COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION Evaluation of Directive 2014/55/EU on electronic invoicing in public procurement Accompanying the document 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

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  EN 

   EUROPEAN COMMISSION  Brussels, 19.2.2024  SWD(2024) 40 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE EVALUATION  Evaluation of Directive 2014/55/EU on electronic invoicing in public procurement                          Accompanying the document 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   {COM(2024) 72 final} - {SWD(2024) 39 final}  
 
 
1. 

Introduction 

The Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 on 
electronic invoicing in public procurement, (the ‘Directive’), aimed at establishing a European 
eInvoicing  standard,  at  creating  capabilities  for  public  authorities  to  process  electronic 
invoices  and  at  enhancing  interoperability,  with  the  final  objective  to  foster  the  Internal 
Market.  The  purpose  of  the  evaluation  in  the  Staff  Working  Document  is  to  assess  the 
performance of the Directive and to provide conclusions that can be used as a basis for future 
policy development. 

The period considered in  the Evaluation  Staff  Working Document lasts from  2014 to  2022, 
with  a  specific  focus  on  the  phase  following  the  transposition  of  the  Directive  for  central 
contracting authorities and entities, i.e., the period after April 2019. The geographical scope 
of the analysis encompasses all EU Member States.  

2.  What was the expected outcome of the intervention? 

In the 2010 Digital Agenda for Europe, the European Commission recognised the potential of 
electronic  invoicing  (eInvoicing)  as  a  key  enabler  for  the  digital  economy  and  a  means  to 
promote the Internal market. In the same year, the EU's policy on eInvoicing was promoted 
with  the  European  Commission  Communication  ’Reaping  the  benefits  of  e-invoicing  for 
Europe’,  advocating  eInvoicing  adoption  and  the  development  of  a  standard.  However,  two 
years  after,  the  EU  landscape  of  eInvoicing  in  public  procurement  had  not  significantly 
changed.  Hence,  in  the  European  Council  Conclusions  of  June  2012,  Member  States 
advocated for actions to encourage eInvoicing, and the European Parliament, in a resolution 
passed  in  April  2012,  urged  the  mandatory  implementation  of  eInvoicing  in  public 
procurement  by 2016.  This  led to  the proposal  of the Directive  accompanied by a thorough 
Impact  Assessment,  which  explored  the  effects  of  promoting  eInvoicing  adoption  and 
interoperability  in  public  procurement.  At  that  time,  eInvoicing  constituted  between  4  and 
15%  of  invoicing  procedures  in  the  EU,  with  challenges  hindering  both  SMEs  and  large 
enterprises.  

In 2014, the Directive was adopted with the aim of enhancing the Internal Market by reducing 
barriers  in  cross-border  public  procurement  caused  by  the  lack  of  interoperability.  The 
Directive aimed to facilitate B2G (Business-to-Government) and B2B (Business-to-Business) 
eInvoicing,  reduce  complexity,  and  lower  costs  for  all  parties  involved  in  transactions.  It 
mandated public administrations to accept eInvoices compliant with the European eInvoicing 
standard  for  public  procurement  contracts.  The  Directive's  expected  impact  was  to  improve 
interoperability, increase eInvoicing uptake, and  simplify invoicing  procedures and business 
flows.  

3.  How has the situation evolved over the evaluation period? 

The European Commission is actively promoting the exchange of eInvoices by strengthening 
its standardisation efforts based on the European eInvoicing standard to support the Internal 
Market. The Commission mandated CEN (European Standardisation Committee) to create the 
2017  European  eInvoicing  standard  as  requested  by  the  Directive  in  its  Article  3.  The 
European  eInvoicing  standard  is  the  semantic  data  model  of  an  electronic  invoice,  which  is 
properly the content of an invoice. In 2017, when the Commission published this standard by 
Commission Implementing Decision (EU) 2017/1870, this was accompanied by two syntaxes, 
which are the only ones that can be used with it for compliance. Furthermore, Member States 

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had  a  deadline  of  April  2019  for  the  implementation  of  electronic  invoicing  in  B2G  at  the 
central  level  and  of  April  2020  for  the  sub-central  level.  Linked  to  the  transposition  of  the 
Directive  into  national  law,  some  Member  States  have  mandated  eInvoicing  in  B2G,  which 
means  that  suppliers  in  public  procurement  can  send  only  electronic  invoices  to  public 
authorities.  Currently,  several  EU  countries  are  planning  to  introduce  mandatory  eInvoicing 
also for B2B transactions. With the current expansion of eInvoicing to  encompass B2B, the 
risk  of  fragmentation  has  intensified.  This  is  critical  as  B2B  transactions  constitute  the 
majority of eInvoicing transactions in Europe.  

