REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the effects of Directive 2014/55/EU on the Internal Market and on the uptake of electronic invoicing in public procurement
Date: 2024-02-19
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: European standard, administrative formalities, application of EU law, digital single market, e-invoicing, electronic government, public procurement, systems interconnection

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.2.2024  COM(2024) 72 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the effects of Directive 2014/55/EU on the Internal Market and on the uptake of electronic invoicing in public procurement {SWD(2024) 39 final} - {SWD(2024) 40 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the effects of Directive 2014/55/EU on the Internal Market and on the uptake of 
electronic invoicing in public procurement 

INTRODUCTION 

This report analyses the impact of the Directive 2014/55/EU of the European Parliament and of 
the  Council  of  16  April  2014  on  electronic  invoicing  in  public  procurement  on  the  Internal 
Market and on the adoption of eInvoicing in the European Union. It notably builds upon the 
results  of  the  evaluation  of  this  legislation  conducted  by  the  European  Commission  (the 
‘Commission’)1.  

The  Directive  on  electronic  invoicing  in  public  procurement  (the  ‘Directive’)2  aimed  at 
improving  the  functioning  of  the  Internal  Market  by  harmonising  the  rules  for  electronic 
invoicing  in  the  public  sector  in  the  European  Union,  as  well  as  reducing  barriers  in  cross-
border public procurement caused by insufficient interoperability among national eInvoicing 
legal requirements and systems. In addition, the Directive also aimed at ensuring a widespread 
harmonised  adoption  of  eInvoicing  using  a  common  standard,  the  European  eInvoicing 
standard, which was instrumental in achieving the Directive’s objectives. 

The  Commission  has  conducted  data  collection  and  consultation  activities  with  different 
categories of stakeholders. It has also commissioned an external study to analyse the Directive’s 
implementation  and  evaluate its  functioning. Based on these activities,  the evaluation  of the 
Directive  was  undertaken  in  2023.  Data  from  secondary  sources,  including  statistical  data, 
legislative  documents,  reports,  and  studies,  were  collected,  and  analysed.  Field  research 
included a Call for Evidence and targeted consultation activities in the forms of surveys and 
interviews with different stakeholder groups, including national authorities, Small and Medium 
Enterprises (SMEs), large enterprises, eInvoicing service and solutions providers, Enterprise 
Resource Planning3  (ERP) vendors,  and  main  professional  associations active in  this  sector, 
such as OpenPeppol and the Global Exchange Network Association (GENA), former European 
E-Invoicing Service Providers Association (EESPA). Case studies covering sampled countries 
were also developed and used as sources of information. 

This review is in line with Article 12 of the Directive which requires the Commission to review 
its impact on the Internal Market and the uptake of electronic invoicing in public procurement 
within  three  years  of  the  deadline  for  the  transposition  of  sub-central  authorities,  set  in 
April 2020.  

CONTEXT AND BACKGROUND OF THE REPORT 

The Directive is  part of  the follow-up to  the 2012 Commission strategy for e-procurement4, 

1 SWD(2024)39 
2 Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on electronic invoicing in public procurement, OJ L 
133, 6.5.2014. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0055 
3 Enterprise Resource Planning is a business process management software that allows an organisation to use a system of integrated 
applications to manage the business and automate many back-office functions such as procurement, production, technology, accounting and 
support services, and human resources. 
4 COM/2012/0179 final, Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions, A strategy for e-procurement. https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=COM:2012:0179:FIN 

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which  aimed  at  modernising  public  procurement  and  fostering  the  digitalisation  of  public 
administration within the EU. 

In the 2010 Digital Agenda for Europe5, the Commission recognised the potential of electronic 
invoicing as a key enabler for the digital economy and a means to promote the Digital Single 
Market.  In  2010,  the  EU's  policy  on  eInvoicing  was  promoted  with  the  Communication 
‘Reaping the benefits of e-invoicing for Europe’6, advocating its adoption and the development 
of a standard. However, two years after, the EU landscape of еInvoicing in public procurement 
had not significantly changed. Therefore, in a resolution in April 2012, the European Parliament 
called for making eInvoicing compulsory in public procurement by 2016, while Member States 
called  for  measures  to  promote  e-invoicing  at  the  Informal  Competitiveness  Council  of 
February 2012 and in the European Council Conclusions of June 20127.  

