 
European  Committee  for  Standardisation  (CEN)  to  develop  the  EN  on  electronic  invoicing 
and  its  related  deliverables.  In  the  mandate,  the  Commission  requested  CEN  specifically  to 
undertake the following tasks: 

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to develop a European standard (EN) for the semantic data model of the core elements 
of an electronic invoice; 
to identify a limited number of invoice syntaxes which fully comply with the 
European standard;  
to develop syntax bindings, i.e. information specifying how the semantic data model 
could be represented in the listed syntaxes, and their automatic validation artefacts;  
to develop guidelines on interoperability of electronic invoices at the transmission 
level; taking into account the need of ensuring the authenticity of the origin and the 
integrity of the electronic invoices’ content;  
to develop guidelines on the optional use of sector or country extensions in 
conjunction with the European standard, including a methodology to be applied in the 
real environment;  
to carry out the test of the European standard with respect to its practical application 
for an end user. 

In order to undertake these tasks, CEN set-up a specific technical committee (TC434) and six 
working  groups  (one  for  each  of  the  above  mentioned  topics).  The  Technical  Committee  is 
composed of technical experts on eInvoicing from the National Standardisation Organisations 

1 OJ L 133, 6.5.2014, p. 1–11   

2  M/528  COMMISSION  IMPLEMENTING  DECISION  C(2014)  7912  final  of  10.12.2014  on  a  standardisation  request  to  the  European 
standardisation  organisations  as  regards  a  European  standard  on  electronic  invoicing  and  a  set  of  ancillary  standardisation  deliverables 
pursuant to Regulation (EU) No 1025/2012 of the European Parliament and of the Council 

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(NSO)  in  several  Member  States.  Private  experts  were  also  involved,  as  well  as 
representatives  of  public  administrations.  This  wide  involvement  of  many  stakeholders 
represents a strong guarantee that the EN is aligned to the latest developments of the market 
and to the needs of users. 

As a result of this process, CEN formally issued the standard and the list of syntaxes on 28 
June 2017, with the reference EN 16931. 

The main deliverable of the Technical Committee is the standard itself, representing the core 
elements  of  the  invoice.  It  underwent  in  March  2016  a  public  inquiry  with  all  National 
Standardisation  Bodies  to  which  600  comments  were  received.  The  Technical  Committee 
subsequently addressed these comments and finalised the draft EN which was put to a vote. 
The EN was unanimously approved by the National Standardisation Organisations. All other 
deliverables  were  also  subject  to  vote,  the  latest  vote,  on  the  syntax  bindings  technical 
specifications being closed on 29 June 2017. 

Another  important  strand  of  work  is  related  to  the  question  of  syntaxes,  representing  the 
software  languages  which  can  be  used  to  implement  the  EN  in  practice.  The  Directive,  and 
also  the  mandate  from  the  Commission,  mentioned  that  CEN  should  identify  a  "limited 
number of syntaxes", as there are several syntaxes used as format for the EN. The Technical 
Committee managed to reach agreement by a vast majority of the Members on a very limited 
number, namely two syntaxes: UN/CEFACT CII (Cross Industry Invoice) and UBL 2.1. 

3.  Evaluating the Standard 

Article  3  of  Directive  2014/55/EU  states  that  prior  to  the  introduction  of  the  European 
standard  on  electronic  invoicing  in  the  Member  States,  the  practical  application  of  the 
standard should be sufficiently tested. This assessment should be done in conjunction with the 
drawing  up  of  the  standard  and  should  involve  end  users.  It  should  address,  in  particular, 
aspects of practicality and user-friendliness, and should demonstrate that the standard can be 
implemented in a cost efficient and proportionate manner. 

This report presents the results of this assessment, based on two main sources:  

  The CEN Technical Report of WG6 of TC434, called "Test of the European standard 
with  respect  to  its  practical  application  for  an  end  user",  mainly  dedicated  to  testing 
the technical aspects of the standard.  

