COMMISSION STAFF WORKING DOCUMENT EVALUATION 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

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.2.2024  SWD(2024) 39 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  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) 40 final}  
 
 
COMMISSION STAFF WORKING DOCUMENT 

EVALUATION 

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 

EN 

  EN 

1 

 
 
 
 
 
Table of Contents 

1. 

INTRODUCTION ................................................................................................................. 14 

Purpose and scope of the evaluation ...................................................................................... 14 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ....................... 14 

2.1. Description of the intervention and its objectives .......................................................... 14 

2.2. Points of comparison ...................................................................................................... 18 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ......... 18 

3.1. 

Legislative Actions ................................................................................................... 18 

3.1.1. Establishment of the new legal framework ................................................................. 18 

3.1.2. Transposition of the Directive in Member States ........................................................ 19 

3.1.3. Mandate for suppliers to issue B2G eInvoices in 17 Member States .......................... 20 

3.1.4. Development of the European eInvoicing Standard .................................................... 23 

3.2. Non-Legislative Actions ................................................................................................. 24 

3.2.1. Peppol .......................................................................................................................... 24 

3.2.2. The e-SENS project ..................................................................................................... 25 

3.2.3. The Connecting Europe Facility (CEF) Programme (2014-2020) .............................. 25 

3.2.4. The EU Digital Building Blocks ................................................................................. 26 

3.2.5. The eProcurement Ontology ....................................................................................... 27 

3.3. Current State of Play....................................................................................................... 27 

4.  EVALUATION FINDINGS.................................................................................................. 29 

4.1.  TO WHAT EXTENT WAS THE INTERVENTION SUCCESSFUL AND WHY?............ 29 

4.1.1.  Effectiveness ............................................................................................................. 29 

4.1.1.1. General Objective ..................................................................................................... 30 

4.1.1.2. Specific objectives .................................................................................................... 38 

4.1.1.3. Operational Objective ............................................................................................... 40 

4.1.2.  Efficiency .................................................................................................................. 41 

4.1.2.1. Costs and benefits for public authorities .................................................................. 41 

4.1.2.2. Costs and benefits for economic operators ............................................................... 46 

4.1.3.  Coherence ................................................................................................................. 48 

4.1.3.1. Internal coherence .................................................................................................... 48 

4.1.3.2. External coherence ................................................................................................... 49 

4.2.  HOW  DID  THE  EU  INTERVENTION  MAKE  A  DIFFERENCE  AND  TO 

WHOM? ................................................................................................................................ 53 

4.3.  IS THE INTERVENTION STILL RELEVANT? ................................................................. 54 

2 

 
 
 
4.3.1. 

Interoperability challenge at the transmission level .................................................. 56 

4.3.2.  Uptake challenge ...................................................................................................... 56 

4.3.3.  B2B use of the European eInvoicing standard .......................................................... 56 

4.3.4.  Common approach in B2G, B2B and B2C ............................................................... 57 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................... 57 

5.1.  CONCLUSIONS ................................................................................................................... 57 

5.2.  LESSONS LEARNT ............................................................................................................. 61 

ANNEX I: PROCEDURAL INFORMATION .............................................................................. 63 

ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED .................................... 65 

ANNEX III. EVALUATION MATRIX ........................................................................................ 68 

ANNEX IV. OVERVIEW OF BENEFITS AND COSTS ........................................................... 105 

ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................. 124 

ANNEX VI. CASE STUDIES AND COUNTRY PROFILES .................................................... 130 

3 

 
 
 
 
 
 
Glossary 

Term or 
acronym 

Access Point 

B2B 

B2C 

B2G 

Buyer or 
Receiver 

CEN 

CEN/TC 434 

Meaning or definition 

In  the  Peppol  and  eDelivery  network,  an  Access  Point is  a  gateway 
linking  the  community  of  end-users  (buyers  and  sellers)  and  their 
service providers with various eInvoicing / eProcurement solutions. It 
is  a  software  service  provided  by  an  Access  Point  provider  that 
enables  the  transfer  of  business  documents,  such  as  orders  and 
invoices, over the Peppol Transport Infrastructure. The Access Point 
provider  is  responsible  for  establishing  its  own  connections  with  its 
Peppol participants and is likely to offer a range of other services.  

Business-to-business stands for a transaction that takes place between 
one business and another. 

Business-to-consumer  stands  for  a  transaction  that  takes  place 
between a business and an individual as an end-customer.  

Business-to-government  stands  for  a  transaction  between  a  public 
sector entity and a business.  

Buyer  of  goods  and  services  from  a  supplier  or  seller.  An  invoice 
issued  by  the  seller  is  issued  to  the  buyer,  who  is,  therefore,  the 
receiver  of  the  goods  and  services  and  the  receiver  of  the  related 
invoice. 

European  Committee  for  Standardisation,  an  association  that  brings 
together  the  National  Standardisation  Bodies  of  33  European 
countries.  CEN 
three  European  Standardisation 
Organisations  (together  with  CENELEC  and  ETSI)  that  have  been 
officially  recognised  by  the  European  Union  and  by  the  European 
Free  Trade  Association  (EFTA)  as  responsible  for  developing  and 
defining voluntary standards at the European level. 

is  one  of 

CEN Technical Committee that was launched in September 2014 as a 
project  and  then  a  technical  committee  operating  within  CEN 
governance,  with  responsibility  for  developing  the  standard  for 
European  eInvoicing  based  on  a  semantic  model  for  the  core 
information  elements  of  an  electronic  invoice,  syntax  selection  and 
bindings, and other related deliverables. 

Clearance 
Model 

It  refers  to  the  approval  process  from  the  tax  authority  to  issue  an 
invoice. In countries that have chosen the ‘clearance model’, the tax 
administration  requires  each  invoice  to  be  reported  and  authorised 
electronically by them before or during the exchange process. 

4 

 
 
Code List 

Predefined list from which some statistical coded concepts take their 
values.  Each  code  list  has  the  following  properties:  a)  identifier  (it 
provides a unique identification within the set of code lists specified 
by  a  structural  definitions  maintenance  agency);  b)  name  (also 
unique); c) description (a description of the purpose of the code list); 
and  d)  code  value  length  (either  an  exact  or  a  maximum  number  of 
characters and a type, i.e. numeric or alphanumeric). Code Lists  are 
used  in  invoice  data  format  standards  to  represent  countries, 
currencies, units of measure, etc. 

Contracting 
authority /CA 

Contracting  authorities  as  defined  in  point  17  of  Article  1  of 
Directive  2009/81/EC,  Article  6(1)  of  Directive  2014/23/EU,  and 
point (1) of Article 2(1) of Directive 2014/24/EU. 

Contracting 
entities 

Contracting  entities  as  defined  in  point  17  of  Article  1  of  Directive 
2009/81/EC,  Article  7(1)  and  (2)  of  Directive  2014/23/EU  and 
Article 4(1) of Directive 2014/25/EU. 

Core elements 
of an electronic 
invoice 

A  set  of  essential  information  elements  which  an  electronic  invoice 
must  contain  to  enable  cross-border  interoperability,  including  the 
necessary information to ensure legal compliance. 

Core Invoice 
Usage 
Specification 
(CIUS) 

CTC 
(Continuous 
Transaction 
Controls) 

eDelivery 

A  specification  that  provides  a  seller  with  detailed  guidance, 
explanations  and  examples,  as  well  as  business  rules  related  to  the 
actual  implementation  and  use  (or  restriction  of  use)  of  structured 
information elements present in the core invoice model in a specific 
trading  situation.  An  instance  document  created  following  a  given 
the  European  Norm 
CIUS  shall  always  be  compliant  with 
(EN16931). 

A  form  of  transaction-based  reporting  or  clearance  either  based  on 
the  actual  invoice  or  a  subset  of  the  invoice.  CTCs  enable  law 
enforcement  agencies,  like  tax  administrations,  to  collect  data 
associated with business activities that are relevant to the exercise of 
their  function.  This  data  is  obtained  directly  from  business  data 
management systems, in real-time or near-real-time. 

that  provides 

A  European  digital  Building  Block 
technical 
specifications  and  standards,  installable  software,  and  ancillary 
services  to  allow  projects  to  create  a  network  of  nodes  for  secure 
digital data exchange. By building with eDelivery, public and private 
organisations  from  different  sectors  can  easily  create  a  safe  and 
interoperable  channel  to  transfer  documents  and  data  among  each 
other over a public or private network. 

EDI 

Electronic Data Interchange. The transfer of data from one computer 
system  to  another  by  standardised  message  formatting,  without 
human intervention. 

5 

 
 
EDIFACT 

Electronic  Data  Interchange  For  Administration,  Commerce  and 
Transport. 

EEA 

European Economic Area. 

GENA 
(formerly 
EESPA) 

e-IDAS 

Electronic 
invoice / 
eInvoice 

Electronic 
Signature 

EN 

EN 16931 

The  Global  Exchange  Network  Association  (GENA),  formerly  the 
European EInvoicing Service Providers Association (EESPA). 

The  EU  Regulation  910/2014  on  electronic  identification  and  trust 
services for electronic transactions in the European internal market. It 
repeals  Directive  1999/93/EC.  In  addition  to  the  regulation  of 
electronic identification services, e-IDAS also regulates various ‘trust 
services’  such  as  electronic  signatures,  timestamps,  and  Electronic 
Registered Delivery Services. 

An  invoice  that  has  been  issued,  transmitted  and  received  in  a 
structured  electronic  format,  which  allows  for  its  automatic  and 
electronic processing. 

A  general  expression  for  any  type  of  electronically  generated 
signature on a message or document transmitted electronically. They 
range from facsimile signatures to more secure digital signatures. 

A European Norm (EN) is a standard which has been adopted by one 
of  the  three  recognised  European  Standardisation  Organisations: 
CEN, CENELEC or ETSI. 

The European  eInvoicing standard.  It  was developed by CEN at  the 
request  of 
the 
Commission in 2017.  

the  European  Commission  and  published  by 

Entity Identifier  Unique digital identifier of a trading party or business entity. This can 
be  a  Legal  Entity  Identifier  or  another  convenient  and  recognisable 
identifier. 

eProcurement 

It  refers  to  the  use  of  electronic  communications  by  public  sector 
organisations when buying supplies and services or tendering public 
works.  

ERP  

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. 

6 

 
 
European 
Interoperability 
Framework 

The  European  interoperability  framework  is  a  commonly  agreed 
approach  to  the  delivery  of  European  public  services  in  an 
interoperable  manner.  It  defines  basic  interoperability  guidelines 
through  common  principles,  models,  and  recommendations.  It 
specifies  layers  of  interoperability  such  as  governance,  legal, 
organisational, semantic, and technical. 

European 
standard 

Extension 

European  standard  as  defined  in  point  (b)  of  Article  2(1)  of 
Regulation (EU) No 1025/2012. 

EN  16931  envisages  requirements  for  trading  parties  to  extend  the 
core  invoice  model  and  the  related  business  rules  and  code  lists  to 
support  business  use  cases  that  are  specific  to  their  trading 
environment  (sector  or  country)  while  at  the  same  time  maintaining 
semantic interoperability with the core invoice model. An Extension 
is  a  specification  of  the  required  additional  or  modified  information 
elements  and,  in  the  EN  16931  is  the  subject  of  an  Extension 
Methodology. 

Format 
conversion or 
transformation 

A  process  by  which  a  structured  eInvoice  is  converted  from  one 
technical  representation  or  syntax  to  another  while  not  altering  its 
business or semantic content. It may also refer to the conversion of a 
structured  eInvoice  into  a  human-readable  presentation  such  as  a 
PDF, and vice-versa. 

Format or File 
Format 

A  standard  way  that  information  is  technically  represented  or 
encoded in a computer file. File formats may be either proprietary or 
free and may be either unpublished or open. In eInvoicing, a format is 
synonymous with syntax. 

Four Corner 
Model 

A  model  for  interoperability  in  which  the  seller  and  buyer  are  not 
using  the  same  service  provider.  The  service  providers  or  a  party 
providing  a  ‘self-service’,  in  turn,  inter-operate  with  each  other, 
either  based  on  bilateral  agreements  or  as  part  of  a  multilateral 
network. 

Global 
Interoperability 
Framework 
(GIF) 

(GIF) 

Interoperability  Framework 

The  Global 
is  a  set  of 
recommended  practices,  policies,  and  standards  for  the  operation  of 
interoperability  network  organised  within  a 
any  ‘four-corner’ 
collaborative  governance  framework  wishing  to  be  GIF  compliant. 
Such  a  network  allows  its  dedicated  access  points,  which  are 
typically service and solution platform providers of various kinds, to 
inter-connect  their  customer  networks  for  the  exchange  of  digital 
supply chain-related transactions such as eInvoices and orders.  

7 

 
 
GS1 (Global 
Standards One) 

A  not-for-profit  standards  organisation  that  manages  the  assignment 
of  various  numbering  schemes  for  global  commerce.  Active  in  the 
world  of  supply  chains  in  retail,  healthcare,  transport,  and  logistics, 
GS1 
the  barcode  and 
implementation  of  standards  such  as  EANCOM,  GLN  and  GS1 
XML. 

is  well  known  for  having  developed 

Hybrid Invoice  A method of embedding structured eInvoice inside a PDF, using the 
PDF  A/3  format.  It  is  often  called  a  ‘hybrid’  invoice,  as  it  includes 
both a structured and a human-readable presentation. All information 
present in the structured format must be present in the readable PDF.  

International 
standard 

International  standard  as  defined  in  point  (a)  of  Article  2(1)  of 
Regulation (EU) No 1025/2012. 

Interoperability  The  ability  of  organisations  to  interact  towards  mutually  beneficial 
goals,  involving  the  sharing  of  information  and  knowledge  between 
these  organisations  through  the  business  processes  they  support,  by 
means of the exchange of data between their ICT systems. 

Intra-EU Trade 

It refers to the trade of goods and services within the EU, among its 
Member States. 

Large 
Enterprises 

OASIS 

Enterprises with 250 or more persons employed.  

The  Organisation  for  the  Advancement  of  Structured  Information 
Standards  (OASIS)  is  a  global  non-profit  consortium  that  works  on 
the  development,  convergence,  and  adoption  of  standards  for  the 
information  society.  In  the  context  of  eInvoicing,  OASIS  is  known 
for the UBL 2.0 standard. 

OpenPEPPOL 
Association 

The  membership  association  responsible  for  the  governance  and 
maintenance of the Peppol specifications. 

PDF 

The  Portable  Document  Format  is  a  file  format  used  to  present 
documents  in  a  manner  independent  of  application  software, 
hardware,  and  operating  systems.  Each  PDF  file  encapsulates  a 
complete  description  of  a  fixed-layout  flat  document,  including  the 
text, fonts, graphics, and other information needed to display it.  

Peppol 

A  set  of  artefacts  and  specifications  enabling  cross-border 
eProcurement. 

8 

 
 
Portal (or Web 
portal) 

A  synonymous  with  ‘gateway’  and  refers  to  a  website  that  often 
serves  as  the  single  point  of  access  for  information,  for  example,  a 
website  that  users  tend  to  visit  as  an  anchor  site  for  a  specific 
purpose. In eInvoicing, a portal is usually provided by an eInvoicing 
service  provider  to  give  suppliers  access  to  a  range  of  eInvoicing 
services  including  the  ability  to  upload  or  prepare  invoices  for 
delivery  to  buyers,  and  to  receive  information  and  status  messages 
and manage exceptions. 

Public 
Procurement 

The  process  by  which  public  authorities,  such  as  government 
departments  or  local  authorities,  purchase  work,  goods  or  services 
from companies. 

Qualified 
Electronic 
Signature 

An  electronic  signature  that  is  compliant  to  EU  Regulation  No 
910/2014  (eIDAS  Regulation)  for  electronic  transactions  within  the 
European  market.  It  enables  parties  to  verify  the  integrity  and 
authenticity  of signed electronic data exchange over long  periods of 
time.  The  difference  between  the  advanced  electronic  signature  and 
the  qualified  electronic  signature  is  the  addition  of  a  qualified 
certificate  and  the  use  of  a  certified  Secure  Signature  Creation 
Device. This certificate is issued by a qualified trust service provider. 

Seller 

The  contractually  responsible  seller  of  goods  and  services  and  the 
issuer or sender of an invoice. 

Semantic Data 
Model 

List  of  business  terms  and  their  meanings  that  specify  the  core 
elements  of  an  electronic  invoice.  In  the  EU  eInvoicing  context,  it 
refers  to  EN  16931-1:2017  Electronic  invoicing  -  Part  1:  Semantic 
data model of the core elements of an electronic invoice. 

SEPA 

Service 
Provider 

The Single Euro Payments Area in which retail payments in euro in 
the  form  of  SEPA  Credit  Transfer,  SEPA  Direct  Debit,  and  SEPA 
Card  Payments  are  made  available  using  common  rules  and 
standards. 

In  the  context  of  eInvoicing,  a  Service  Provider  is  an  organisation 
that  provides  its  customers  with  services  for  the  creation,  delivery, 
and processing of eInvoices and other related eBusiness transactions, 
as well as supporting software and analytics. Such organisations are 
typically  based  on  the  provision  of  networks,  business  outsourcing, 
financial services, technology and/or EDI platforms. 

9 

 
 
Shared Services  The  provision  of  a  service  by  one  part  of  an  organisation  or  group 
acting as a central servicing unit. It often applies to activities such as 
finance, administration, human resources, and facilities management, 
where there are economies of scale and scope, which have previously 
been  carried  out  individually  by  every  operating  unit.  The  funding 
and resourcing of the centralised service is shared, and the providing 
unit or shared service centre effectively  becomes an internal  service 
provider. 

SME 

Small  and  medium-sized  enterprises.  SMEs  are  defined  in  the  EU 
recommendation 2003/361. The main factors determining whether an 
enterprise  is  an  SME  are  staff  headcount  and  turnover  or  balance 
sheet total. 

Structured 
eInvoice 

Sub-central 
contracting 
authorities 

Supplier 
onboarding 

A  structured  electronic  invoice  contains  (structured)  data  in  a 
machine-readable format that can be automatically imported into the 
buyer's  Account  Payable  (AP)  system  without  requiring  manual 
entering. Structured data refers to data that is organised and formatted 
in  a  specific  way  to  make  it  easily  readable  and  understandable  by 
both humans and machines. This is typically achieved through a well-
defined  schema  or  data  model,  which  provides  a  structure  for  the 
data. 

All  contracting  authorities  which  are  not  central  government 
authorities  as  defined  in  point  (3)  of  Article  2(1)  of  Directive 
2014/24/EU. 

The  process  of  interfacing  with  the  management  of  a  supplier, 
gathering and providing the information needed to set up a company 
as  an  approved  supplier,  and  establishing  connectivity,  in  order  to 
enable a supplier to efficiently conduct business, access services, and 
receive payments. 

Syntax 

The machine-readable language or dialect used to represent the data 
elements contained in an electronic invoice. 

Syntax bindings  Guidelines  on  how  a  semantic  data  model  for  an  electronic  invoice 

could be represented in the various syntaxes. 

10 

 
 
 
Three Corner 
Model 

An  arrangement  where  a  single  service  provider  connects  both  the 
supplier  and  the  buyer  to  its  platform  to  offer  eInvoicing  and  other 
supply chain services. 

Two Corner, 
Bilateral, or 
Direct Model 

An  arrangement  where  invoice  transmission  takes  place  on  a  direct 
connection basis between the trading parties. The trading parties may 
use a third-party service or solution provider or SaaS to provide the 
functionality. 

UBL 

The  Universal  Business  Language  is  an  open  library  of  standard 
electronic  XML  business  documents 
for  procurement  and 
transportation,  such  as  purchase  orders,  invoices,  transport  logistics 
and  waybills.  UBL  was  developed  by  an  OASIS  Technical 
Committee  with  participation  from  a  variety  of  industry  data 
standards  organisations.  It  is  one  of  the  syntaxes  selected  for  use  in 
the EN 16931 to represent the semantic model. 

UN/CEFACT 
and 
UN/CEFACT 
Syntax 

The  United  Nations  Centre  for  Trade  Facilitation  and  Electronic 
Business.  One  of  the  key  standards  it  has  developed  is  the  Cross 
Industry Invoice (CII). The underlying syntax for the CII is one of the 
technical languages selected for use in the EN 16931 to represent the 
semantic model. 

UN/EDIFACT  United  Nations/Electronic  Data  Interchange  for  Administration, 
Commerce  and  Transport  (UN/EDIFACT)  is  the  international  EDI 
standard developed under the United Nations. In 1987, following the 
convergence  of  the  UN  and  US/ANSI  syntax  proposals,  the 
UN/EDIFACT Syntax Rules were approved as the ISO standard ISO 
9735 by the International Organisation for Standardisation. 

Unstructured 
invoice 

An invoice presented in a format other than a structured format, such 
as  a  humanly  generated  PDF  that  is  not  capable  of  automated  and 
electronic processing. 

Validation or 
Verification 

Web Form 

A process carried out by an eInvoice receiver or a service provider on 
its behalf to  ensure that  an eInvoice, inter alia, is compliant with its 
business  and  technical  requirements  and  with  the  transaction 
undertaken. 

A form on a web page that allows a user to enter data that is sent to a 
server  for  processing.  Forms  can  resemble  paper  or  database  forms 
because  web  users  fill  out  the  forms  using  standard  graphical  user 
interface elements such as checkboxes, templates, or text fields. Web 
forms  are  commonly  provided  in  eInvoicing  portals  for  customers, 
which do not use an integrated file transfer solution. 

11 

 
 
XML 

Table 1 Glossary 

Extensible  Mark-up  Language  is  a  mark-up  language  that  defines  a 
set  of  rules  for  encoding  documents  in  a  format  that  is  human-
readable and machine-readable. Several  schema systems  exist to  aid 
in the definition of XML-based languages, while programmers have 
developed many application programming interfaces (APIs) to aid the 
processing of XML data. XML provides a widely used foundation for 
creating documents and document systems. 

12 

 
 
 
 
 
 
 
 
 
 
1. 

INTRODUCTION 

Purpose and scope of the evaluation 

The  purpose  of  this  evaluation  is  to  review  the  implementation  and  performance  of 
Directive 2014/55/EU of the European Parliament and of the Council of 16 April 2014 
on  electronic  invoicing  in  public  procurement  (hereinafter,  ‘the  Directive’)1,  and  to 
provide conclusions that can be used as a basis for future policy development. 

The  evaluation  allowed  the  gathering  of  valuable  insights  regarding  the  Directive's 
implementation  in  the  Member  States.  It  aimed,  in  particular,  to  evaluate  whether  the 
Directive has effectively achieved its intended objectives and expected outcomes. 

The  evaluation  of  the  Directive  has  followed  the  European  Commission’s  Better 
Regulation Guidelines2.  A study supporting this ex-post evaluation of the Directive has 
been carried out  by independent  consultants3. The general  public, industry stakeholders 
and  representatives  of  national  administrations  have  participated  in  this  process.  The 
evaluation  has  addressed 
the  five  mandatory  evaluation  criteria  of  relevance, 
effectiveness, efficiency, consistency, and EU added value. 

The  evaluation  period  considered  in  this  evaluation  report  extends  from  2014  to  2022. 
The impact assessment4 accompanying the Directive proposal served as the baseline for 
this evaluation. 

The geographical scope of this study encompasses all 27 EU Member States (UK is not 
included).  Additionally,  responses  to  the  questionnaire  from  national  authorities  in 
Iceland and Norway were collected and used for comparison alongside the EU Member 
States. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1. Description of the intervention and its objectives 

In  the  2010  Digital  Agenda  for  Europe5,  the  European  Commission  recognised  the 
potential  of  electronic  invoicing  (eInvoicing)  as  a  key  enabler  for  the  digital  economy 
and a means to  promote the single market.  In 2010, the EU's policy on eInvoicing was 
promoted  with  the  Communication  "Reaping  the  benefits  of  e-invoicing  for  Europe"6, 

1  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, p. 1 https://eur-lex.europa.eu/legal-content/EN/LSU/?uri=CELEX:32014L0055 
2 Better regulation: guidelines and toolbox (europa.eu)  
3  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 
4  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,  Brussels. 
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2013:0222:FIN:EN:PDF 
5 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52010DC0245 
6 https://joinup.ec.europa.eu/collection/eprocurement/document/eu-reaping-benefits-e-invoicing-europe-commission-communication 

13 

 
 
 
 
advocating eInvoicing adoption and the development of a standard. However, two years 
after,  the  EU  landscape  of  еInvoicing  in  public  procurement  had  not  significantly 
changed. Therefore, the Member States called for measures to promote еInvoicing in the 
European Council Conclusions of June 2012. In parallel, the European Parliament called 
for making еInvoicing compulsory in public procurement by 2016 in a resolution adopted 
in  April  2012.  This  led  to  a  proposal  for  a  Directive,  accompanied  by  an  impact 
assessment  that  analysed  the  expected  impacts  of  promoting  eInvoicing  adoption  and 
interoperability  in  public  procurement.  In  2013,  eInvoicing  constituted  4-15%  of  all 
invoicing procedures in the EU public and private sector, with challenges hindering both 
Small and Medium Enterprises (SMEs) and large enterprises. At the time of the adoption 
of  the  Directive,  the  eInvoicing  landscape  in  Europe  was  marked  by  diverse  national 
formats,  leading  to  non-interoperable  systems.  Several  countries,  including  Denmark, 
Austria, and Italy, had mandated eInvoicing in public procurement. Other countries, such 
as Czechia, Finland, France, Germany, and Spain, were also taking steps towards broader 
use  of  eInvoicing  in  public  procurement.  However,  EU  Member  States  were  adopting 
different  national  formats. This  lack of a common standard created market  barriers  and 
complexity  for  firms  conducting  cross-border  public  procurement  and  led  to  a 
fragmented eInvoicing landscape in the EU7. 

In regard to eInvoicing procedures in the private sector, Eurostat data from 2011 showed 
that only 8.2% of EU enterprises exchanged eInvoices. Legal and technical complexities 
of  eInvoicing  hindered  its  adoption,  especially  for  SMEs,  with  approximately  40%  of 
them not considering eInvoicing due to the multitude of standards. Large enterprises also 
faced challenges with unclear laws and regulations related to eInvoicing adoption. 

7 SWD(2013) 222 final, Commission Staff Working Document, Impact Assessment accompanying the proposal for a Directive of the 
European  Parliament  and  of  the  Council  on  electronic  invoicing  in  public  procurement.  26.6.2013,  Brussels.  https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2013:0222:FIN:EN:PDF 

14 

 
 
 
Figure 1 eInvoicing problem tree 

(Source: Impact assessment accompanying the proposal for a Directive of the European Parliament and of the Council on electronic 
invoicing in public procurement.) 

In  this  context,  the  main  objective  of  the  EU  intervention,  as  identified  in  the  impact 
assessment accompanying the proposal for the Directive, was to enhance the functioning 
of  the  Internal  Market  by  reducing  market  access  barriers  in  cross-border  public 
procurement caused by the lack of interoperability in eInvoicing technical requirements 
and standards. The preferred option chosen in the assessment was obligatory acceptance, 
consisting  of  proposing  a  European  eInvoicing  standard  to  the  market  and  making  it 
mandatory  for  all  contracting  authorities.  While  parties  could  still  agree  to  exchange 
eInvoices  in  other  standards,  the  common  standard  aimed  to  achieve  eInvoicing 
interoperability and simplify cross-border business. 

The  Directive  aimed  not  only  to  address  eInvoicing  challenges  in  cross-border  public 
procurement - Business-to-government (B2G) - but also to facilitate Business-to-business 
(B2B)  cross-border  trade.  Specific  objectives  included  reducing  complexity  and 
enhancing legal certainty for economic operators by allowing them to use  the European 
eInvoicing  standard  with  several  business  partners,  public  and  private,  in  their  own 
Member State or in the other Member States. Additionally, lowering operating costs for 
economic  operators,  such  as  the  cost  of  supporting  multiple  eInvoicing  standards  and 
systems,  was  an  important  goal.  The  Directive  also  sought  to  create  conditions  for  the 
emergence  of  technical  solutions  (operational  objective)  to  ensure  cross-border 
interoperability,  making  communication  between  eInvoicing  systems  less  resource-
intensive for buyers and sellers. 

In  pursuit  of  the  eInvoicing  policy  objectives,  the  European  Commission  introduced 
legislative  actions,  establishing  a  new  legal  framework  for  mandatory  acceptance  of 
eInvoices compliant with the new common European eInvoicing standard. The European 
Committee for Standardisation (CEN) was assigned the task of necessary standardisation 

15 

 
 
work  to  implement  the  eInvoicing  Directive.  Non-legislative  actions,  such  as  financing 
projects  to  promote  interoperable  eInvoicing  solutions  in  the  EU  (e-SENS)  and 
supporting  the  development  of  end-to-end  eProcurement,  including  eInvoicing  through 
the Connecting Europe Facility (CEF), were also undertaken. Additionally, the European 
Commission continued to support the work of the European Multi-Stakeholder Forum on 
eInvoicing (EMSFEI). This European expert group gathered experts from each Member 
State government as well as market actors which contributed to the EU policy with key 
recommendations to the Commission. 

Overall,  the  Directive's  aims  included  facilitating  the  use  of  eInvoicing  by  economic 
operators  supplying  goods,  works,  and  services  to  public  administration,  harmonising 
technical  implementations  based  on  the  European  eInvoicing  standard,  and  simplifying 
business  processes.  It  mandated  all  public  administrations  in  Europe  to  receive  and 
process electronic invoices (eInvoices) compliant with the EU eInvoicing standard when 
related  to  contracts  governed  by  the  EU  Public  Procurement  Directives8.  The  primary 
expected impact of the Directive was improved interoperability, as eInvoices would have 
to  be  accepted  by  all  public  buyers.  This,  in  turn,  was  foreseen  to  lead  to  an  increased 
uptake of eInvoicing and lower costs and complexity of procedures9. 

Figure 2 Intervention logic 

8  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, 
Brussels. 
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, Brussels. 
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, Brussels. 
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, Brussels. 
9 SWD(2013) 222 final, Commission Staff Working Document, Impact Assessment accompanying the proposal for a Directive of the 
European  Parliament  and  of  the  Council  on  electronic  invoicing  in  public  procurement,  26.6.2013,  Brussels.  https://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2013:0222:FIN:EN:PDF 

16 

 
 
 
 
2.2. Points of comparison  

The  impact  assessment  accompanying  the  proposal  for  the  Directive  described  the 
expected  impacts  of  the  proposal's  measures  compared  to  the  situation  at  the  time. 
Therefore, the assessment of the Directive's actual impact must be based on the analysis 
of the compliance with the objectives and targets established by the Directive. The first 
point of comparison is the adoption of the Directive, which represents the key milestone 
for evaluating the evolution of eInvoicing in Member States and how the intervention has 
influenced  it.  The  following  key  point  of  comparison  is  represented  by  the  mandatory 
deadlines  for  the  transposition  of  the  Directive  by  central  and  sub-central  contracting 
authorities  and  entities,  2019  and  2020,  respectively.  They  are  relevant  because  they 
serve  to  verify  the  timely  transposition  of  the  Directive  in  the  Member  States  and  to 
assess  the  impact  on  eInvoicing  uptake  and  how  it  evolved  in  the  years  before  the 
mandatory  transposition  (2019)  and  after  the  final  optional  deadline  for  sub-central 
authorities (2020).  

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

Beyond  the  Directive,  the  EU  eInvoicing  policy  included  cooperation  with  Member 
States and market actors to foster eInvoicing within the EU. The Commission worked to 
implement  its  policy  through  legislative  and  non-legislative  initiatives.  The  legislative 
actions considered are the establishment of the new legal framework, the transposition of 
the  Directive  in  Member  States,  which  was  accompanied  in  certain  cases  by  a 
complementary obligation for suppliers to issue B2G eInvoices in 17 Member States. 

The  non-legislative  actions  considered  are  Peppol,  the  e-Sens  Project,  the  EU  Digital 
Building Blocks, the Connecting Europe Facility (CEF) Programme (2014-2020), and the 
e-Procurement Ontology. While the scope of the evaluation concerns the implementation 
of the Directive, the non-legislative actions are described below as they had an important 
role in the evolution of EU policy for eInvoicing.  

3.1.  Legislative Actions 

3.1.1. Establishment of the new legal framework 

Directive  2014/55/EU10  aimed  to  remove  obstacles  to  cross-border  trade  caused  by 
different  national  eInvoicing  requirements  and  lack  of  interoperability.  It  applies  to 
eInvoices  issued  for  contracts  under  EU  Public  Procurement  Directives  (Directive 
2009/81/EC,  Directive  2014/23/EU,  Directive  2014/24/EU,  and  Directive  2014/25/EU) 
and is part of 2014 Public procurement legislative package, pursuing the same objective: 
the modernisation of public procurement.  

The Directive emphasises the importance of promoting interoperability. Interoperability, 
as  defined  by  the  European  Interoperability  Framework,  consists  of  four  layers:  legal, 

10  Directive  2014/55/EU  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on  electronic  invoicing  in  public 
procurement  

17 

 
 
 
 
organisational,  semantic,  and  technical  interoperability11  (for  details,  see  Figure  10  on 
page  36).  The  Directive  covers  two  layers:  the  semantic  (defining  the  content  of  the 
invoice) and syntax (specifying the format or language used) levels, which are part of the 
technical interoperability. To achieve this goal, as defined in Article 3 of the Directive, 
the  European  Commission  was  called  to  give  a  mandate  for  the  development  of  a 
European  standard  for  the  semantic  data  model  of  eInvoices  and  the  identification  of 
syntaxes  that  comply  with  this  standard.  The  responsibility  for  creating  this  European 
eInvoicing standard was entrusted to CEN, the European Committee for Standardisation. 
The  Directive,  in  its  Article  7,  required  Member  States  to  ensure  that  contracting 
authorities  receive  and  process  eInvoices  compliant  with  the  European  eInvoicing 
standard and the list of syntaxes published in the Official Journal of the European Union 
(OJEU).  Only  machine-readable  invoices  that  can  be  processed  automatically  are 
considered  eInvoices.  In  Article  2,  the  Directive  introduced  the  following  definition  of 
eInvoice: ‘an eInvoice is an invoice that has been issued, transmitted and received in  a 
structured  data  format  which  allows  for  its  automatic  and  electronic  processing; 
electronic invoicing is the exchange of an eInvoice document between a supplier and a 
buyer’.  