This  led to  a 2013 Impact  Assessment,  accompanying  the proposal  for the Directive, which 
explored  the  effects  of  promoting  eInvoicing  adoption  and  interoperability  in  public 
procurement. At that time, eInvoicing constituted 4-15% of invoicing procedures in the EU and 
it was posing particular challenges to both Small and Medium Enterprises (SMEs) and large 
enterprises, due to lack of interoperability.  

eInvoicing in the private sector had been implemented since the 1980s through the Electronic 
Data  Interchange  systems  (EDI)  to  standardise  electronic  communication  between  trading 
partners. EDI was primarily used in industries such as automotive, retail, and logistics. Since 
2005, some Member States started to mandate the use of specific national eInvoicing formats 
and legal requirements to suppliers of the public sector. These formats were not interoperable 
and forced suppliers to comply with different rules when trading cross-borders. 

Since 2007, the European Union has been supporting projects aiming at the harmonisation of 
public  procurement  processes  including,  among  others,  eInvoicing.  In  2008,  the  EU-funded 
Pan-European Public Procurement On-Line (Peppol) project was initiated by 18 government 
agencies in 11 Member States to facilitate eProcurement across borders, building on the work 
of  the  European  Committee  for  Standardisation  (CEN).  It  provided  a  set  of  technical 
specifications  that  can  be  implemented  in  existing  eProcurement  solutions  to  make  them 
interoperable,  and  it  developed  into  a  network  of  Access  Points  for  the  exchange  electronic 
invoices and other documents. In 2012, the OpenPeppol Association was set up by a group of 
Member States to ensure the sustainability of the project’s results. Since then, it has witnessed 
a significant expansion of its members’ community and its network8. 

TRANSPOSITION AND IMPLEMENTATION OF THE DIRECTIVE 

The Directive was adopted in April 2014, with the general objective to improve the functioning 
of  the  Internal  Market  by  reducing  barriers  in  cross-border  public  procurement  caused  by 
insufficient interoperability among national eInvoicing legal requirements and standards.  

In  addition  to  this  general  objective,  the  Directive  had  two  specific  objectives:  (i)  reducing 
complexity and improving clarity and legal certainty for economic operators by enabling firms 

5 COM(2010)245 final, Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions, A Digital Agenda for Europe, 19.5.2010. https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0245:FIN:EN:PDF 
6 COM (2010) 712, final Communication from the Commission to the European Parliament, the Council, the European Economic and Social 
Committee and the Committee of the Regions, Reaping the benefits of electronic invoicing for Europe, 2.12.2010. https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0712:FIN:en:PDF 
7 https://data.consilium.europa.eu/doc/document/ST-76-2012-INIT/en/pdf 
8 https://peppol.org/ 

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to send invoices in standards with which they were familiar and which would have been widely 
accepted; (ii) and lowering operating costs for economic operators participating in cross-border 
public procurement, such as the cost of supporting multiple eInvoicing standards and systems.  

Ultimately,  the  operational  objective  of  the  Directive  was  to  create  the  conditions  for  the 
emergence  of  technical  solutions  for  eInvoicing  in  public  procurement,  which  would  have 
ensured cross-border interoperability, so that communication and mapping between eInvoicing 
systems  would  have  been  less  resource  intensive,  allowing  buyers  and  sellers  to  exchange 
invoices in public procurement at the lowest cost and with minimal complexity. 

To achieve these objectives, according to Article 3 of the Directive, the Commission mandated 
first of all the development of a European standard for the semantic data model of an electronic 
invoice, which is properly the content of an invoice, the list of elements or terms that need to 
be included (European eInvoicing standard or European standard)9. Secondly, it required the 
identification  of  a  limited  number  of  syntaxes  (format  or  language)  which  comply  with  the 
European standard.  This standard was designed  also  to  support the EU legislation on Value 
Added Tax (VAT). The responsibility for creating the standard was entrusted to the European 
Committee for Standardisation (CEN). The Commission requested that CEN drafted guidelines 
on  transmission  interoperability10,  even  if  those  guidelines  were  not  binding  on  contracting 
authorities  and  contracting  entities.  A  set  of  ancillary  deliverables  published  by  CEN 
simultaneously accompanies the standard. 