  A  complementary  study  conducted  by  an  external  contractor,  PWC,  for  the 
Commission, between end March 2017 and July 2017. The study focused more on the 
practical impact for end-users and is available on Commission's website, DG GROW/ 
Public procurement/ Studies. 

3.1 Results of the CEN testing 

The Technical Report describes the testing of the EN at a semantic and syntax level. It also 
includes  the  methodology  and  testing  of  the  validation  artefacts.  These  validation  artefacts 
represent  mandatory  elements  and  rules  of  the  EN  in  an  open  source  code  and  ensure  that 
conformance of an invoice with the EN can be checked automatically. 

The report includes three main sections. The first one concerns the semantic testing where an 
overview of the methodology, the testing and the results are described. Similarly, the second 

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section  covers  the  syntax  methodology,  testing  and  results.  The  final  section  has  two  sub-
chapters  describing  the  tests  performed  to  ensure  the  EN  is  suitable  for  payments  and 
automatic processing respectively. 

No  major  issues  were  raised  during  the  testing  process.  This  was  probably  because  CEN 
Working  group  responsible  for  the  EN  had  already  undertaken  its  own  quality  assurance 
testing. Also, testing ran alongside EN development so that issues could be raised in parallel 
without building to significant numbers.  

At the semantic level, the process did improve the EN since the resulting updated definitions 
and usage notes will help implementers and end users to understand it more easily.  

Syntax  testing  was  primarily  focused  on  ensuring  the  validation  artefacts  were  suitable  for 
checking conformance and was also based on lessons learned from the CEN WS/BII project 
(CEN  Workshop  on  Business  Interoperability  Interfaces  for  public  procurement  in  Europe). 
The  availability  of  validation  artefacts  is  key  to  facilitate  the  practical  use  of  the  EN  for 
implementers. 

3.2 Complementary study on the practical impact for an end-user 

In order to complement the technical results of the CEN testing, the Commission decided to 
perform an additional study, which was carried out by PWC. The objective of the PWC study 
was to assess the EN with respect to the three main criteria listed in the Directive 2014/55/EU, 
as follows: 

A.  Practicality:  This  criterion  refers  to  elements  such  as  being  effective,  useful  and 

suitable for a particular purpose or situation.  

B.  User-friendliness: This criterion involves an assessment of the easiness to use and to 
implement  the  standard,  in  particular  taking  into  account  existing  systems,  such  as 
Enterprise Resource Planning (ERP).  

C.  Implementation costs:  This  criterion refers to the implementation costs to  be  borne 
by end-users (contracting authorities and their suppliers) for supporting the standard, 
covering the full set of identified scenarios. 

The methodology used for the study started by defining a number of different implementation 
scenarios.  The  final  set  of  scenarios  covered  six  countries:  France,  Ireland,  Italy,  the 
Netherlands, Norway and Poland. These countries were selected for in-depth analysis in order 
to reflect the diversity of situations in the EU, based on the following areas: 

  Area 1: Level of (de)centralisation for eInvoicing at the national level 
  Area 2: eInvoicing maturity level 
  Area 3: Use of eInvoicing standards 

The  second  phase  of  this  project  focused  on  gathering  and  consolidating  data  that  were 
required for assessing the EN and analysing these data. The study built upon the test results of 
the CEN report, which looked at the practical application (fitness for purpose) of the EN from 
a  technical  perspective.  Furthermore  data  was  gathered  by  means  of  desk  research.  This 

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research was undertaken to clarify the eInvoicing models that are in place, their capabilities 
offered and pricing models. 

Finally,  targeted  interviews  were  held  with  Member  State,  regional  authorities  and  industry 
representatives, service providers and software vendors. During these interviews, a predefined 
set  of  questions  was  presented  to  the  representatives.  These  meetings  were  recorded, 
documented in meeting minutes and approved by the corresponding representatives. 