Central  authorities  had  until  April  2019  to  comply  with  the  obligation  stemming  from 
Article  7  of  the  Directive,  and  sub-central  authorities  had  until  April  2020,  for  the 
Member  States  that  chose  this  option  in  their  transposition  law.  Existing  national 
standards  could  be  used  alongside  the  European  standard  in  all  Member  States,  but 
eInvoices  should  not  be  refused  solely  for  non-compliance  with  other  requirements. 
Member States were free to extend the scope of the mandate and require suppliers to send 
eInvoices to contracting authorities and contracting entities, and 17 of them chose to do 
so.  

3.1.2. Transposition of the Directive in Member States  

All  Member  States  have  transposed  the  Directive  into  national  laws;  17  required  the 
derogation for one year for sub-central contracting authorities, until April 2020.  

The  following  table  includes  the  reference  to  the  national  legislation  in  Member  States 
that implemented Directive 2014/55/EU and whether they used the extra year until April 
2020  as  the  optional  extension  for  the  implementation  of  the  Directive  by  sub-central 
authorities  and  entities.  As  indicated  in  the  table,  12  Member  States  were  late  in 
transposing  and  subsequently  submitted  non-transposition  letters.  However,  in  the 
meantime, all of them have completed the transposition process. 

Member State 

National legislation implementing Directive 2014/55/EU 

Use of extra year 

Austria 

Federal Public Procurement Act, §368. Publication: 20 August 2018 

Belgium 
Bulgaria 

Croatia 
Cyprus 

Czechia  

Law on public procurement. Publication: 7 April 2019 
Law for Amending and Supplementing the Public Procurement Act. 
Publication: 18 October 2018 
Act on eInvoicing in public procurement. Publication: 17 October 2018  
Law on electronic invoicing (eInvoicing) in public procurement. Publication: 26 
June 2019 
Act no. 134/2016 Coll. on Public Procurement. Publication: 19 April 2016 

Yes 

No 
No  

No 
Yes 

Yes 

11 Levels of Interoperability: https://joinup.ec.europa.eu/collection/nifo-national-interoperability-framework-
observatory/solution/european-interoperability-framework-eif-toolbox/levels-interoperability  

18 

 
 
 
 
Member State 

National legislation implementing Directive 2014/55/EU 

Use of extra year 

Denmark 
Estonia 

Finland 

France 

Germany 

Greece 
Hungary 

Ireland  
Italy 
Latvia 

Lithuania 

Luxembourg 

Malta 
Poland 

Portugal 
Romania 

Slovakia 

Slovenia 

Spain  

Sweden 

The Netherlands 

EEA  

Iceland 

Norway 

Law on use of electronic invoice no 1593. Publication: 18 December 2018 
Accounting Act Official publication: Riigi Teataja; Number: RT I, 15.03.2019, 
3. Publication: 1 July 2019 
Law 241/2019 on electronic invoicing ("Laki hankintayksiköiden ja 
elinkeinonharjoittajien sähköisestä laskutuksesta"), Official publication: 
Suomen säädöskokoelma (SK); Number: 241/2019. Publication: 27 February 
2019 
Business Growth and Transformation law – PACTE, articles L.2192-1 to L. 
2192-7, L.2392-1 to L.2392-7 and L. 3133-1 to L.3133-5. Publication: 23 May 
2019 
E-Rechnungsgesetz; Federal level: Bundesgesetzblatt Teil 1 (BGB 1); Number: 
19. Publication: 10 April 2017 
Law 4601/2019. Publication: 9 March 2019 
Act LXXXIII of 2018 amending Act CXLIII of 2015. Publication: 28 
November 2018 
Statutory Instrument 258, in effect from 12 June 2019. Publication: 2019 
Legislative decree n. 148/2018. Publication: 27 December 2018. 
Cabinet Regulation No.154 “Applicable Electronic Invoicing Standard and 
Specification and Procedure for the Use of its Basic Elements". Publication: 17 
April 2019 
Law No. XIII-1491 amending the Law on Public Procurement of the Republic 
of Lithuania No. XIII-2158. Publication: 10 June 2019 
The Law of 16 May 2019 on electronic invoicing in public procurement and 
concession contracts. Publication: 23 May 2019 
Legal Notices 403 and 404. Publication: 30 November 2018 
The Act of November 9, 2018, on electronic invoicing in public procurement, 
concessions for construction works or services and public-private partnerships. 
Publication: 23 November 2018 
Decree-Law 123/2018. Publication: 28 December 2018 
Law 199/2020 on electronic invoicing in public procurement, on 8 September 
2020. Publication: 8 September 2020 
Act No. 2015/2019 on Guaranteed Electronic Invoicing and the Central 
Economic System. Publication: 17 July 2019 
Act Amending the Provision of Payment Services to Budget Users Act. 
Publication: 2 December 2016 
Law 18/2022 of 28 September, of creation and development of bussinesses. 
Publication: 28 September 2022 
Act (2018:1277) on electronic invoicing as a result of Public Procurement. 
Publication: 6 June 2018  
Law of 20 December 2017 amending the Public Procurement Law 2012. 
Publication: 17 July 2018 

Regulation 44/2019 on electronic billing in public procurement. Publication: 24 
January 2019 
Regulation on electronic invoicing in public procurement (FOR-2019-04-01-
444). Publication: 1 April 2019 

Yes 
No 

Yes 

Yes 

Yes 

Yes 
No 

Yes 
Yes 
Yes 

Yes 

Yes 

Yes 
No 

Yes 
No 

Yes 

No 

Yes 

No 

No 

Yes 

No 

Table 2 National legislation implementing the Directive in Member States 

(Source: EC eInvoicing Country Factsheets) 

3.1.3. Mandate for suppliers to issue B2G eInvoices in 17 Member States 

The  Directive  required  contracting  authorities  and  entities  to  be  able  to  receive  and 
process eInvoices compliant with the European eInvoicing standard.  

The  following  figure  shows  the  number  of  Member  States  that  have  introduced 
obligations  for  suppliers  to  send  eInvoices  to  the  public  sector  (Yes),  the  number  of 
Member States that introduced partial obligations (Partially), and the number of Member 
States that have not introduced obligations to suppliers (No). 

19 

 
 
No

10

Partially

4

Yes

13

0

5

10

15

20

25

Figure 3 Member States that introduced obligations to suppliers for issuing B2G eInvoices. 

(Source: Member State survey) 

Of the 27 EU Member States: 

•  13  Member  States  mandated  suppliers  to  issue  eInvoices  for  B2G  (Croatia, 
Denmark,  Estonia,  Finland,  France,  Italy,  Lithuania,  Luxembourg,  Portugal, 
Romania, Slovenija, Spain, and Sweden). 

•  4  Member  States  have  partial  mandates  on  national  suppliers  to  issue  eInvoices 
for B2G (Austria, Belgium, Germany, The Netherlands). For example, in Austria, 
the mandate refers to suppliers at the central level (this means they can only send 
electronic invoices to the federal level), and the mandate does not cover the sub-
central level. 

•  10 Member States have no mandates on national suppliers to issue eInvoices for 
B2G  (Bulgaria,  Cyprus,  Czechia,  Greece,  Hungary,  Ireland,  Latvia,  Malta, 
Poland, and Slovakia). 

The following table shows the Member States that had already introduced the obligation 
to  suppliers  to  issue  eInvoices  to  the  public  sector  from  2014  to  2018.  Member  States 
such as France gradually introduced the obligation to suppliers based on their size.  

Member States requiring suppliers to issue B2G eInvoices before 2019 

Member State 

Austria 

Belgium (Flanders) 

Denmark 

France 

Italy 

Slovenija 

Spain 

Obligation 

Partial * 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

The Netherlands 

Partial *** 

When 

2014 ** 

2017 ** 

2005 ** 

2017 to 2020 ** 

2014 ** 

2015 ** 

2015 ** 

2017 ** 

EEA 

Iceland 

Yes 

2014 ** 

Table 3 Member States requiring suppliers to issue B2G eInvoices from 2014 to 2018 

20 

 
 
 
 
* Only suppliers to the Austrian federal government. 
** The law of 2015 introduced mandatory eInvoicing, but not the European standard. 
*** Only suppliers to the Dutch central government. 
(Sources: Member State survey and EC eInvoicing Country Factsheet) 

The following table shows Member States that had introduced the obligation to suppliers 
for B2G eInvoicing in 2019 and 2020 at the time of the transposition of the Directive. 

Member States requiring suppliers to issue B2G eInvoices in 2019 and 2020 

Member State 

Obligation 

Croatia 

Estonia 

Germany 

Lithuania 

Sweden 

EEA 

Norway 

Yes 

Yes 

Partial * 

Yes 

Yes 

Yes 

When 

2019 

2019 

2020 

2019 

2019 

2019 

Table 4 Member States requiring suppliers to issue B2G eInvoices in 2019 and 2020 

* Only suppliers to the German Federal authorities. 
(Sources: Member State survey and EC eInvoicing Country Factsheet) 

The following table shows Member States that had introduced the obligation to suppliers 
for B2G eInvoicing from 2021. 

Member States requiring suppliers to issue B2G eInvoices from 2021 

Member State 

Obligation 

Belgium 

Finland 

Luxembourg 

Romania 

Portugal 

Yes 

Yes 

Yes 

Yes 

Yes 

When 

2022 to 2023 

2021 

2022 

2022 

2021 to 2023 

Table 5 Member States requiring suppliers to issue B2G eInvoices from 2021 

* Only suppliers of the regional government of Flanders and the regional government of Brussels. 
(Sources: Member State survey and EC eInvoicing Country Factsheet) 

10 EU Member States have not yet imposed obligations on suppliers to issue eInvoices 
for  B2G,  of  which  6  Member  States  have  plans  to  mandate  national  suppliers  in  the 
future  to  issue  eInvoices  for  B2G  (Bulgaria,  Cyprus,  Greece,  Latvia,  Poland,  and 
Slovakia)  and  4  Member  States  have  no  plans  to  mandate  national  suppliers  to  issue 
eInvoices for B2G (Czechia, Hungary, Ireland, and Malta). 

21 

 
 
 
 
3.1.4. Development of the European eInvoicing Standard 

The CEN Technical  Committee 43412 (CEN/TC 434) is the working  body in  CEN, the 
European  Standardisation  Organisation,  which  is  responsible  for  developing  and 
maintaining  the  European  eInvoicing  standard.  CEN  is  funded  by  the  European 
Commission.  The  Table  below  presents  the  deliverables  published  by  CEN  Technical 
Committee 434 as part of the European eInvoicing standard (EN 16931). 

Reference 

EN 16931-1 

TS 16931-2 

TS 16931-3-1 

TS 16931-3-2 

Title 

Part 1: Semantic data model of the core elements of an electronic invoice 

Part 2: List of syntaxes that comply with EN 16931-1  

Part 3-1: Methodology for syntax bindings of the core elements of an electronic invoice 

 Part 3-2: Syntax binding for ISO/IEC 19845 (UBL 2.1) invoice and credit note 

TS 16931-3-3 

Part 3-3: Syntax binding for UN/CEFACT XML Industry Invoice D16B 

TR 16931-3-4 

Part 3-4: Syntax binding for UN/EDIFACT INVOIC D16B 

TR 16931-4 

TR 16931-5 

TR 16931-6 

Part 4: Guidelines on interoperability of electronic invoices at the transmission level 

Part 5: Guidelines on the use of sector or country extensions in conjunction with EN 16931–1 

Part 6: Result of the test of EN 16931–1 with respect to its practical application for an end user 

Table 6 CEN Technical Committee 434 deliverables 

In  October  2017,  the  reference  of  EN  16931-1:2017  -  Electronic  invoicing  —  Part  1: 
Semantic data model of the core elements of an eInvoice and the list of syntaxes CEN/TS 
16931-2:2017, Electronic invoicing — Part 2:2017 was published in the Official Journal 
of the European Union. 

EN 16931-1 defines the information elements necessary for legal and fiscal compliance 
and enables cross-border, cross-sector, and domestic eInvoicing interoperability.  

It  supports  various  invoice-related  functionalities,  including  issuance,  validation, 
accounting, VAT reporting, payment, and auditing. The semantic model may be used by 
public  and  private  sector  organisations  for  public  procurement  invoicing  (B2G 
eInvoicing).  It  may  also  be  used  for  invoicing  between  private  sector  enterprises  (B2B 
eInvoicing). 

The  European  standard  allows  optional  elements  to  be  included  in  the  core  semantic 
model  through  Core  Invoice  Usage  Specifications  (CIUS),  which  provide  detailed 
guidance  and  rules  for  specific  trading  situations.  A  Core  Invoice  Usage  Specification 
(CIUS) is a specification that provides a seller with detailed guidance, explanations, and 
examples, as well as rules (business rules) related to the actual implementation and use of 
structured  information  elements  present  in  the  core  invoice  model  in  a  specific  trading 

12 CEN - CEN/TC 434 (cencenelec.eu)  

22 

 
 
 
situation13. According to the EN 16931, a compliant specification uses some features of 
the core invoice model, but all features used are in accordance with the rules of the core 
invoice model. Therefore, the CIUS is a compliant specification. 

When  additional  information  elements  that  are  not  part  of  the  core  invoice  model  are 
included in a technical specification for an eInvoice, this would become an extension. EU 
or  Common  Extensions  could  ensure  harmonisation  across  multiple  sectors,  while 
Domain Extensions cater to specific industry sectors or supply chains. According to the 
EN  16931,  a  conformant  instance  or  specification  uses  all  features  of  the  core  invoice 
model in accordance with its rules and is extended with additional features. Therefore, an 
Extension is a conformant specification. 

The difference between the core invoice data model and extensions are explained below: 

•  The Core Section contains the basic information elements (i.e. the core elements 
referred to in the Directive) required to exchange eInvoices between all types of 
trading  entities  (covering  the  basic  needs  of  cross-border  and  cross-sector 
eInvoicing). 

•  The Sector extension contains those information elements that are only a concern 
of a specific industry sector, community, supply chain or buyers and sellers of a 
particular  product  type.  Such  information  elements  may  be  incorporated  in  an 
invoice as an ’Extension’ to the Core Section information elements. 

•  The  Country  extension  contains  information  elements  or  further  information 
about such information elements, which represent the specific requirements of a 
particular Member State. 

The list of syntaxes that comply with the European eInvoicing standard are: 

•  UBL 2.1 invoice and credit note message as defined in ISO /IEC 19845:2015 
•  UN/CEFACT Cross Industry Invoice (CII) XML 16B 

The CEN/TC 434 also provided a syntax binding for UN/EDIFACT INVOIC D16B14. 

3.2. Non-Legislative Actions 

3.2.1. Peppol 

The  EC-funded  Peppol  project15  (2008-2012),  developed  before  the  publication  of  the 
Directive,  played  a  strategic  role  in  addressing  interoperability  challenges  in  the 
eProcurement domain (including eInvoicing, eOrdering, eCatalogues, etc.) in Europe and 
globally.  The  basis  of  the  European  eInvoicing  Standard  was  developed  during  this 
project as technical specifications.  

The  Pan-European  Public  Procurement  On-Line  (Peppol)  project  was  initiated  to 
facilitate eProcurement across borders. Peppol provides a set of technical specifications 
that can be implemented in existing eProcurement solutions to make them interoperable. 
The sustainability of the Peppol project has been ensured by the OpenPeppol Association 

13 Ref. EN16931-1:2017 Chapter 7. 
14 CEN - CEN/TC 434 (cencenelec.eu) 
15 https://peppol.eu/about-openpeppol/history-of-openpeppol/ 

23 

 
 
 
 
set up in 2012, which has seen a significant expansion of its community of members. In 
2012,  the  Peppol  specifications  had  been  implemented  in  production  by  private  and 
public  entities,  and  real  transactions  had  begun,  demonstrating  how  differently 
eProcurement  and  eInvoicing  systems  could  interoperate  across  borders  by  using 
common  standards,  definitions  and  rules  for  transmission  of  eProcurement  messages, 
such as eInvoices, eOrders, eCatalogues, to name a few, under an agreed governance and 
legal framework. 

Since  then,  public  and  private  entities  in  Europe  have  used  Peppol  as  a  solution  to 
comply with the technical requirements of the Directive. Moreover, countries outside of 
Europe  have  recognised  the  value  of  Peppol  in  addressing  common  issues  in  terms  of 
format  fragmentation  and  the  lack  of  interoperability  between  separate  systems.  The 
Peppol  Interoperability  Framework,  with  its  legal  agreements,  policies,  technical 
specifications, and governance model, has been recognised as a global reference point for 
the  exchange  of  electronic  business  documents  (such  as  eInvoices,  eOrders,  eDespatch 
advice, etc.). Its use is also expanding in specific industries, such as logistics. 

In  the  EU,  23  Member  States  have  implemented  Peppol  to  ensure  interoperability  of 
eInvoicing across borders (see section 4 below for more information). 

3.2.2. The e-SENS project 

The  European  Commission  funded  the  e-SENS  project  from  2013  to  2017  to  develop 
interoperable eInvoicing solutions across the EU. It involved over 100 public and private 
actors  from  22  countries  and  aimed  to  consolidate  the  work  of  previous  projects  like 
Peppol16, providing generic IT solutions for cross-border communication. 

The  e-SENS  project  focused  on  supporting  the  standardisation  of  public  procurement 
processes and eInvoicing17. It successfully tested the sending and processing of eInvoices 
between  suppliers  and  contracting  authorities  in  different  Member  States,  reducing 
administrative burdens, and improving efficiency in business processes. 

e-SENS offered a common standard-based eDelivery technical solution for cross-border 
eInvoicing, enabling seamless and secure document transfer between contractors in post-
award procurement. Austria, Norway, Greece, and Slovenia launched online eInvoicing 
services based on e-SENS18. 

3.2.3. The Connecting Europe Facility (CEF) Programme (2014-2020) 

CEF  was  an  EU  funding  programme  to  support  the  development  of  high-performing, 
sustainable  and  efficiently  interconnected  trans-European  networks  in  the  fields  of 
transport, energy, and digital services.  

From 2015-2022, the CEF Telecom eInvoicing project19 funded and supported the uptake 
of the eInvoicing and the implementation of the EN 16931, by supporting the deployment 
of  eInvoicing  solutions  for  B2G  purposes.  In  total,  49  projects  in  27  countries  (24 

16 Peppol Final Report, 2012. https://peppol.eu/wp-content/uploads/2016/08/20121205_PEPPOL_final_report_v2_4_web.pdf  
17 http://www.esens.eu/content/e-procurement http://www.esens.eu/content/e-procurement 
18 http://www.esens.eu/sites/default/files/fs_e-invoicing.pdf  
19 https://hadea.ec.europa.eu/system/files/2022-06/DSI%20fiche%20eInvoicing_final_version.pdf  

24 

 
 
 
Member States, Norway, Iceland, and the United Kingdom) were implemented under the 
CEF Telecom eInvoicing calls.  

3.2.4. The EU Digital Building Blocks  

CEF Telecom Programme supported the implementation of EU Digital Building Blocks, 
including eInvoicing, eDelivery, eSignature, and eID, providing open and reusable digital 
solutions  for  cross-border  digital  public  services20.  Currently,  the  Building  Blocks 
continue to be supported under the Digital Europe Programme (DIGITAL) (2021-2027) 
to  accelerate  the  digital  transformation  of  public  administrations  and  promote 
interoperability across Europe. 

eInvoicing Building Block 

The eInvoicing Building Block plays a crucial role in supporting public administrations 
to  comply  with  the  Directive  and  promote  the  adoption  of  eInvoicing  solutions.  The 
Building Block offers a set of tools of different kinds to ease the work of its stakeholders:  

•  The validation artefacts and a conformance tool are tools, to facilitate and test the 
implementation of the European eInvoicing standard in IT systems and services. 

•  The  European  Commission  maintains  two  essential  code  lists  related  to  the 
standard,  the  Electronic  Address  Scheme  code  list  and  the  VAT  Exemption 
Reasons code list.  

•  The eInvoicing  DIGITAL website is  available as a place to  compile all relevant 
information, and a user community is available to serve as a hub for stakeholders 
to be engaged.  

eDelivery Building Block 

The eDelivery Building Block facilitates secure and reliable exchange of electronic data 
and  documents  among  users.  Its  four  corner  model  employs  Access  Points  to  ensure 
interoperability  between  diverse  IT  systems,  allowing  seamless  communication.  These 
Access Points, managed by public or private entities in Member States, enable safe data 
exchange even among independently developed systems. 

20 https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/About+us 

25 

 
 
 
 
Figure 4 The four corner model 

eDelivery's domain-neutral use cases and technical specifications empower organisations 
to  create  a  unified  network  for  secure  digital  data  exchange.  This  fosters  collaboration 
and  efficiency  in  document  transfer  across  different  sectors.  The  standard  transmission 
protocol, eDelivery AS4, ensures secure and payload-agnostic data exchange, supporting 
a variety of document types and network topologies. 

By  widely  adopting  eDelivery  for  transmitting  electronic  documents,  including 
eInvoices,  efficiency is  maximised, and cross-border data exchange becomes smoother. 
The  reusability  and  seamless  integration  of  eDelivery  make  it  a  powerful  tool  for 
streamlining data exchange processes across Europe. 

3.2.5. The eProcurement Ontology 

The eProcurement Ontology enables the creation and dissemination of linked open data 
in  the  public  procurement  data  space.  Covering  all  phases  of  public  procurement 
procedures,  it  permits  not  only  the  publication  of  public  procurement  data  but  most 
importantly  the  consumption  and  interpretation  of  this  data  to  derive  reports,  analyses, 
and insights for decision-making.  

The  ultimate  objective  of  the  eProcurement  Ontology  is  to  conceptualise  and  formally 
encode  eProcurement  data  and  make  it  available  in  an  open,  structured,  and  machine-
readable  format.  This  data  would  cover  the  process  from  end-to-end,  i.e.,  from 
notification, through tendering, awarding, ordering, invoicing, and finally to payment. 

3.3. Current State of Play 

The  European  Commission  has  placed  significant  emphasis  on  promoting  an  open  and 
seamless  exchange  of  eInvoices  based  on  a  common  European  standard  to  support  the 
Internal Market and strengthen European leadership in standardisation worldwide. In line 
with  this  vision  and  the  Directive’s  requirement  that  the  European  standard  for 
eInvoicing has to be kept up to date, the CEN was given a mandate in 2022 via a Grant 

26 

 
 
Agreement to ensure that the 2017 European eInvoicing standard's evolution aligns with 
the EU's new policy priorities. 

To enhance cross-border interoperability and cooperation among EU Member States, the 
European  Commission  adopted  the  Interoperable  Europe  Act  proposal21  in  November 
2022. This proposal imposes obligations on Member States to share their interoperability 
solutions for digital services with public sector bodies in other Member States, aiming to 
streamline  processes  and  promote  efficiency.  Therefore, 
the 
Interoperable Europe Act establishes  the broader EU framework to  which the Directive 
shall align. On 8 December 2022, in the framework of its Action Plan for fair and simple 
taxation, the Commission unveiled the legislative proposals on VAT in the Digital Age22 
(ViDA). These proposals seek to modernise the EU VAT system and address VAT fraud 
issues  that  have  resulted  in  substantial  revenue  losses.  The  ViDA  package's  key 
objectives include modernising VAT reporting obligations, addressing challenges posed 
by  the  platform  economy,  and  introducing  a  single  VAT  registration  to  eliminate  the 
need for multiple registrations within the EU. 

the  proposal  for 

As  part  of  the  plan,  starting  from  January  2028,  eInvoicing  would  become  the  default 
method  for  issuing  invoices,  and  its  definition  would  be  aligned  with  Directive 
2014/55/EU  (this  means  eInvoices  must  be  issued,  transmitted,  and  received  in  a 
structured  electronic  format,  enabling  automatic  and  electronic  processing).  ViDA 
extends  and  promotes  the  European  eInvoicing  standard  by  imposing  its  use  for  VAT 
reporting of intra-community transactions at a minimum. It will stimulate the adoption of 
eInvoicing  in  general.  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). 

The  European  Commission  has  also  been  actively  engaged  in  various  international 
initiatives,  such  as  free  trade  agreements  (FTAs)  and  Digital  Partnerships,  to  expand 
digital  trade  opportunities  and  promote  eInvoicing  globally.  Notably,  FTAs  have  been 
concluded  with  New  Zealand,  and  there  are  ongoing  negotiations  with  Australia  and 
India. Digital Partnerships have been established with South Korea, Singapore, and Japan 
to  foster  collaboration  on  digital  issues,  including  eInvoicing  and  digital  payments. 
Complementing  these  efforts,  regulatory  dialogues  have  proven  instrumental  in 
addressing  digital  trade  challenges.  The  EU's  intensified  cooperation  with  the  U.S., 
through  the  Trade  and  Technology  Council  Working  Group  10  on  Global  Trade 
Challenges,  which  facilitates  discussions  on  interoperable  eInvoicing.  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.  

21 https://ec.europa.eu/commission/presscorner/detail/en/ip_22_6907 
22 COM/2022/701 final, Proposal for a COUNCIL DIRECTIVE amending Directive 2006/112/EC as regards VAT rules for the digital 
age, Brussels, 8.12.2022. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A701%3AFIN 

27 

 
 
 
the  European  Commission's  efforts 

In  conclusion, 
to  promote  eInvoicing  and 
digitalisation  are  aimed  at  simplifying  processes,  enhancing  cross-border  cooperation, 
reducing  administrative  burdens,  and  fostering  economic  growth  within  the  EU  and  on 
the  international  stage.  These  initiatives  hold  the  promise  of  facilitating  smoother  and 
more efficient transactions for businesses and individuals alike. 

4.  EVALUATION FINDINGS  

4.1. 

 To what extent was the intervention successful and why?  

The  success  of  the  intervention  has  been  assessed  by  evaluating  its  effectiveness,  its 
efficiency, and its coherence.  

4.1.1.  Effectiveness 

Directive  2014/55/EU  has  set  up  a  series  of  objectives,  both  direct  objectives,  which 
translated in the provisions of the Directive, and underlying objectives, which are listed 
in  its  recitals  and  in  the  Impact  Assessment  that  accompanied  the  creation  of  the 
Directive. 

The  Directive  and  the  introduction  of  the  European  eInvoicing  standard  fostered  the 
Internal Market for electronic invoicing in Europe by fulfilling its direct objectives:  

•  By setting up a standard: the Directive created a common European instrument to 
be  used  both  in  B2B  and  B2G,  both  in  the  EU and  beyond  EU  borders,  by  our 
international  partners.  Beyond  B2G,  the  European  eInvoicing  standard  has  been 
implemented and used in the market as the common European reference standard 
for eInvoicing.  

•  By  driving  the  implementation  of  the  pan-European  eInvoicing  capability,  the 
public  sector  in  the  EU  was  required  to  create  IT  systems  able  to  receive  and 
process  eInvoices  compliant  with  the  European  eInvoicing  standard  (or  update 
their  existing  system).  To  support  in  practice  the  EU  eInvoicing  uptake  and  the 
implementation  of  the  Directive,  in  the  framework  of  the  Digital  Infrastructures 
policies financed by the Commission, CEF Telecom eInvoicing calls funded  the 
implementation of eInvoicing solutions compliant with the European standard in 
24 Member States on projects deployed between 2015 to 2022. 

The underlying objectives are the following: 

A  general  objective:  to  improve  the  functioning  of  the  Internal  Market  by  introducing 
mechanisms  that  would  diminish  market  access  barriers  in  cross-border  public 
technical 
procurement  generated  by 
requirements and standards. 

interoperability  of  eInvoicing 

insufficient 

Specific objectives:  

•  Reduce technical complexity and improve legal clarity for economic operators. 

•  Lowering operating costs for economic operators. 

28 

 
Operational objective: 

•  Creating the conditions for the emergence of technical solutions for eInvoicing in 

public procurement, which would ensure cross-border interoperability. 

To assess the effectiveness of the Directive, the analysis looked into how successful the 
EU intervention has been in achieving the above-mentioned objectives, encompassed in 
the intervention logic. 

4.1.1.1. General Objective 

The  main  objective  of  the  EU  intervention  identified  in  the  impact  assessment  was  to 
improve  the  functioning  of  the  Internal  Market  by  addressing  the  issue  of  insufficient 
interoperability  of  eInvoicing  technical  requirements  and  standards.  To  do  so,  the 
Directive  addressed  interoperability  at  the  semantic  and  syntax  levels.  At  the  semantic 
level,  it  established  a  European  standard,  which  is  a  core  semantic  data  model.  At  the 
syntax  level,  it  led  to  the  identification  of  two  syntaxes  and  required  EU  public 
authorities to accept any eInvoice sent to them in the European Standard and one of the 
two  selected  syntaxes.  Furthermore, 
the 
implementation,  the  European  eInvoicing  standard  is  also  accompanied  by  supporting 
technical specifications and reports published by CEN at the same time as the standard, 
as foreseen by the Directive.  

interoperability 

in  order 

to  help 

in 

For the transmission level, for example, which was a challenge already identified at the 
time of the adoption of the Directive and mentioned in its recital 27, but not as a main 
challenge,  only  guidelines23  have  been  issued  by  CEN  together  with  the  European 
eInvoicing Standard: “Part 4: Guidelines on interoperability of electronic invoices at the 
transmission level”. These guidelines are not mandatory.  

Fostering an Internal Market for eInvoicing 

While  the  Directive,  in  what  was  considered  a  minimal  approach,  required  contracting 
authorities  and  entities  to  be  able  to  receive  and  process  eInvoices  compliant  with  EN 
16931, it did not impose an obligation on suppliers to send eInvoices to the public sector.  

In  addition,  the  Directive  and  its  provisions,  as  per  their  scope,  only  apply  to  public 
procurement contracts above the EU thresholds24, leaving the freedom to Member States 
to require it also for contracts below the EU thresholds.  

As  regards  the  objective  of  fostering  an  Internal  Market  for  eInvoicing,  this  can  be 
assessed  either  based  on  the  subjective  evaluation  by  the  Member  States  surveyed,  as 
described below, and also on the following elements: 

•  Analysing the developments in terms of interoperability in the EU. 

•  Measuring the uptake of eInvoicing in general. 

23 CEN/TR 16931-4:2017 Electronic invoicing - Part 4: Guidelines on interoperability of electronic invoices at the transmission level. 
24 https://single-market-economy.ec.europa.eu/single-market/public-procurement/legal-rules-and-implementation/thresholds_en 

29 

 
 
 
•  Measuring the uptake of eInvoicing in B2G. 

•  Measuring the uptake of the European Standard for eInvoicing.  

As regards the subjective evaluation by the Member States, when Member States replied 
to the question “To what extent has the Directive and the introduction of the EN 16931 
contributed  to  foster  the  functioning  of  the  Internal  Market”,  15  out  of  23  surveyed 
assessed  the  impact  as  positive,  from  medium  to  very  high.  The  seven  Member  States 
that  have  said  the  impact  was  low  or  very  low  are  either  Member  States  with  a  low 
eInvoicing  uptake  or  Member  States  which  made  eInvoicing  mandatory  before  the 
European eInvoicing standard was introduced, as explained below:  

•  No  or  very  low  eInvoicing  uptake  and  no  supplier  mandates,  as  Romania,  

Cyprus, Czechia, and Greece. 

•  High eInvoicing uptake and supplier mandates to issue B2G eInvoices and use of 
a  mandatory  national  standard,  as  in  Estonia  and  Italy.  As  the  uptake  was  high 
before the Directive, these Member States did not experience a significant impact 
of  it.  The  mandatory  use  of  the  respective  national  eInvoicing  standard  was 
introduced before EN 16931 became available. In Estonia, however, the strategy 
for  the  future  is  to  replace  the  national  standard  with  European  eInvoicing 
standard and use Peppol for cross-border trade. 

There were two indirect major developments in the Member States which were triggered 
either  by  the  existence  of  the  Directive  itself,  before  even  the  transposition  into  the 
national law or by the transposition process:  

•  First,  making  eInvoicing  mandatory  for  suppliers  in  B2G.  This  happened  in  17 
Member  States  either  with  a  full  mandate  in  13  Member  States  or  a  partial 
mandate in four Member States. 

•  Second,  extending  the  obligation  for  contracting  authorities  even  below  the  EU 

thresholds. It should be noted that nine Member States have done it. 

Interoperability 

Achieving  interoperability  at  the  semantic  and  syntax  level  was  a  key  objective  of  the 
Directive,  through  the  adoption  of  the  European  eInvoicing  standard.  Moreover, 
improved  interoperability  was  considered  as  the  primary  expected  impact  of  the  EU 
intervention in the Impact Assessment accompanying the proposal for the Directive (see 
Section 2). 

The  Directive  positively  addressed  interoperability  challenges  by  tackling  the  semantic 
and  syntax  levels  with  the  development  of  the  EU  eInvoicing  standard  (EN  16931). 
However, in order to achieve full interoperability as defined in the European Framework 
for  Interoperability,  other  levels  should  have  been  addressed,  such  as  the  transmission 
level and the governance level, which were not identified as big challenges at the time of 
the adoption of the Directive and, therefore, not covered by the EU initiative. Ultimately, 
the  Directive  improved  interoperability  but  not  to  the  extent  predicted  due  to  the 
emergence of transmission as a main challenge.  