To stimulate the uptake of eInvoicing in public procurement in the EU, Article 7 of the Directive 
required all public administrations in Europe to receive and process electronic invoices issued 
as the result of the performance of contracts to which the EU Public Procurement Directives 
apply (Directive 2009/81/EC11, Directive 2014/23/EU12, Directive 2014/24/EU13 and Directive 
2014/25/EU14), if the electronic invoice is compliant with the European standard. 

Central authorities had until April 2019 to comply with the provisions of the Directive, and sub-
central authorities until April 2020 in those Member States that opted for the one-year extension 
for sub-central contracting authorities in their national transposition law.  

Up to July 2023, significant progress has been made in the adoption of eInvoicing within the 
European  Union.  All  Member  States  have  transposed  the  Directive  into  national  laws. 
Seventeen  out  of  27  Member  States  have  implemented  legislation  making  it  mandatory  for 
suppliers to issue eInvoices to the public sector, fully in 13 of them and only partially in four 
Member States. Some of these have imposed the obligation on suppliers precisely at the time 
of transposition of the Directive. Additionally, nine Member States have extended eInvoicing 
for public procurement contracts below the EU thresholds.  

9 The European standard on eInvoicing was developed by CEN and published by the European Commission,   
It defines the core business terms of an electronic invoice in a semantic data model. https://ec.europa.eu/digital-building-
blocks/wikis/display/DIGITAL/Compliance+with+eInvoicing+standard 
10 The European standard on eInvoicing addresses the issue of transmitting the eInvoices with a guidelines report. The guidelines support 
implementers in selecting and designing transmission solutions. https://ec.europa.eu/digital-building-
blocks/wikis/display/DIGITAL/Navigating+the+eInvoicing+standard+documentation 
11 Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of procedures for the award of 
certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, and 
amending Directives 2004/17/EC and 2004/18/EC (Text with EEA relevance), OJ L 216, 20.8.2009, p. 76–136. 
12 Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award of concession contracts Text with 
EEA relevance, OJ L 94, 28.3.2014, p. 1–64. 
13 Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 
2004/18/EC, OJ L 94, 28.3.2014. 
14 Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities operating in the 
water, energy, transport and postal services sectors and repealing Directive 2004/17/EC, OJ L 94, 28.3.2014, p. 243–374. 

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CURRENT EVOLUTION OF EINVOICING 

The emergence of new EU policy initiatives, in particular the legislative proposals ‘VAT in the 
digital age’ (ViDA)15, will reshape the European eInvoicing landscape in the coming years. On 
8 December 2022, the Commission put forth a set of proposals to modernise and enhance the 
EU VAT system. This reform aims at broadening the scope of EU policy to cover Business-to-
Business (B2B) transactions through the implementation of ‘near real-time’ digital reporting 
for  VAT  on  EU  cross-border  transactions  based  on  eInvoicing  and  making  eInvoicing  the 
default  system  for  issuing  invoices  by  January  2028.  Additionally,  the  ViDA  initiative 
reinforces the Internal Market as it ensures greater alignment among national systems across 
the EU: the acceptance of the European standard would have to be guaranteed in all national 
eInvoicing  systems.  Ultimately,  ViDA  presents  an  opportunity  to  foster  digital  integration 
among businesses within the Digital Single Market, to bolster eInvoicing standardisation and 
to stimulate innovation. 

Another important evolution of eInvoicing is linked to the increasing influence of the European 
eInvoicing standard at the international level. In order to foster the competitiveness of European 
businesses and to strengthen EU position as global leader in standardisation, the Commission 
is actively promoting the EU-model based on the European Standard and Peppol specifications. 
Currently, non-EU countries, such as Australia, Japan, Malaysia, New Zealand and Singapore, 
have based their national eInvoicing specifications on the European standard as extensions and 
are actively interested in the Peppol International Invoice Model (PINT)16, operational since 
July  2023,  which  generalises  the  European  standard  in  a  systematic  way,  facilitating  the 
interoperable exchange of invoices across the Peppol Network internationally. Other countries 
and  regions  have  PINT  as  a  reference,  adapting  it  to  their  specific  needs.  The  eInvoicing 
cooperation with EU partner countries offers the opportunity to maximise the investments and 
implementations already carried out by EU companies and minimise trade costs by fostering 
eInvoicing interoperability across regions.  