4.  Outcome of the evaluation 

The three criteria mentioned by the Directive are addressed one by one below. 

A.  Practicality 

The  practicality  of  the  European  standard  for  eInvoicing,  in  terms  of  its  fitness  for  purpose 
has been confirmed by the Member State authorities and stakeholders interviewed. No major 
technical problem was identified. In addition, the EN has been unanimously approved by all 
National Standardisation Bodies. 

The EN for eInvoicing is based on existing international standards widely adopted in Europe.  
The decision to limit the number of formats for implementing the semantic data model of the 
core invoice to UBL 2.13 and UNCEFACT/CII will result in further simplification, since these 
are  two  very  common  syntaxes  already  in  use  in  the  market.  Most  of  the  contracting 
authorities interviewed for this study will prioritise the support for only one syntax, UBL 2.1. 

B.  User-friendliness  

By identifying a common set of information elements of an invoice that cover the majority of 
business and legal requirements, the core invoice semantic data model is of great value for the 
establishment of user-friendly and cost-efficient eInvoicing systems.  

The  role  of  ERP  and  software  vendors  is  considered  to  be  crucial  by  central,  regional  and 
local  authorities. In  particular,  the implementation  of  the  EN  natively in  their  solutions  will 
reduce the need for format conversion, thus significantly decreasing complexity and costs to 
end-users.  

The  EN  is  considered  to  be  flexible  due  to  the  possible  use  of  optional  elements,  free  text 
fields and code lists included. However, this advantage may result in excessive proliferation 
of  Core  Invoice  Usage  Specifications  (CIUS)  and  extensions.  The  CIUS  are  specifications, 
which  are  aimed  to  help  implementers  of  solving  the  practical  aspects  of  defining  the  IT 
systems based on the EN. The use of CIUS and extensions should be monitored and limited, 
possibly  through  a  coordinated  European  initiative,  in  order  to  safeguard  interoperability 
across borders. 

C.  Possible implementation costs 

UBL  2.1.  has  been  identified  by  the  Commission  for  referencing  in  public  procurement  by  Commission  Decision.      

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2014/771/EU:  Commission  Implementing  Decision  of  31  October  2014  on  the  identification  of  Universal  Business  Language 
version 2.1 for referencing in public procurement Text with EEA relevance 

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The costs of implementing eInvoicing are largely dependent on the two key variables in each 
country: the level of maturity and the architecture chosen by the public sector for eInvoicing. 

eInvoicing maturity at national level is determined by the adoption rates in the public and the 
private sector, the existence of a competitive market for eInvoicing services and solutions, and 
the  level  of  organisational  and  IT  readiness.  The  impact  of  the  EN,  in  terms  of  costs  and 
complexity,  will  be  lower  in  Member  States  with  high  maturity  levels.  It  will  be  higher  in 
Member States where eInvoicing adoption is low, where the number of solution and service 
providers is limited and the national IT infrastructure is not very advanced. 

The  impact  of  the  EN  will  also  depend  on  the  national  legislation,  policy  and  related 
requirements.  Governments  will  benefit  from  defining  a  strategy  to  implement  Directive 
2014/55/EU (from minimal compliance with the Directive to full invoice process automation), 
and  planning  a  national  roll-out.    Several  countries  have  had  positive  experience  with  such 
strategies. The use of eInvoicing for suppliers to the public sector may be mandated, including 
the use of specific formats. 

Two different architectures for eInvoicing in public procurement can be identified and are 
already in place in most of the Member States, namely: 

  a  central  hub  (or  a  combination  of  several  hubs)  that  receives  all  eInvoices  from 
suppliers and dispatches them to the relevant contracting entity/authority (centralized 
system); or 

  a distributed system  where the eInvoices  have  to be sent by the suppliers directly to 

the relevant contracting entity/authority (distributed system). 