30 

 
Interoperability  Framework, 

While  the  Directive  only  mandates  interoperability  at  the  semantic  and  syntax  level,  in 
practice,  the  market  has  seen  the  emergence  of  the  Peppol  network  for  exchange  of 
electronic invoices, which has achieved interoperability in all the layers that are part of 
the  European 
legal,  organisational, 
governance, and technical (format of business documents and secure transmission using 
eDelivery). Peppol has implemented the European standard in its technical specifications 
for  electronic  invoicing  (Peppol  BIS  Billing  3.0).  This  means  that,  if  the  Peppol 
specifications  are  implemented,  compliance  with  the  European  standard  is  ensured  by 
default.  In  addition,  as  Peppol  also  mandates  the  use  of  a  common  exchange  method 
across the network, interoperability at the transmission level is also ensured. 

including 

the 

The European Commission continued to support the development of Peppol through the 
maintenance  of  the  Service  Metadata  Locator  (SML)25,  which  is  the  only  centralised 
component  of  the  Peppol  Network.  Public  entities  in  Europe  have  used  Peppol26  as  a 
solution  to  comply  with  the  technical  requirements  of  the  Directive.  The  Peppol 
Interoperability Framework, with its legal agreements, policies, technical specifications, 
and governance model, has been recognised as a global reference point for the exchange 
of electronic business documents (such as eInvoices, eOrders, eDespatch advice, etc.). Its 
use is also expanding in specific industries, such as logistics. 

The following 12 Member States have established a Peppol Authority within the national 
government:  Belgium  (BOSA),  Denmark  (ERST),  Finland  (VK),  Germany  (KoSIT), 
Greece  (GSIS),  Ireland  (OGP),  Italy  (AGID),  Luxembourg (Ministry of  Digitalisation), 
Poland  (MriT),  Portugal  (eSPap),  Sweden  (Digg),  The  Netherlands  (NPA).  There  are 
Peppol  Authorities  in  Norway  and  Iceland  (EEA),  the  UK  (England  NHS),  Singapore, 
Australia, Malaysia, New Zealand and Japan. 

OpenPeppol  developed  a  specification  (Peppol  BIS  Billing  3.0)  to  provide  Peppol 
participants (buyers and sellers) with a common and documented approach to becoming 
compliant  with  the  European  standard.  This  specification  is  a  Core  Invoice  Usage 
Specification  (CIUS)  of  EN  16931  and  is  supported  by  several  Member  States  in  their 
national central eInvoicing infrastructure. Any eInvoice compliant with this specification 
is  compliant  with  the  European  Standard  (EN  16931).  The  purpose  of  the  CIUS  is  to 
clarify aspects that are undefined in the standard and to give usage guidance to business 
partners  in  order  to  begin  exchanging  eInvoices  without  prior  bilateral  agreements  on 
how to use the standard. Currently, all Peppol members, as soon as they become part of 
the network, need to support the Peppol CIUS for all transactions in the Peppol Network.  

the  Global  Interoperability 
Another  parallel  development 
Framework (GIF) - a set of recommended practices, policies, and standards to be used by 

interoperability 

in 

is 

25 The Service Metadata Locator (SML) is the key component that enables dynamic discovery of participants in message exchange 
networks. As a result, these networks can scale up without being affected by the management of an increasing number of participants. 
26 As of July 2023, 19 countries have established a Peppol Authority, there are 527 Peppol members present in 43 countries globally, 
and  780,440  organisations  are  uniquely  registered  to  receive  Peppol-based  business  documents.  Peppol  Authorities  are  typically 
government agencies, and are in place in 12 EU Member States 2 EEA countries and 5 countries outside the EU and EEA. Peppol 
Authorities  represent  the  Peppol  governance  framework  at  the  national  level,  thereby  ensuring  compliance  of  Peppol  participants, 
such  as  Service  Providers,  with  the  Peppol  rules  and  agreements,  including  certain  jurisdiction-specific  requirements  requested  by 
Peppol Authorities. 

31 

 
 
 
any interoperability network, under a collaborative environment27. The GIF’s approach is 
based on the European standard (four corner model of exchanging eInvoices) and builds 
upon  an  eDelivery  network28.  GIF  was  an  initiative  of  four  main  stakeholders:  GENA 
(the  European  Association  of  eInvoicing  Service  Providers),  BCP  (The  Business 
Payments Coalition), Connect ONCE and OpenPeppol.  

Since  its  formation,  GENA  established  the  Interoperability  Working  Group,  where 
volunteer  member  representatives  of  the  community  actively  participate.  The  working 
group  advises  and  guides  GENA  Members  on  the  adoption  and  implementation  of  the 
Multilateral Interoperability Agreement (MIFA) and the bilateral Model Interoperability 
Agreement (MIA), as well as addressing specific technical, compliance, and operational 
issues. 

On  2  February  2022,  OpenPeppol  and  GENA  announced  the  move  to  a  common 
interoperability  framework,  as  both  organisations  support  the  European  standard  on 
electronic  invoicing  and  eDelivery.  An  incubation  project  was  approved  by  both 
Associations in May 2023 and is currently running, with the objective of GENA bringing 
its interoperability activities onto the Peppol Network. In parallel, the two Associations 
have  been  running  since  September  2022  a  proof-of-concept  project  to  support  the 
eInvoicing mandate in France. 

eInvoicing adoption in general  

The increase  in eInvoicing uptake in  Europe was the expected secondary impact  of the 
Directive.  The  availability  of  a  European  standard  and  obligation  to  accept  compliant 
eInvoices was expected to significantly increase the uptake of eInvoicing, depending on 
business decisions. A “boule de neige” effect was expected to happen by inducing the EU 
suppliers in public procurement adopt the harmonised eInvoicing based on the European 
eInvoicing standard, even in the absence of an obligation, and, for them in turn, to induce 
their  own  suppliers  to  adopt  the  same  standard.  However,  the  findings  from  the 
evaluation showed that, even in B2G, 100% eInvoicing adoption is (or is to be) achieved 
only in the Member States that mandated B2G eInvoicing to their suppliers.  

The first graph below illustrates the overall adoption trends of eInvoicing at the EU level. 
National  trends  are  then  compared,  based  on  the  entry  into  force  of  an  obligation  for 
suppliers to issue B2G eInvoices, and a correlation is determined between the mandates 
and the adoption patterns. 

Eurostat  gathers  data  from  Member  States  on  the  percentage  of  enterprises  (with  more 
than 10 employees) that send eInvoices, suitable for automated processing. The data does 
not distinguish between B2G, B2B, nor B2C transactions.  

27 In 2019, an international group of associations and bodies with a common interest in interoperability for the exchange of supply 
chain digital transactions developed the Global Interoperability Framework [6] (GIF). The founders include OpenPeppol, the EU trade 
association for eInvoicing service providers (GENA), the Business Payments Coalition (BPC) from the US and Connect Once. 
28 Under the four-corner model, there are 4 corners underpinning the issue, exchange and receipt of e-invoices, namely: C1 – Sender 
of Invoice (C1 sends e-invoice to C2) C2 – Service Provider (C2 sends e-invoice to C3) C3 – Service Provider (C3 send e-invoice to 
C4). 

32 

 
 
 
Figure 5 Percentage of EU enterprises sending eInvoices (2011-2020) 

(Source: Eurostat) 

The  above  figure  shows  that  the  percentage  of  EU  enterprises  that  were  sending 
eInvoices  suitable  for  automated  processing  from  2011  to  2020  has  increased 
considerably,  moving from  8.2% in  2011 to  10.3% in  2013 (prior to  the publication of 
the  Directive),  and  32.2%  in  2020,  a  fourfold  increase.  In  2015,  B2G  eInvoicing  was 
mandated  in  certain  countries  and  B2B  eInvoicing  was  mandated  in  Italy.  In  2016,  the 
effect of the obligations showed up in the general uptake of eInvoicing. 

This  figure  includes  XML-based  formats  such  as  UBL,  UN/CEFACT,  also  national 
formats  and  non-XML  formats  such  as  UN/EDIFACT-based  eInvoices.  It  does  not 
include  PDFs  as  the  Eurostat  query  was  for  eInvoices  that  could  be  processed 
automatically. 

The  following  figure  shows  the  use  of  eInvoicing  among  EU  enterprises  in  Member 
States  that  introduced  an  obligation  to  suppliers  to  send  eInvoices  to  the  public  sector 
before the mandatory deadline for the transposition of the Directive in April 2019. 

33 

 
 
% of enterprises sending eInvoices, in a standard 
structure suitable for automatic processing, in MSs 
that mandated eInvoicing before April 2019

100

90

80

70

60

50

40

30

20

10

0

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

Austria

(2014)

Spain

(2015) 

(2005) 

(2017) 

Denmark

Italy

(2015) 

Slovenia

(2015) 

The Netherlands

France

(2014) 

Figure 6 Percentage of enterprises sending eInvoices, in a standard structure suitable for automatic 
processing in Member States that mandated eInvoicing before April 2019  

(Source: Eurostat) 

In  the  above  figure,  the  number  of  enterprises  in  Italy,  Slovenia,  and  Spain  using 
eInvoicing  significantly  increased  after  a  short  period  from  the  time  the  national 
obligations to send only eInvoices to the public sector entered into force.  

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 a European 
standard, the Directive has encouraged developments in B2B, where the EU standard is 
already used and its usage will be further extended by the ViDA legislation. 

Adoption of eInvoicing in B2G 

The annual invoice volume was estimated to reach 36 billion invoices in 2016;  50% of 
the  total  volume  were  B2G  and  B2B  invoices  (the  other  50%  relates  to  Business-to-
Consumer). Each year, 18 billion B2B and B2G invoices were sent within the EU29. The 
public sector is responsible for 14% of the GDP in all purchases in the EU30. Therefore, 
B2G volumes are estimated between 3.24  – 5.4 billion in Europe.It represents typically 
9-15% of a country’s inbound and outbound invoices.  

29 https://www.ecb.europa.eu/paym/intro/mip-online/2016/html/mip_qr_1_article_4_e-invoicing.en.html 
30 https://single-market-scoreboard.ec.europa.eu/business-framework-conditions/public-procurement_en 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
The following table represents the total number of B2G eInvoices received by central and 
sub-central  contracting  authorities,  from  national  and  foreign  suppliers,  in  Member 
States.  The  percentage  in  parenthesis,  in  certain  cases,  shows  the  percentage  of  B2G 
eInvoices  over  the  total  number  of  B2G  invoices  (not  electronic),  if  available.  The 
adoption percentage is high in Member States that have mandated suppliers to send B2G 
eInvoices. Conversely, it is typically lower in countries where suppliers are not mandated 
to send B2G eInvoices.  

Country 

2019 

2020 

2021 

2022 

Belgium 

550 000 

2 674 531 

6 

680 000 

5 292 282 

208 

1 100 000 

5 700 887 

119 

5 973 266 

50 000 (96%) 

370 000 (100%) 

4 548 697  

5 333 929 (91%) 

54 000 000 

68 000 000 

74 000 000 (75%) 

Croatia 

Cyprus 

Estonia 

Finland 

France 

Greece 

0 

48 000 

Ireland* 

48 000 

48 000 

Italy 

31 000 000 

31 000 000 

31 000 000 

Lithuania 

1 195 000 

1 121 000 

1 268 107 

Luxembourg 

Malta 

0 

0 

70 

0 

Netherlands 

1 176 044 (59%) 

1 290 275 (66%) 

1 646 106 (77%) 

Poland 

Portugal 

Romania 

3 356  

107 

97 000 

352 

263 829  

2 202 

0.10% 

3 000 

700 000 

0 

4 980 

Spain 

12 700 000 

12 800 000 

14 400 000 

15 900 000 

Slovenia 

432 894 

403 859 

437 572 

Sweden 

19 000 000 (60%) 

21 200 000 (70%) 

24 300 000 (80%) 

Table 7 B2G eInvoicing uptake in Member States 

Uptake of the European eInvoicing Standard  

Since  the  publication  of  EN  16931  in  October  2017,  new  national  standards  have  not 
been  imposed  for  eInvoicing  in  the  B2G  context.  This  represents  an  important 
achievement of the intervention as it has prevented the proliferation of national standards 
for B2G eInvoicing reducing technical complexity by establishing the use of a common 
semantic data model and only two syntaxes. This is also fully in line with the rules of the 
EU  standardisation  system  according  to  which  there  cannot  be  competing  national 
standards when a harmonised European standard is adopted. Nevertheless, there is a risk 
of  potential  fragmentation  in  B2B  eInvoicing  if  Member  States  mandate  national 
technical specifications in this context. 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Member States that had already introduced national standards prior to the publication of 
the  European  eInvoicing  standard  have  continued  using  them,  as  it  emerges  from  the 
eInvoicing  Country  Factsheets.  However,  Estonia,  Finland  and  Sweden  have  been 
gradually replacing their national standard with the European one. 

Finland, in particular, recognised the benefit of using the European eInvoicing Standard 
(EN), its structured data and code lists as the key factor for higher data accuracy in public 
procurement.  Previously,  that  was  done  through  RPA  (Robotic  Process  Automation), 
which  proved  to  be  unnecessary  with  the  advent  of  EN  compliant  eInvoicing  (see 
corresponding Case Study in Annex VI). 

The  following  table  indicates  the  percentage  of  B2G  eInvoices  received  by  contracting 
authorities that are compliant with the EN 16931, based on the information received from 
the Member States that responded to the survey comducted for the evaluation. Therefore, 
not  all  Member  States  are  included  in  the  analysis.  The  use  of  Peppol  is  a  general 
indicator of compliance with the European eInvoicing standard.  

2022 

Use of Peppol 

2019 

2020 

5% 

5% 

100%  

100% 

100% 

100% 

31% 

2021 

5% 

100% 

100% 

20% 

34.5% 

Austria 

Belgium 

Croatia 

Cyprus 

Czechia 

Denmark 

Estonia 

Finland 

France 

Germany 

* 

58% 

Greece 

0% 

0% 

0% 

100% 

Hungary 

Ireland 

Italy 

Latvia 

0% 

0% 

0% 

Lithuania 

0% 

2% 

Luxembourg 

100% 

100% 

Malta 

Netherlands 

100% 

100% 

Poland 

3% 

100% 

100% 

100% 

100% 

100% 

Portugal 

100% 

100% 

100% 

100% 

36 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
2019 

2020 

2021 

2022 

Use of Peppol 

Romania 

Slovenia 

Sweden 

40% 

50% 

60% 

No 

Yes 

Yes 

Table 8 Percentage of B2G eInvoices compliant with EN 16931 

*Belgium reported 1 420 000 eInvoices compliant with the European eInvoicing standard in 2022. 

According  to  the  EC  eInvoicing  country  factsheets31,  all  Member  States  declare  to 
support the use of the European standard at the national level for B2G eInvoicing. Some 
Member States developed a national CIUS to ensure compliance with EN 16931. Others 
developed extensions, i.e. technical specifications that include information that is not part 
of  the  European  standard.  For  instance,  the  Netherlands  developed  three  extensions  to 
EN 16931.  

23  Member  States  have  implemented  the  Peppol  BIS  Billing  3.0  to  ensure  compliance 
with the European standard, making it, by default, the most common specification used 
in  the  European  Union  for  ensuring  cross-border  interoperability  (at  the  semantic  and 
syntax level).  

4.1.1.2. Specific objectives 

Reduce technical complexity and improve legal clarity for economic operators 

The  Directive  and  the  introduction  of  the  European  standard  aimed  at  reducing  the 
proliferation of national  formats for B2G eInvoicing (see General  Objective:  Uptake of 
the  European  Standard  for  eInvoicing  section)  that  was  creating  cross-border  market 
barriers, unnecessary complexity and costs. At the same time, it provided a coherent legal 
framework to foster interoperability at the technical level, which signalled a clear policy 
direction towards the need of harmonising legal and technical frameworks. 

Article  2  of  the  Directive  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,  and 
consistency with the relevant provisions of Directive 2006/112/EC32. 

The Directive increased legal certainty and reduced technical complexity for eInvoicing 
by  establishing  a  clear  legal  basis  and  setting  the  European  eInvoicing  standard  as  the 
common standard to be supported by the EU public sector. Evidence of this is that 14 out 
of the 23 Member States surveyed, reported that the intervention had a positive impact on 

31 EC eInvoicing country factsheets for the following Member State have not been verified by national authorities: Bulgaria, Czechia, 
Germany, Greece, Hungary, Lithuania, Malta, Portugal, Romania, Slovakia, Spain. 
32 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, OJ L 347, 11.12.2006, Brussels. 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
increasing  legal  certainty  and  reducing  technical  complexity.  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. 

Two-thirds  of  the  private  sector,  particularly  SMEs,  view  the  European  eInvoicing 
standard as  a means  of significantly simplifying intra-EU trade. This  has been reported 
by 66% of surveyed SMEs and by all large enterprises surveyed (7 out of 7).  

However,  41%  of  surveyed  SMEs  still  experience  technical  challenges  when  using 
eInvoicing,  including  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 eInvoicing standard but did not mandate 
its use by suppliers. As a result, enterprises must support multiple eInvoicing formats in 
Member States where a national standard is mandated for B2G transactions while using 
other  formats  for  B2B  transactions.  The  public  sector  essentially  acts  as  a  large  buyer 
imposing also its requirements on suppliers. 

European  bussinesses,  especially  large  enterprises  implement  legal  requirements 
regarding  eInvoicing  in  several  countries.  The  clarity  of  these  requirements,  as  well  as 
consideration  of  practical  issues,  differed  strongly  between  the  countries  based  on  the 
findings of the survey targeting national  authorities. Because of national  and individual 
requirements regarding eInvoicing in the different EU Member States, it is necessary to 
the 
have 
implementation of an EU common standard. 

local  specialists  and  service  providers.  This 

is  costly  compared 

to 

The seven large enterprises surveyed also believe that a common EU standard  used for 
B2G and B2B transactions would be beneficial only if every Member State uses the same 
standard without exceptions. For cross-border B2B eInvoicing, the same data set must be 
defined without exceptions. 

According  to  the  Global  Exchange  Network  Association  (GENA),  the  Directive  is  the 
first  important  step towards eInvoicing  standardisation. The minimal standard approach 
enables Member States to continue accepting other formats while setting a baseline that 
removes the costs for suppliers that wish to adopt a single standard. According to GENA, 
notwithstanding  the  value  of  a  minimum  standard  that  the  suppliers  can  adopt  across 
Member States for B2G eInvoicing, the Directive could not lead to a significant increase 
of  eInvoicing  volumes,  in  either  of  the  European  eInvoicing  standard  syntaxes,  in 
practice due to the lack of mandate. This result is also related to the lack of adoption of 
incentives  for  suppliers  where  a  B2G  eInvoicing  method  was  implemented  prior  to  the 
availability of the European eInvoicing standard in October 2017.  

Lower operating costs for economic operators 

For  the  specific  objective  of  lowering  operating  costs  for  economic  operators,  the  EU 
intervention has not been particularly successful.  Operating costs  are closely dependent 
on the number of eInvoices exchanged by businesses and the availability of cost-effective 
solutions  and  services.  The  lack  of  data  does  not  allow  to  estimate  whether  operating 
costs have increased or decreased after the Directive’s implementation.  

38 

 
Operating  costs  for  economic  operators  are  influenced  by  the  number  of  eInvoicing 
transactions,  formats  supported,  transmission  protocols,  and  number  of  countries  in 
which the businesses operate as specialised support is required in each Member State that 
has  mandated  specific  formats  and  requirements.  This  will  be  further  detailed  with 
quantitative elements in the Efficiency section below.  

For  SMEs,  the  availability  of  eInvoicing  functionalities  within  ERP  systems  and 
accounting  software  is  considered  the  most  crucial  factor  in  facilitating  adoption.  It 
would  result  in  a  new  capability  of  IT  systems  that  they  already  use,  thus  significantly 
lowering costs, as mapping and other integration costs will be eliminated. However, ERP 
vendors would support a standard only when there is sufficient demand for it and when 
mandated by the government. 

The  business  case  for  eInvoicing  is  closely  dependent  on  the  number  of  eInvoices 
exchanged by businesses. According to the Swedish Companies Registration Office33, a 
minimum number of five eInvoices per month makes eInvoicing financially viable.  

4.1.1.3. Operational Objective 

Create  the  conditions  for  the  emergence  of  technical  solutions  ensuring  cross-border 
interoperability for eInvoicing in public procurement 

Following  the  Directive,  this  objective  was  achieved  to  a  significant  extent  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 interoperability.  

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) has to be considered. This is 
the  case  in  Spain  and  Poland  (although,  according  to  current  information,  Poland  will 
gradually  phase  out  the  B2G  platform  that  is  ensuring  compliance  with  the  European 
standard).  Monitoring  technical  developments  and  adoption  at  the  EU  level  also  poses 
challenges due to varying common procedures and requirements and the absence of  an 
obligation on Member States to monitor and report. 

Secondly, with the creation of the European eInvoicing standard,  the conditions for the 
emergence  of  technical  solutions  have  been  created  as  the  Directive  facilitated  the 
expansion of the Peppol network as a solution for ensuring compliance with EN 16931 
through  the  use  of  common  specifications,  a  common  transmission  method,  legal 
agreements,  and  a  governance  model.  From  the  result  of  the  Member  States  survey,  it 
emerged  that  the  number  of  Peppol-based  eInvoices  is  increasing  in  Belgium,  Finland, 
France, the Netherlands, Slovenia, and Sweden. This result was achieved through several 
contributing  factors,  including  the  original  EU  funding  for  the  Peppol  large-scale  pilot 

33 EC eInvoicing webinar with Swedish stakeholders, 15th June 2023 

39 

 
 
 
project. The willingness of governments to sustain its results since 2012 and implement 
its interoperability framework at the national level also played a role, as it emerged from 
consultations with  OpenPeppol.  Service providers  have developed access points for the 
public sector and private companies.  

The Peppol Interoperability Framework has been adopted in several countries outside of 
the EU, including Australia, Japan, Malaysia, New Zealand, and Singapore. In the U.S., 
the  reuse  of  Peppol  with  minor  variants  has  been  successfully  piloted  in  the  private 
sector.  

Some Member States have imposed the use of eSignatures to guarantee the authenticity 
and  integrity  of  eInvoices,  and  this  constitutes  a  barrier  to  cross-border  eInvoicing.  As 
proven by systems that do not use this method of authentication, in practice this is not at 
all necessary. 

4.1.2.  Efficiency 

This  section  analyses  the  costs  and  benefits  for  public  authorities  and  the  different 
identified categories of economic operators. There are important variations of costs and 
benefits among stakeholders.  

4.1.2.1. Costs and benefits for public authorities   

This section discusses the costs and benefits borne by public authorities to implement the 
national  mandate  to  receive  and  process  eInvoices  compliant  with  the  European 
eInvoicing standard.  

For public authorities, the costs of implementing eInvoicing are largely dependent on the 
level of IT maturity of the public sector. The following categories of transposition costs 
were identified: 

•  one-off investment costs to set up or update a central platform for B2G; 
• 
•  adaptation cost of the existing national B2G eInvoicing format.  

implementation costs related to the standard (included in Table 9 below); 

The  implementation  of  eInvoicing  for  the  Member  States  that  decided  to  use  a  central 
platform for B2G, implied an initial investment cost for either setting up a new platform 
or  updating  an  existing  one.  This  is  confirmed  by  the  results  of  the  survey  targetting 
Member States.  

The costs specifically linked to the implementation of the European eInvoicing standard 
vary  depending  on  the  existence  of  a  national  standard  and  the  requirement  to  ensure 
interoperability  with  the  European  eInvoicing  standard.  However,  the  highest  costs  are 
related to the establishment and maintenance of the national eInvoicing infrastructure, as 
explained below and detailed in Table 9.  

National authorities in 15 out of the 23 surveyed Member States incurred costs related to 
the transposition of the Directive. These costs include the expenses due to the compliance 
with the European eInvoicing standard. Seven Member States declared they did not incur 
costs (Cyprus, Check Republic, Denmark, France, Finland, Greece and Romania). 

40 

 
 
 
The following Member States provided estimates of direct compliance costs:  

•  Poland is the Member State that incurred the highest  costs, with a total  of EUR 
6.1 million,  of which EUR 5 million  have been funded through the Operational 
Program Digital Poland that was used for the establishment of the national B2G 
eInvoicing platform.  

• 

Ireland has incurred total costs of EUR 1 144 863. 

•  Lithuania has incurred total costs of EUR 260 520. 

•  Luxembourg has incurred total costs of EUR 145 000. 

•  Malta has incurred costs of EUR 34 750.  

Table 9 provides detailed information on the compliance and implementation costs borne 
by national authorities, which answered the Member States survey.  

Compliance costs include the costs Member States incurred  for the transposition of the 
Directive  and  the  implementation  of  the  European  standard  in  national  eInvoicing 
systems,  which  can  be  one-off  costs,  as  for  the  setting  up  of  the  platform  or  its  initial 
adaption, or maintenance costs to ensure it remains functional, efficient, and safe.  

The costs of implementation for the public authorities are of different nature and consist 
of: 

•  Adjustment  costs,  which  include  the  following:  software,  hardware,  training, 

change management, test environment, and service providers’ fees. 

•  Administrative  costs,  which  include  legal  and  solution  analysis,  publicity,  user 

guides, support, security audit, and Peppol membership fee. 

Member State 

Category 

Cost breakdown 

Croatia 

Cyprus 

Germany 

Greece 

Software 

hardware 

/ 

The cost for the maintenance of National Central Platform cannot be disclosed. 

Training costs 

No fees charged for 150 educational workshops. 

Software 

hardware 

Software 

hardware 

/ 

These costs have not yet materialised as there is no mandatory eInvoicing 

Costs for all categories have arisen but have not been determined. 

/ 

Adapting  software  especially  for  SMEs  and  contracting  authorities.  Complementary 

actions for that are being implemented. 

Training costs 

Costs mainly for contracting authorities.  

Test environment 

It has been centrally implemented.  

Service 

providers 

Only for the economic operators for using eInvoicing service providers 

fees 

Hungary 

Italy 

No information provided 

No information provided 

41 

 
 
 
 
 
 
 
 
Ireland 

Lithuania 

Software 

hardware 

Change 

management* 

Software 

hardware 

/ 

EUR 894 863 

EUR 250 000 

/ 

EUR 68 500 

Training costs: 

EUR 0 

Change 

management 

EUR 16 720 

Test environment 

EUR 38 000 

Service 

providers 

EUR 7 500 

fees 

Other 

EUR  129  800  for  legal  and  solution  analysis,  publicity,  user  guides,  support,  security 

Luxembourg 

Training costs 

EUR 10 000 

Service 

providers 

EUR 100 000 

audit, etc. 

Malta 

Poland 

fees 

Other 

Total 

Technical implementation costs: ~ EUR 35 000 

EUR 34 750 

Service 

providers 

Cost per eInvoice received will be charged according to pre-established volumes/bands. 

fees 

Software 

hardware 

/ 

EUR 5 000 000 

(for the establishment of national B2G eInvoicing platform) 

Test Environment 

Included in software category. 

Service 

Provider 

Included in software category. 

fees 

Training costs 

EUR 100 000 

Change 

management 

EUR 1 000 000 

Slovenia 

Other 

Public  Payments  Administration  of  the  Republic  of  Slovenia  pays  an  annual 

Sweden 

Software 

hardware 

membership fee for Peppol 

/ 

Relevant cost incurred but values not available. 

Test Environment 

Relevant cost incurred but values not available. 

Service 

Provider 

Relevant cost incurred but values not available. 

fees 

* Change management costs due to the usage/implementation of new methods or processes with software/hardware 

Table 9 Costs incurred for the transposition of the Directive and the implementation of the EN 16931  

(Source: Member State survey) 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Was there a cost associated with ensuring the national format complied with EN 16931? 

Member States with an existing national B2G eInvoicing format had to adapt it or replace 
it with the EN 16931. The following figure shows which Member States experienced the 
related adjustment costs (Yes) and those who did not (No). 

Was there a cost burden associated with ensuring the 
national format complied with EN 16931?

Yes
44%

Did not reply
28%

LU, CY, RO, FR, 
GR, CZ, SI

HR, IT, AT, DK, 
LT, FI, SE, PL, EE

IE, BE, NL, DE, 
PT, LV, MT

No
28%

Figure 7 Cost burden to ensure compliance with EN 16931 in Member States 

(Source: Member State survey) 

Out  of  16  Member  States  that  provided  an  answer  to  the  survey,  nine  Member  States 
reported that they experience a cost burden related to ensuring their national format was 
European  eInvoicing  standard  compliant;  and  seven  Member  States  answered  that  they 
did not experience a cost burden. 

The  following  nine  Member  States  sustained  costs  for  ensuring  alignment  with  the  EN 
16931, as detailed below: 

• 

• 

• 

In  Finland,  the  conversion  of  the  national  eInvoicing  standard  costed  EUR  250 
000 to the national authorities. They consider that the benefits outweigh the costs. 

In Italy, two CEF eInvoicing funded projects were implemented for the alignment 
of the national standard to the EN 16931: eIGOR with funding of EUR 1 152 500 
and EeISI with funding of EUR 1 136 942. 

In Poland, approximately EUR 1.5 million were spent to ensure that the national 
format  was  compliant  with  the  EN  16931.  It  was  necessary  to  implement  an 
extension  to  the  EU  norm,  which  enabled  the  inclusion  of  representatives  of 
specific  sectors  of  mass  services  (such  as  energy  or  gas)  in  the  eInvoicing 
process.  Benefits  are  expected  to  be  achieved  in  the  coming  years,  as  the 
extension was implemented in mid-2022 (see Country Profiles in Annex for more 
information). 

43 

 
 
•  Slovenia incurred costs that were funded via the EU projects ROSE and ROSE 2 
(see  Country  Profile  for  more  information),  for  a  total  of  EUR  88  407  for  the 
Public Payment Administration (PPA).  

• 

In  Sweden,  the  upgrade  of  the  national  format  to  the  EN  16931  resulted  in 
conversion  costs,  but  the  Swedish  authorities  perceive  that  the  benefits  still 
outweigh the costs. There have been conversion costs for parties unable to handle 
the EN16931 from the start, but these costs are expected to vanish over time, and 
the benefits still outweigh the costs (see Country Profiles).  

For the seven Member States, which declared that they bore no costs for the alignment to 
the  European  eInvoicing  standard,  the  two  following  cases  are  relevant  because  they 
represent two typical scenarios: 

•  France,  which  went  beyond  the  minimal  obligation  of  the  Directive  relying  on 
public  authorities  (in  their  national  eInvoicing  policy)  and  mandated  eInvoicing 
for all suppliers in public procurement, declared it incurred no cost to ensure that 
the national format complied with the EN. Similarly, it did not incur costs for the 
transposition  of  the  Directive.  Indeed,  France  did  not  seek  funds  to  ensure 
compliance.  France  stated  that,  as  a  measure  to  increase  the  efficiency  of  the 
initiative, the EN 16931 should be updated to consider some data required in B2B 
transactions or by the tax authorities. 

•  Greece declared they did not incur costs related to ensuring compliance with the 
EN 16931 (neither related to the transposition of the Directive), because the main 
costs are related to the establishment of the national eInvoicing infrastructure. 

Overall, according to the findings of the consultation activities, the benefits outweighed 
the  costs  for  public  authorities.  Five  Member  States  provided  estimates  of  the  costs  to 
ensure  compliance  of  the  national  formats  to  the  EN.  With  the  exception  of  Poland, 
where  the  eInvoicing  uptake  is  still  very  low,  the  benefits  outweighed  the  costs.  The 
benefits  include  operational  efficiencies,  improved  transparency,  and  environmental 
benefits.  Process  automation  is  perceived  as  the  main  driver,  followed  by  the  use  of  a 
common standard, faster processing, and less complexity. 

A high level of legal certainty was introduced by the Directive and significant technical 
simplification was provided through the use of a common European eInvoicing standard, 
leading to a considerable cost reduction. 

CEF funding 

The  Connecting  Europe  Facility  (CEF)  Telecom  eInvoicing  calls,  between  2015-2019, 
funded  and  supported  the  uptake  of  eInvoicing  and  the  implementation  of  EN  16931. 
CEF Telecom eInvoicing funding supported consortia of private and public stakeholders 
to  implement  the  final  version  of  the  EU  eInvoicing  standard,  or  to  update  existing 
solutions.  

Most  of  the  EU  Member  States  received  funding  under  the  CEF  eInvoicing  calls  from 
2015 to 2019, which greatly facilitated and enabled the implementation of the EN 16931. 
In  total,  24  Member  States  received  EU  funds  under  the  CEF  Telecom  programme  to 
develop eInvoicing solutions.  

44 

 
49  projects  in  27  countries  (24  Member  States,  Norway,  Iceland,  and  the  United 
Kingdom)  were  implemented  under  the  CEF  Telecom  eInvoicing  calls.  A  total  of 
approximately EUR 28.6 million of CEF Telecom funding was allocated. 

The following table shows the CEF funding received by Member States. Spain, Italy, and 
Ireland  received  the  highest  amounts  of  funding,  while  Bulgaria,  Czechia,  and 
Luxembourg did not receive any. 

CEF funding (€ thousand)

7
1
,
9
0
6
5 3
0
,
2
5
2
3

1
0
,
0
5
9
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9
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8
,
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1

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7

8
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4
4
5

5
0
,
5
6
2

9
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3
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2

4
9
,
4
4
6

8
4
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5
0
2

1
0
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4
1
4

3
2
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3
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1

0

0

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1
9
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3
2
2
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2
3
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5
1
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7
6
,
7
0
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4
9
,
7
8
3

3
0
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8
1
1

8
7
,
6
1

4000

3500

3000

2500

2000

1500

1000

500

0

9
2
,
3
8
9

2
2
,
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2

T
A

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B

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L

T
M

L
P

T
P

O
R

I

K S
S

S
E

E
S

L
N

Figure 8 CEF Telecom eInvoicing funds received in Member States 

(Source: European Commission, INEA) 

The  CEF  eInvoicing  Building  Block  includes  services  such  as  conformance  testing  for 
implementers  to  ensure  the  correct  implementation  of  syntaxes,  maintenance  of  code 
lists,  interaction  with  the  stakeholder  community,  as  well  as  onsite  and  online  training 
courses  to  build  the  capacity  of  public  administrations  in  adopting  the  European 
eInvoicing standard and facilitate interoperability among contracting parties in Europe.  