Lastly, emerging technologies and innovative approaches are shaping the future of eInvoicing. 
For  a  greener  Europe,  emissions  reporting  could  become  more  precise,  with  emissions 
calculated  and  disclosed  at  the  line-item  level  within  electronic  invoices,  enhancing 
environmental accountability. For tax purposes, Digital VAT returns pre-filled using data from 
eInvoices  streamline  compliance  for  businesses.  Predictive  tax  calculations,  powered  by 
Artificial  Intelligence  (AI)  could  allow  predictions  of  tax  amounts  for  businesses  and 
individuals. The battle against fraud employs AI-driven semantic analysis, machine learning, 
and data mining from structured electronic invoices to enhance monitoring and accuracy. The 
Real-Time Economy aims to enable real-time information exchange and to this purpose, data 
from  electronic  invoices  could  be  used  as  the  most  accurate  dataset  regarding  a  business 
transaction,  reducing  administrative  burdens.  Additionally,  blockchain-enabled  invoice 
financing, with the creation of a unique digital fingerprint for each invoice, addresses the risk 
of  duplicate  invoice  financing  across  borders.  Ultimately,  these  advancements  reshape 
eInvoicing and EU and its Member States have the duty to rally around the common objective 
to create the most favourable conditions for this innovation to develop in the EU. 

KEY  FINDINGS  FROM  THE  ANALYSIS  OF  EINVOICING  DIRECTIVE 

15 https://taxation-customs.ec.europa.eu/taxation-1/value-added-tax-vat/vat-digital-age_en 
16 PINT is the specification that implements the Peppol BIS billing for use in Europe. It describes the use of the invoice and credit note 
messages in Peppol, and facilitates an efficient implementation and increased use of electronic collaboration. https://test-
docs.peppol.eu/pint/pint-eu/pint-eu/bis/ 

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IMPLEMENTATION 

The  current  report,  as  required  by  Article  12  of  the  Directive,  reviews  the  impact  of  the 
Directive on the Internal Market, and examines eInvoicing adoption in Europe, starting from 
the findings of the 2023 Evaluation exercise. To assess the performance and the impact, the 
analysis focused on the Directive's implementation and achievements between 2014 and 2022, 
looking more closely at the period after the transposition for central authorities in April 2019, 
knowing that the final deadline for implementation for sub-central authorities was April 2020. 

The findings and conclusions are based on the outcomes of the evaluation of the Directive by 
the  Commission  conducted  in  2023  before  the  Report.  In  line  with  the  Better  Regulation 
principles,  this  evaluation  examined  the  performance  of  the  Directive  according  to  five 
evaluation  criteria:  relevance,  effectiveness,  efficiency,  coherence,  and  EU  added  value.  It 
looked at: The challenges to the Internal Marker for eInvoicing, the impact of the Directive on 
the Internal Market and uptake as well as on main categories of stakeholders, the Directive’s 
value added and coherence of the EU eInvoicing policy with other EU policies. 

Challenges to the Internal Market: past and present 

The Directive is still relevant today as the challenges that prompted its adoption in 2014 persist 
and still create barriers to the functioning of the Internal Market. In addition, new challenges 
and  developments  have  emerged  since  its  adoption,  leading  to  the  current  common  positive 
opinion  among  national  authorities  from  18  out  of  27  Member  States  about  the  ongoing 
relevance of the Directive17. 

The challenges identified in 2014 continue to be relevant today: they relate to the adoption level 
of  eInvoicing  in  Europe  and  the  interoperability  of  IT  systems  for  electronic  invoicing. 
Concerning the uptake of eInvoicing in  public procurement, it is  noteworthy  that, while the 
capabilities for receiving electronic invoices are to a certain extent present, significant adoption 
is  mainly  observed,  firstly,  in  countries  that  have  required  suppliers  to  send  only  electronic 
invoices to public authorities and, secondly, in digitally mature Member States. Notably, 17 
Member  States,  which  introduced  supplier  obligations  either  fully  (13  Member  States)  or 
partially (4 Member States), report either 100% uptake of eInvoicing in public procurement or 
the expectation to achieve this target by the end of year or 2024. Conversely, in other Member 
States, uptake tends to be low, except for digitally advanced countries, such as Estonia, Finland 
and Sweden. These countries, equipped with advanced eInvoicing legislation and capabilities, 
demonstrate higher levels of adoption. Uptake also tends to be high in the scenario where, even 
if not mandated by law, there is an administrative permission for public authorities to require 
eInvoicing in tenders, essentially constituting a ‘mandate by practice’.  