Member  States  with  a  high  level  of  eInvoicing  maturity  are  characterised  by  high  adoption 
rates,  a  competitive  environment  for  eInvoicing  service  and  solution  providers,  and  an 
advanced organisational and IT readiness. 

Member  States  with  a  mature  and  decentralised  eInvoicing  architecture  will  rely  on 
eInvoicing service and solution providers to upgrade their systems to support the EN, offering 
competitive solutions to public and private entities of all sizes. In this scenario, the impact of 
the  implementation  of  the  EN  is  expected  to  be  low  or  moderately  low,  depending  on  the 
situation.  The  cost  for  upgrading  the  systems  will  be  borne  by  the  service  providers  and 
consequently by end-users (contracting authorities and their suppliers). It will be marginal if 
the  service  providers  are  supporting  standards  already  aligned  to  the  EN,  while  it  will  be 
relatively  higher  in  the  opposite  case.  All  ERP  vendors  and  eInvoicing  service  providers 
interviewed  for  the  study  stated  they  will  offer  solutions  conformant  to  the  EN  based  on 
market demand. However, the cost for implementing the EN will increase if a high number of 
extensions will be used at a national and sectoral level, significantly reducing the benefits of a 
common standard. 

In Member States where a mature and centralised eInvoicing architecture is in place, the 
impact of the EN on end-users will be generally low. Any change required to support the EN 
and  the  related  cost  will  be  borne  mainly  by  the  entities  managing  the  central  eInvoicing 
system. In France for example, the system in place since January 2017, Chorus Pro, is based 
on the implementation of a shared solution for all suppliers (both private and public) of the 
public sphere. The EN will have no impact on (small) public administration as Chorus Pro is 

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provided at no cost for administrations or suppliers. The EN does not disrupt SMEs either as 
they remain free to send PDF invoices to public administrations. 

Small  contracting  authorities  will  decide  the  level  of  investment  and  process  automation  of 
the  eInvoicing  services  and  solutions  they  will  use,  based  on  the  national  requirements  and 
their  business  case.  The  cost  to  purchase  the  EN  from  CEN  is  not  a  major  issue  but  the 
availability  of  information  through  CEF  and  CEN  related  to  the  European  Standard  and  its 
ancillary deliverables free of charge is considered to be important.  

Member States with low eInvoicing maturity adopting a decentralised architecture will 
face challenges  to  ensure the take up and implementation  of the EN. However, this  may be 
mitigated by the government providing clear guidance and rules, such as the use of standards. 
In addition, awareness, advocacy, senior sponsorship, training, competence centres and shared 
services  will  play  a  significant  role  in  supporting  the  use  of  the  EN.  In  this  scenario,  the 
impact  of  the  EN  and  the  related  costs  are  expected  to  be  significant.  Unless  Contracting 
Authorities  choose  the  option  to  use  shared  services,  which  would  hugely  reduce  and 
mutualize costs or to apply a share and re-use policy, there will be an impact on their budget. 
In Member States with low eInvoicing maturity which chose to implement a centralised 
eInvoicing  system,  the  impact  of  the  EN  will  depend  on  the  national  requirements  and  the 
level of readiness in the public and the private sector. Countries that have mandated the use of 
standards  already  aligned  to  EN  will  not  face  any  major  technical  challenge.  If  the  level  of 
readiness  is  high,  eInvoicing  adoption  would  increase  accordingly.  Contracting  authorities 
will  be  supported  and  enabled  through  the  centralised  system;  while  suppliers  will  rely  on 
commercial operators, and in some cases, free of charge services will be offered for a limited 
number  of  invoices.  However,  in  order  to  materialise  these  benefits,  a  certain  investment  is 
needed by the central authorities to put in place such a central system. 

5.  Impact on specific stakeholders 

Impact on small contracting authorities   
The interviews with regional and local authorities show that: 

  The usage of standard is crucial for local authorities in order to reduce the costs. 
  The most common way to implementing the EN is expected to be through the upgrade 
of ERP (Entreprise Resource Planning) systems natively supporting the standard. 
  As  long  as  extensions  can  be  avoided,  implementing  the  EN  is  expected  to  be 

inexpensive for all public administrations. 