4.1.2.2. Costs and benefits for economic operators 

The EU intervention has not been particularly successful in lowering operating costs for 
economic operators. However, market dynamics depend on different factors, such as the 
cost  of  labour  per  hour,  the  IT  maturity  of  the  society  and  the  level  of  eInvoicing 
adoption. In addition, pricing models vary significantly depending on specific eInvoicing 

45 

 
 
features  and  are  not  always  transparent,  creating  confusion  for  businesses,  in  particular 
SMEs, when selecting eInvoicing services and solutions (see Annex IV on Cost-Benefit 
Analysis).  

One  of  the  main  impacts  of  the  Directive  is  the  automation  of  eInvoicing.  From  the 
findings  of  the  Study  on  the  Evolution  of  eInvoicing  conducted  for  the  European 
Commission in 202334 (see Annex IV), across all categories of stakeholders, the general 
quantitative benefits from automating the invoicing process are estimated at around EUR 
5.28 to EUR 8.4 per eInvoice received (and processed), considering the cost of labour per 
hour at EUR 46. The same study indicates that eInvoicing can result in  cost savings of 
61–72%, compared to conventional paper invoice processing. 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 cycle. 

As  aforementioned,  costs  vary  among  and  within  each  stakeholder  category  based  on 
several  external  and  internal  factors.  The  results  of  the  SME  survey  show  that  costs 
mainly  vary depending  on the eInvoice service  package they select  and  the volumes of 
eInvoices  handled.  In  general,  enterprises  with  higher  eInvoicing  volumes  yield  more 
benefits, proportionally to the number of eInvoices they exchange. Furthermore, costs for 
SMEs may vary depending on whether the SME uses a service provider or an accountant 
It is important to consider that free-of-charge eInvoicing services  are made available to 
SMEs by some governments, but this did not constitute a major factor for adoption due to 
lack of user-friendly features and services. Overall, there are considerable differences in 
costs  borne  per  SME.  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)35. 

In  regards  to  the  benefits  perceived  by  SMEs,  in  addition  to  savings  per  eInvoice,  the 
main eInvoicing benefits are easier B2G invoicing, followed by improved efficiency, and 
easier invoicing to large enterprises. Enhanced security and sustainability are ranked as 
second-tier  benefits,  followed  by  improved  accuracy  and  data  quality.  Increased 
interoperability and reduction in operating costs are considered as moderately important 
benefits.  

The results of the survey for large corporates show that for one of them (out of seven), 
the set-up costs for establishing eInvoicing in different EU Member States are significant 
(EUR  180  000  per  country)  and  require  the  use  of  different  service  providers  to  cover 
specific  national  requirements.  Recurring  costs  vary  significantly  across  the  large 
corporates surveyed, depending, for instance, on the use of internal or external resources 
for eInvoicing. In regards to the benefits for large corporates, in addition to savings per 
eInvoice,  improved  interoperability  in  supply  chains,  easier  invoicing  public  bodies, 

34  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 
35 https://www.corrierecomunicazioni.it/digital-economy/polimi-da-fattura-elettronica-risparmi-per-3-miliardi/ 

46 

 
 
 
increased  accuracy,  improved  data  quality,  and  enhanced  security  are  considered  the 
most relevant benefits associated with eInvoicing. 

On one hand, in general, companies (of all sizes) have to acquire eInvoicing services or 
software,  and  the  prices  for  the  eInvoicing  services  are  still  relatively  high.  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,  and the number of countries in  which the businesses 
operate, as specialised support is required in each Member State that has defined specific 
formats and requirements. For SMEs, the availability of eInvoicing functionalities within 
ERP systems and accounting software is considered the most crucial factor in facilitating 
adoption.  

On the other hand, according to the SMEs survey, even when they acquire the respective 
software/service, a company will fully reap the benefits of its investment when it is able 
to use electronic invoicing with all its business partners, which is far from being the case. 
On  top  of  this,  all  companies  would  maximise  their  benefits  when  they  are  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 (see Annex IV). 

Mass  adoption  of  eInvoicing  would  both  allow  the  lowering  of  fees  for  eInvoicing 
services  and  maximise  the  benefits  from  using  eInvoicing  by  default  and  for  further 
applications. 

Lastly, for service providers, while no precise data was provided, the evidence gathered 
shows  that  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. In addition, based on the findings of the 
Country Profiles,  service providers are perceived as the stakeholders who benefited the 
most from eInvoicing. 

4.1.3.  Coherence 

4.1.3.1. Internal coherence 

The internal coherence of the eInvoicing Directive refers to how the various components 
of  the  intervention  worked  together  effectively.  These  components  include:  (i)  the 
development  and  mandatory  support  of  the  European  eInvoicing  standard  by  EU 
contracting  authorities,  and  (ii)  the  establishment  of  the  European  Multi-Stakeholder 
Forum on eInvoicing (EMSFEI). 

At  the  legislative  level,  the  EU's  provisions  for  the  mandatory  use  of  the  European 
eInvoicing standard, published in October 2017 in the Official Journal of the EU (OJEU), 
align  seamlessly  with  the  requirements  specified  in  the  Directive.  The  Directive  called 
for the creation of a European standard for the semantic data model of core elements in 
an eInvoice and identified a limited number of syntaxes complying with this standard for 
interoperability.  Additionally,  non-binding  guidelines  for  eInvoicing  transmission  were 
stipulated  to  ensure  further  interoperability.  These  requirements  have  been  successfully 

47 

 
reflected in the deliverables of the CEN Technical Committee, confirming the coherence 
between legislative objectives and the development of the European eInvoicing standard. 

Furthermore,  the  development  of  the  European  eInvoicing  standard  is  aligned  with  the 
recommendations  of  the  European  Multi-Stakeholder  Forum  on  Electronic  Invoicing 
(EMSFEI). The EMSFEI's deliverables, including the endorsement of the 'Core  Invoice 
Usage  Specifications’,  complement  and  support  the  implementation  of  the  European 
standard, addressing potential interoperability challenges effectively. 

In  conclusion,  the  internal  coherence  of  the  eInvoicing  Directive  is  evident  in  how  its 
components  complement  each  other.  The  alignment  between  the  provisions  of  the 
Directive,  the  European  eInvoicing  standard,  and  the  EMSFEI  recommendations  has 
contributed  to  the  successful  implementation  and  advancement  of  eInvoicing  adoption 
within the EU. 

4.1.3.2. External coherence 

External coherence refers to how well the eInvoicing Directive aligns with other EU and 
national  interventions  that  share  similar  objectives,  including  the  promotion  of  the 
digitisation of public procurement and related 2014 Public Procurement Directives36, the 
VAT  in  the  Digital  Age  (ViDA)  proposal37,  and  the  new  proposal  for  a  regulation38 
repealing the current Late Payment Directive 39.  

This evaluation of the external coherence of the Directive focuses on several key areas of 
alignment with other policies, as shown in the Figure below. Each intervention category 
is  scored  from  1-5,  with  1  indicating  coherence  at  a  very  low  extent  and  5  indicating 
coherence at a very high extent. 

As Figure 9 shows, Member States assess that the eInvoicing Directive aligns coherently 
with  initiatives  aimed  at  fostering  the  Internal  Market,  reducing  technical  complexity, 
improving legal certainty, and lowering operating costs for Economic Operators (EOs).  

36  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, 
Brussels. 
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, Brussels. 
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, Brussels. 
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, Brussels. 
37 COM/2022/701 final, Proposal for a COUNCIL DIRECTIVE amending Directive 2006/112/EC as regards VAT rules for the digital 
age, Brussels, 8.12.2022. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52023PC0533(01)  
38  COM  (2023)  533  final,  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) 
39 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, Brussels. 

48 

 
 
 
35

30

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1=very low extent 5=very high extent

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AT BE HR CY CZ DK EE FI FR DE GR IE IT LV LT LU MT PL PT RO SI SE NL

Digitalisation of public procurement

Promoting European standards

Improving interoperability

Fostering the internal market

Reducing technical complexity

Improving legal certainty

Lowering operating costs for Eos

Figure  9  Member  States’  perception  of  the  extent  the  initiative  is  consistent  with  other  EU  and 
national interventions 

(Source: Member State survey) 

Digitisation of Public Procurement 

The eInvoicing Directive is perceived to be coherent with EU and national interventions 
related  to  the  digitisation  of  public  procurement.  For  instance,  the  2014  Public 
tools  and  devices  for 
Procurement  Directives  mandate 
communication 
the  eInvoicing 
in  procurement  procedures,  which  complements 
Directive's objective of establishing electronic invoicing as a standard practice in public 
procurement. Member States generally acknowledge this alignment, with some variations 
in their perceptions, according to the findings of the survey targeting national authorities.  

the  use  of  electronic 

Promoting European Standards 

There  is  a  high  level  of  coherence  between  the  eInvoicing  Directive  and  initiatives 
promoting European standards. Most Member States see strong alignment in this regard. 
For  example,  the  EU's  provision  of  funds  through  the  CEF  programme  from  2015  to 
2019 has played a crucial role in advancing eInvoicing adoption and the implementation 
of the European standard. The CEF Telecom eInvoicing calls funded and facilitated the 
uptake  of  eInvoicing,  supporting  the  implementation  of  compliant  solutions  for  B2G 
transactions in 24 Member States.  

The  Digital  Building  Block  funded  under  CEF  –  eInvoicing  Building  Block  and 
eDelivery  Building  Block  –  supported  the  implementation  of  the  Directive.  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 

49 

 
 
eInvoices, as well as other secure digital data exchanges. Some eInvoicing solutions used 
eDelivery as a transmission method.  

In  addition,  EU  structural  funds  were  utilised  for  similar  purposes  to  the  one  provided 
under CEF, with countries like Poland leveraging these funds for eInvoicing initiatives. 

Improving Interoperability 

The eInvoicing Directive effectively addresses interoperability at both the semantic and 
legal layers. The European eInvoicing standard, consisting of EN 16931-1 and TS 16931-
2,  specifies  the  semantic  data  model  and  mandatory  syntaxes,  ensuring  seamless 
exchange  of  eInvoices  across  different  systems.  This  aligns  well  with  the  European 
Interoperability Framework (EIF), as shown by the conceptual model below.  

Figure 10 EIF Conceptual Model 

However,  as  mentioned  multiple  times,  it  has  not  addressed  all  EIF  four  layers  of 
interoperability,  including  transmission  (technical  interoperability)  and  governance 
(organisational interoperability), which would have further facilitated interoperability. 

VAT in the Digital Age (ViDA) Proposals 

The  ViDA  legislative  proposals  complement  the  eInvoicing  Directive,  especially  in 
ensuring harmonisation and interoperability in cross-border eInvoicing for B2G and B2B 
transactions. While the Directive limited the mandate to the public sector, ViDA extends 
the use of eInvoicing to both senders and receivers of eInvoices in intra-Community B2B 
transactions. This  alignment streamlines VAT reporting, reduces  administrative burden, 
and  fosters  convergence  towards  the  European  eInvoicing  standard.  Several  articles  in 
the ViDA proposals directly align with the provisions of the Directive: 

•  Article  217  defines  'electronic  invoice'  consistently  with  the  definition  of  the 
Directive,  clarifying  that  invoices  containing  unstructured  data  cannot  be 
considered as electronic invoices. 

•  Article  218  establishes  electronic  invoicing  as  the  default  system  for  issuing 
invoices, while the deletion of Article 232 removes the need for acceptance of the 

50 

 
 
eInvoice  recipient.  Taxable  persons  can  issue  eInvoices  compliant  with  the 
European  standard  and  its  syntaxes,  as  set  out  in  the  Directive.  The  mandatory 
authorisation or verification by tax authorities, known as the 'clearance model’, is 
also eliminated, ensuring a smoother process for eInvoicing. 

•  Articles 262 to 264 provide for the submission of information for each transaction 
and the adoption of implementing rules to define a common electronic message, 
which establishes a common subset of the European eInvoicing standard referred 
to as a digital VAT report. 

•  The  deletion  of  Article  266  enables  full  harmonisation  of  data  requirements 
across the EU by eliminating Member States' ability to request additional data on 
intra-Community transactions. This standardisation ensures that taxpayers submit 
the same information, regardless of the Member State where the transaction takes 
place, which is crucial for developing the subset of the EU standard. 

•  Articles 271a to 273 aim to reduce the administrative burden on taxable persons 
operating  in  different  Member  States  by  aligning  the  reporting  systems  for 
domestic  transactions  with  the  digital  reporting  system  designed  for  intra-
Community  transactions.  This  alignment  should  be  completed  by  2028  at  the 
latest. 

Additionally,  ViDA  requires  the  transmission  of  data  in  compliance  with  the  EU 
eInvoicing standard, while Member States have the flexibility to allow other formats as 
long  as  they  ensure  interoperability  with  the  European  standard  for  intra-Community 
transactions. This provision aims to promote interoperability at the semantic and syntax 
levels,  making  it  easier  for  taxable  persons  to  submit  data  according  to  the  European 
standard for digital VAT reporting. 

However, the coherence between the two EU initiatives might evolve due to changes in 
the text of ViDA in the frame of the ongoing Council negotiations.  

The implementation of the Directive is coherent  with the provisions of the current Late 
Payment  Directive40  and  with  the  2023  proposal  for  a  Regulation  repealing  the  current 
Late  Payment  Directive41,  as  it  automates  the  approval  process  for  eInvoices, 
streamlining payment procedures and ensuring timely payments. The 2023 proposal for a 
Regulation  on  combating  late  payment  in  commercial  transactions  stresses  that  it  is 
important to promote systems that give legal certainty as regards the exact date of receipt 
of  invoices  by  the  debtors,  including  in  the  field  of  eInvoicing  where  the  receipt  of 
invoices could generate electronic evidence.  

In  addition,  the  current  activities  carried  out  by  the  European  Commission  with  its 
international partners are coherent with the Directive, both in the formal negotiations and 
during  bilateral  dialogues.  Currently,  non-EU  countries,  such  as  Australia,  Japan, 

40 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, Brussels. 
41  COM  (2023)  533  final,  Proposal  for  a  regulation  of  the  European  Parliament  and  of  the  Council  on  combating  late  payment  in 
commercial transactions, Strasbourg, 12.9.2023. 

51 

 
 
 
Malaysia,  New  Zealand,  and  Singapore42,  have  based  their  national  eInvoicing 
specifications  on  the  European  standard  as  extensions  and  are  actively  interested  in 
Peppol  International  (PINT)  Invoice  Model,  operational  since  July  2023,  which 
generalises  the  European  standard  in  a  systematic  way,  facilitating  interoperable 
exchange  of  invoices  across  the  Peppol  Network  internationally.  Other  countries  and 
regions have used the European model 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  to  comply 
with  the  European  standard  and  minimise  trade  costs  by  fostering  eInvoicing 
interoperability across regions. 

Overall,  the  eInvoicing  Directive  demonstrates  a  high  level  of  coherence  with  other 
relevant interventions.  

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

The  EU's  intervention  in  eInvoicing  for  public  procurement  was  justified  based  on  the 
need  for  interoperability  and  to  prevent  fragmentation  within  the  Internal  Market.  The 
2013 Impact Assessment highlighted that actions taken by individual Member States had 
exacerbated  interoperability  challenges,  resulting  in  the  emergence  of  various  national 
eInvoicing  standards.  To  address  this  issue  and  promote  a  cohesive  approach,  the  EU's 
involvement was deemed beneficial. 

The survey targetting Member States indicates   varied assessment on the importance of 
EU-wide interoperability at the semantic and syntax levels. Out of 21 replies, 12 Member 
States believe that achieving these objectives individually would have been impractical, 
and they acknowledge the necessity of the EU's intervention as it can be seen in Figure 
11.43 

No response

2

No

Partially

Yes

0

4

5

5

12

10

15

20

Figure 11 No. of Member States that believe the objectives of the Directive could not be achieved by 
Member States acting alone 

(Source: Member State survey) 

The Directive's implementation has yielded positive outcomes in several Member States, 
in the public and private sector. The EU's intervention has improved the functioning of 
the  Internal  Market  through  the  adoption  of  interoperable  eInvoicing  solutions  in 
Member States. It has done so by enabling the entire European public sector to process 

42 Malaysia is also in the process. 
43 Among these are Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Malta, Portugal, Sweden, and also 
the authorities of Iceland and Norway. 

52 

 
 
 
 
European standard-compliant eInvoices and facilitating the adoption of Peppol to ensure 
compliance  with  the  European  eInvoicing  standard.  Additionally,  it  has  paved  the  way 
for further harmonisation in the B2B context, where the EU standard is set to be reused 
under the ViDA proposal. 

The  establishment  of  a  European  standard  has  significantly  simplified  decisions  for 
contracting  authorities  and  service  providers  in  selecting  and  investing  in  a  single 
eInvoicing  format  for  both  domestic  and  cross-border  public  procurement  and  because 
they could use only one standard with many of their business partners who choose to use 
the European standard. This intervention has proven to be a strong enabler. 

Moreover,  the  Directive  has  promoted  cooperation  among  Member  States  and  with  the 
European  Commission,  encouraging  the  establishment  of  national  eInvoicing  fora  and 
fostering cooperation in achieving common objectives. 

The  European  eInvoicing  standard  is  considered  to  have  become  a  standard  with  a 
broader impact by fostering interoperability globally, as demonstrated by the adoption of 
the  Peppol  Interoperability  Framework  outside  of  Europe  in  countries  like  Australia, 
Malaysia, New Zealand, Japan, and Singapore. The European Commission is involved in 
several initiatives to foster the European Interoperability Framework at the international 
level,  such  as  free  trade  agreements  (FTA),  Digital  Partnerships  and  Regulatory 
Dialogues.  

In  conclusion,  the  EU's  intervention  in  eInvoicing  for  public  procurement  has  brought 
significant added value by addressing interoperability challenges and fostering a cohesive 
approach within the Internal Market and beyond. 

4.3. 

Is the intervention still relevant? 

National  authorities from  18 out  of 27 Member States, consulted through a stakeholder 
survey targeting national authorities, consider that the needs and problems addressed by 
the Directive remain relevant today. 

The challenges present at the time of the adoption of the Directive are still relevant today, 
while other challenges have emerged. The landscape of eInvoicing in Europe has evolved 
significantly over the past decade, largely due to the impact of the Directive, resulting in 
a  broader  adoption  of  eInvoicing.  However,  there  is  a  general  consensus  among 
stakeholders  that  the  needs  and  problems  addressed  by  the  Directive  remain  relevant 
today. An important  objective underlying the EU eInvoicing policy and the Directive’s 
adoption was the increased uptake of eInvoicing in Europe, both in B2G and in B2B. 

At  the  time  of  the  introduction  of  the  Directive,  several  challenges  were  identified,  as 
described  in  the  2013  Impact  Assessment.  The  existence  of  multiple  non-interoperable 
eInvoicing systems in the EU led to excessive technical complexity and legal uncertainty 
for  economic  operators  trading  across  intra-EU  borders.  Additionally,  it  imposed  high 
operating costs on economic operators who had to acquire and maintain interoperability 
between eInvoicing systems and standards across borders within the EU. 

These challenges have also evolved from the entry into force of the Directive and during 
its implementation.  

53 

 
While  the  EU  intervention  effectively  tackled  the  primary  challenges  identified  at  the 
time of its introduction, the central challenge - ensuring the interoperability of eInvoicing 
systems  and  solutions  -  persists  in  both  the  B2G  and  B2B  contexts.  Although  the 
integration  of  the  European  eInvoicing  standard  into  national  eInvoicing  public 
procurement  systems  has  created  the  foundation  for  the  harmonisation  of  the  Internal 
Market, divergent national requirements result in variations of the standard that may not 
always be compatible. 

On the other hand, the implementation of eInvoicing in the B2G context, as well as the 
expansion of eInvoicing use in B2B, have resulted in the amplification of problems that 
had  not  been  identified  before  as  issues  for  policy  decisions.  In  particular,  the  need  to 
ensure  seamless  transmission  of  eInvoices  across  the  EU  has  emerged  as  a  key  new 
challenge.  

One  major  development  consists  in  the  emergence  of  new  applications  of  eInvoicing, 
meaning  that  the  eInvoicing  software  and  data  can  be  used  for  a  large  spectrum  of 
innovative  uses  which  can  simplify  life  of  companies,  by  reducing  their  administrative 
burden or allowing them to use eInvoicing for getting innovative financing. Examples of 
these  new  applications  include  VAT  reporting  based  on  eInvoicing  as  introduced  by 
ViDA;  the  use  of  eInvoicing  for  the  fulfilling  of  administrative  obligations,  such  as 
customs  declaration,  sustainability  reporting,  or  crowfactoring,  eInvoice  finance  and 
other processes such as  electronic orders and despatch  advice. This is illustrated by the 
study  commissioned  by  the  European  Commission  “Report  on  the  evolution  of 
eInvoicing in the Digital Age”44. 

The EU policy on eInvoicing has evolved to encompass new applications of eInvocing, 
with  an  initial  focus  on  VAT  reporting,  introducing  a  set  of  novel  challenges  in  the 
process. In December 2022, the European Commission introduced the ViDA legislative 
proposals, aiming to mandate the use of eInvoicing by companies for B2B transactions to 
facilitate  cross-border  VAT  reporting.  Simultaneously,  the  Commission  proposals 
envision  electronic  invoicing  becoming  the  default  invoicing  method  across  the  EU  by 
2028.  Consequently,  a  new  need  emerged  to  further  adapt  the  European  eInvoicing 
standard to accommodate diverse business needs, an ongoing process currently underway 
in CEN. 

Monitoring  the  adoption  of  eInvoicing  in  all  Member  States  is  another  challenge,  as 
procedures and tools may not always be in place in Member States and no monitoring or 
reporting obligation is included in the Directive.  

Moreover,  the  uptake  and  interoperability  challenges  have  evolved  over  time  as 
described  below,  and  the  general  evolution  of  eInvoicing  brought  up  new  challenges, 
including those related to B2B use and the need for a common approach in B2B, B2G, 
and B2C. 

44  European  Commission,  Directorate-General  for  Internal  Market,  Industry,  Entrepreneurship  and  SMEs,  Ciciriello,  C.,  Gray,  E., 
Report  on 
the  European  Union,  2024, 
https://data.europa.eu/doi/10.2873/104234 

the  digital  age,  Publications  Office  of 

the  evolution  of  eInvoicing 

in 

54 

 
 
 
 
4.3.1.  Interoperability challenge at the transmission level 

Currently,  Member  States  have  implemented  eInvoicing  systems  at  the  national  level, 
and they ensure receiving capabilities for EN-compliant eInvoices. However, challenges 
exist for the transmission of eInvoices between non-interoperable networks and systems 
(see  Section  on  Effectiveness).  This  is  to  the  disadvantage  of  companies,  including 
SMEs, which have to register to multiple platforms at the request of their customers. Key 
challenges  for  eInvoicing  are  the  lack  of  a  mandate  for  interoperability  between  public 
and private eInvoicing platforms and agreement on common transmission methods across 
the EU. 

4.3.2.  Uptake challenge 

One  of  the  initial  challenges  that  the  Directive  addressed  was  the  level  of  adoption  of 
electronic  invoicing  in  the  EU.  eInvoicing  uptake  has  increased  mainly  in  the  Member 
States that introduced supplier mandates for B2G eInvoicing. 17 Member States, which 
introduced the obligation on suppliers, report either 100% uptake of eInvoicing in public 
procurement or this target is expected to be achieved in 2023/2024. 

Based on the SME survey conducted in 2022 as part of the stakeholder consultation, this 
evaluation  reaffirms  the  same  need  that  SMEs  expressed  when  the  Directive  was 
implemented (in the Impact Assessment done in 2013). From the SMEs consultation, one 
of the main challenges for SMEs for the eInvoicing adoption is the lack of integration of 
eInvoicing with ERP accounting software, which would allow them to access eInvoicing 
features immediately. Currently, SMEs have to use different solutions with their business 
partners. 

In  addition,  some  Member  States  with  mature  eInvoicing  infrastructures  have  and  will 
take measures to promote the use of compliant eInvoicing modules amongst the ERP and 
accounting software vendors in their countries (e.g. Denmark, Sweden45).  

4.3.3.  B2B use of the European eInvoicing standard 

In  view  of  its  use  in  B2B  for  VAT  reporting  in  cross-border  transactions,  and  also  in 
domestic  transactions  if  a  Member  State  decides  to  adopt  such  a  system,  the  European 
eInvoicing  standard  will  be  adapted  by  CEN  to  cover  all  B2B  use  cases,  including 
sectoral specifications. In light of the ViDA requirements, this need has been recognised 
by national authorities across EU Member States and it also emerged from the findings of 
the consultation activities (surveys and call for evidence). Without the adaptation of the 
European  standard,  there  is  a  risk  of  fragmentation  of  the  Internal  Market  if  different 
non-interoperable  national  technical  specifications  for  B2B  eInvoicing  are  being 
developed. According to the EU standardisation policy reinforced by CEN rules, if there 
is a European standard for a specific domain, such as eInvoicing, Member States are not 
allowed to adopt competing national standards. 

Member  States  pointed  out  that  the  appropriate  legal  framework  to  support  B2B 
eInvoicing requires a deep understanding of business flows. Focusing excessively on the 

45 Annex VI: Country profiles. 

55 

 
 
 
tax  collection  aspects  may  cause  a  bias  in  the  legal  framework,  undermining  other 
legitimate requirements. 

4.3.4.  Common approach in B2G, B2B and B2C 

Additionally, it has been emphasised that a significant challenge for economic operators 
stems from varying approaches in national policies concerning B2G, B2B, and even B2C 
in  Member  States  that  choose  to  regulate  the  latter.  Economic  operators,  who  offer 
services across all eInvoicing domains, require a unified process  where consistent tools 
can  be  applied.  Presently,  the  distinction  between  B2G  and  B2B  approaches  poses 
difficulties  for  end-users  in  Member  States.  This  is  evident  in  the  development  of 
separate  platforms  by  governments  for  B2G  and  B2B  eInvoicing,  creating  unnecessary 
complexity for enterprises compelled to use both. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1.  Conclusions 

The  Directive  on  electronic  invoicing  in  public  procurement  has  been  successful  to  a 
certain extent, as shown by the assessment of its effectiveness, efficiency and EU added-
value. 

Effectiveness 

The implementation of the Directive, with the creation and the adoption of the European 
eInvoicing  standard  by  public  authorities  and  business  in  Europe  has  significantly 
contributed to the harmonisation of electronic invoicing in Europe and its uptake. 

The  Directive  has  been  partially  effective  in  fulfilling  its  objectives.  With  regard  to  its 
two direct objectives, translated in the provisions of the Directive, the first one - to set up 
the  European  eInvoicing  standard  -  was  fully  achieved  by  endorsing  the  CEN  standard 
(EN  16931)  in  October  2017.  For  the  second  objective,  which  has  been  partially 
achieved,  the  Directive  imposed  an  obligation  on  Member  States  and  their  public 
authorities to require 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. The absence of a monitoring mechanism does not allow to 
assess  full  achievement  of  this  objective.  This  intervention  has  facilitated  the 
establishment of pan-European eInvoicing capabilities.  

Concerning  the  Directive’s  underlying  objectives,  these  were  partially  fulfilled.  The 
Directive  aimed  at  fostering  the  Internal  Market  by  addressing  interoperability, 
increasing legal certainty, reducing legal complexity, and lowering the cost for economic 
operators  (specific  objectives),  as  well  as  creating  the  conditions  for  the  emergence  of 
technical  solutions  for  eInvoicing  in  public  procurement,  to  ensure  interoperability 
(operational objective).  

The  Directive  primarily  focused  on  addressing  interoperability  challenges  related  to 
semantic  and  syntax  levels.  The  development  of  the  European  eInvoicing  standard 
effectively tackled these two layers of interoperability, amongst four levels, the other two 
being  transmission  and  governance.  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 

56 

 
avoiding further fragmentation. This is fully in line with the EU policy on standardisation 
which  prevents  Member  States  from  creating  competing  national  standards.  While 
transmission and governance have not been addressed by the Directive, in practice,  full 
interoperability across borders based on the European eInvoicing standard completed by 
other  technical  specifications  has  been  ensured  by  the  implementation  of  Peppol-based 
solutions in 23 Member States.  

The Directive increased legal certainty and reduced technical complexity for eInvoicing 
by  establishing  a  clear  legal  basis  and  setting  the  European  eInvoicing  standard  as  the 
common  standard  to  be  supported  by  the  EU  public  sector.  Article  2  of  the  Directive 
establishes  the  definition  of  an  electronic  invoice,  which  ensures  legal  clarity:  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, and consistency with the relevant 
provisions of Directive 2006/112/EC46. 

For  the  specific  objective  of  lowering  operating  costs  for  economic  operators,  the  EU 
intervention has not been particularly successful. Operating costs for economic operators 
depend  on  the  availability  of  cost-effective  solutions  and  services,  as  well  as  on  the 
uptake  of  eInvoicing.  These  are  influenced  by  the  number  of  eInvoicing  transactions, 
formats  supported,  transmission  protocols,  and  number  of  countries  in  which  the 
businesses  operate  as  specialised  support  is  required  in  each  Member  State  that  has 
mandated  specific  formats  and  requirements.  Mass  adoption  of  eInvoicing  has  the 
potential  to  contribute  to  lowering  fees  for  eInvoicing  services  and  maximising  the 
benefits  from  using  eInvoicing  by  default  with  all  business  partners,  including 
governments,  and  making  use  of  eInvoicing  for  further  applications  like  VAT  or 
Environmental, Social and Governance (ESG) reporting, crowdfactoring and others. 

As  regards  the  operational  objective  of  creating  the  conditions  for  the  emergence  of 
technical  solutions  for  eInvoicing  in  public  procurement,  ensuring  interoperability  was 
achieved  in  two  manners:  first  of  all,  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 
interoperability  and  secondly,  since  its  adoption,  the  Directive  facilitated  and  gave  an 
impetus  to  the  use  of  Peppol  as  a  technical  interoperable  network  for  the  exchange  of 
European standard-compliant electronic invoices among Member States. 

Efficiency 

With regard to  the efficiency  of the  Directive  for public authorities, the  analysis of the 
costs  and  benefits  shows  a  very  varied  situation  from  Member  State  to  Member  State. 
However,  a  significant  number  of  Member  States  confirmed  that  the  benefits  of 
eInvoicing  outweighed  their  associated  costs  at  the  national  level.  The  benefits  include 
operational  efficiencies,  improved  transparency,  and  environmental  benefits.  Process 

46 Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax, OJ L 347, 11.12.2006, Brussels. 

57 

 
 
 
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  largely  depend  on  the  IT  maturity  level  of  the  public  sector:  the  higher  the 
digital maturity, the lower the costs. The costs specifically linked to the implementation 
of  the  European  eInvoicing  standard  vary  depending  on  the  existence  of  a  national 
standard  or  technical  specifications.  However,  the  highest  costs  are  related  to  the 
establishment and maintenance of the national eInvoicing infrastructure. 

As regards the efficiency analysis for economic operators, the evaluation has shown that 
this  depends  mainly  on  the  uptake  of  eInvoicing  and  its  mass  adoption  in  two 
dimensions. On the one hand, in general, companies have to acquire eInvoicing services 
or software, and the prices for eInvoicing services are still relatively high. On the  other 
hand, even when they acquire the respective software/service, a company will fully reap 
the  benefits  of  its  investment  when  it  is  able  to  use  electronic  invoicing  with  all  its 
business partners, which is far from being the case. Mass adoption of eInvoicing has the 
potential  to  contribute  to  lowering  the  fees  for  eInvoicing  services  and  maximise  the 
benefits from using eInvoicing by default and for further applications. 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.  Large  companies 
(multinationals)  surveyed  reported  significantly  high  set-up  costs  for  establishing 
eInvoicing  in  different  EU  Member  States.  Recurring  costs  vary  considerably.  These 
costs correlated to  the need to  use different  service providers to  cover specific national 
requirements. 

Quantitative benefits from automating the invoicing process are estimated at around EUR 
5.28 to EUR 8.4 per eInvoice, considering the cost of labour per hour at EUR 46. Greater 
savings  are  achieved  when  automating  the  entire  order-to-pay  cycle,  including  orders, 
transport  documents,  invoices,  and  payment  notices,  resulting  in  benefits  estimated 
between EUR 25 and EUR 65 per cycle. 

Coherence 

The  coherence  of  the  Directive  has  been  evaluated  on  two  main  levels:  internal  and 
external.  

For  the  internal  coherence,  the  Directive  is  coherent  with  the  subsequent  work  on  the 
European  eInvoicing  standard.  First  of  all,  the  Directive  called  for  the  creation  of  a 
European standard for the semantic data model of core elements in an electronic invoice. 
Secondly,  it  listed  several  requirements  for  the  European  standard,  which  have  been 
successfully  reflected  in  the  deliverables  of  CEN  TC  434,  confirming  the  coherence 
between legislative objectives and standard development. 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  digital 
policies, including the digitisation of public procurement.  

58 

 
•  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 European Commission 
VAT  in  the  Digital  Age  (ViDA)  legislative  proposals47  as  regards  the  role  of 
eInvoicing  in  VAT  reporting  and  the  establishment  of  electronic  invoicing  as  a 
default method, starting in 2028.  

•  The  implementation  of  eInvoicing  and  the  Directive  has  been  coherent  with  the 
provisions  of  the  Late  Payment  Directive.  The  EU  intervention  is  also  aligned 
with  the  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 EIF, the eInvoicing Directive effectively addresses interoperability 
at  both  the  semantic  and  syntax  layers,  but  not  at  all  the  interoperability layers, 
such as transmission and governance. 

• 

• 

In regard to the Digital Building Blocks, the eInvoicing Building Block provided 
essential  tools  to  facilitate  and  validate  compliant  implementations  of  the 
European eInvoicing standard in  IT systems and services. At the same time, 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.  

In  addition,  the  current  activities  carried  out  by  the  European  Commission  with 
its  international  partners  are  coherent  with  the  Directive,  both  in  the  formal 
negotiations and during bilateral dialogues. The EU-model model (Peppol-based) 
has  been  adopted  in  several  countries  outside  of  the  EU,  including  Australia, 
Japan, Malaysia, New Zealand, and Singapore.  