It  is  important  to  highlight  that the uptake of eInvoicing does not  necessarily align with the 
uptake of the European eInvoicing standard. Some Member States have ensured the uptake of 
eInvoicing in public procurement by imposing obligations on suppliers, without simultaneously 
requiring  the  use  of  the  European  standard.  Consequently,  the  adoption  of  the  European 
Standard remains lower, as it relies on a suppliers' voluntary choice. In Member States that had 
systems pre-existing the adoption of the European standard, the use of the national standard 
tends to prevail.  

In  this  context,  to  consolidate  the  Internal  Market  for  eInvoicing,  it  would  be  helpful  to 

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

5 

 
 
 
maximise the use of the European eInvoicing standard in order to reduce administrative burdens 
for  companies.  Adopting  a  single  eInvoicing  standard  across  all  Member  States  would 
streamline  invoicing  processes  and  procedures  in  Europe,  simplifying  invoicing  for  public 
administrations and their business partners. This simplification will be further supported by the 
application of the same standard for VAT reporting, as foreseen by ViDA. Ultimately, the use 
of the European eInvoicing standard not only facilitates the consolidation of the Internal Market 
for  eInvoicing  but  also  contributes  to  the  reduction  of  costs  associated  to  cross-border 
transactions for economic operators.  

Secondly, the challenge of interoperability persists, as not all the four levels of interoperability, 
as  defined  by  the  European  Interoperability  Framework,  including  transmission  and 
governance, were addressed by the Directive. While interoperability at the semantic and syntax 
level was identified as  a challenge to be addressed in EU policy already  in 2014 and it was 
addressed by the creation of a European eInvoicing standard in 2017, transmission has emerged 
as one of the main challenges during the implementation of eInvoicing. Only recommendations 
on transmission, which are non-binding, were issued by CEN alongside the European standard, 
as mentioned in the recitals of the Directive. However, this situation may evolve in the light of 
new EU eInvoicing policy developments related to the ViDA legislative proposals.  

Currently, as regards interoperability in B2B, businesses and, in particular small businesses, are 
forced  to  use  the  specific  eInvoicing  networks  of  their  large  customers.  These  networks  are 
closed networks and do not interoperate with each other. This has negative consequences for 
small companies that cannot use a single eInvoicing provider to exchange invoices with their 
trading partners, in their own country and furthermore at the EU level. If common transmission 
methods and protocols are agreed between parties (or mandated by law), this issue can be easily 
overcome. In addition, if at national level a platform for B2G has been put in place, this would 
mean that a company will have to use still another system to send eInvoices to the public sector.  

For service and solutions providers, offering pan-European services for eInvoicing based on a 
common  standard,  the  European  eInvoicing  standard,  created  opportunities  to  reach  an  EU-
wide customer base. However, when country-specific requirements are imposed on them, such 
as the registration of a VAT number, or stringent certification schemes, which generate high 
investment costs, their benefits are reduced. This challenge exists in both Greece and France18. 
Moreover,  an  increasing  number  of  Member  States  are  planning  to  introduce  national 
certification systems for eInvoicing services and solutions which will create new barriers to the 
Internal Market. In parallel, the use of eSignatures to guarantee the authenticity and integrity of 
eInvoices, which was imposed by some Member States, constitutes another challenge to cross-
border eInvoicing. As proven by systems that do not use this method of authentication, the use 
of such requirement has not proven to be necessary in practice.  

New  developments  have  taken  place  since  the  Directive's  adoption.  In  particular,  the  ViDA 
(VAT in the Digital Age) legislative proposals will, when adopted, impose that, starting from 
January 2028, eInvoicing would become the default method for issuing invoices. This means 
eInvoices must be issued, transmitted, and received in a structured electronic format, enabling 
automatic  and  electronic  processing.  Member  States  would  have  the  option  to  mandate 
eInvoicing  without  requesting  derogations.  Furthermore,  the  European  eInvoicing  standard 
would  be  widely  accepted  across  all  Member  States,  enabling  seamless  transmission  of 
eInvoices for Business-to-business transactions (B2B) either directly between trading parties or 

18 SWD(2024)39 

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through public portals set up by tax administrations. 