The  benefits  for  simplifying  payment  procedures  are  therefore  considered  to  outweigh  the 
limited costs for implementation. 

As mentioned before, Directive 2014/55/EU only applies to contracts with a value above the 
EU  thresholds,  thus  limiting  the  number  of  small  contracting  authorities  concerned  by  this 
obligation.  In  general,  it  will  be  up  to  each  contracting  authority  to  decide  the  level  of 
automation and IT sophistication of their systems and the investment they are willing to make. 
This will be based on their business case and on national requirements. The funding provided 
by CEF Telecom is considered to be a useful instrument to support the implementation of the 
EN. 

Impact on SMEs  
There  is  no  obligation  stemming  from  the  Directive  for  private  parties  to  use  eInvoicing, 
although  national  rules  may  make  it  mandatory.  However,  in  case  they  decide  to  use 

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eInvoicing in procurement, the EN will have a positive effect on SMEs, by preventing public 
administrations  in  different  countries  to  require  different  eInvoicing  specifications.  In  some 
Members States, eInvoicing services are offered free of charge to SMEs for a limited number 
of eInvoices. In  Italy, the Chamber  of Commerce  provides such  a service,  also including  e-
archiving.  

Finally,  the  EN  is  agnostic  to  the  use  of  eSignatures.  Any  cost  related  to  the  use  of 
eSignatures  for  eInvoicing  to  the  public  sector,  in  Member  States  where  their  use  is 
mandatory, should be foreseen by SMEs in their budgets.  

6.  Challenges ahead 

The contacted stakeholders put  forward a number of measures to  support the roll-out  of the 
EN and maximise the benefits. These are listed below in order of recurrence: 

 

the  existing  test  environment,  freely  accessible  (no  authentication  required)  to  be  further 
enhanced  (e.g.  more  meaningful  explanations  for  errors,  updated  as  validation  artefacts 
evolve) and provide examples of complex and simple invoices;  

  a  central  European  registry  listing  all  service  and  solution  providers  which  are 

supporting the EN or the CIUS, as key element of a governance system; 

  clear documentation about the EN and its implementation; 
  a technical Service Desk to provide support through the implementation of the EN; 
  validation  artefacts  for  the  EN  to  be  publicly  accessible  and  the  testing  services 
available  through  an  application  programming  interface  (API)  promoted  to  a  wider 
audience; 
financial support for the implementers; 
the ISA² core vocabularies and relevant semantic specifications could be considered. 

 
 

The roll-out of the EN will require maintenance and governance. For instance, a governance 
system  should  be  put  in  place  for  evaluating  the  extensions  at  both  the  semantic  and 
syntactical  level  and  to  look  for  commonalities  between  countries  and  sectors,  based  on  a 
controlled process.  

In addition, there are benefits for public buyers adopting a ‘maximal strategy’ based on full 
process  automation.  In  order  to  promote  this,  the  role  of  the  Technical  Committee  and  the 
European Commission will be critical to provide the necessary support. 

7.  Conclusion 

This Report concludes the work on the preparation of the European Standard for eInvoicing. 
The three criteria mentioned in the Directive itself, (practicality, user-friendliness and possible 
implementation  costs)  have  been  evaluated.  According  to  the  two  main  sources,  the  CEN 
Technical Report and the PWC Study, the EN is considered fit for purpose. 

In  parallel  to  the  transmission  of  this  Report  to  European  Parliament  and  Council,  the 
reference to the EN will be published in the Official Journal of the European Union. Pursuant 
to article 11 of the Directive, this publication is the starting point for the starting point for the 
implementation  of  the  deadlines  in  the  first  subparagraph  of  Article  11(2)  of  Directive 
2014/55/EU. 

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