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

EU Added Value  

There  is  a  broad  consensus  among  EU  Member  States  that  the  Directive  has  produced 
significant value at the EU level since its adoption in 2014.  

From  the  perspective  of  national  authorities,  the  main  EU  contribution  consists  of 
limiting the emergence of various national eInvoicing standards.  

47 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, Brussels. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A701%3AFIN 

59 

 
 
 
 
Relevance 

The Directive is still relevant today as the challenges that prompted its adoption in 2014 
persist. In addition, new challenges and developments have emerged since its adoption. 

Concerning the challenges identified in  2014 that  continue to  be relevant today, one of 
the  main  ones  is  the  uptake  of  eInvoicing  in  public  procurement.  It  is  noteworthy  that 
while  the  capabilities  for  receiving  electronic  invoices  in  B2G  are  present  to  a  certain 
extent, significant adoption in public procurement is primarily observed only in Member 
States  that  have  required  by  law  their  suppliers  to  send  electronic  invoices  to  public 
authorities or in digitally mature Member States.  

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,  but 
they have not  simultaneously required the use of the European standard. Consequently, 
the adoption of the European Standard remains lower, as it relies on suppliers' voluntary 
choice.  

Secondly,  the challenge of interoperability persists, as all four levels  of interoperability 
defined  by  the  European  Interoperability  Framework,  including  transmission  and 
governance,  were  not  fully  addressed  by  the  Directive.  While  interoperability  at  the 
semantic and syntax level was identified as a challenge in 2014 and addressed by the EU 
intervention, transmission has emerged as a main challenge during the implementation of 
the eInvoicing Directive. This challenge is particularly burdensome for SMEs, which are 
required to register with multiple platforms to accommodate their customers' preferences. 
The  lack  of  a  mandate  for  interoperability  between  public  and  private  eInvoicing 
platforms and  agreement on common transmission methods across the EU stand out  as 
key  technical  challenges  for  eInvoicing  adoption.  Beyond  its  immediate  impact  within 
the  public  procurement  sphere,  the  Directive  has  played  a  role  in  promoting  further 
harmonisation in the B2B context. 

5.2.  Lessons Learnt 

New developments have taken place since the Directive's adoption. In particular, in line 
with the ViDA (VAT in the Digital Age) legislative proposals, EU action to ensure that 
the current European standard evolves to cover all B2B cases would avoid unnecessary 
burden  on  companies  as  they  will  use  the  same  system  to  fulfil  several  obligations. 
According  to  the  EU  standardisation  policy  reinforced  by  CEN  rules,  if  there  is  a 
European  standard  for  a  specific  domain,  such  as  eInvoicing,  Member  States  are  not 
allowed  to  adopt  competing  national  standards.  If  the  European  eInvoicing  standard  is 
not enforced in B2B, there is a risk of fragmentation within the Internal Market stemming 
from  the  use  of  national  non-interoperable  technical  specifications  for  B2B  eInvoicing. 
The  coherence  between  the  Directive  and  ViDA  is  ensured  with  the  current  draft 
legislative  proposals,  which  are,  however,  subject  to  evolution  during  the  ongoing 
political  negotiations.  In  light  of  the  above,  coherence  between  the  two  legislative 
instruments appears particularly important. 

Monitoring  the  technical  developments  and  adoption  at  the  EU  level  also  poses 
challenges  due  to  varying  procedures  and  requirements  in  the  Member  States  and  the 
absence of an obligation for monitoring and reporting. 

60 

 
As  regards  technical  complexity,  businesses,  especially  SMEs,  experienced  technical 
challenges  when  using  eInvoicing,  including  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.  

Overall,  the  Directive  is  a  significant  achievement  in  the  harmonisation  of  eInvoicing 
across Europe and beyond. It has successfully accomplished its goal of interoperability at 
the semantic and syntax levels, but it did not fully solve all interoperability related issues. 
Especially,  the  implementation  of  the  Directive  by  the  Member  States  showed  that 
addressing  interoperability  at  the  transmission  level  is  a  critical  element  for  full 
interoperability. 

61 

 
ANNEX I: PROCEDURAL INFORMATION 

Lead DG and internal references  

DG GROW is the lead Directorate General for the evaluation of the eInvoicing Directive.  

The Decide Planning entry is: PLAN/2022/2793 

Organisation and timing 

The evaluation was launched in December 2022. The evaluation was coordinated by an InterService Steering Group (ISG), which was established early 
in the evaluation process and which was consulted on all key deliverables:  

•  Stakeholder  consultation  strategy,  which  set  a  number  or  consultation  activities  comprising  a  Call  for  Evidence  and  targeted  consultation 

activities, in the form of interviews and surveys.  

•  Call for Evidence, which was open for feedback from 17 March 2023 until 14 April 2023.   

•  External Evaluation Study, which was conducted by an external contractor between November 2022 and July 2023.  

•  Report from the Commission to the European Parliament and Council and Commission Staff Working document. 

The ISG is composed of DG GROW (unit G4), TAXUD, CNECT, DIGIT, Legal Service and Secretariat General. 

Exceptions to the better regulation guidelines  

The Better Regulation Guidelines were followed. No exceptions applicable. 

62 

 
 
 
 
Consultation of the RSB (if applicable)  

This evaluation was not selected for assessment by the Regulatory Scrutiny Board.  

Evidence, sources and quality 

The  evaluation  relies  to  a  large  extent  on  the  external  support  study.  During  the  evaluation  the  consultant  used  a  mix  of  approaches  including  desk 
research, field research and case studies.  

Literature evidence was identified to develop several of the indicators that support the analysis for the evaluation questions and subsequently to identify 
key information for the development of the answers to the evaluation questions. 

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

The evaluation findings rely on different sources and data collection methods, including desk research, stakeholder consultations, a Call for Evidence and 
interviews. 

The Commission published a Call for Evidence in December 202248. 

A study was commissioned to an external contractor to provide information to support the preparation of the Staff Working Document evaluation and the 
report to the European Parliament and the Council. 

The aim of the desk research was to collect, organise and analyse relevant information from relevant secondary sources. This included statistical data, 
legislative documents, and relevant reports and studies, such as the KMPG eInvoicing and Digital Reporting global updates49, as well as data collected by 
the European Commission in the context of the eProcurement monitoring activities in the Member States and the EC eInvoicing country factsheets50. 

Different stakeholder groups were consulted in the context of the study by developing specific targeted surveys.  

•  A  questionnaire  for  national  authorities  was  launched  on  30  November  2022  and  was  open  until  28  April  2023.  Twenty-three  Member  States 
responded to the survey. National authorities from Iceland and Norway also provided feedback. Four Member States did not respond (Hungary, 
Bulgaria, Slovakia, and Spain).  

•  A  survey  was  published  for  SMEs,  and  100  companies  responded.  These  enterprises  were  based  in  Spain,  Germany,  Italy,  Belgium,  Sweden, 

France, and Estonia. There were 63 micro, 16 medium, 18 small, and three did not state their size. 

48 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13669-Public-procurement-EU-rules-on-electronic-invoicing-in-public-procurement-evaluation-_en 
49 https://kpmg.com/gr/en/home/insights/2022/05/electronic-invoicing-digital-reporting-global-updates.html 
50 https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/eInvoicing+Country+Factsheets+for+each+Member+State+and+other+countries  

64 

 
 
 
 
 
•  A  survey  was  also  published  for  large  enterprises,  and  seven  of  them  responded.  These  were  multinationals,  which  included  sectors  such  as 

Energy, Chemical, Retail, and International Shipping. 

Professional associations have also been consulted to gather more quantitative data on the uptake of eInvoicing and to use it to triangulate data received 
by national authorities in Member States. The OpenPeppol Association51 and GENA, the European Association of the eInvoicing Service Providers, were 
consulted and contributed to the findings of this study.  

The  OpenPeppol  Association  provided  feedback  based  on  data  from  seven  of  its  members.  They  operate  in  Denmark,  Germany,  Italy,  Sweden,  The 
Netherlands, and Poland.  

GENA responded to the survey based on data from eight members with operations in Belgium, Croatia, Estonia, Hungary, Norway, Portugal, Romania, 
Slovenia, and Sweden. The largest service provider handled 80 million eInvoices per year.  

Interviews  with  three  service  providers  and  Enterprise  Resource  Planning  (ERP)  vendors  have  been  conducted  to  collect  more  details  on  why 
stakeholders hold certain opinions.  

Four case studies were carried out based on the desk research and interviews covering the following countries: Croatia, Finland, France, and Italy. These 
four countries represent different eInvoicing scenarios. 

All the analytical findings provide the basis for the evaluation of how the Directive has scored on the evaluation  criteria. Each criterion was addressed 
through evaluation questions. 

Assumptions and Limitations 

Limitations and robustness of findings 

51  OpenPeppol  is  a  member-driven  non-profit  Association  set  up  as  an  Association  Internationale  Sans  But  Lucratif  (AISBL)  under  Belgian  law.  It  unites  over  500  member-organisations  including  EU  government  entities, 
enterprises and service providers. 

65 

 
 
 
 
 
While  the  study  was  designed  to  ensure  the  robustness  of  the  evidence  supporting  the  findings,  limitations  were  identified  during  the  analysis  of  the 
gathered information. 

Limitations concerning the stakeholder consultation 

The information gaps in the three Member States that did not reply at all to the questionnaire were addressed through desk research and insights from the 
authors. Although the Hungarian Prime Minister's Office provided some feedback on eInvoicing,  it contained very limited information. The European 
Commission's desk officers were contacted to liaise with the non-responsive Member States to improve the response rate. Additionally, additional survey 
were conducted from 5 May to 30 June 2023 to gather further feedback. Interviews were conducted with two additional service providers, and insights 
from two webinars with Greek and Swedish stakeholders were integrated into the study's results. 

Reaching accounting associations proved challenging, and no data were directly received from them through the surveys. However, this limitation was 
compensated for through comprehensive desk research. 

Limitations concerning 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. While data availability has improved in recent years, estimates for pre-2019 had to be used, and triangulation with other 
data sources was performed. The evaluation relies primarily on stakeholder-reported data and data published on national authorities' portals. 

66 

 
 
 
 
 
 
 
ANNEX III. EVALUATION MATRIX  

This  annex  encompasses  three  distinct  Evaluation  Matrices  —  for  National  Authorities,  Economic  Operators,  and  Service  Providers.  These  matrices 
serve  as  structured  tools,  each  designed  to  assess  specific  entities'  effectiveness,  efficiency,  EU  added  value,  coherence,  and  relevance  within  their 
domains. With tailored evaluation criteria and mapped questions. 

Annex III.1 Evaluation Matrix National Authorities  

This  matrix  evaluates  National  Authorities'  performance  through  criteria  such  as  effectiveness,  efficiency,  EU  added  value,  relevance,  and  coherence. 
With  48  mapped  questions,  it  assesses  key  aspects  such  as  the  implementation  of  eInvoicing  mandates  and  alignment  with  VAT  digital  reporting, 
ensuring compliance with EU standards and directives. 

Evaluation 
Criteria 

Effectiveness 

Evaluation Question 

1. To what extent has the Directive and the 
introduction of the EN 16931 contributed to 
foster the functioning of Internal market?  

How was this achieved? 

Please indicate if there are still challenges that 
have to be addressed to facilitate cross-border 
eInvoicing related to any of the following 
aspects.      

Indicator  

Data sources and 
collection methods 

Perception (1:low ; 5:high) 

Questionnaire* 

Feedback 

Questionnaire 

Semantic data model: 

Perception (1:low ; 5:high) 

Questionnaire 

Syntax: 

Perception (1:low ; 5:high) 

Questionnaire 

Transmission: 

Perception (1:low ; 5:high) 

Questionnaire 

Governance: 

Perception (1:low ; 5:high) 

Questionnaire 

Legal certainty: 

Perception (1:low ; 5:high) 

Questionnaire 

67 

 
 
 
  
 
  
 
 
 
 
 
Organisational 

Perception (1:low ; 5:high) 

Questionnaire 

Other, please describe: 

Feedback 

Questionnaire 

2. Is electronic invoicing mandatory for 
businesses in your country?  

B2G: 

B2B: 

B2C: 

Comment: 

 Since when (for B2G; B2B; B2C; etc.)? 

 B2G 

B2B: 

B2C: 

Yes/No 

Yes/No 

Yes/No 

Feedback 

Year 

Year 

Year 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

Questionnaire 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

National portals; 
KPMG reports; EC 
eInvoicing fact sheets 

 If not, are there plans to make electronic invoicing mandatory in your 

Yes/No 

Questionnaire 

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
country? 

 As part of the mandate, are there any standard or format foreseen? 

Yes/No 

Questionnaire 

3. What is the national eInvoicing strategy in the medium (2023-2024) 
and long term (2025-2030)? 

Feedback 

Questionnaire 

4. What is the strategy for ensuring cross-border eInvoicing 
interoperability? 

Feedback 

Questionnaire 

5. Is eInvoicing currently used for VAT 
digital reporting? 

 If not, is eInvoicing planned to be used for VAT digital reporting? 

 Comment: 

6. Is eInvoicing data used, or planned to be 
used, for decision-making and policy 
purposes? 

Please describe how eInvoice data are used, or   
planned to be used: 

Yes/No 

Yes/No 

Feedback 

Yes/No 

Financial planning: 

Feedback 

Fiscal monitoring: 

Feedback 

environmental impact : 

Feedback 

energy consumption: 

Feedback 

water consumption: 

Feedback 

Sustainable Development  Feedback 

69 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

 
 
 
 
 
 
 
  
 
 
 
  
 
 
 
 
 
 
Goals (SDGs): 

Other, please describe: 

Feedback 

Questionnaire 

7. What technologies are used and planned to be used to leverage invoice 
data and the use cases? 

Technology type 

Questionnaire 

8. Is anonymised or aggregated invoice data published as Open Data? 

9. What was the eInvoicing (i.e. structured 
data) uptake in your country before or at the 
time of the introduction of the Directive 
2014/55/EU in B2G and B2B transactions? 

B2G, in 2013 or 2014: 

B2G, in 2013 or 2014: 

B2B, in 2013 or 2014: 

B2B, in 2013 or 2014: 

Select Anonymised / 
Aggregated 

Number of eInvoices  

Percentage of eInvoices  

Number of eInvoices 

Percentage of eInvoices 

Please, comment and/or 
provide a link to relevant 
survey or data already 
gathered in your country:  Feedback 

70 

Questionnaire 

Questionnaire; 
national portals; desk 
research 

Questionnaire; 
national portals; desk 
research 

Questionnaire; 
national portals; desk 
research 

Questionnaire; 
national portals; desk 
research 

Questionnaire 

 
 
 
 
  
 
 
 
 
 
 
 
10. To what extent has Directive 2014/55/EU 
and the introduction of the EN 16931 
contributed to increasing the adoption of 
eInvoicing in your country in B2G and B2B 
transactions? 

Please indicate impact on 
uptake in B2G: 

Please indicate impact on 
uptake in B2B: 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Please, comment and/or 
provide a link to relevant 
survey or data already 
gathered in your country:  Feedback 

11. What is the number of Public Contracting 
Authorities using eInvoicing? 

12. What is the number of public contracting 
authorities and entities using eInvoicing 
compliant with the EN 16931, versus the total 
number of public contracting authorities and 
entities in your country?  

2019  Number of CAs  

2020  Number of CAs 

2021  Number of CAs 

2019  Number of CAs 

2020  Number of CAs 

2021 

Number of CAs 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

13. What is the number of suppliers sending 
eInvoices for public procurement contracts? 

2019  Number of Economic 

Operators  

Questionnaire 

2020  Number of Economic 

Operators 

Questionnaire 

2021  Number of Economic 

Operators 

Questionnaire 

71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
14. Is eInvoicing mandatory to suppliers for contracts below the EU 
thresholds? 

Yes/No 

Questionnaire; 
national law;  

2019  Perception (1:low ; 5:high) 

Questionnaire 

2020  Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Feedback 

Questionnaire 

15. To what extent (i.e. percentage) is the EN 
16931 used in eInvoicing in your country 
versus other format (e.g. national formats)? 
Please include the percentage of EN 16931 
compliant eInvoices over the total number of 
eInvoices for the following years 

 Please, comment and/or provide a link to relevant survey or data 
already gathered in your country: 

16. How many B2G eInvoices from national 
suppliers does the Public Sector in your 
country receive on a yearly basis? 
         - Central level 

         - Sub-central level 

2021 

2019 

2020 

2021 

2019 

Number of eInvoices 

Number of eInvoices 

Number of eInvoices 

Questionnaire; desk 
research; national 
portals 

Questionnaire; desk 
research; national 
portals 

Questionnaire; desk 
research; national 
portals 

Questionnaire; desk 
research; national 
portals 

Questionnaire; desk 
research; national 

Number of eInvoices 

2020  Number of eInvoices 

72 

 
 
 
 
 
 
 
 
 
 
 
 
 
2021 

Number of eInvoices 

portals 

Questionnaire; desk 
research; national 
portals 

 Please, comment: 

Feedback 

Questionnaire 

17. How many B2G eInvoices from foreign 
suppliers does the Public Sector receive on a 
yearly basis? 

B2G 2019  Number of eInvoices 

Questionnaire 

B2G 2020  Number of eInvoices 

Questionnaire 

B2G 2021  Number of eInvoices 

Questionnaire 

18. What is the percentage of public 
procurement Contract Notices (CN) in your 
country including an eInvoicing requirement? 

B2G 2020  Number of eInvoices 

Questionnaire 

B2G 2021  Number of eInvoices 

Questionnaire 

19. Is the PEPPOL eDelivery network used in your country? 

   Please comment: 

  If yes, how many B2G eInvoices are 
exchanged via PEPPOL  

Yes/No 

Feedback 

B2G 2019 

B2G 2020 

B2G 2021 

Number of eInvoices 

Number of eInvoices 

Number of eInvoices 

Questionnaire; desk 
research 

Questionnaire 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  Please comment  

Feedback 

Questionnaire 

20. How many eInvoices are exchanged in the 
B2B sector at a domestic level  

the number of B2B eInvoices exchanged at a 
cross-border level  

21. Please indicate the percentage of eInvoices 
based on the EN 16931 over the total number 
of eInvoices in your country in B2G and B2B 
eInvoices 

Domestic 2019 

Domestic 2020 

Domestic 2021 

Cross-border 2019 

Cross-border 2020 

Cross-border 2021 

Number of eInvoices 

Number of eInvoices 

Number of eInvoices 

Number of eInvoices  

Number of eInvoices 

Number of eInvoices 

B2G:2019 

B2G: 2020 

B2G: 2021 

B2B: 2019 

Percentage of eInvoices 

Percentage of eInvoices 

Percentage of eInvoices 

Percentage of eInvoices 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
B2B: 2020 

B2B: 2021 

Percentage of eInvoices  

Percentage of eInvoices 

Questionnaire; desk 
research 

Questionnaire; desk 
research 

22. To what extent has the national policy been effective in increasing the 
adoption of eInvoicing? 

 Please comment  

Perception (1:low ; 5:high) 

Questionnaire 

Feedback 

Questionnaire 

23. If applicable, please describe the reasons for not achieving high levels 
of eInvoicing adoption in your country (in B2G and B2B transactions) 

Feedback 

Questionnaire 

24. Describe the most effective measures that 
could further increase eInvoicing adoption at 
EU and national level  

Mandatory B2B: 

Perception (1:low ; 5:high) 

Questionnaire 

Mandatory B2G: 

Perception (1:low ; 5:high) 

Questionnaire 

Economic incentives: 

Perception (1:low ; 5:high) 

Questionnaire 

education and 
awareness: 

Perception (1:low ; 5:high) 

Questionnaire 

integration 

Perception (1:low ; 5:high) 

Questionnaire 

Please, provide your 
comments: 

Feedback 

Questionnaire 

25. To what extent has it influenced your 
policy decision for eInvoicing in B2G and B2B 
transactions (going beyond the mandatory 

B2G transactions 

Perception (1:low ; 5:high) 

Questionnaire 

B2B transactions 

Perception (1:low ; 5:high) 

Questionnaire 

75 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
provisions of the Directive)? 

Please, comment: 

Feedback 

Questionnaire 

26. To what extent has Directive 2014/55/EU increased legal certainty for 
eInvoicing requirements and reduced technical complexity? 

Perception (1:low ; 5:high) 

Questionnaire 

27. To what extent the following factors have 
contributed to achieving this objective?  

Clear legal basis 

Perception (1:low ; 5:high) 

Questionnaire 

Common specifications 

Perception (1:low ; 5:high) 

Questionnaire 

Training 

Perception (1:low ; 5:high) 

Questionnaire 

28. Since the transposition of the Directive 
2014/55/EU and the EN 16931, has your 
country experienced the expected benefits 
associated with eInvoicing in any of the 
following areas? 

Other, please describe: 

Feedback 

Operational efficiencies:  Feedback 

Tax revenues: 

Feedback 

Improved transparency:  Feedback 

Social benefits: 

Feedback 

Environmental benefits:  Feedback 

Others, please describe:  Feedback 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

29. What are the drivers behind these 
benefits? 

Process automation: 

Perception (1:low ; 5:high) 

Questionnaire 

Common standard: 

Perception (1:low ; 5:high) 

Questionnaire 

Less complexity: 

Perception (1:low ; 5:high) 

Questionnaire 

Faster/timely 

Perception (1:low ; 5:high) 

Questionnaire 

76 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
processing: 

Other, please describe: 

Feedback 

Questionnaire 

30. Which stakeholders have benefitted the 
most? 

Central Authorities: 

Perception (1:low ; 5:high) 

Questionnaire 

Sub-central Authorities:  Perception (1:low ; 5:high) 

Questionnaire 

Large corporates: 

Perception (1:low ; 5:high) 

Questionnaire 

Medium and small: 

Perception (1:low ; 5:high) 

Questionnaire 

Micro-enterprises: 

Perception (1:low ; 5:high) 

Questionnaire 

Service providers: 

Perception (1:low ; 5:high) 

Questionnaire 

Other 

Feedback 

Questionnaire 

Efficiency 

31. To what extent has it lowered operating 
cost for economic operators participating in 
cross-border public procurement? 

Please indicate: 

32. Did your country incur costs solely related to transposing the 
Directive 2014/55/EU and ensuring compliance with EN 16931? 

Perception (1:low ; 5:high) 

Questionnaire 

Yes/No 

Questionnaire 

33. If so what are these costs 

Purchase software / 
hardware: 

Actual cost 

Training costs: 

Actual cost 

Change management: 

Actual cost 

Questionnaire 

Questionnaire 

Questionnaire 

77 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Economic (implementation) costs 

Social costs 

Environmental costs 

Test environment: 

Actual cost 

Service providers fees: 

Actual cost 

Questionnaire 

Questionnaire 

Other, please describe: 

Actual cost 

Questionnaire 

Reduced number of staff 
working on manual 
invoicing: 

Number of staff 
redeployed in value 
added activities: 

Actual cost 

Questionnaire 

Actual cost 

Questionnaire 

Higher electricity usage 
due to processing power 
and data storage space:  Actual cost 

Increase in long term of 
electronic waste 
products: 

Actual cost 

Other, please describe: 

Feedback 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

34. Have EU funds been used to ensure compliance? 

Yes/No 

Please indicate: 

Name of the EU funding 
programme: 

Name of fund 

Questionnaire 

Requested funding (in 
euro): 

Amount 

Questionnaire 

78 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
  
35. Which stakeholders have borne the 
highest costs? 

Year: 

Large CAs: 

Small CAs: 

Year 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Large corporates: 

Perception (1:low ; 5:high) 

Questionnaire 

Small and Medium: 

Perception (1:low ; 5:high) 

Questionnaire 

Micro-enterprises: 

Perception (1:low ; 5:high) 

Questionnaire 

Service Providers 

Perception (1:low ; 5:high) 

Questionnaire 

Other 

Feedback 

Questionnaire 

36. To what extent the overall benefits outweighed the costs in your 
country? 

Perception (1:low ; 5:high) 

Questionnaire 

37. What is the perceived legal certainty introduced by the Directive and 
the technical simplification provided through the use of a common EU 
eInvoicing standard?  

Perception (1:low ; 5:high) 

Questionnaire 

38. What is the perceived cost reduction as a result of the Directive and 
the EN 16931  

Perception (1:low ; 5:high) 

Questionnaire 

39. What measures and policy options could the European Commission 
implement to further increase the efficiency of the intervention? 

Feedback 

40. Did you calculate a return on investment (ROI) for eInvoicing in your 
country, or did you quantify the overall benefits? 

Yes/No 

Questionnaire 

Questionnaire 

79 

 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 If yes, please provide the quantitative benefits (e.g. overall savings, ROI, 
number of years to recover the costs, etc.): 

 Please, comment: 

Savings amount 

Feedback 

41. Was there a cost burden associated with ensuring the national format 
complied with the EN 16931? 

Yes/No 

 If so, what is the estimated cost (in euro)? 

 If yes, did the benefits outweigh the costs, and why? 

Cost amount 

Feedback 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

Questionnaire 

EU Added 
Value 

42. Could the objectives of the Directive, in particular EU-wide 
interoperability, be achieved sufficiently by the Member States acting 
alone? 

Yes/No 

Questionnaire 

43. Briefly describe the positive effects of the Directive 2014/55/EU (e.g. 
facilitating cross-border eInvoicing and/or cross-border public 
eProcurement, etc.): 

44. Were there benefits in replacing different national policies and rules 
with a more homogenous policy approach (to address the challenges 
related to the existence of multiple eInvoicing formats and systems that 
were not interoperable)? Please indicate: 

 Please, comment: 

Feedback 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Feedback 

Questionnaire 

Relevance 

45. To what extent do the needs and problems addressed by the Directive 
2014/55/EU continue to require action at EU level? 

Perception (1:low ; 5:high) 

Questionnaire 

46. Please describe the needs and the 

in B2G: 

Perception (1:low ; 5:high) 

Questionnaire 

80 

 
 
 
 
 
 
 
 
 
 
 
 
problems that are still relevant in your 
country in the eInvoicing context 

in B2B: 

Coherence 

47. To what extent is the Directive 2014/55/EU 
and the publication of the EN 16931 
consistent with other EU and national 
interventions that have similar objectives to: 

digitisation of public 
procurement: 

Promoting European 
standards: 

Improving 
interoperability: 

Fostering the Internal 
Market: 

Reducing technical 
complexity: 

Improving legal 
certainty: 

Lowering operating 
costs for economic 
operators: 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Perception (1:low ; 5:high) 

Questionnaire 

Please, comment: 

Feedback 

Questionnaire 

81 

 
 
 
 
  
 
 
 
 
 
 
 
48. What other measures that could be introduced at the EU and 
national level to increase the coherence of policies and initiatives with 
similar objectives?  

Feedback 

Questionnaire 

* Questionnaire refers to the questionnaire of national authorities 

Annex III.2 Evaluation Matrix Economic Operators 

This matrix puts a focus on Economic Operators, this matrix evaluates criteria of effectiveness, efficiency, and uptake related to eInvoicing. With 21 
mapped questions, it examines elements such as the clarity of legal requirements and seeks measures to enhance eInvoicing adoption among EU 
businesses, aiming to streamline operations and improve compliance with both national and European standards. 

Evaluation 
Criteria 

Effectiveness: 
Internal Market 

Evaluation Question 

Indicator  

Data sources and 
collection methods 

1. Are you aware of a European eInvoicing standard? 

Yes/No 

Questionnaire 

    If yes do you use or plan to use it?  

    Comments:  

Feedback 

Questionnaire 

2. To what extent could the EU eInvoicing standard simplify intra-EU 
trade with other enterprises (or public bodies)?  

Perception (1:low, 5:high) 

Questionnaire 

82 

 
 
 
 
 
  
  
  
  
  
  
   Comment 

Feedback 

Questionnaire 

3. Are you aware of Peppol or eDelivery? 

Yes/No 

Questionnaire 

    If yes, are you using it or planning to use it, and why? 

 Feedback 

 Questionnaire 

    Comment 

Feedback 

Questionnaire 

4. Would you welcome the general acceptance of using only one European 
eInvoicing standard for trade across the EU (for business-to-business and 
business-to-government transactions)?  

Yes/No 

Questionnaire 

    Comment 

Feedback 

Questionnaire 

5. Would you welcome the general acceptance of selected common 
methods to exchange eInvoices (i.e. transmission protocols) for trade 
across the EU?  

Yes/No 

Questionnaire 

83 

 
 
 
  
  
  
  
  
  
  
Effectiveness: 
Reduce 
complexity and 
improve clarity 
and legal 
certainty 

    Comment 

Feedback 

Questionnaire 

6. To what extent are the national legal eInvoicing requirements clear and 
accessible?  

Perception (1:low, 5:high) 

Questionnaire 

    Comment 

7. To what extent are eInvoicing requirements in other European 
Member States that you trade with clear and accessible?  

Feedback 

Questionnaire 

Perception (1:low, 5:high) 

Questionnaire 

    Comment 

Feedback 

Questionnaire 

8. What is the ERP system/accounting software used (or planned to be 
used)? 

Feedback 

Questionnaire 

9. Who is your eInvoicing service provider?  

Feedback 

Questionnaire 

    Comment 

Feedback 

Questionnaire 

10. What are the main services used (or planned to 

Integration with 

Select all that apply 

Questionnaire 

84 

 
 
 
  
  
  
  
  
  
  
be used)?  

ERP system: 

Handling of 
electronic orders, 
dispatch advices: 

Onboarding 
suppliers: 

Technical support 
for suppliers: 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

Invoice validation:  Select all that apply 

Questionnaire 

Compliance testing 
facilities: 

Reporting and 
analytics: 

Compliance with 
eInvoice legal 
requirements: 

Other:  

Would you plan to use an eInvoicing service provider also to fulfil your 
VAT-reporting obligations (based on the legislative proposal on VAT in 
the Digital Age)?  

85 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

Feedback 

Yes/No 

Questionnaire 

Questionnaire 

 
 
 
  
    Comment 

Feedback 

Questionnaire 

11. Do you use or plan to use the European eInvoicing standard? 

Yes/No 

Questionnaire 

    Comment 

Feedback 

Questionnaire 

12. Which format do you use to send elnvoices to 
foreign companies?  

European 
eInvoicing standard 

Select all that apply 

Questionnaire 

13. What eInvoicing formats/syntaxes do you 
support?  

Proprietary format 

Select all that apply 

Questionnaire 

No format 

Select all that apply 

Questionnaire 

Other, please 
specify 

EDIFACT or 
EANCOM 

UN/CEFACT 
XML 

Feedback 

Questionnaire 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

UBL 

Select all that apply 

Questionnaire 

National 
mandatory format 

Select all that apply 

Questionnaire 

86 

 
 
 
  
  
  
Efficiency 

14. What costs do you associate with eInvoicing? 

Setup fee: 

Actual cost 

Other, please 
specify 

Feedback 

Questionnaire 

Actual cost 

Questionnaire 

Questionnaire 

Actual cost 

Questionnaire 

Actual cost 

Questionnaire 

Actual cost 

Questionnaire 

Actual cost 

Questionnaire 

Hardware 
- Once-off cost: 
 - Recurring annual 
cost: 

Software  
- Once-off cost: 
- Recurring annual 
cost: 

Training internal 
staff: 

Legal and 
regulatory 
compliance cost 
(e.g. professional 
advice): 

Service provider 
fees  
- Subscription fees: 
- Transaction fee 
for sending an 
eInvoice: 
- Transaction fee 

87 

 
 
 
    Comment 

15. What are the main eInvoicing benefits 
perceived?) 

for receiving an 
eInvoice:  

vii. Any other cost:  Actual cost 

Feedback 

Questionnaire 

Questionnaire 

Improved 
interoperability in 
supply chains: 

Reduction in 
operating costs: 

Reuse the data, 
such as for digital 
VAT reporting: 

Easier to invoice 
public bodies: 

Easier to invoice 
large enterprises: 

Improved 
efficiency: 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Increased accuracy:  Perception (0:none, 5:high) 

Questionnaire 

Improved data 

Perception (0:none, 5:high) 

Questionnaire 

88 

 
 
 
  
16. What are the main technical challenges?  

quality: 

Enhanced security:  Perception (0:none, 5:high) 

Questionnaire 

Enhanced 
sustainability: 

Other, please 
comment: 

Interoperability 
with trading 
partners: 

Integration with 
service providers: 

Infrastructure and 
connectivity: 

Support for 
multiple eInvoicing 
formats: 

Data security and 
privacy concerns: 

Archiving invoices 
for audit purposes: 

Perception (0:none, 5:high) 

Questionnaire 

Feedback 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Perception (0:none, 5:high) 

Questionnaire 

Other, please 

Feedback 

Questionnaire 

89 

 
 
 
 
Uptake 

17. What percentage of electronic invoices from 
suppliers are processed automatically? 

comment: 

2019: 

2020: 

2021: 

2022: 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

18. Do you send electronic invoices to public entities (B2G)? 

Yes/No 

Questionnaire 

Please enter the number of B2G eInvoices sent by year 
in the European Union  

2019: 

2020: 

2021: 

2022: 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

Number of eInvoices 

Questionnaire 

19. Do you send electronic invoices to enterprises (B2B)? 

Yes/No 

Questionnaire 

Please enter the number of B2B eInvoices sent per year  Domestic 2019: 

Number of eInvoices 

Questionnaire 

Domestic 2020: 

Number of eInvoices 

Questionnaire 

Domestic 2021: 

Number of eInvoices 

Questionnaire 

90 

 
 
 
  
  
Domestic 2022: 

Number of eInvoices 

Questionnaire 

Intra-EU 2019: 

Number of eInvoices 

Questionnaire 

Intra-EU 2020: 

Number of eInvoices 

Questionnaire 

Intra-EU 2021: 

Number of eInvoices 

Questionnaire 

Intra-EU 2022: 

Number of eInvoices 

Questionnaire 

Total 2019: 

Number of eInvoices 

Questionnaire 

Total 2020: 

Number of eInvoices 

Questionnaire 

Total 2021: 

Number of eInvoices 

Questionnaire 

Total 2022: 

Number of eInvoices 

Questionnaire 

20. Do you receive electronic invoices from enterprises (B2B) in the 
European Union? 

Yes/No 

Questionnaire 

Please enter the number of B2B eInvoices received per 
year (if no distinction from domestic and intra-EU can 
be made, please provide totals) 

Domestic 2019: 

Number of eInvoices 

Questionnaire 

Domestic 2020: 

Number of eInvoices 

Questionnaire 

Domestic 2021: 

Number of eInvoices 

Questionnaire 

Domestic 2022: 

Number of eInvoices 

Questionnaire 

91 

 
 
 
  
21. What are the measures that should be taken to 
increase eInvoicing adoption among EU businesses? 
(select all that apply) 

Intra-EU 2019: 

Number of eInvoices 

Questionnaire 

Intra-EU 2020: 

Number of eInvoices 

Questionnaire 

Intra-EU 2021: 

Number of eInvoices 

Questionnaire 

Intra-EU 2022: 

Number of eInvoices 

Questionnaire 

Total 2019: 

Number of eInvoices 

Questionnaire 

Total 2020: 

Number of eInvoices 

Questionnaire 

Total 2021: 

Number of eInvoices 

Questionnaire 

Total 2022: 

Number of eInvoices 

Questionnaire 

• eInvoicing 
functionality built 
into 
ERP/Accounting 
systems: 

• Education and 
awareness: 

• Technical 
support: 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

• Funding: 

Select all that apply 

Questionnaire 

• Earlier payment 

Select all that apply 

Questionnaire 

92 

 
 
 
from customers: 

• eInvoicing used 
for VAT 
Reporting: 

• Mandatory use of 
eInvoicing at 
national level in 
B2G and B2B: 

Select all that apply 

Questionnaire 

Select all that apply 

Questionnaire 

    Comment 

Feedback 

Questionnaire 

• Other: 

Select all that apply 

Questionnaire 

Annex III.3 – Evaluation Matrix Service Providers 

Centered on Service Providers, this matrix evaluates effectiveness, efficiency, EU added value, and coherence. With 45 mapped questions, it assesses 
items such as interoperability challenges and measures to improve collaboration among service providers. It aims to analyse data to address existing 
hurdles and foster more efficient and integrated services across sectors. 