Additionally,  several  Member  States  are  currently  preparing  new  legislation  to  mandate 
eInvoicing in B2B transactions, based on a derogation from the VAT Directive, in line with 
Article 395 of that Directive. Sometimes, the scope of these policies might extend also to B2C, 
and in that regard, it should be noted that there is current standardisation work in CEN: CEN 
TC434 is currently developing technical specifications for eReceipt. In this context, alignment 
between B2G, B2B and B2C eInvoicing setups and systems would avoid excessive technical 
complexity  and  legal  uncertainty  for  economic  operators,  in  their  own  country  or  when 
engaging in cross-border trade within the EU. 

Lastly, data security and privacy have emerged as challenges during the evaluation consultation 
activities. To tackle this  issue,  agreements between service and solution  providers generally 
include a clause that requires the safeguarding of client data and forbids its use for anything 
other than what is explicitly necessary and agreed upon. However, its use is not systematic. 

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

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

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

Regarding the first objective, the harmonisation of eInvoicing rules and standards in Europe 
was achieved to a certain extent by establishing a European standard for eInvoicing developed 
by CEN and endorsed by the Commission19 in October 2017, and by creating the conditions for 
an Internal Market in public procurement. The European eInvoicing standard encompasses two 
interoperability levels, semantic and syntax, which were identified as challenges to intra-EU 
interoperability in 2014. 

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

19 Commission Implementing Decision (EU) 2017/1870 of 16 October 2017 on the publication of the reference of the European standard on 
electronic invoicing and the list of its syntaxes pursuant to Directive 2014/55/EU of the European Parliament and of the Council (Text with 
EEA relevance), C/2017/6835, OJ L 266, 17.10.2017, p. 19–21. 

7 

 
 
 
States have created mechanisms to monitor eInvoicing implementation within their countries. 
Typically, these are Member States that have mandated their suppliers to send eInvoices to the 
public sector and have central monitoring tools in place, such as France, Italy and Spain.  

One  of  Directive’s  expected  impacts  on  the  Internal  Market  was  to  increase  adoption  of 
eInvoicing in a harmonised way throughout the EU. For the adoption of eInvoicing in general, 
the percentage of EU enterprises sending eInvoices (in general, not exclusively in B2G) has 
grown from  approximately  10.3% in  2013 to  32.2% in  2020, based on a Eurostat survey  of 
companies with more than 10 employees. Although the analysis faced limitations in terms of 
data availability and consistency since there is no reporting obligation for the Member States 
applicable  under  the  Directive,  data  from  Eurostat20,  desk  research  and  interviews  with 
stakeholders have compensated for the shortcomings21. 

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

In the absence of a mandate for sending electronic invoices (either in B2G or B2B), the adoption 
level  has  increased  slowly.  According  to  the  SMEs  targeted  consultation,  the  most  efficient 
measure to increase adoption by businesses that are already using ERP and accounting software 
is to ensure that these solutions also include an eInvoicing functionality. This means that they 
can immediately be enabled to send and receive an eInvoice from their existing system without 
having to manually enter data, ensuring automation. This was already suggested by SMEs in 
the  2013  Impact  Assessment22  of  the  Directive,  which  shows  that  it  is  a  critical  factor  for 
adoption of eInvoicing by SMEs. This is the policy chosen by Denmark, for example, with their 
recent Bookkeeping Act23.  

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

20 The data represented in this section are an elaboration of the following Eurostat’s dataset: ISOC_EB_ICS. 
21 SWD(2024)39  
22 SWD(2013) 222 final, Commission Staff Working Document, Impact Assessment accompanying the document Proposal for a Directive of 
the European Parliament and of the Council on electronic invoicing in public procurement, 26.6.2013. https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2013:0222:FIN:EN:PDF 
23 Bill on the Danish Bookkeeping Act (danishbusinessauthority.dk) 
The Danish parliament passed the Bookkeeping Act on May 19th, 2022, initially stated to take effect on July 1st, 2022. The Act mandates all 
companies of all sizes to issue, receive, process, and archive invoices electronically. 