A recent important policy development in the EU invoicing policy  is linked to the ’VAT in 
the  Digital  Age’  legislative  proposals,  which  were  published  on  December  8,  2022.  The 
ViDA  package  aims  to  modernise  the  EU  VAT  system,  to  reduce  administrative  costs  for 
businesses.  It  also  seeks  to  help  tax  administrations  address  VAT  fraud  issues,  through  a 
series  of  proposed  measures,  notably,  by  making  eInvoicing  the  default  method  for  issuing 
invoices  in  Europe  from  January  2028,  and  by  making  VAT  reporting  to  be  based  on 
electronic  invoicing  for  intra-community  transactions.  The  eInvoicing  definition  would  be 
aligned  with  the  eInvoicing  Directive,  covering  only  structured  electronic  invoices  fit  for 
automatic processing.  

4. Evaluation findings 

To what extent was the intervention successful and why? 

The  Directive's  implementation  and  the  adoption  of  the  European  eInvoicing  standard  by 
public  authorities  and  economic  operators  have  significantly  contributed  to  harmonising 
electronic invoicing in Europe. However, the Directive’s objectives have been each fulfilled 
to a different extent, as shown below. 

The Directive has successfully set up the European eInvoicing standard in 2017. However, the 
objective  of  making  national  public  authorities  at  all  levels  (i.e.  central,  sub-central)  accept 
and process eInvoices compliant with the standard was only partially achieved. This objective 
has been generally secured at the central level, as all the Member States - with the exception 
of  two,  Cyprus  and  Slovakia,  that  are  currently  building  their  invoicing  platforms,  have 
ensured  the  receiving  and  processing  of  eInvoices  compliant  with  the  European  eInvoicing 
standard. Yet, it has not fully been achieved at the sub-central level.  

Regarding  its  specific  objectives  related  to  the  fostering  of  the  Internal  Market,  namely  by 
ensuring interoperability, achieving widespread adoption, enhancing the ease of operations for 
economic  entities  through  legal  certainty,  mitigating  technical  complexity,  and  by  reducing 
costs, the impacts vary.  

In  regard  to  ensuring  interoperability,  the  Directive  has  effectively  addressed  obstacles  to 
interoperability  at  both  the  semantic  and  syntax  levels.  However,  the  evolving  landscape  of 
eInvoicing in the last decade has brought new challenges, particularly regarding the necessity 
for  interoperability  at  the  transmission  level  across  the  EU.  In  terms  of  the  operational 
objective, which was to  create conditions  for  the emergence of  technical  solutions  in public 
procurement,  the  intervention  facilitated  the  establishment  of  pan-European  eInvoicing 
capabilities,  particularly  in  the  public  sector.  Interoperability  was  achieved  by  imposing 
obligations on public authorities and  allowing the use  and expansion  of the  Peppol network 

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present  in  23  EU  Member  States  as  a  harmonised  solution  for  transmission  and  for 
exchanging European eInvoicing standard-compliant eInvoices across the EU.  

When  it  comes  to  achieving  widespread  adoption  of  eInvoicing,  the  Directive  has  played  a 
pivotal role by setting the legal basis for eInvoicing adoption. However, there is a high level 
of B2G eInvoicing adoption only in Member States where the government mandated suppliers 
to send only eInvoices in public procurement and in digitally mature countries (e.g. Estonia, 
Finland,  Sweden).  Beyond  its  immediate  impact  within  the  public  procurement  sphere,  the 
Directive  has  played  a  role  in  promoting  further  harmonisation  in  the  B2B  context.  By 
establishing a common foundation for eInvoicing practices within the EU and introducing the 
European eInvoicing standard, the Directive has encouraged developments in B2B, where the 
EU  standard  is  already  used  and  its  usage  will  likely  be  further  extended  by  the  ViDA 
legislation, for which the European eInvoicing standard is currently being adapted through the 
work of CEN to cover all use cases.  

The  efficiency  of  eInvoicing  implementation  in  terms  of  costs  and  benefits  shows  a  varied 
situation among Member States. The costs borne by public authorities depend on the digital 
maturity  of  their  public  sectors.  Economic  operators,  particularly  Small  and  Medium 
Enterprises  (SMEs),  face  varying  costs  depending  on  eInvoicing  service  packages  available 
and transaction volumes. Nevertheless, a significant number of Member States, 17 out of 23 
surveyed,  confirmed  that  the  benefits  of  eInvoicing  outweighed  their  associated  costs  at  the 
national  level  for  all  stakeholders.  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 shortened payment delays 
as well as less complexity.  