Evaluation 
Criteria 

Evaluation question 

Indicator  

Data sources and 
collection methods 

93 

 
 
 
  
 
 
 
Effectiveness 

Objective 1 – Internal market and interoperability 

To what extent has the European Standard (EN 16931) improved the 
facilitation of cross-border eInvoicing? 

Since the introduction of the EN 16931, to what extent has 
interoperability for cross-border eInvoicing advanced? 

What are the issues still hampering interoperability? 

Please indicate the 
perception: 1 (very low) to 5 
(very high) 

Interoperability achieved with 
other Service/Solution 
Providers: from 0 to 5: 
- Low interoperability  = 0 
- High Interoperability = 5  

Please indicate if the issues 
are related to any of the 
following interoperability 
layers: 

Questionnaire 

Questionnaire 

Questionnaire 

Semantic and Syntax 

Questionnaire 

Technical (incl. transmission)  Questionnaire 

Governance 

Legal 

Questionnaire 

Questionnaire 

Organisational 

Questionnaire 

Other (please describe) 

Questionnaire 

94 

 
 
 
  
  
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
What measures could improve interoperability? 

Feedback 

Questionnaire 

When was your solution EN compliant and ready to process eInvoices? 

Please indicate the indicative 
time (Month / Year) 

Questionnaire 

Has EN 16931 and its mandate in law the potential to increase your 
uptake of clients? 

Please indicate:  
for B2G 1 (very low) to 5 
(very high) 
for B2B 1 (very low) to 5 
(very high) 

Questionnaire 

What would further increase or decrease the uptake e.g. mandating 
business to send, mandate B2B? 

Feedback 

Questionnaire 

How many eInvoices has your organisation exchanged in the B2G sector 
at domestic level?  

number of eInvoices 

Questionnaire 

How many eInvoices has your organisation exchanged in the B2G sector 
at cross-border level?  

number of eInvoices 

Questionnaire 

How many of the B2G eInvoices exchanged are compliant with the EN 
16931? 

Number or percentage of 
compliant eInvoices 

Questionnaire 

How many eInvoices has your organisation exchanged in the B2B sector 
at domestic level? 

Number of invoices 

Questionnaire 

How many eInvoices has your organisation exchanged in the B2B sector 
at cross-border level? 

Number of invoices 

Questionnaire 

How many B2B eInvoices are compliant with the EN 16931? 

Number or percentage of 

Questionnaire 

95 

 
 
 
 
 
 
 
 
 
 
 
 
 
Objective 2 - Reduce complexity and improve clarity and legal certainty 

To what extent has Directive 2014/55/EU and the introduction of the EN 
16931 reduced complexity and increased compliance for eInvoicing 
requirements? 

Indicate: 1 (very low) to 5 
(very high) 

Questionnaire 

compliant eInvoices 

What are they key factors that have contributed to achieving this 
objective? 

Please select one or more of 
the following:  
1. Clear national legal basis;  
2. Less complex technical 
specifications;  
3. Support and Training 
provided at National/EU 
level;  
4. Other (please describe).  
5. N/A 

Questionnaire 

What are the issues that still have to be tackled in this area, especially in 
the area of reducing complexity? 

Feedback 

Questionnaire 

Objective 3 - Lowering operating cost (method) 

Since the introduction of the Directive and the EN 16931, has your 
organisation experienced the expected benefits associated with eInvoicing 
in any of the following areas? 

Please indicate: 
- Operational efficiencies 
- Improved transparency 
- Social benefits 
- Others, please describe 

Questionnaire 

96 

 
 
 
 
  
 
 
 
 
 
 
  
 
 
15.1 What are the drivers behind these benefits? 

Please indicate:  
- process automation 
- common standard 
- less complexity 
- faster/timely processing 
- other (please describe) 

Questionnaire 

Efficiency 

Did your organisation incur costs solely related to transposing the 
Directive and ensuring compliance with EN 16931? 

Yes / No 

Questionnaire 

If so, what were those costs? 

Economic (implementation) costs 

- Purchase software / 
hardware  
- Training costs 
- Change management  
- Test environment 
- Service providers fees 
- Other (please describe) 

Questionnaire 

97 

 
 
 
 
 
 
  
 
 
Social costs 

Environmental costs 

If yes, did the benefits outweigh the costs?  

Have EU funds been used to ensure compliance with the EN 16931 in 
your organisation? 

- Reduced number of staff 
working on mapping; - 
Number of staff redeployed 
in value added activities 

Questionnaire 

- Higher electricity usage due 
to processing power and data 
storage space; 
- Increase in long term of 
electronic waste products;  
- Other (please describe) 

Questionnaire 

Perception: 1 (very low) to 5 
(very high) 

Questionnaire 

- Name of the EU funding 
programme: 
- Requested funding (in 
euro): 
- Year: 

Questionnaire 

To what extent the overall benefits outweighed the costs in your 
organisation? 

Perception: 
1 (very low) to 5 (very high) 

Questionnaire 

For organisations in Member States that use a national format in parallel 
with the European standard 

98 

 
 
 
 
 
 
 
 
 
  
  
Was there a cost burden associated with ensuring the national format 
complied with the European standard? If so, what is the estimated cost? 

Estimated cost 

Questionnaire 

If yes, did the benefits outweigh the costs?   

Yes / No 

Questionnaire 

Why? 

Feedback 

What is the perceived simplification and cost reduction potential of the 
EU intervention (compared to the scenario of the EU taking no action)? 

Perception: 
1 (very low) to 5 (very high) 

Questionnaire 

What measures could the European Commission implement to further 
increase the efficiency of the intervention?  

Feedback  

Questionnaire 

Did you calculate a return on investment (ROI) for eInvoicing in your 
organisation? 

If yes, what was the ROI? 

Yes / No 

ROI value 

Questionnaire 

Questionnaire 

If yes, how many years to recover the cost (ROI) 

Estimated number of years 

Questionnaire 

EU Added Value  Could the objectives of the Directive, in particular EU-wide 

interoperability, be achieved sufficiently by the Member States acting 
alone? 

Yes/No/Some 

Questionnaire 

In the absence of EU level action, to what extent would your Government 
have had the ability or possibility to put in place appropriate measures to 

Perception: 1 (very low) to 5 
(very high) 

Questionnaire 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
achieve the objectives? 

In case the initial problem and its causes (e.g. multiple eInvoicing formats 
and non-interoperable systems) varied across the national, regional and 
local levels, did the EU level action help establish a level playing field? 

Yes/No/Some 

Questionnaire 

Were there significant cross-border aspects being tackled, such as 
facilitating cross-border eInvoicing (either in B2G and B2B) and/or 
public eProcurement by the Directive? 

feedback 

Questionnaire, 
Eurostat 

Could these be quantified? 

Were there clear benefits from EU level action? 

% change of cross-border 
eInvoices, and/or % change 
of cross-border tenders  

Questionnaire, 
Eurostat 

Perception:  1 (no clear 
benefits) to 5 (very clear 
benefits) 

Impact Assessment 

If yes, please describe them 

Feedback 

Questionnaire 

What is the additional value resulting from the introduction of the 
Directive and the EN 16931, compared to what could have reasonably 
been achieved (in terms of effectiveness and efficiency) by Member States 
acting at national and/or regional levels? 

Feedback 

Questionnaire, Desk 
Research 

Did you find the EU supporting initiatives that were put in place 
beneficial? 

Which of the EU supporting initiatives that were put in place did you find 
beneficial? 

Yes / No 

Questionnaire 

Select all the applicable ones:  
1. CEN/TC 434 Development 
of the EN 

Questionnaire 

100 

 
 
 
 
 
 
 
 
 
 
 
2. EMSFEI (European Multi 
Stakeholder Forum on 
eInvoicing 
3. EU funding to public and 
private stakeholders 
4. CEF eInvoicing Test Bed 
5. CEF eDelivery Test Bed  
6. EC eInvoicing Support 
Desk  
7. CEF Stakeholder 
Management Office 
8. Other (please describe) 

Were there EU economies of scale and services sharing (larger benefits 
per unit cost)?  

Yes / No 

Questionnaire, Desk 
Research 

Were there benefits in replacing different national policies and rules with 
a more homogenous policy approach? 

Perception  1 (very low) to 5 
(very high) 

Questionnaire, Desk 
Research 

Is it still valid today to assume that the objectives of the Directive 
2014/55/EU can best be met by action at EU level? 

Yes / No 

Questionnaire, Desk 
Research 

Has the reduction in complexity allowed for a more streamlined 
workforce? If yes, has this afforded your organisation more opportunities 
for innovation? 

Coherence 

To what extent do the needs/problems addressed by the Directive 
2014/55/EU continue to require action at EU level? 

Perception  1 (very low) to 5 
(very high) 

Questionnaire + 
Interview with SP 

Please describe the needs and the problems that are still relevant in your 

Feedback 

Questionnaire + 

101 

 
 
 
 
 
 
 
  
  
 
organisation in the eInvoicing context (B2G and B2B), if any. 

Interview with SP 

To what extent did the scope (B2G eInvoicing) and the main three 
objectives of the EU intervention remain relevant over the 
implementation period in your organisation? 

Perception  1 (very low) to 5 
(very high) 

Interview with SP; 
Desk Research 

To what extent have the circumstances changed in the meantime, so much 
that the provisions of the Directive have to be adapted to future needs and 
trends (e.g. increased digitisation; use of eInvoicing compliant with the 
EN 16931 for VAT reporting of intra-EU transactions; etc.)? 

Perception  1 (very low) to 5 
(very high) 

Interview with SP; 
Desk Research 

How well adapted is the Directive and the EN 16931 to the technological 
advances that have appeared since its introduction? 

Perception  1 (very low) to 5 
(very high) 

Interview with SP; 
Desk Research 

How well adapted is the Directive and the EN 16931 to the UN 
Sustainable Development Goals? 

Perception  1 (very low) to 5 
(very high) 

Interview with SP; 
Desk Research 

How did the objectives of the EU intervention (legislative or spending 
measure) correspond to wider EU policy goals and priorities? 

Feedback 

Internal analysis 

To what extent is this intervention consistent with other EU and national 
interventions that have similar objectives to: 

- Improving interoperability 

- Fostering the Internal Market 

- Reducing complexity 

Perception  1 (very low) to 5 
(very high) 

Questionnaire + Desk 
research 

Perception  1 (very low) to 5 
(very high) 

Questionnaire + Desk 
research 

Perception  1 (very low) to 5 
(very high)) 

Questionnaire + Desk 
research 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
- Improving legal certainty 

- Lowering operating costs for economic operators 

Perception  1 (very low) to 5 
(very high) 

Questionnaire + Desk 
research 

Perception  1 (very low) to 5 
(very high) 

Questionnaire + Desk 
research 

103 

 
 
 
 
 
  
 
 
 
 
 
ANNEX IV. OVERVIEW OF BENEFITS AND COSTS  

This  annex  provides  an  overview  of  eInvoicing  cost-benefits,  results  of  desk  research  conducted  on  eInvoicing  pricing  models  and  fees  offered  by 
commercial operators and results from SMEs survey conducted as a part of the stakeholder consultation in relation to the eInvoicing costs? They have 
incurred, if any.  

The public sector is responsible for 15-18% of all purchases in a country. It represents typically 9-15% of a country’s inbound and outbound invoices52.  

The annual invoice volume was estimated to reach 36 billion invoices in 2016, 50% of the complete volume were B2G and B2B invoices53. Each year 18 
billion B2B and B2G invoices were sent within EU54.  B2G volumes are estimated between 3.24 and 5.4 billion in Europe.  

The  analysis  indicates  the  benefits  of  automation  per  eInvoice  issued  of  EUR  5.28  and  EUR  8.4  per  eInvoice  received,  when  labour  cost  per  hour  is 
estimated at EUR 46. 

The results of the SME survey show that costs vary depending on the package they select and the volumes of eInvoices handled.  Free-of-charge are also 
available. All the SMEs surveyed have purchased eInvoice packages at fixed yearly costs while three SMEs purchased eInvoice packages with fixed costs 
and variable fees depending on transaction volumes. Pricing per eInvoice transaction range 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).  

52 Billentis, The International E-Invoicing market development and the role of key stakeholders, Forum Elektronicznego Fakturowania, 23rd October 2012. 
53 https://www.ecb.europa.eu/paym/intro/mip-online/2016/html/mip_qr_1_article_4_e-invoicing.en.html 
54 Https ://www.ecb.europa.eu/paym/intro/mip-online/2016/html/mip_qr_1_article_4_e-invoicing.en.html  

104 

 
 
 
 
 
 
 
Table 1. Overview of costs and benefits identified in the evaluation55 

Businesses  

Administrations 

Quantitative  

Qualitative 

Quantitative  

Qualitative 

[Cost or Benefit description]: 

Mark the type of cost/benefit, 
each on a separate line: 

Costs: 

Direct compliance costs 
(adjustment costs, administrative 
costs) 

Type: 
Choose 
one-off or 
recurrent 

Benefits: 

Pricing models for 
eInvoicing services and 
solutions vary. They include 
the following categories: 
-  Use based 
-  Transactions based 
-  Recurrent 

subscription fees 
Functionality based 
Pay per use 

- 
- 

Direct compliance costs vary 
per category and Member 
State. 

Costs range from EUR 145 
000 (in Lithuania) to EUR  
6 100 000 in Poland. 

The adjustment costs include: 
software, hardware, training, 
change management, test 
environment, service providers’ 
fees. 

The administrative costs 
include: legal and solution 
analysis, publicity, user guides, 
support, security audit, Peppol 
membership fee. 

55 Where there is a prior impact assessment, the table should contain as a minimum the costs/benefits identified in the IA with  the information gathered on the actual cost/benefit. As available, the table 
should  include  the  monetisation  (EUR  )  of  the  costs/benefits  based  on  any  quantitative  translation  of  the  data  (time  taken,  person  days,  number  of  records/equipment/staff  etc.  affected  or  involved 
represented in monetary value  – see Standard cost model, for example). For all information presented, it should be included in the comments section whether it relates to all Member States or is drawn 
from a subset. An indication of the robustness of the data should be provided in Annex II on Methodology and analytical models used. 

105 

 
 
 
 
 
 
 
 
 
                        
 
 
 
 
 
 
 
 
Direct benefits: costs and time 
savings. 

Indirect benefits: increased data 
quality and process optimisation.  

Benefits of automation per 
eInvoice issued of EUR 5.28 and 
EUR 8.4 per eInvoice received. 

Benefits of automation per 
eInvoice issued of EUR 5.28 
and EUR 8.4 per eInvoice 
received. 

The results of the survey for multinational corporations show that for one of them, the set-up costs for establishing eInvoicing in different EU Member 
States are significant (EUR 180 000 per country) and require the use of different service providers to cover specific national requirements. A transaction-
based  pricing  model  is  used  by  one  of  the  multinational  corporations  (EUR  0.40  per  eInvoice).  Recurring  costs  vary  significantly.  One  of  the 
multinationals only used internal resources for eInvoicing. A multinational stated that an impact assessment will be launched once the B2B eInvoicing 
legislation will be finalised and clear in all the Member States. 

The results of the desk research show that in transaction-based pricing models, the pricing ranges between EUR 0.01 – EUR 11 per eInvoice. Free-of-
charge  packages  with  basic  eInvoicing  functionalities  are  offered  by  service  providers  in  most  of  the  Member  States  analysed  (with  the  exception  of 
Portuguese service providers surveyed).  

eInvoicing implementation costs vary based on the complexity of the project which typically takes into account the number of formats to be supported, 
related  mapping  and  conversion  services,  transmission  protocols  and  value-added  services.  In  general,  pricing  for  transaction  volumes  decreases 
proportionally  with  the  increase  in  eInvoicing  volumes,  thus  resulting  in  a  few  eurocents  (between  EUR  0.01  -  EUR  0.30)  per  eInvoice  for  large 
eInvoicing volumes (from 10 000 to 500 000 eInvoices). 

eInvoicing cost-savings models 
This section of the annex analyses selected eInvoicing cost-benefit models in order to assess the results in terms of cost savings of each model and the 
rationale they are based on. 

Three models have been taken into account to assess eInvoicing-related cost benefits: 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
1.  Standard Cost Model – University of Hasselt 
2.  Process-based cost analysis – Billentis 
3.  Time-based model – Visma.  

These models have been chosen for this study in order to estimate any savings experienced with the introduction of (structured) eInvoicing as opposed to 
unstructured invoicing methods and to distinguish between the savings for the issuer and the savings to the receiver.  

Standard Cost Model 
In a study conducted at the University of Hasselt in 2014 56, the Standard Cost Model (SCM)57 has been used to determine the costs that a company may 
save using eInvoicing. The SCM was applied to the eInvoicing adoption in Belgium between 2012 and 2014. 

The SCM measured the opportunity cost of complying with information obligations (i.e. the time spent and the hourly tariff) as well as other ‘out-of-
pocket’ costs (e.g. postal costs, printing costs, etc.) regarding the sending and receiving of eInvoices. 

Calculations performed under this model include the five following administrative steps that a business will undertake:  

1.  data collection  

2.  drafting the invoice using accounting software 

3.  printing the invoice and preparing the envelope 

4.  sending the invoice by mail 

5.  archiving the invoice. 

56 Kevin Poel, Marneffe, W., Vanlaer, W., Assessing the electronic invoicing potential for private sector firms in Belgium, the International Journal of Digital Accounting Research, Vol. 16, 2016, pp. 1 – 34. 
57 The Standard Cost Model is a method for determining the administrative burdens for businesses imposed by regulation. It is a quantitative methodology that can be applied in all countries and at different levels. 

107 

 
 
 
 
 
 
The  authors  of  the  research  assumed  that  the  time  to  complete  these  5  steps  for  a  single  invoice  amounted  to  8  minutes  and  the  out-of-pocket  costs 
amounted to  EUR  0.76 /invoice (cost  of the postal  stamp) with  an hourly administrative employee’s tariff of  EUR  35.21/invoice, the issuing  of 1000 
invoices brought the authors of the study to the following calculations:  

P = Tariff x Time = ((EUR 35.21 * 8 min)/60) + EUR 0.76 = EUR 5.45 

Q = (Number of businesses * Frequency) = (1 * 1,000) = 1,000 

Administrative Burden = ∑ P x Q = EUR 5.45 * 1,000 = EUR 5,455 

Using the Standard Cost Model (SCM), an estimate was made for the (total) amount of administrative cost burdens of invoicing for the Belgian private 
sector and citizens.  

Within the scope of that research, the average cost per B2B and B2C invoice was also calculated for both issuers and receivers. In total, according to the 
calculation, each B2B eInvoice saved EUR 9.01 and each B2C eInvoice saved EUR 5.32. 

Type of transaction 

Paper invoice issue 

eInvoice issue 

E-mail invoice issue 

Cost savings eInvoice issue 

Cost savings e-mail issue 

Paper invoice receiving  

eInvoice receiving 

B2B Invoice (EUR) 

B2C Invoice (EUR) 

4.44  

1.20  

2.02  

3.24 

2.42 

8.04 

2.27 

4.44  

1.20  

2.02  

3.24 

2.42 

2.77 

0.69 

108 

 
 
 
 
 
 
E-mail invoice receiving 

Cost savings  eInvoice receiving 

Cost savings e-mail invoice receiving 

Total cost savings eInvoicing  

Total cost savings e-mail invoicing 

7.68 

5.77 

0.36 

9.01 

2.80 

Table 10 Paper and electronic invoice cost per unit for our sample 

Key findings 

1.73 

2.08 

1.04 

5.32 

3.46 

•  Cost savings per eInvoice issued compared to a paper invoice in B2B is estimated at EUR 3.24.   
•  Cost savings per eInvoice received compared to a paper invoice in B2B is estimated at EUR 5.77. 
•  Average labour cost/hour: EUR 35.21/hour. 

The calculations conducted through SCM have shown that, eInvoicing saves 54.5% of issuing costs, 71.77% of receiving costs, and 72.2% of total costs. 

Billentis 
The second model chosen for this report is a study prepared by Billentis in 2017. The author of the model analysed the situation in an industry company 
with  5  000  employees,  based  on  calculated  staff  costs  of  EUR  60/hour  (full  costs  including  overhead,  working  place,  etc.).  The  full  costs  based  on 
traditional paper-based processes were analysed and compared with the new electronic automated solution58. 

58European  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, p. 166. 

109 

 
 
 
 
 
 
 
 
 
 
 
The following table presents the cost savings per eInvoice issued. 

Costs per invoice (EUR) 

Archiving 

Remittance and cash management 

Payment reminders 

Print, envelope send 

Full costs 

Paper 

2.20 

4.50 

0.50 

3.90 

11.10 

Electronic, automated 

0.80 

3.00 

0.40 

0 

4.50* 

Table 12 Saving potential for invoice/bill issuers (actual customer case) 

* + 0,30 EUR of third-party processing costs 

Average saving per invoice 

EUR 6.60 = 59% 

The following table presents the cost savings per eInvoice received. 

Costs per invoice (EUR) 

Paper 

Electronic, automated 

110 

 
 
 
 
 
 
 
 
 
Archiving 

Payment and cash management 

Dispute management 

Validation and matching 

Full costs 

Entering codification 

Receive 

Full costs 

2.20 

4.80 

2.50 

4.00 

11.10 

3.00 

1.10 

17.60 

0.80 

2.00 

2.00 

1.30 

4.50 

0 

0 

*6.40 

Average saving per invoice 

EUR 11.20 = 64% 

Table 13 Saving potential for invoice/bill recipients (actual customer case) 

+ EUR 0.40 of a service provider processing cost 

Key findings 

•  Cost savings per eInvoice issued compared to a paper invoice is estimated at EUR 6.60.   
•  Cost savings per eInvoice received compared to a paper invoice is estimated at EUR 11.20. 
•  Average labour cost/hour: EUR 60/hour. 

Visma 

The third model chosen for this report is the business case on eInvoicing cost savings published by Visma in 2019, conducted for the Nordic countries. 

111 

 
 
 
 
In the analysis,  savings for issuers were calculated by multiplying the number of non-electronic invoices by  EUR 6, which is  the assumed saving per 
eInvoice issued by the businesses. It was done based on the gross number on savings estimated at EUR 6.90 in 2015. For calculation purposes the sum of 
EUR 6 was used with an assumption that there is no free-of-charge eInvoicing solution and there are transaction costs attached. For that purpose EUR 
0.90 was used.  

The  estimate  of  savings  for  receivers  is  time-based.  The  time  it  takes  to  receive  a  paper  invoice  and/or  scanned/OCRed  invoice  was  estimated  and 
compared to full manual handling for this process. Labour cost per country was also included59.  

Norway 

Sweden 

Denmark 

Finland 

Invoices total amount 
(sent) 

612 600 000 

1 400 000 000 

630 000 000 

831 818 500 

Share B2B/B2G (40%) 

245 040 000 

560 000 000 

252 000 000  

332 727 400 

eInvoices  

B2B/B2G 

95 565 600 

196 000 000 

100 800 000 

243 900 000 

Invoices non-electronic 
(Paper, email) 

B2B/B2G 

149 474 400 

364 000 000 

151 200 000 

88 827 400 

2 504 606 400 

6 337 200 000 

2 575 200 000 

1 332 411 000 

Savings for issuers 
(EUR  6/invoice) 
assuming converting 
all paper to digital 

59 Visma, Business case: E-invoicing Across the Nordics, September 2019 

112 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
invoices 

Savings for receivers 
assuming converting 
all non-electronic to 
digital invoices 
(average EUR 8.30 
/eInvoice)  

Annual potential 
saving (Euros) 

Cross Nordic business 
case annual savings – 
Nordic countries 
combined in Euros 

1 724 602 182 

2 822 191 103 

1 337 932 073 

449 959 336 

4 229 208 582 

9 159 391 103 

3 913 132 073 

1 782 370 336 

19 084 102 094 

Table 14 Detailed eInvoicing cost savings per country in the Nordics 

Country 

Norway 

Sweden 

Denmark 

Finland 

Average 

Cost of labour per hour (EUR) 

Savings per eInvoice received (EUR) 

60 

40 

46 

26 

43 

11.54 /eInvoice 

7.75 /eInvoice 

8.85 /eInvoice 

5.07 /eInvoice 

8.30/eInvoice 

Table 15 eInvoice receiving cost savings per country in the Nordic region 

Key findings 

•  Cost savings per eInvoice issued compared to a paper invoice is estimated at EUR 6.   
•  Cost savings per eInvoice received compared to a paper invoice is estimated at EUR 8.30. 

113 

 
 
 
 
 
 
 
•  Average labour cost/hour: EUR 43 per hour 

Conclusions  
The analysis by Billentis (2017) correlates with the findings in absolute values of Visma (2019), indicating savings per eInvoice received ranging from 
EUR 11.22 - EUR 11.45 when labour cost per hour is estimated at EUR 60.  The comparison of the Billentis model with the SCM proposed by the 
University of Hasselt shows significant correlation in terms of percentages, with a margin of 5-8%.   

Savings by category (%) 

Standard Cost Model 

Billentis 

Issuer costs savings  

Receiver costs savings  

54.5% 

71.77% 

59% 

64% 

Table 16 SCM and Billentis cost saving comparison 

The analysis indicates the benefits of automation per eInvoice issued of EUR 5.28 and EUR 8.4 per eInvoice received, when labour cost per hour is estimated at EUR 46. 

eInvoicing pricing models and fees 

Pricing models and fees for 31 service providers from Estonia, France, Germany, Italy, Portugal Spain, and Sweden have been analysed in this section of the study. The information was gathered from public sources, official 
webpages of the service providers in the selected Member States. 

These pricing models and fees have then been compared to the results from the survey for SMEs, as part of the stakeholder consultation conducted for this study to benchmark the data collected. 

Pricing Models  
Throughout the analysed service providers, four pricing models have been indicated.  

•  User-based 

13 service providers (42%) included user-based pricing. The price charged depends on the number of users that use the solution.  

•  Transaction-based  

10  service  providers  (32%)  included  a  charge  per  transaction.  This  model  has  pricing  depending  on  the  number  of  eInvoicing  transactions 
executed.  

114 

 
 
 
 
•  Recurrent subscription fees  

This fee is charged per year or month and often includes a number of eInvoice transactions bundled in the price. 

•  Functionality-based 

This pricing model is applied by 7 service providers (23%). Pricing depends on the features required by the customer. The more advanced the 
features, the higher the fee will be.  

•  Pay per use 

One package (in Estonia) is priced according to the ‘pay as you go’ model. This model allows access to unlimited resources, but the payment is 
made based on what is actually used. 

Although, these basic models are present in the majority of cases, service providers may also offer a mix of pricing models within the same package. 

Example of eInvoicing packages  

Package I 
Target: Self-employed and micro-enterprises with limited eInvoicing needs.  

Features: typically, these enterprises avail of the national platforms that are provided free of charge in many countries. They may also avail of free-of-
charge packages – see below. 

Package II 
Target: Small enterprises with small volumes of eInvoicing. 

Features: typically, packages from this category include the features of the first category with sending and receiving capacities for European standard 
eInvoices, full Peppol connectivity, PDF conversion into a structured format, and larger archiving capacities. 

Package III 
Target: Medium and large enterprises with high volumes of eInvoicing. 

Features: typically, they offer very low transaction-based fees for very high invoicing volumes, plus a recurrent subscription fee. They will also typically 
integrate with ERP systems and therefore incur set-up costs, which vary greatly depending on the complexity of the implementation. 

115 

 
 
 
Package IV 

Target: Tax payer with flat rate tax regime (Italy). 

Features: the service provider is an accountant who provides added value services such as computerised accounting, bookkeeping, and archiving.  When 
upgrading to an eInvoice system, the cost would be proportionally larger. In one case, in Italy, the accountant charged a fee of EUR 400 per annum for 
sending and receiving less than 20 eInvoices per year.  

In the sample analysed, 20 service providers (65%) offer the three above-mentioned packages. 9 service providers (29%) offer 4-6 packages. 3 service 
providers offer 1-2 packages.  

User-based pricing models 
The following table presents the monthly pricing range and average monthly fee for pricing models based on the number of users in the selected Member 
States. The average monthly fee takes into account all the packages within the pricing range. 

Country 

Estonia 

Sweden 

France 

Germany 

France 

Spain* 

Italy 

Monthly pricing range (EUR per user) 

8 – 199  

21 – 69  

3.7 - 36 

0.75 - 30  

6.6 - 99 

30 - 5 229  

2 - 120 

Table 17 Monthly pricing range of user-based pricing models in selected Member States 

* In Spain, service providers offer solutions within the framework of a national subvention policy “Kit Digital” that covers eInvoicing services for micro and small enterprises (up to 49 employees). 

116 

 
 
 
Transaction-based pricing models 

The following table presents the pricing range and average fee for transaction-based pricing models in the selected Member States.  

Country 

Estonia 

Sweden 

Portugal 

Germany 

France 

Spain 

Italy 

Pricing ranges (EUR per eInvoice) 

0.05 - 0.40  

0,3060 

0.22 – 2.40  

0.01– 0.50 

0.11 – 1.14  

0.68 – 11  

0.12 – 0.5 

Table 18 Pricing range and average fee for transaction-based pricing models in selected Member States 

Free-of-charge packages 
In Estonia, free-of-charge packages may include a limited number of eInvoices issued, up to 5 eInvoices per month. Also, it may include sending 
capability for up to 12 month under specific conditions. Finally there is a free solution offering unlimited sending/receiving of eInvoices solely based on 
the national standard. 4 out of 5 service providers analysed provide free-of-charge packages. 

In France and Germany, free-of-charge offers include capability to send and receive eInvoices for up to 5 users.  

60 Source: EC eInvoicing webinar with Swedish stakeholders, 15th June 2023. 

117 

 
 
 
 
 
In Spain, a free-of-charge solution may offer unlimited national and Peppol-based eInvoice sending capability for 1 user, as well as eInvoice receiving 
within the same service provider network.  

In Sweden, a service provider offers a free-of-charge service only in the following context: when a business receives a letter from a service provider on 
behalf of a customer requesting them to use eInvoicing, the customer may cover the service provider’s fees. In this case, the service is free of charge for 
the supplier up to 100 eInvoices sent to the client. 

In Italy, in addition to free-of-charge solutions provided by service providers, the Chamber of Commerce, the National Software Association also offer 
free-of-charge solutions. 

In Portugal, none of the service providers analysed provides free-of-charge services. 

Free-of-charge eInvoicing services provided by Member States 

Member State 

Service 

Austria 

Belgium 

Croatia 

Czechia 

Denmark 

Estonia 

Finland 

Delivery of eInvoices to this service (E-Rechnung.gv.at) is free of charge for the user. (Factsheet) 

Mercurius Web Portal. 

Servis eRačun za državu platform 

The national platform is Národní elektronický nástroj (NEN). 

The NemHandel platform exchanges eInvoices in B2G eInvoicing. 

Estonian Ministry of Finance and RIK have agreed that businesses can use e-Financials free from charge for 
one year 

Three platforms provided free-of-charge, by the State Treasury: Handi, Basware Supplier Portal, or Post 
Network Service. 

118 

 
 
 
 
France 

Germany  

Hungary 

Italy 

Chorus Pro Portal is the national platform for central and sub-central contracting authorities. 

E-Rechnungs-Portal is used for eInvoicing with the federal government. 

NAV is the centralised national platform used for real-time eInvoicing reporting. 

The Revenue Agency has put in place free services to support the onboarding process of SMEs and to facilitate 
the process of transmission and archiving of eInvoices. 

Lithuania 

The central platform is eSaskaita.  

Poland 

Portugal 

Slovenia 

Spain 

The National eInvoicing platform (PEF) 

The Plataforma Eletrónica de Compras, a cost-free platform. 

The national platform is PPA eInvoicing system 

Free eInvoicing client software is provided by the Spanish Ministry of Industry. 