8 

 
 
 
The Directive primarily focused on addressing interoperability challenges related to semantic 
and syntax levels, but it did not tackle all four interoperability layers, including transmission 
and governance. The development of the European eInvoicing standard effectively tackled the 
semantic and syntax interoperability layers. Evidence of this is that, since the publication of the 
European  standard  in  October  2017,  the  Directive  has  fostered  the  Internal  Market  by 
preventing the introduction of new national eInvoicing formats for the public sector (B2G), thus 
avoiding further fragmentation. Three Member States - Estonia, Finland and Sweden, have been 
gradually replacing their national standard with the European Standard. Other Member States, 
which  mandated  the  use  of  a  national  standard  before  the  introduction  of  the  European 
eInvoicing standard, simply allow for the use of the European Standard. It is important to stress 
that, while transmission and governance have not been addressed by the Directive, in practice, 
interoperability  across  borders  has  been  ensured  by  the  implementation  of  Peppol-based 
solutions in 23 Member States. The Directive fostered the Internal Market by increasing legal 
certainty and reducing technical complexity for eInvoicing: it established a clear legal basis and 
set the European eInvoicing standard as the common standard to be supported by the entire EU 
public  sector.  Fourteen  Member  States  out  of  the  21  that  responded  to  the  targeted  survey, 
reported that the intervention had a positive impact on increasing legal certainty and reducing 
technical complexity24. About 80% of SMEs in the targeted survey perceived that national legal 
requirements  for  eInvoicing  are  clear  and  accessible  and  these  requirements  are  mainly  the 
result of the transposition of the Directive into national law.  

The Directive, in its Article 2, established the definition of an electronic invoice which ensured 
legal clarity: “electronic invoice means an invoice that has been issued, transmitted and received 
in a structured electronic format which allows for its automatic and electronic processing”. Only 
structured invoices fit for automation are covered. The Directive also sets the requirements for 
the  European  eInvoicing  standard,  including  technological  neutrality,  compatibility  with 
international standards, suitability for commercial transactions between enterprises and support 
for the needs of SMEs, consistency with the relevant provisions of Directive 2006/112/EC25, 
etc. 

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

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

The Directive focused on addressing interoperability issues and providing the conditions for 
widespread use of eInvoicing compliant with the European standard but did not require its use 

24 SWD(2024)39 . 
25 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, OJ L 347, 11.12.2006. 

9 

 
 
 
by  suppliers.  As  a  result,  enterprises  must  support  multiple  eInvoicing  formats  in  Member 
States where a national standard is required for B2G transactions while using other formats for 
B2B transactions. The public sector essentially acts as a large buyer, imposing its requirements 
on suppliers.  

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

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

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

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

Secondly, since its adoption, the Directive facilitated and gave an impetus to the use of Peppol 

10 

 
 
as a technical interoperable solution and network for eInvoicing between EU countries. Peppol 
is used in 23 Member States with common specifications, legal agreements, and a governance 
model.  

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

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

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

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

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

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

11 

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

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

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

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

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

Quantitative benefits from automating the invoicing process are estimated at around EUR 5.28 
per eInvoice issued and EUR 8.4 per eInvoice received, considering the cost of labour per hour 
at EUR 4626. Moreover, greater savings are achieved when automating the entire order-to-pay 
cycle, including orders, transport documents, invoices, and payment notices. Automating these 
processes  allows  for  consistent  electronic  document  exchange  and  enables  automated 
reconciliation, resulting in benefits estimated between EUR 25 and EUR 65 per purchase-to-
pay cycle27. 

Coherence with other EU policies and EU added value 

To support the creation of the Digital Single Market for eInvoicing, the Directive needed to be 
coherent with all other EU policies, mainly those targeting digitisation. The coherence of the 
Directive  has  been  evaluated  on  two  main  levels:  internal  and  external  coherence.  Internal 
coherence examines how the different components of the EU intervention work together, while 
under external coherence, the analysis looks into how the Directive is aligned with a few EU 
policy initiatives, legislative and non-legislative: 2014 Public Procurement Directives28, Late 

26 European Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, Ciciriello, C., Gray, E., 
Preparatory study on the effects of the Directive 2014/55/EU on electronic invoicing in public procurement, Publications Office of the 
European Union, 2024, https://data.europa.eu/doi/10.2873/27631 
27 https://www.corrierecomunicazioni.it/digital-economy/polimi-da-fattura-elettronica-risparmi-per-3-miliardi/ 
28 Directive 2009/81/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of procedures for the award of 
certain works contracts, supply contracts and service contracts by contracting authorities or entities in the fields of defence and security, and 
amending Directives 2004/17/EC and 2004/18/EC  

12 

 
 
 
 
Payment Directive29 and 2023 proposal for a Regulation repealing the current Late Payment 
Directive30,  2022  VAT  in  the  Digital  Age  (ViDA)  legislative  proposals,  European 
Interoperability  Framework  (EIF)31,  Connecting  Europe  Facility  (CEF)  eInvoicing  and 
eDelivery  Building  Block32  and  the  Commission  policy  work  on  the  global  dimension  of 
eInvoicing and the promotion of the EU model. 