•  For national authorities, the main cost factor for the implementation of the Directive 
was the establishment of the national eInvoicing infrastructure (if it was not already in 
place) and the maintenance of such infrastructure, while the cost of adjustment to the 
European eInvoicing Standard was marginal. 

•  SMEs  have  difficulties  to  quantify  the  advantages  brought  by  eInvoicing,  but  they 
state that they would clearly benefit if eInvoicing were adopted across the board and if 
they  would  be  able  to  use  eInvoicing  for  new  innovative  applications  such  as  tax 
reporting, eco reporting, eInvoice financing, or customs declaration.  

•  For  large  enterprises,  implementing  eInvoicing  across  different  EU  Member  States 

that have different legal and technical rules is expensive.  

As  regards  the  coherence  criteria  for  success,  the  Directive  demonstrates  both  internal  and 
external  coherence.  Its  objectives  are  aligned  with  the  development  of  the  European 
eInvoicing  standard,  ensuring  consistency  between  legislative  objectives  and  further 
adaptation  of  the  standard  by  CEN.  Externally,  it  aligns  with  EU  policies  such  as  Public 
Procurement  Directives,  the  2023  proposal  for  a  regulation  repealing  the  Late  Payment 
Directive,  and  VAT  in  the  Digital  Age  (ViDA)  legislative  proposals,  contributing  to  the 
harmonisation of EU eInvoicing rules and interoperability.  

How did the EU intervention make a difference and to whom? 

There  is  a  broad  consensus  among  EU  Member  States  and  eInvoicing  stakeholders  that  the 
Directive has produced significant value at EU level in several aspects. 

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From the perspective of national authorities, the main EU contribution consists of limiting the 
emergence  of  various  national  eInvoicing  standards.  A  high  level  of  legal  certainty  was 
introduced by the Directive and significant technical simplification was provided thanks to the 
use of a common European eInvoicing standard, leading to considerable cost reduction. 

For  economic  operators,  the  Directive’s  impact  varies  among  and  within  each  stakeholder 
category. 

•  For  SMEs,  the  main  contribution  consists  of  easier  B2G  invoicing,  followed  by 

improved efficiency, and easier invoicing to large enterprises. 

•  For 

large  enterprises, 

improved 
interoperability in supply chains, easier invoicing to public bodies, increased accuracy, 
improved data quality, and enhanced security are considered the most relevant positive 
impacts associated with the eInvoicing Directive. 

to  cost  savings  per  eInvoice, 

in  addition 

•  For  service  providers  operating  in  this  field,  the  establishment  of  a  European 
eInvoicing standard helped simplify decisions in relation to selecting and investing in 
a single eInvoicing format for both domestic and cross-border public procurement. 

Is the intervention still relevant? 

The Directive, adopted in 2014, remains highly relevant due to persistent challenges and the 
emergence of new issues. The Directive has successfully established a European eInvoicing 
standard  and  created  the  conditions  for  public  authorities  to  receive  and  process  electronic 
invoices compliant with the European standard.  

National variations of the European standard still pose ongoing challenges to interoperability 
Furthermore,  new  interoperability  challenges  have  appeared  due  to  the  evolution  of 
eInvoicing in the last ten years, especially at the transmission level. 

5. What are the conclusions and lessons learned?  

The Directive has  played a crucial role in  harmonising eInvoicing within Europe, achieving 
significant  progress  in  enhancing  the  Internal  Market  through  the  deployment  of  national 
eInvoicing  infrastructures  compliant  with  the  European  standard  for  B2G  transactions  and 
through  its  adoption  by  economic  operators.  Due  to  the  positive  developments  in  the  EU, 
Europe's  influence in  eInvoicing extends globally, with  Peppol  specifications  being  adopted 
by countries in different regions of the world. 

Despite  these  achievements,  the  evaluation  has  identified  shortcomings  that  hinder  the 
Directive's  full  potential,  especially  at  the  level  of  adoption.  Moreover,  ensuring  full 
interoperability,  including  the  transmission  level,  remains  challenging.  The  variations  in 
national  implementations  of  the  European  standard  may  limit  the  seamless  exchange  of 
eInvoices,  which  could  be  further  exacerbated  when  EU  governments  mandate  for  B2B 
eInvoicing are enforced. 

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