Table 19 Free-of-charge eInvoicing services provided by Member States 

SME survey 

This section includes the results of the SMEs survey in relation to the costs reported for eInvoicing services and solutions. The survey involved 63 micro, 16 medium, 18 small sized companies and 1 did not state its size.  48 
companies are based in Spain, 17 in Belgium, 8 in Italy, 6 in Germany, 1 in Estonia, 12 in Sweden and 4 in France.  

Country 

Size 

No. 

Intra EU 

Recurring  yearly fee: 

Recurring yearly fee: 
Software 

Recurring yearly fee: 
Hardware (EuR) 

No. recurring fees 

Cost per eInvoice 
France 

Package (EUR) 

France 

Belgium 

Micro 

Medium 

Micro 

3 

1 

14 

1 

1 

5 

100x1 

120 x1 

80x1 

(EUR) 

2 500x1  

1 200x1 

119 

2 500x1  

0 

0 

0 

7 

 
 
 
 
 
 
 
 
 
Country 

Size 

No. 

Intra EU 

Recurring  yearly fee: 

Recurring yearly fee: 
Software 

Recurring yearly fee: 
Hardware (EuR) 

No. recurring fees 

Cost per eInvoice 
France 

Package (EUR) 

Spain 

Small 

Medium 

3 

10 

2 

2 

Micro 

28 

6 

Small 

9 

1 

300x1 

360x1 

100x1 

120x2 

121x1 

300x1 

18x1 

100x4 

120x3 

121x3 

300x1 

500x1 

100x1 

121x1 

150x1 

(EUR) 

50x1 

120x1 

121x1 

300x1 

54x1 

120x1 

150x1 

200x1 

600x1 

1 000x1 

100x1 

120x1 

121x1 

300x1  

1 500x1 

120 

400x1  

130x1 

3 500x1 

27.78x1 

100x1 

120x1 

300x1 

2 000x1 

100x1 

900x1 

1 

0 

0 

0 

0 

 
 
 
 
 
 
 
 
 
Country 

Size 

No. 

Intra EU 

Recurring  yearly fee: 

Recurring yearly fee: 
Software 

Recurring yearly fee: 
Hardware (EuR) 

No. recurring fees 

Cost per eInvoice 
France 

Germany 

Small 

Estonia 

Italy 

Sweden 

Medium 

Micro 

Micro 

Medium 

Micro 

Small 

Medium 

Micro 

2 

1 

3 

1 

2 

1 

1 

2 

9 

1 

1 

0 

0 

1 

1 

1 

1 

Table 19 SME recurring eInvoicing costs 

Large enterprises (LE) survey 

The following information was provided by 4 multinational corporations.  

0 

0 

0 

0 

0.05x1 

0 

0 

 0.40x1  

0.30x1  

1 

1 

5 

Package (EUR) 

(EUR) 

300x1 

100x1 

100x1 

100x1 

100x1 

120x1 

2 500x1 plus 0.05 per 
eInvoice  

1 300x1 

1300x1 

150x1 

120x1 plus 0.4 per eInvoice 
sent 

500x1 

150x1 

100x1 

150 x1 

550 x1plus 0.30 per 
eInvoice sent 

450x1 

121 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
LE1:  

•  Service Provider annual fee: EUR 500, no fees per transaction. 
•  Setup costs: EUR 5 000 (one-off) 
•  Training: EUR 2 000 (one-off) 
•  Legal advice: EUR 2 000 (one-off) 
•  Hardware: EUR 10 000 (one-off) 
•  Software: EUR 5 000 (one-off) 
•  Recurring hardware costs: EUR 500 
•  Recurring software costs: EUR 500 

LE2:  

•  Recurring costs: EUR 400 000 (different service providers) 
•  Set-up costs: EUR 180 000 per country 

LE3:  

•  Transaction-based pricing model: EUR 0.40 per eInvoice  
•  No annual fees 

LE4:  

• 

Internal costs only  

A multinational stated that an impact assessment will be launched once the B2B eInvoicing legislation will be finalised and clear in all the Member States.  

122 

 
 
 
 
 
 
 
 
 
ANNEX V. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

The stakeholder consultation activities aimed to quantitatively and qualitatively evaluate the impact of the Directive. Surveys directed at Member States, 
EEA  members,  SMEs,  and  large  enterprises,  gathering  insights  on  the  Directive's  effects  were  conducted.  In  addition,  professional  associations  and 
eInvoicing service providers (Peppol and GENA) provided data, and an ERP vendor was interviewed. The European Commission conducted a Call for 
Evidence61 and an additional online survey. The detail of such activities can be found below: 

•  Member States and EEA members were asked to respond to a survey: The objective was to gather quantitative and qualitative information to 
support an evidence-based assessment on the effects of Directive. 23 Member States responded to the survey. National authorities from Iceland 
and  Norway  also  provided  feedback.  Four  Member  States  did  not  respond,  including  Hungary,  Bulgaria,  Slovakia,  and  Spain.  However,  the 
Hungarian Prime Minister Office provided limited feedback to the survey. 

•  A survey targeted to SMEs was published: 100 SMEs responded. These enterprises were based in Spain, Germany, Italy, Belgium, Sweden, 

and France. There were 60 micro, 16 medium, 15 small and seven did not state their size. 

•  A survey targeted to large enterprises was also published: Seven responded. These were multi nationals that included sectors, such as Energy, 

Chemical, Retail, and International Shipping. 

•  Professional associations have also been consulted to gather more quantitative data on the uptake of eInvoicing and to use it to triangulate data 

received by national authorities in Member States.  

o  Seven Peppol service providers responded that they provide services to Denmark, Germany, Italy, Sweden, Netherlands, and Poland. The 

largest provider consulted handled over 22 million eInvoices per year. 

61 https://single-market-economy.ec.europa.eu/news/commission-seeks-views-evaluation-eu-rules-electronic-invoicing-public-procurement-2023-03-17_en, n.d. 

123 

 
 
 
 
 
o  Eight  service  providers  from  GENA  responded  who  provided  services  in  Croatia,  Slovenia,  Romania,  Belgium,  Portugal,  Estonia, 

Sweden, Norway, and Hungary. Among these, the largest service provider consulted handled 80 million eInvoices per year. 

•  An ERP vendor has been interviewed. 
•  A Call for Evidence62 was launched by the European Commission from 17 March until 14 April 2023. The consultation related to the uptake of 
eInvoicing in public procurement, the effects of the Directive on the Internal Market and its degree of success in meeting the objectives. A total of 
24 responses were received. The results of the Call for Evidence are summarised below63. 

62 https://single-market-economy.ec.europa.eu/news/commission-seeks-views-evaluation-eu-rules-electronic-invoicing-public-procurement-2023-03-17_en, n.d. 
63 Public procurement – EU rules on electronic invoicing in public procurement (evaluation) (europa.eu). https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13669-Public-procurement-EU-rules-on-electronic-
invoicing-in-public-procurement-evaluation-/feedback_en?p_id=31908659 

124 

 
 
 
 
 
Figure 12 Call for evidence by category of respondent 

•  The graph illustrates respondent categories: EU citizens represented the highest participation with 7 respondents, followed by business 
associations  (5),  company/business  (4),  public  authorities  (4),  NGOs  (2),  academic/research  institutions  (1),  and  one  response 
categorised as 'Other.'. 

125 

 
 
 
 
 
Spain

Finland

Ireland

Iceland

Italy

Latvia

Sweden

Belgium

Germany

Netherlands

Slovakia

France

Call for evidence by country

1
1
1
1
1
1

2

3
3
3
3

0

1

2

3

4

4

Figure 13 Call for evidence by country 

•  The  graph  depicts  the  response  distribution  by  the  number  of  responses  received  by  country.  France  led  with  4  responses,  followed  by 
Slovakia, Netherlands, Germany, and Belgium, each with 3. Sweden had 2 responses, while Latvia, Italy, Iceland, Ireland, Finland, and Spain 
each contributed 1 response. 

•  An additional online survey open to all stakeholders was carried out in the context of the Call for Evidence: It was conducted from 5 
May 2023 to 30 June 2023 and collected a total of 36 responses. This was a simplified version of the Call for Evidence. These responses have 
predominantly  come  from  Small  and  Medium-sized  Enterprises  (SMEs),  service  providers,  and  business  associations,  highlighting  the 
valuable perspectives and insights from key stakeholders in the field.  

126 

 
 
 
 
 
Additional online survey by type of organisation

Accounting organisation

Business association

EU public sector organisation

Large corporation

Other

SME

Solution/service provider

3%

3%

11%

17%

14%

22%

22%

Member State public sector organisation

8%

0%

5%

10%

15%

20%

25%

Figure 14 Additional online survey by category of respondent 

•  The graph illustrates diverse participation: SMEs and solution/service providers accounted for the highest at 22% each, followed by business 
associations  (17%),  large  corporations  (14%),  accounting  organizations  (11%),  Member  State  public  sector  organizations  (8%),  with  EU 
public sector organizations and 'Other' representing 3% each. 

127 

 
 
 
 
 
 
 
Additional online survey by country

11%

8%

11%

3% 3%

3%

3%

3%

3% 3%

3%

3%

6%

6% 6%

6%

6%

17%

18%
16%
14%
12%
10%
8%
6%
4%
2%
0%

Figure 15 Additional online survey by country 

•  The graph depicts the response distribution by the number of responses received by country. Belgium and Sweden stood out with 17% of the 
responses each, followed by Germany and Sweden with 11% each, while Denmark held 8%. The Netherlands, Romania, and Spain, Italy and 
multiple other countries accounted for 6% each, and the rest held 3%. 

•  Lastly,  communications,  such  as  emails  or  letters  addressed  to  the  Commission,  from  stakeholders  have  also  been  received  by  the 

European Commission after the entering into force of the Directive. The related information has been reflected by this study.  

128 

 
 
 
 
 
 
 
ANNEX VI. CASE STUDIES AND COUNTRY PROFILES  

Four  Member  States  including  France,  Italy,  Croatia,  and  Finland  are  analysed  in  this  Annex,  in  relation  to  the  evaluation  criteria  of  effectiveness, 
efficiency, coherence, EU added value, and relevance. Challenges and solutions are discussed, particularly future challenges that need to be addressed.  

1.1 France 

Responsible 

Ministry for the Economy and Finance (policy making) and Agency for State Financial Information (AIFE) (implementation and maintenance). 

Legal Framework  

•  Ordinance No. 2014-69764 of 26 June 2014 on the development of electronic invoicing 
•  Business Growth and Transformation law - PACTE65 (Law’s final text adopted since 11 April 2019) 
•  Decree No 2019-748 of 18 July 2019 on electronic invoicing in public procurement66, Official publication: Journal Officiel de la République 

Française (JORF); Publication date: 2019-07-21. 

•  Article 153 off the French law 2019-147967 prepares France to move to an obligation to send and receive B2B electronic invoices. 
•  Ordinance n°2021-1190 of 15 September 202168 on the generalisation of electronic invoicing in transactions between taxable persons for value 

added tax and the transmission of transaction data. 

64 https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000029140226&categorieLien=id  
65 https://www.gouvernement.fr/en/pacte-the-action-plan-for-business-growth-and-transformation  
66 https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000038793215&categorieLien=id  
67 
https://www.legifrance.gouv.fr/affichTexteArticle.do;jsessionid=9359FBB55B3F3B6C7BB7248CBDAF37A0.tplgfr32s_3?idArticle=JORFARTI000039684090&cidTexte=JORFTEXT000039683923&dateTexte=29990101&categ
orieLien=id  
68 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000044044176?init=true&page=1&query=facturation+electronique&searchField=ALL&tab_selection=all  

129 

 
 
 
 
 
B2G eInvoicing mandates: 

•  Receiving and processing: Central authorities, regional authorities & local authorities 
•  Submitting: Economic Operators 

Standard/format  
The European standard on eInvoicing is implemented under UBL 2.1 and CII. 

CIUS:  

•  CIUS for Chorus Pro 
•  CIUS for Factur-X, Basic profile 
•  Peppol BIS Billing 3.0  

Platforms  
Chorus Pro, developed by the Agence pour l’Informatique Financiére de l’État (AIFE), the French national public agency for IT. 

The current Chorus Pro solution provides/allows:  

•  B2G eInvoicing: eInvoices to public bodies from national or foreign company 
•  A user interface for managing invoices issued and received (portal) 
•  Multiple transmission protocols such as PeSIT HS E, AS2, and SFTP protocols. 

o  Peppol is used as receiving access point. 
o  API for sending, receiving, and managing invoices. 

In the next years, the Chorus Pro solution will also cover the following use cases:  

130 

 
 
 
 
 
•  B2B eInvoicing: issuing and receiving eInvoices between private companies (French or foreign) subject to VAT in France.  

o  Invoice  data  will  be  used  by  the  administration  to  pre-fill  the  VAT  return  and  to  improve  its  knowledge  of  French  companies  and  the 

French economy.  

• 

International B2B eInvoicing: receipt of eInvoices received or sent by a company subject to VAT in France, issued or intended for a company not 
subject to VAT in France.  

o  These  invoices  will  not  be  transmitted  to  their  addressee  (exploitation  of  the  data  by  the  administration  for  the  pre-filling  of  the  VAT 

return).  

•  B2C eInvoicing: Receipt of invoices issued by a company subject to VAT in France to a final consumer. 

o  These invoices will not be transmitted to their recipients (data processing by the administration for the pre-filling of the VAT return)  

The Chorus Pro solution will also allow the use of AS4 protocol management to the flow exchange solution (EDI). It will require compliance with the 
EN  16931  standard  for  exchanged  invoices  and  will  limit  the  accepted  input  and  output  formats  to  UBL,  CII  and  Factur-X  (simple  PDF  will  be 
deprecated and then rejected within 3 years). It will use a new format for exchanging invoice life cycle data (UN/CEFACT SCRDM CI Cross Domain 
Application Response message). 

Evaluation of the effects of Directive 2014/55/EU 
Since January 2012, under Article 25 of Law No. 2008-776 of 4 August 2008 on the modernisation of the economy, France developed the Chorus portal 
to transmit electronic invoices between State suppliers and the Chorus information system that is used by the  entire State administration.  Despite the 
advantages for suppliers, and for the State, these transmission methods were little known and little used.  

In 2013, the State was only able to process 34 000 electronic invoices.  

The vast majority of the 95 million annual invoices received by the State, local authorities and public institutions were issued and transmitted in paper 
format. The processing of paper invoices required several tasks with low added value representing a significant cost, both for issuers and receivers of 
invoices. 

Electronic invoicing was implemented progressively to consider the size of the undertakings concerned and their ability to fulfil this obligation. In 2014, 
the following milestones were proposed: 

131 

 
 
 
•  January 1, 2017: obligation for large companies and public entities. 
•  January 1, 2018: obligation for mid-caps.  
•  January 1, 2019: obligation for small and medium-sized enterprises. 
•  January 1, 2020: obligation for micro-enterprises. 

Effectiveness 

France perceives the Directive 2014/55/EU and EN 16931 as moderately contributing to fostering the functioning of the Internal Market. eInvoicing in 
public procurement helped reduce low-value tasks and late payments for both buyers and economic operators. 

Other eInvoicing formats were available before the Directive 2014/55/EU and EN 16931 were published, however, France indicated that the Directive 
and  the  European  eInvoicing  standard  contributed  highly  to  eInvoicing  adoption  in  B2G.  France  also  went  beyond  the  scope  of  the  Directive  and 
mandated  B2G  eInvoicing,  including  contracts  that  fall  below  the  EU  thresholds.  The  combination  of  the  EU  eInvoicing  Directive,  the  European 
standard, and France’s own national policies was the main contributing factor for increasing B2G eInvoicing adoption. This has been a driver to mandate 
B2B eInvoicing, which is due to commence by September 2026. 

B2G eInvoices in 2022 

•  National suppliers to central authorities: 4 368 900 
•  National suppliers to sub-central authorities: 66 743 093 
•  Suppliers sending eInvoices for public procurement contracts: 892 234. 

In recent years, eInvoices received from foreign suppliers to France’s public sector has been on an upwards trend, from 143 696 eInvoices in 2019 to 532 
734 eInvoices in 2022. 

132 

 
 
 
 
 
600.000

500.000

400.000

300.000

200.000

100.000

0

2019

2020

2021

2022

eInvoices from foreign suppliers to the Public Sector

Figure 16 eInvoices from foreign suppliers to France's public sector 

Peppol  eDelivery  network  is  used  through  a  Pagero Access  Point. There  has  been  a  constant  increase  in  the  number  of  eInvoices  exchanged  through 
Peppol each year. From 0 in 2016 to 244 063 in 2022. 

133 

 
 
 
 
260000

240000

220000

200000

180000

160000

140000

120000

100000

80000

60000

40000

20000

0

2016

2017

2018

2019

2020

2021

2022

eInvoices exchanged through Peppol

Figure 17 eInvoices exchanged through Peppol in France 

However, these increasing and positive trends are not a full representation of the effectiveness of the Directive 2014/55/EU  and EN 16931. EN 16931 
compliant  eInvoicing  only  accounted  for  2.86%  of  the  total  number  of  eInvoices  exchanged  in  France  in  2021  (a  small  increase  of  0.41%  from  the 
previous year). A high level of adoption was not achieved in the B2B sector; this is due to change from 2024-2026 when B2B mandated eInvoicing is 
enacted and approximately 4 million companies will require eInvoicing capabilities. France has adapted the B2G system to meet the standards required 
for their B2B system. France has submitted additional requirements that include extensions to CEN TC 434. 

According to VAT rules, the majority of B2C transactions do not imply invoices, therefore France do not see a point in making eInvoicing mandatory for 
this category of transactions. However, B2C transactions will be subject to eReporting to the tax administration. B2G and B2B transactions are subject to 
the transmission of data to the tax administration. 

134 

 
 
 
 
How the objectives of the initiative were met 

Directive 2014/55/EU increased legal certainty for eInvoicing requirements and reduced technical complexity to a very high extent. A clear legal basis 
and common technical specifications were the factors that most contributed to achieving these objectives. 

One  of  the  aims  of  the Directive  is  to  reduce  late  payments.  The  average  payment  time  is  less  than  14  days  for  State  accountants  in  2022.  Particular 
attention was paid to the possibility for economic operators to follow the progress of eInvoices in the payment process.   

France describes the main drivers of these benefits to be process automation, less complexity, and faster/more timely processing. Services providers are 
the  stakeholders  who  benefitted  the  most,  with  large  corporates  and  medium  and  small  enterprises  also  seeing  high  benefits.  France  predicted  micro-
enterprises will realise moderate benefits, but SMEs entered the B2G system in 2022, therefore, it is too early to fully evaluate the impact on them. The 
stakeholders that had the least realised benefits were central and sub-central authorities. 

Use of invoice data 

Invoicing data will be used to fight against VAT fraud. It will also be used to propose a new service to enterprises: VAT prefilling. Data will also be used 
to better monitor public policies. 

Efficiency 

France did not incur costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. There was also no cost burden 
ensuring the national format complied with the EN.  

135 

 
 
 
The French Ministry stated that overall benefits greatly outweighed the costs. A very high level of legal certainty was introduced by the Directive and 
significant technical simplification was provided through the use of a common EU eInvoicing standard. There was a considerable cost reduction because 
of the Directive and the EN 16931.  

The impact  study,  related to  Ordinance 2014-69769,estimates the potential for  recurring  gains,  once electronic invoicing  is generalised (2021) at  EUR 
710.2 million per year, which can be broken down into financial gains of EUR 121 million and overall time savings representing 11 925 FTE equivalents.    

•  For companies, these gains would represent EUR 335 million per year, which can be broken down into EUR 83 million of financial  gains and 

3700 FTE equivalents.  

•  For local authorities, the estimate would represent EUR 260 million per year, which can be broken down into EUR 31 million in financial gains 

and 6 100 FTE equivalents.   

•  For the other administrations (State and EPN), the valuation would represent EUR 114 million per year, which can be broken down into EUR 6.8 

million in financial gains and 2 100 FTE equivalents.   

eInvoicing would also contribute to the digitisation of the public procurement process, making it possible to speed up the payment of the administration's 
suppliers. Finally, by avoiding the sending of 95 million paper invoices per year, it contributes to the preservation of the environment.  

The State offered a shared technical solution to all the public bodies concerned, based on the one it currently has, to allow companies to have all their 
invoices on a single electronic portal. This measure has been the subject of extensive prior consultation with organisations representing businesses, local 
authorities, national entities, and the supervisory ministries.  

136 

 
 
 
   
 
 
 
In  SMEs  and  particularly  micro-enterprises,  the  time  saved  per  invoices  received  or  issued,  will  be  much  less  than  one  FTE  (Full  Time  Equivalent) 
person and therefore not seen as a significant saving in that regard. 

Cost estimate (for the creation and maintenance of the single portal and the evolution of the Helios system) 

The estimates carried by the State, are broken down as follows: 

•  cost of creating the single portal: EUR 7.66M 
•  cost of evolution of the Helios system: EUR 3.25M 
•  maintenance cost of the single portal: from EUR 2.6M in 2015 to EUR 4.5M from 2019 

France  stated  that  as  a  measure  to  increase  the  efficiency  of  the  initiative,  the  EN  16931  should  be  updated  to  consider  some  data  required  in  B2B 
transactions or by the tax authorities. 

Coherence 

France stated that the Directive 2014/55/EU and the publication of the EN 16931 is consistent with other EU and national interventions that have similar 
objectives to: 

•  digitisation of public procurement 
•  promoting European standards 
• 
improving interoperability 
• 
fostering the Internal Market 
• 
improving legal certainty 

They also stated that it was moderately consistent with the following EU and national intervention areas: 

• 
• 

reducing technical complexity 
lowering operating costs for economic operators 

137 

 
 
 
 
5

4

3

2

1

0

Figure 18 France's coherence scores 

EU Added Value 

France stated that the objectives of the Directive, in particular EU-wide interoperability, could not be achieved sufficiently by the Member States acting 
alone.  

As part of the work of the national eInvoicing Forum, companies that participated in its workshops identified the main advantage of eInvoicing, namely: 

•  elimination of paper, envelopes, stamps, and lower printing costs 
•  elimination of postal delivery and delay associated. 

138 

 
 
 
 
faster processing time at the customer's premises for invoices (no slow transmission from one department to another) 

• 
•  simplification of the relationship with the public accountant (instant transmission, less missing paper) 
•  simplification of transmission, consultation, filing and storage 
• 
• 

reduction of payment times 
reduction of legal disputes. 

The benefits for the administration are: 

• 
• 

• 
• 
• 
• 

reduction of storage costs, delivery, and postal costs 
improving accounting quality: the implementation of an automatised and unified processing chain is a quality factor by making the circulation of 
information faster and more reliable. 
real-time monitoring of the invoice processing circuit 
improved relationships with suppliers 
reduction of time-consuming tasks 
reduction of ecological impact. 

There were moderate benefits in replacing different national policies and rules with a more homogenous policy approach. 

Relevance 

France believes that any revision of the Directive 2014/55/EU should take into account the VAT in Digital Age proposal final  work and limit itself to 
reproduce its rules so as to simplify the implementation of eInvoicing for companies. 

Future plans 

eInvoicing will be mandatory for B2B transactions from September 2026 and subject to a transmission of data to the tax administration. This change will 
affect approximately 4 million companies, therefore, the B2G system has been adapted so as to meet the standards of the B2B system. 

139 

 
 
 
 
 
Three formats / syntaxes will be accepted which comply with the EN 16931 standard: UBL, CII and a hybrid format called Factur-X (which encapsulates 
both structured data and a pdf). 

140 

 
 
 
 
 
 
1.2 Italy 

Responsible 
Ministry of Economy and Finances, supported by the Revenue Agency. 

Legal Framework:  
The 2008 Budget Law states that eInvoices for state administrations must be transmitted through the Exchange System (SDI). 

Ministerial Decree April 3, 2013, Number 55, lays down rules regarding the issue, transmission, and receipt of electronic billing and defines the way the 
Exchange System (Sistema di Interscambio - SDI) works. 

eInvoicing to public administrations (B2G) has been mandatory since 31 March 2015. 

eInvoicing between companies (B2B) has been mandatory since January 2019. 

eInvoicing between companies and consumers (B2C) has been mandatory since January 2019. 

From the April 30th, 2019, the Italian government mandated economic operators to send to the Revenue Agency the so-called "esterometro" based on a 
quarterly submission of a summary of transactions carried out from January 1st, 2019, to and from foreign subjects, according to a specific data format. 

From  July  1st,  2022,  Italy  has  improved  its  FatturaPA  eInvoicing  technical  specification  to  support  a  new  way  of  communicating  cross-border 
transactions (intra-EU and extra-EU) by using the same eInvoicing data model. This has eliminated the previous practice (“esterometro”). 

Platform 
Sistema di Interscambio (SDI) - centralised national eInvoicing hub 

Standard/format 
National format 

FatturaPA XML format 

141 

 
 
 
PEPPOL CIUS – national extension 

AGID  maintains 
docs.agid.gov.it/docs/my_index_fatt.jsp. 

the  national  CIUS 

implemented  using 

the  PEPPOL  CIUS  PEPPOL  which 

includes  extensions:  https://peppol-

Customisation ID: urn:cen.eu:en16931:2017#compliant#urn:fdc:peppol.eu:2017:poacc:billing:3.0#conformant#urn:www.agid.gov.it:trns:fattura:3.0 

The PEPPOL network is used to exchange eInvoices in this format. 

National CIUS 

The Italian Tax Authority (Agenzia delle Entrate - AdE) has developed a CIUS of the EN 16931 without extensions and is used only to receive eInvoices 
compliant with the EU eInvoicing standard. 

urn:cen.eu:en16931:2017#compliant#urn:fatturapa.gov.it:CIUS-IT:2.0.0 

Web services are used to receive eInvoices in this format. 

Evaluation of the effects of Directive 2014/55/EU 
Effectiveness  

At  the  time  of  the  introduction  of  Directive  2014/55/EU,  the  use  of  eInvoicing  in  B2G  in  Italy  was  already  mandatory  using  a  national  platform  and 
mandatory format. Hence the effects in terms of effectiveness, the impact on the Italian eInvoicing market is extremely limited. However, Italy suggests 
that  the  key  challenges  to  be  addressed  to  facilitate  cross-border  eInvoicing  are  mainly  related  to  the  transmission,  followed  by  governance  and  legal 
certainty. 

For cross-border transactions, Italy would fully support the EN 16931, while leaving freedom of choice for the transmission level.  

142 

 
 
 
eInvoicing  is  already  used  also  for  VAT  reporting,  to  conduct  risk  analysis,  and  provide  services  to  simplify  fiscal  compliance.  During  the  COVID 
pandemic, it has been possible to use eInvoicing data to determine loss in turnover compared to 2019. Thus it has been possible to distribute grants even 
without requesting directly to those enterprises which had evident difficulties. 

Uptake 

Since 2019, 22 800 over 43 000 public administrations have been using eInvoicing, while only a few dozen have been supporting the EN 16931. 

Since 2019, 800 000 over 5 000 000 Economic Operators have been sending eInvoices to the public sector. 

In the B2B context, since 2019, approximately 2 000 000 000 eInvoices are exchanged on a yearly basis. 

Mandatory use of eInvoicing between enterprises (B2B) would be effective at EU level but makes no difference at domestic level. 

Italy  experience  benefits  from  the  adoption  of  eInvoicing.  Nevertheless,  as  Italy  adopted  B2G  eInvoicing  before  implementing  directive  2014/55/EU, 
they are not able to attribute benefits directly to the Directive 2014/55/EU. 

The  EN  16931  is  rarely  used,  while  Peppol  is  used  in  the  Emilia  Romagna  region  where  209  public  entities  support  the  related  specifications 
(https://notier.regione.emilia-romagna.it/notier/pub/countDocumenti.html) 

Efficiency 

Italy  incurred  costs  related  to  support  the  EN  16931  by  purchasing  software/hardware  and  were  funded  some  costs  using  European  funds  (CEF 
eInvoicing). 

In general, the major cost is related to the implementation of the eInvoicing platform, it was paid by the public administration. 

143 

 
 
 
 
Coherence 

In general the initiative is considered to be consistent with other EU and national initiatives that have similar objectives such as ensuring interoperability, 
facilitating  the  digitisation  of  public  procurement  and  the  use  of  EU  standards  but  has  not  contributed  to  lower  the  operating  costs  or  increased  legal 
certainty, due to the national context. 

5

4

3

2

1

0

Figure 19 Italy's coherence scores 

144 

 
 
 
 
EU added value 

The  Directive  marked  a  point  in  developing  a  European  standard  on  eInvoicing.  However,  benefits  cannot  be  fully  realised  until  the  adoption  of  the 
standard reaches a critical mass. 

Relevance 

eInvoicing is not mandatory in B2G for cross-border transactions and eInvoicing is rarely used in B2B for cross-border transactions. 

Future plans 

In its future plans, Italy will maintain the eInvoicing obligations and use of eInvoicing data to facilitate compliance. 

Key findings 
Between January-December 2019, The Politecnico di Milano conducted a statistically representative survey through a series of interviews with SMEs and 
large enterprises from all the regions of Italy.  

The  survey’s  overview  of  the  state  of  the  art  of  eInvoicing  in  Italy  shows  that  60%  of  eInvoices  were  sent  by  companies’  resident  in  Northern  Italy, 
particularly in Lombardy (34%). In terms of sector of activity, most eInvoices (47%) came from the wholesale, retail, and utilities sectors, characterised 
respectively by the highest number of companies and an average of eInvoices per issuer more than 25 times higher than the other sectors.  

Large  enterprises  (with  more  than  250  employees)  sent  57%  of  the  invoices  received  by  the  SDI.  SMEs  (10-249  employees)  sent  23%  and  sole 
proprietorships and micro enterprises (2-9 employees) the remaining 20%. More than three quarters of the invoices had a taxable amount between EUR 1 
and EUR 400 and only 1% had amounts over EUR 25 000. 

145 

 
 
 
The survey’s results shown in the 2020 report70 testify to the success of the initiative, which, since its launch, has recorded limited rejections and typical 
criticalities of the start-up phase of a new system. The report links the success to the maturity of the Italian market as regards B2G eInvoicing, among 
other factors. According to the Politecnico di Milano, the introduction of the obligation on eInvoicing started to bring benefits both in terms of combating 
evasion and increasing efficiency and effectiveness for companies. 

Benefits 

Direct benefits 

Cost-saving
Time-saving 

Additional flows
Personalisation

eInvoice senders

29%

28%

43%

0%

20%

40%

60%

80%

100%

120%

Beneftis

Burdening

No Effect

Figure 20 Direct benefits of eInvoice senders in Italy 

70 Politecnico di Milano, Osservatorio Digital B2b, Scambio documentale in Italia e obblighi in vigore, Milan, 2020 

146 

 
 
 
 
 
 
Higher quality Process optimisation
Cost-saving Time-saving

Reconciliation 

eInvoice receivers

53%

16%

31%

0%

20%

40%

60%

80%

100%

120%

Beneftis

Burdening

No Effect

Figure 21 Direct benefits of eInvoice receivers in Italy 

When it comes to eInvoice issuers, companies report two main problems:  

• 
• 

the need to customise a lot of information within eInvoices at the request of individual customers. 
the need to maintain a parallel flow, typically the EDI - which contains more information – and the national format. 

From an eInvoicing receiver perspective, Italian enterprises’ challenges were mainly determined by the reconciliation of eInvoices with other documents 
in the order cycle.  

Benefits of eInvoicing vs unstructured invoicing  

147 

 
 
 
 
 
8

7

6

5

4

3

2

1

0

EUR 5-EUR 9/invoice

EUR 2-EUR 4/invoice

Invoicing via e-mail

eInvoicing

Cost-benefits of eInvoicing

Figure 22 Benefits of eInvoices vs unstructured invoicing in Italy 

Invoicing via e-mail: 

•  Payback time: <2 years 
•  Sources of the benefits: 

o  Transmission 
o  Space 
o  Materials 
o  Document research 

eInvoicing:  

•  Payback time: <1 year 
•  Sources of the benefits: 

o  Personnel productivity 
o  Higher accuracy 

148 

 
 
 
 
 
Indirect benefits 

The indirect benefits of electronic invoicing are perceived by 34% of Italian companies. In 2019, 53% of Italian companies receiving eInvoices and 30% 
of those sending eInvoices claimed that they were reaping benefits from the policy71. 

The  benefits  depend  strongly  depend  on  the  enterprise’s  situation  prior  to  the  start  of  the  obligation  on  eInvoicing.  However,  among  both  eInvoice 
receiving and sending enterprises several indirect benefits have been identified:  

•  Efficiency: time and cost savings, reduction of errors 
•  Effectiveness: increase in the quality of information and optimisation of processes 
•  For eInvoice sending enterprises: important cost savings in terms of consumables and the reduction in the time taken to perform activities.  

Although, both senders and receivers of eInvoices perceived similar indirect benefits, benefits for the enterprises-receivers were slightly more palpable 
than those for senders. 

71 Ibid. 

149 

 
 
 
 
 
37%
36%
35%
34%
33%
32%
31%
30%
29%
28%
27%

Reconciliation
process

Business
processes

Marketing &
sales

Procurement

Operations

Credit
management

Share of surveyed enterprises that perceived the benefit.

Figure 23 eInvoicing benefits perceived by Italian enterprises 
On average, 34% of all the enterprises have perceived benefits from at least one category72. 

Fiscal benefits of eInvoicing in Italy  

In  Italy,  the  introduction  of  eInvoicing  was  related  to  4  factors:  fight  against  VAT  evasion,  fiscal  and  administrative  simplification,  Italy’s 
competitiveness on the international scale, and higher digitalisation of the country’s enterprises73.  

At the point of eInvoicing introduction, Italy registered around 25% of EU’s tax evasion rate.  

72 Ibid. 
73 Ibid. 

150 

 
 
 
 
 
 
From January to December 2019, eInvoicing contributed to an increase in revenue of EUR 3.5 billion. This increase was based on 3 factors: 

•  3.6% increase in VAT payments. 
•  Direct taxes: the increase is conservatively estimated at around EUR 580 million. 
•  Undue compensations: from January to November 2019, EUR 945 million of EUR 104.7 billion in VAT payments were detected and blocked as 

false VAT credits. 