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

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

There is a strong link between the Directive and the 2022 Commission VAT in the Digital Age 
(ViDA)  legislative  proposals33  as  regards  the  role  of  eInvoicing.  The  proposal  aims  to 
modernise the EU VAT  system,  addressing challenges related to  the platform  economy  and 
introducing  a  single  VAT  registration  to  avoid  multiple  registrations  within  the  EU. 
Furthermore, it will implement a reporting system for VAT for EU cross-border transactions, 
which will be based on eInvoicing and on the European eInvoicing standard, while requiring 
Member States that want to put in place a VAT reporting system for domestic transactions to 
also  base  it  on  eInvoicing.  As  part  of  the  proposal,  eInvoicing  is  set  to  become  the  default 
invoicing method by January 2028.  

The coherence between the Directive and ViDA is ensured with the current  draft legislative 
proposals,  which are,  however, subject  to  evolution  during the adoption  process. The ViDA 
proposals are an opportunity to ensure alignment on the EU definition of electronic invoicing 

Directive 2014/23/EU of the European Parliament and of the Council of 26 February 2014 on the award of concession contracts Text with 
EEA relevance 
Directive 2014/24/EU of the European Parliament and of the Council of 26 February 2014 on public procurement and repealing Directive 
2004/18/EC 
Directive 2014/25/EU of the European Parliament and of the Council of 26 February 2014 on procurement by entities operating in the water, 
energy, transport and postal services sectors and repealing Directive 2004/17/EC 
29 Directive 2011/7/EU of the European Parliament and of the Council of 16 February 2011 on combating late payment in commercial 
transactions (recast), OJ L 48, 23.2.2011, p. 1–10. 
30 Proposal for a regulation of the European Parliament and of the Council on combating late payment in commercial transactions. https://eur-
lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52023PC0533(01) 
31 https://ec.europa.eu/isa2/eif_en/ 
32 https://joinup.ec.europa.eu/collection/digital-building-blocks/solution/edelivery/about 
33 COM/2022/701 final, Proposal for a COUNCIL DIRECTIVE amending Directive 2006/112/EC as regards VAT rules for the digital age, 
8.12.2022. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A701%3AFIN 

13 

 
 
 
in the VAT legislation and in the Directive. The ViDA’s new definition of electronic invoicing 
is consistent with the one included in the Directive. This alignment ensures coherence across 
various EU policies and facilitates the smooth implementation of eInvoicing initiatives within 
the EU.  

Furthermore,  the  Directive  focuses  specifically  on  B2G  eInvoicing  and  aligns  in  its  current 
main  lines  with  the  ViDA  proposal,  which  targets  B2B  eInvoicing.  Ultimately,  the  ViDA 
proposals  complement  the  eInvoicing  Directive,  especially  in  ensuring  harmonisation  and 
interoperability in cross-border eInvoicing in B2G and B2B transactions, allowing the reduction 
of administrative burden, and fostering convergence towards the European eInvoicing standard, 
as also stressed in the 2023 Rolling Plan for ICT standardisation34.  

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

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

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

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

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

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

From  the  perspective  of  national  authorities,  the  main  EU  contribution  consists  in  reducing 
barriers  in  cross-border  public  procurement,  by  limiting  the  emergence  of  various  national 
eInvoicing standards. The Directive required public administrations throughout the European 

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

14 

 
 
 
Union  to  receive  and  process  eInvoices  issued  under  contracts  subject  to  EU  Public 
Procurement directives,  provided they  comply with  the European e-invoicing  standard. This 
Directive-induced action has not only prevented the fragmentation of the internal market but 
has also fostered EU-wide eInvoicing interoperability.  

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

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

CONCLUSIONS 

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

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

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

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

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

15