Blocked false VAT credits on EUR 945 million:  

Blocked VAT 
payments 
(€945 m)
6%

45

40

35

30

25

20

15

10

5

0

17

8

15

VAT Gap (€ bn)

Evasion without consistency

Omitted payment

Evasion with consistency

Figure 24 Italy’s blocked and false VAT credits 

VAT 
payments
94%

VAT payments

Blocked VAT payments (€945 m)

151 

 
 
 
 
   
 
152 

 
 
 
 
 
1.3 Croatia 

Responsible 
Ministry of Economy and Sustainable Development74 

Legal Framework 
Act on eInvoicing in public procurement75 (transposing Directive 55/2014/EU) entered into force on 1 November 2018. (OJ 94/2018) 

Mandates:   

•  Receiving and processing: central and sub-central authorities and entities 
•  Sending: Suppliers of public bodies 
• 

In Croatia the obligation for issuing eInvoices in public procurement was introduced from 1.7.2019.  The Directive’s scope was widened, so the 
Croatian Act on eInvoicing in public procurement includes all procurement procedures above but also those under the EU threshold. 

•  For B2B, the obligation is planned to be introduced 2023-2024. This is the jurisdiction of the Ministry of Finance. 

Platforms 
Servis eRačun za državu76 

Standard/format 
The European standard on eInvoicing is implemented under UBL 2.1. Croatia is using EN 16931 for B2G, and it is expected to use it for the B2B as well, 
with some national requirements added. 

74 https://www.mingo.hr/en  
75 https://narodne-novine.nn.hr/clanci/sluzbeni/2018_10_94_1817.html  
76 http://www.fina.hr/Default.aspx?sec=1354  

153 

 
 
 
 
 
CIUS:  

•  CIUS at the national level77 that complies with the Croatian VAT legislation. 
•  The national CIUS provides descriptions of elements and data that should be used in invoices for public procurement. 

Evaluation of the effects of Directive 2014/55/EU 
Effectiveness 

In  terms  of  effectiveness,  the  introduction  of  the  EN  16931  European  standard  has  created  the  possibility  of  wider  harmonisation  and  acceleration  of 
eInvoicing adoption in the public sector at the national level of each Member State. The adoption of the eInvoicing Directive has also removed obstacles 
to cross-border procurement and trade. 

However,  challenges  still  need  to  be  addressed  to  facilitate  cross-border  eInvoicing,  such  as  the  lack  of  mandatory  eInvoicing  for  businesses  in  EU 
countries, and extensions that other countries apply, which create barriers when conducting cross-border public procurement.  

Croatia believes that the eInvoicing Directive and EN 16931 have had a significant effect on the adoption of B2G eInvoicing. However, the initiative had 
limited impact on B2B due to slow adoption, high investment costs, and no mandates.  

To  fully  realise  their  effectiveness,  mandatory  B2G  and  B2B  adoption,  as  well  as  economic  incentives,  education  and  awareness  campaigns  are 
necessary.  Some  semi-public  bodies  have  cited  the  lack  of  integration  with  accounting  software  as  a  significant  obstacle  in  their  efforts  to  adopt 
eInvoicing. However, faster processing and process automation are key drivers to help overcome these obstacles. Adoption needs to increase EU-wide in 
order to fully realise the benefits associated with automation.  

77 https://www.fina.hr/e-racun-u-javnoj-nabavi  

154 

 
 
 
 
 
In 2021, the National Central Platform for eInvoice Exchange (NCP) received approximately 5.7 million invoices, with around 5 000 of them received 
through Peppol. In comparison, NCP received 5.3 million invoices in 2020 and 2.7 million in 2019. 

6000000

5000000

4000000

3000000

2000000

1000000

0

2019

2020

2021

NCP

PEPPOL

Figure 25 NCP and Peppol eInvoices exchanged in Croatia 

Efficiency 

Croatia did not provide specific cost figures related to the implementation of the eInvoicing Directive and EN 16931. They did mention the development 
of  a  National  Central  Platform  for  eInvoicing  exchange  in  public  procurement,  which  had  a  cost  burden,  but  no  further  information  was  available 
regarding the costs associated with developing and maintaining it. Croatia did not believe that any stakeholder incurred significant costs to date. 

155 

 
 
 
 
Croatia conducted more  than 150 educational  workshops  free of charge to introduce the Directives obligations and EN 16931. They received funding 
from CEF Telecom involving 40 contracts where they acted as coordinator. Croatian beneficiaries were funded for a total cost of EUR 13.2 million, of 
which EUR 1 627 556 of the funding was for eInvoicing. 

Croatia stated that currently, (EU compliant) eInvoicing benefits only moderately outweigh costs. The implications in their survey response indicate that 
full benefits will not be realised until EU compliant eInvoicing adoption rates increase throughout the EU.  

They also noted that some of the prices for eInvoicing services can be quite high. This can contribute to the reluctance to adopt, particularly for SMEs 
and  Micro  Enterprises.  Currently,  costs  are  only  moderately  reduced  through  the  use  of  eInvoicing,  this  combined  with  the  cost  burden  of  adopting 
compliant eInvoicing are contributing factors for low adoption in areas where eInvoicing is not mandated. Croatia also reported a moderate increase in 
perceived legal certainty and reduced technical complexity through the introduction of the Directive 2014/55/EU and EN 16931. 

Operational efficiencies  have been achieved  since transposing the Directive and the  EN 16931, Croatia have  automated  and digitised procedures  as a 
result of implementing eInvoicing. Archiving has been simplified, and Croatia has reported that the improved transparency has resulted in higher fiscal 
transparency and eInvoicing data which will be used for decision-making and policy purposes in the areas of financial planning (better planning of the 
state budget, calculation of savings, potential investments of added value) and fiscal monitoring (enables better transparency of fiscal performance and 
simplifies the inspection and supervision process). 

Coherence 

Croatia  stated  that  the  EN  16931  publication  and  Directive  2014/55/EU  are  aligned  with  other  EU  and  national  measures  aimed  at  enhancing 
interoperability, promoting the Internal Market, and improving legal certainty. It moderately aligns with EU and national measures aimed at digitising 
public procurement, promoting EU standards, and reducing technical complexity.  

Croatia reported that the Directive and the EN 16931 have a low alignment with other EU and national measures aimed at lowering operating costs for 
Economic Operators.  

156 

 
 
 
5

4

3

2

1

0

Figure 26 Croatia's coherence scores 

EU added value 

Regarding the EU added value of the eInvoicing Directive and EN 16931, the Ministry of Economy and Sustainable Development in Croatia commented 
that while Member States could partially achieve the objectives of the Directive on their own, the key benefit of EU wide involvement was in facilitating 
cross-border eInvoicing including cross-border procurement. 

Issuers of eInvoices could reduce administrative costs associated with invoice preparation, printing, and postage, as well as benefit from faster delivery 
and secure electronic storage. For recipients of eInvoices, the speed and accuracy of invoice processing are critical, and faster payment can be ensured. 
Additionally, the use of eInvoicing can enable better financial management, increase productivity, and enhance transparency in public procurement. The 

157 

 
 
 
 
 
positive effects of the Directive on these fronts were significant while lowering operating costs was not. Croatia believe the positive effects will increase 
if adoption becomes more widespread, particularly in the B2B sector, throughout the EU.  

Relevance 

Regarding the ongoing needs and challenges of eInvoicing adoption across the EU, it is important to note that in the B2G context, some Member States 
have not yet mandated eInvoicing and others have requested extensions, which has resulted in additional challenges in cross-border procurement. 

In  Croatia,  in  the  B2B  context,  the  adoption  of  EN  16931  has  been  slow,  and  the  high  costs  associated  with  implementation  are  also  a  challenge. 
Moreover, there is currently no mandatory requirement for B2B eInvoicing adoption. 

Future plans 

In its future plans, Croatia intends to implement a national strategy mandating eInvoicing for B2B transactions in the coming years. 

For  cross-border  eInvoicing,  the  Croatian  Financial  Agency  will  serve  as  the  access  point  for  Peppol,  enabling  the  receipt  of  cross-border  invoices 
through this platform. 

In terms of VAT digital reporting, the plan is to use EN 16931-compliant eInvoicing. 

Moreover, eInvoicing data will be utilised for decision-making and policy purposes. This data can enable better planning of the state budget, calculation 
of savings, and identification of potential investment opportunities. Furthermore, it can enhance the transparency of fiscal performance and facilitate the 
inspection and supervision of the eInvoicing system. 

Croatia are aiming to maximise savings by establishing a more efficient public procurement process that includes: 

•  Electronic public tenders 
•  Electronic submission of tenders 
•  Electronic supervision of contracts 

158 

 
 
 
•  eInvoicing 
•  ePayments  

Savings achieved through electronic public procurement are approx. 6 to 12 % of the total amount of public procurement in Croatia, which amounts to 
HRK 2.6 billion. 

159 

 
 
 
 
1.4 Finland 

Responsible 
State Treasury 

Legal Framework 
Law 241/2019 on electronic invoicing78 "Laki hankintayksiköiden ja elinkeinonharjoittajien sähköisestä laskutuksesta" (Act on Electronic Invoicing of 
Contracting Entities and Traders), Official publication: Suomen säädöskokoelma (SK); Number: 241/2019; Publication date: 2019-02-27.  

Mandates: Finland’s national law on eInvoicing, which entered into force on April 1st, 2020, has two national extensions to Directive 2014/55/EU: 

• 
• 

include invoices based on contracts above national thresholds but below EU thresholds, 
the Contracting Entity or Trader (Buyer) has the right to receive, on request, an eInvoice from another Contracting Entity (Seller).  

Strategy 
National strategy: in medium term Peppol based electronic invoicing is increasing in cross-border invoicing. Peppol is also strongly supported in order-
delivery and logistics area. Long term target is to close down national electronic invoice format usage and converge into UBL/Peppol based format. 

Cross-border strategy: Enable and support Peppol infrastructure and usage of Peppol BIS 3.0 and PINT format invoices. 

VAT Reporting: Currently eInvoicing is not used for VAT reporting.  However there are plans to follow ViDA requirements. 

eInvoicing data used, or planned to be used, for decision-making and policy purposes: Finland is investigating the use of standardised structured 
data for different purposes like national statistics or sustainability reporting. 

78 https://www.finlex.fi/fi/laki/alkup/2019/20190241#Pidp446241968  

160 

 
 
 
 
 
Aggregated invoice data is currently published as Open Data 

Platforms 
Basware Supplier Portal, Handi supplier portal (State Treasury free portal), Tieke (collaboration forums and an eInvoice address repository). The Post 
Network Service ended in 2022. 

Standard/format 
In Finland there are two national formats widely used (TEAPPSXML 3.0, Finvoice 3.0.) and those are updated to support EN 16931 semantic contents.  

CIUS: Peppol CIUS plus National CIUS 

65% of all eInvoices sent to the state meet the EU standard requirements (source: Invoicing the state - Valtiokonttori79). 

Evaluation of the effects of Directive 2014/55/EU 
Effectiveness 

The survey responses from Finland indicate that while progress has been made in the adoption of the eInvoicing Directive and the European eInvoicing 
standard formats, there are still challenges that need to be addressed to facilitate cross-border eInvoicing. These challenges include: 

•  semantic data modelling,  
•  syntax,  
•  governance,  
•  support for consumer eInvoicing,  

79 
questions-about-the-european-standard-of-electronic-invoicing 

https://www.valtiokonttori.fi/en/services/public-administration-services-2/public-administration-services/invoicing-the-state/#application-instructions-for-public-administration-and-instructions-en16931_frequently-asked-

161 

 
 
 
 
 
•  national level VAT summary calculation, and  
•  common guidelines for certain invoice types.  

Finland  gave  moderate  scores  for  the  effectiveness  of  the  Directive  and  EN  16931  in  adoption, with  30%  usage  of  the  European  eInvoicing  standard 
format in 2021. They also emphasised the importance of cost-effectiveness and easy-to-use applications for micro-companies. Finland gave a low score 
for the effectiveness of the national policy in adoption, instead they credit service providers (operators and banks) and large corporates for having a major 
impact on eInvoicing adoption.   

Figure 27 EU compliant eInvoices to the Finnish Government 

Finland  clarified  that  while  clear  legal  basis  and  common  specifications  were  beneficial  in  achieving  this  objective,  some  cases  saw  an  increase  in 
technical complexity due to additional requirements such as codelists. This increased complexity was justified as the EN 16931 compliant eInvoices had 
significantly fewer errors than the national format and was therefore better for automated processing. As a result, Finland is now phasing out the older 
national format, which should further reduce errors. 

162 

 
 
 
 
 
Service  providers  provide  statistics  to  the  government  (it  was  in  the  contract  in  the  procurement  tender,  they  are  contractually  obliged  to  collect  and 
provide data). Operators trust the government that they use the data correctly and it helps everybody to develop the policies. 

Uptake 

Finland has achieved very high B2G adoption, this amounts to 692 924 eInvoices for the central government and 4 641 005 for municipalities in 2021, 
without a government-wide mandate. However, the law states that a buyer can mandate a seller to an eInvoice.   

Share of eInvoices in public sector purchase invoices 

Figure 28 Finland's share of eInvoices in public sector purchases 

Finland have agencies who continuously promote and create awareness of the benefits of eInvoicing. Service providers that include banks have been very 
influential.  

163 

 
 
 
 
Finland considers the  role of ERP vendors and accountants to  be important  for adoption.   There is great  cooperation with accounting  firms,  and they 
promote eInvoicing. This is how the small businesses have been involved. The very small businesses (one man firm) typically invoice through a bank or 
service provider.  

The Finnish authorities believe that the role of ERP vendors is important in driving the adoption.    

Currently, Peppol usage is very low and used for non-domestic transactions such as intra-EU. This accounts for only 5 000 out of 139 million.   

Figure 29 Sent invoice quantities in Finland 

Finland also participate in the Nordic Smart Government (NSG) – automating financial flow between Scandinavian countries.   

164 

 
 
 
 
Efficiency 

Finland  did  not  incur  costs  solely  related  to  transposing  the  Directive  2014/55/EU  and  ensuring  compliance  with  EN  16931.  The  cost  to  ensure  the 
national format complied with the EN 16931 was estimated at EUR 250 000. They obtained CEF funding in a EUR 100 000 joint project with Estonia in 
2017 to 2018.  

Finland commented that national format owners and software houses have borne the highest cost, however, although evidence was not collected Finland 
believes that the benefits significantly outweighed the costs. Legal certainty was introduced by the Directive and the technical simplification provided 
through the use of a common EU eInvoicing standard.  

The main benefits come from increased data quality of the eInvoice which is important for process automation and good statistics. With the introduction 
of the EN 16931, the use of a common data structure and validation artefacts removed the need for machine learning (and RPA). 

A  key  challenge  is  the  adoption  of  eInvoicing  for  small  businesses  that  have  to  use  many  different  eInvoicing  portals  (up  to  17)  and  this  is  not 
sustainable. 

Finland suggests that the EC could increase efficiency by implementing measures such as: 

•  avoiding national implementations,  
•  adopting the same VAT reporting, and  
•  harmonising the usage of VAT codes. 

Coherence 

Finland provided the following score in relation to the extent to which the Directive and the European eInvoicing standard is consistent with other EU 
and national interventions: 

165 

 
 
 
5

4

3

2

1

0

Figure 30 Finland's coherence scores 

Promoting EU standards and interoperability are considered highly consistent policies with the score of 4/5. 

EU added value 

Finland stated that the objectives outlined in the eInvoicing Directive could not be achieved by Member States acting alone. Where previously they had 
implemented some B2B eInvoicing prior to this, the Directive resulted in the implementation of eInvoicing in public procurement (B2G). 

166 

 
 
 
 
Relevance  

Finland gave a moderate score of 3 for the extent the needs and problems addressed by the Directive continue to require action at EU level indicating EU 
action may still be required. Finland stated the following needs and problems are still relevant in their country in B2G context: 

•  VAT calculation 
•  Existence of non-compliant eInvoices 
•  Since the Directive implies only invoices above EU threshold there is a lot of invoices outside the Directive scope and therefore benefits are only 

partially collected 

Future plans 

The Finnish government is adding Peppol BIS 3.0 capabilities to its own Handi-supplier portal. This should be ready in April 2024, when government 
starts to demand Peppol-orders. 

Another project  is  a universal  procurement-portal  which should give abilities to  all Finnish  SMEs to  use Peppol  BIS 3.0-messages regardless  of their 
customers. This project is in a pre-evaluation phase.  

The national strategy is to: 

• 

• 

in medium term to promote Peppol based electronic invoicing in cross-border invoicing and usage of Peppol BIS 3.0 and PINT format invoices. 
Peppol is also supported in order-delivery and logistics area.  
in the long term the target is to close down national electronic invoice format usage and converge into UBL/Peppol based format. 

It is under consideration to make B2B electronic invoicing mandatory in ongoing "yrityksen digitalous" program. The objective is to reach 90% adoption 
in B2B transactions in 2023. 

Finland are investigating the use of standardised structured data for other purposes like national statistics or sustainability reporting. 

They are also investigating new technologies like trust-over-ip and using Mobile based solutions for B2C invoicing. 

167 

 
 
 
 
In addition to the four case studies of Member States (i.e. France, Italy, Croatia, and Finland) analysed in this Annex; below a series of country profiles 
are outlined encapsulating comprehensive information regarding EU Member States. The case studies are of analytical nature while the country profiles 
are more of an informative nature. 

168 

 
 
 
 
 
 
Austria 

Legislation 

The provision of the IKT Konsolidierungsgesetz §580 mandates that all contracting partners of the federal government, including foreign contracting 
partners, must only submit structured electronic invoices for the provision of goods and services to government departments. 

The national transposition of Directive 2014/55/EU is contained in  BVergG 2018 §36881. In Austria, there has been a minimal transposition of the 
Directive and the obligation was applied only for contracting authorities above the EU thresholds.  

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities & Local authorities. 
•  Sending: Since 2014, Economic Operators must send eInvoices to the Federal Government  

Platform 

Any  portal  can  be  used  if  connected  to  the  authentication  services  of  the  Federal  Service  Portal  (Unternehmensserviceportal  –  USP)  E-
rechnung.gv.at for eInvoicing Transmission 

Standard(s) 

National Standard in use (if any) 

ebInterface (national XML standard) 

EN 16931 compliant standard 

Two CIUSs have been developed: 

•  CIUS  AT  NAT  -  CIUS  with  the  legal  rules,  which  is  based 

directly on the EN. 

•  CIUS  AT  GOV  -  CIUS  with  special  rules  from  e-
Rechnung.gv.at  for  the  federal  government.  This  CIUS  is 
based on the "CIUS AT NAT". 

Monitoring 

The monitoring is implemented only at the federal level.  

80 https://www.ris.bka.gv.at/NormDokument.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20007805&Paragraf=5  
81 https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=20010295&FassungVom=2019-04-18  

169 

 
 
 
 
 
Strategy 

There is no national eInvoicing strategy. 

Structured eInvoicing uptake 

All Contracting authorities in the federal government receive eInvoices plus there are 34 other public entities82. 5% of B2G eInvoices are based on 
EN 16931.  

The following data is based on an Austrian Chambers of Commerce (WKO) survey that was carried out in the second half of September 2021 and 
addressed  to  444  self-employed/managing  directors,  freelancers  or  employees  who  deal  with  accounting  in  the  company  and  carry  out  invoice 
receipt internally and accept electronic invoices.  

• 
• 
• 
• 

15% of the respondents received between 1% & 25% of their invoices electronically. 
22.3% of the respondents received between 26% & 50% of their invoices electronically. 
28.1% of the respondents received between 51% & 75% of their invoices electronically. 
34.1% of the respondents received between 76% & 100% of their invoices electronically. 

The most common format for invoices received electronically is a PDF document. 

The following figure shows the percentage of invoices received electronically. 

82 https://www.erechnung.gv.at/erb/recipients_others  

170 

 
 
 
 
 
 
 
 
 
 
Figure 31 percentage of invoices received electronically (Source Austrian Chambers of Commerce (WKO) survey) 

The following figure shows the formats of invoices received electronically. 

171 

 
 
 
 
Percentage 
of 
sending eInvoices 

Figure 32 formats of invoices received electronically (Source Austrian Chambers of Commerce (WKO) survey) 

enterprises 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

The data83 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

7.5% 

9.4% 

11% 

25% 

24.9% 

20.5% 

22% 

83 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

172 

 
 
 
 
 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Table 12 Eurostat Sending eInvoices suitable for automatic processing in Austria 

Approach  

Austria mandated the use of the Federal Service Portal (Unternehmensserviceportal – USP), the central processing eInvoicing platform of the federal 
government to receive eInvoices. eInvoices based on Austrian national eInvoicing format ‘ebInterface’ as well as PEPPOL eInvoices are sent to the 
Austrian Federal Government through the Federal Service Portal. The portal is operated by the Federal Computing Centre (BRZ).  

Uptake of EN 16931 

The Directive 2014/55/EU and the introduction of EN 16931 contributed moderately to increasing the adoption of eInvoicing in Austria. 

Is Peppol / eDelivery used  

Yes, the federal computing centre offered a Peppol interface. 

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   

2019: 5% 

2020: 5% 

2021: 5% 

Cost and Benefits 

Austrian authorities confirmed that they incurred costs ensuring the national format complied with the EN 16931. 

Table 13 Uptake EN 16931 in Austria 

CEF Telecom eInvoicing funding  

•  Budget requested: EUR 212 220.  

eInvoicing services offered by the government (free of charge) 
Delivery of eInvoices to E-Rechnung.gv.at is free of charge for the user. 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

N/A 

N/A 

173 

 
 
 
Key findings 

The  Austrian  Bundesbeschaffung  GmbH  (Federal  Procurement)  indicated  that  the  Directive  and  the  European  eInvoicing  standard    contributed 
moderately to increasing adoption in B2G but had no contribution to adoption in B2B. However, they defined the following positive effects of the 
Directive: structured eInvoicing operations, transparent and effective process submitting an invoice, and statistical analyses of the invoicing data. 

Central  authorities  benefitted  significantly  followed  by  large  and  medium  enterprises  that  had  some  benefits  while  micro  enterprises  and  service 
providers did not benefit. They indicate that process automation is a key driver behind benefits. 

As can be seen by Eurostat data, adoption rate overall is still low. They indicated that mandatory B2G followed by mandatory  B2B are the most 
effective measures that could increase eInvoicing adoption at EU and national level. 

174 

 
 
 
 
 
 
Belgium 

Legislation 

Transposition of European Directives 

The  federal law  modifying  the  VAT  code  of  17.12.201284 transposes  the  Directive  2010/45/EU.  This  law  links  the  use  of  eInvoices  with  the 
willingness of the receivers to process it. This law does not mandate the use of eInvoices in B2G procurement. 

The federal law on public procurement of 7 April 201985 transposes the Directive 2014/55/EU. 

The Belgian Parliament  enacted the  new  Royal Decree of March 9, 202286, which establishes new  requirements for eInvoicing in Belgium in the 
public sector. The procedures relate to the obligation of economic operators with regard to electronic invoicing in the context of public procurement 
and concession contracts. The new legislation expands the scope of existing eInvoicing requirements nationwide. The implementation schedule of 
this mandate requires suppliers of public bodies to issue eInvoices based on a combination of (a) the publication date of the tender, and (b) the value 
of the contract with the public body, excluding VAT, as follows: 

• 
• 
• 

1 November 2022: equal or greater than EUR 215,000. 
1 May 2023: equal to or greater than EUR 30,000. 
1 November 2023: below EUR 30,000 but above 3,000. Contract values below EUR 3,000 are exempt from the eInvoicing obligation. 

Regional decisions 

The regional government of Flanders decided in 201687 to make the use of eInvoices in B2G procurement also mandatory for economic operators as 

84 law modifying the VAT code of 17.12.2012 
85 law on public procurement of 7 April 2019 
86 Royal Decree of March 9, 2022 
87 https://overheid.vlaanderen.be/sites/default/files/documenten/overheidsopdrachten/e-procurement/B2016-12-16_beslissing_e-facturatie_0.pdf  

175 

 
 
 
 
 
of 1 January 2017 for all its regional entities. 

Since 1 November 2020, only eInvoices are accepted for all public contracts awarded by the administrations and public organisations of the Brussels-
Capital Region. 

Since 1 January 2022, eInvoices are the preferred method for B2G transactions in the Wallonia region following the region’s announcement88 and 
a guide89 for the contracting suppliers. Invoices sent via PDF or Word formats are no longer accepted, but invoices can still be submitted by post. 
Taxpayers  can  send  eInvoices  through  the Peppol network  to  the  public  entities  or  submit  invoices  manually  via Mercurius90 platform.  All  B2G 
invoices must have an invoice reference, a date, a VAT number, and a supplier's bank account number. Additionally, a Bank Identity Statement will 
be required to be included on the invoices if the bank account details of the issuer are not present in the new database of the Wallonia region. 

Mandatory for  

•  Receiving and processing: Central, regional, and local contracting authorities 

•  Sending: Economic operators of Regional government of Flanders and regional government of Brussels 
•  Mandatory below the EU thresholds: Yes 

Platform 

The Belgian approach is platform agnostic. 

•  The Belgian public sector operates the Mercurius platform for the exchange of eProcurement documents and supports Peppol.  
•  Hermes platform provides a bridge between the entities capable of sending invoices complying with the European Norm, and receivers who 

have not yet found a suitable tool to receive such invoices natively. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented. 

88 announcement 
89 Guide 
90 Mercurius 

176 

 
 
 
 
 
 
Monitoring 

Strategy 

There is a monitoring system in place at the central and sub-central levels. Mercurius ensures partially the monitoring, as the usage of this platform is 
not mandatory.  

The Government of Flanders reports on its results on a monthly basis.  

Suppliers  will  be  mandated  to  use  eInvoicing  and  a  more coordinated  approach  is  in progress  between  central  and  local  authorities.  Belgium  has 
adopted the Peppol interoperability model. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Between 2023-24 Belgium expects to consolidate the results of the initiative of the Flemish Government and the Brussels Government and extend 
them to all contracting authorities in Belgium. In the long term, the entry into force of the ViDA proposal may lead to a wider eInvoicing strategy. 

Strategy for ensuring cross-border eInvoicing interoperability 
Belgium has moved away from traditional platform-centric approach towards a distributed eInvoicing architecture based on  Peppol interoperability 
model. 

The  results  achieved  by  the  Flemish  region  (80%  penetration  of  eInvoicing)  and  the  Brussels  region  (30%  penetration),  which  are  based  on  the 
adoption of Peppol in combination with awareness programmes, indicate that this approach meets its objectives. 

Structured eInvoicing uptake  According to a study performed by the Agency of Administrative simplification:  

• 

In 2013, 29 650 667 (6.02%) outbound invoices and 33 258 300 (7.40%) inbound invoices of enterprises were electronic.  

The Government of Flanders has received close to 80% of all eInvoices based on Peppol. Overall, the growth in the percentage of eInvoices received 
over the past 4 years has increased from 8% of invoices being electronic in early 2017 to 78% in March 2021.  

•  They have approximatively 5 500 Contracting Authorities 
•  The Mercurius platform, that helps Contracting Authorities to receive standardised eInvoices by connecting them to the Peppol network, 
currently supports 2 500 Contracting Authorities, out of which 1 100 are effectively able to receive structured invoices. The only format 
available is EN-compliant.  

•  They estimate the evolution of this figure as follows: 2019: 500 (9%); 2020: 800 (14%); 2021: 900 (16%) (End of year); today: 1 100 (20%) 
•  On  the  side  of  Economic  Operators,  we  currently  have  approximatively  8  000  of  them  sending  eInvoices  through  Peppol  to  our 

Contracting Authorities. We estimate the evolution of this figure as follows: 2019: 3 000; 2020: 4 000; 2021: 6 000; 2022: 8 000.  

177 

 
 
 
•  They don't have a reliable estimate of the total amount of economic operators. To produce such a figure we should specify how it is to be 

calculated, and probably collect and consolidate figures across the Belgian public sector.  

•  CAs have freedom of choice how they meet the Directive, the ones not using Mercurius might use other solutions.  
•  They have not been informed of any other solution to receive EN-compliant invoices for  Contracting Authorities (other than the Peppol - 

Mercurius combination) 

Number  of  Contracting  Authorities  using 
eInvoicing  

2019: 500 (9%) 

2020: 800 (14%) 

2021 Q4: 900 (16%) 

2023 Q1: 1 100 (20%) 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

Note:  estimates  provided  by  the  BE  authorities  for  1  100  Contracting  Authorities  receiving 
eInvoices out of 2 500 CAs, supported by the Mercurius Platform. A total of 5 500 Contracting 
Authorities are present in Belgium.   
2019: 3 000 

Number  of  B2G  eInvoices  from  national 
suppliers  

2020: 4 000 

2021: 6 000 

2022: 8 000 
Central level  

2019: 50 000 

2020: 80 000 

2021: 100 000 

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2022: 120 000 

Sub-central level 

2019: 500 000 

2020: 650 000 

2021: 1 000 000 

2022: 1 300 000 

Notes on above data  

The data reflect both domestic and foreign suppliers.  

All eInvoices handled by Mercurius are exchanged via Peppol,  with the exception of a minor 
volume of manually keyed in invoices (today less than 5%) 

Table 14 Structured eInvoicing uptake in Belgium 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
of 
sending eInvoices 

enterprises 

The data91 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

10% 

11.6%  10.9%  12.3%  15.5%  18.3%  20.6% 

24.6% 

Table 15 Sending eInvoices suitable for automatic processing in Belgium 

91 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

179 

 
 
 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The Belgian public sector receives eInvoices from any sender that meets the Peppol interoperability specifications. The Mercurius platform helps the 
entities  composing  the  Belgian  public  sector  by  providing  a  mailroom  service,  thereby  facilitating  the  technical  aspects  for  both  the  sending  and 
receiving side.  

eInvoice processing is the responsibility of each entity. It highly depends on the business, technical capabilities, and organisational context of each 
entity. 

 Adoption of Peppol along with the national platform Mercurius, has been identified as the way to avoid different implementations and is broadly 
adopted in the public sector. 

All Belgian entities can receive eInvoices compliant with the European standard on eInvoicing, using the components described above. 

Uptake of EN 16931 

According  to  the  Federal  Public  Service  Policy  and  Support  (BOSA),  the  Directive  2014/55/EU  and  the  introduction  of  EN  16931  moderately 
contributed to increasing the adoption of eInvoicing in Belgium for B2G transactions. 

They  also  state  that  for  B2G,  up  to  now,  only  a  fraction  of  Belgian  Contracting  Authorities,  mostly  at  the  Flemish  government  and  the  Brussels 
government,  have  implemented  eInvoicing  up  to  a  significant  level.  Flanders  has  launched  its  adoption  program  before  the  Directive  and  the 
European  Norm.  Brussels  stacked  to  the  timing  of  the  Directive.  Only  now  that  the  national  law  also  mandates  B2G  eInvoicing  for  all  public 
procurement, it is expected that adoption will significantly take up. 

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

Yes 

2019: 500 (9%) 

2020: 800 (14%) 

2021 Q4: 900 (16%) 

2023 Q1: 1 100 (20%) 

180 

 
 
 
Note:  estimates  provided  by  the  BE  authorities  for  1  100    Contracting  Authorities  receiving 
eInvoices out of 2 500  Contracting Authorities, supported by the Mercurius Platform, where all 
eInvoices are exchanged via Peppol, except for a minor volume of manually keyed in invoices 
(today less than 5%). 

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices  

These are estimates of provided by the Belgian authorities for the Mercurius platform. 

Central level  

2019: 100% for all 

2020: 80 000 

2021: 100 000 

2022: 120 000 

Sub-central level 

2019: 500 000 

2020: 650 000 

2021: 1 000 000 

2022: 1 300 000 

Cost and Benefits 

The  expected  benefits  of  the  eInvoicing  adoption  in  Belgium  were  estimated  to  EUR  3.37  billion/year.  The  long-term  objective  is  the  massive 
adoption of eInvoicing. The fragmentation of the eInvoicing landscape is recognised as one of the main obstacles to such massive take-up. 

Table 16 Uptake of EN 16931 in Belgium 

It is also expected that the European eInvoicing standard should be  usable for B2B transactions and become a cross-sector common denominator 
standard. The main additional essential practical component to avoid fragmentation, is adoption of a common framework that goes beyond semantic 

181 

 
 
 
and  syntactic  interoperability,  and  encompasses  legal  aspects,  connectivity,  and governance,  providing  a global  and  consistent  model  that  enables 
unlimited interoperability.   

Implementation costs for EN 16931 

•  Purchase software/hardware:  
•  Training costs:  
•  Change management:  
•  Test environment:  
•  Service providers fees:  
•  Reduced number of staff working on manual invoicing:  
•  Number of staff redeployed in value added  
•  Higher electricity usage due to processing power and data storage space:  
• 

Increase in long term of electronic waste products:  

Table 17 Implementation costs for EN 16931 in Belgium 

CEF Telecom eInvoicing funding  
Budget requested: EUR 983 290  

Benefits at the national level 
The Flemish government communicated92 often about the benefits derived from eInvoicing implementation.  

N/A 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

Feedback from GENA 

GENA states that the directive was an important step towards eInvoicing, but it has led to moderate/low volumes of invoices in European eInvoicing 

92 https://overheid.vlaanderen.be/e-invoicing/resultaten 

182 

 
 
 
 
 
 
standard syntaxes. This is partly due to a lack of adoption incentive for suppliers where a B2G e-invoicing method was already in place. GENA urges 
the Commission to ensure that Member States fully transpose Directive 2014/55/EU.  GENA members agree that the European eInvoicing standard 
does not fully cover all use cases for B2B e-invoicing. The Commission should review realistic paths to resolve existing discrepancies, considering 
that it might not be possible to fully cater for using standardised data for every B2B use case, and that evolution of the European eInvoicing standard 
for B2B purposes may drive adaptation costs for B2G platforms in Member States. 

Feedback from GS1 

GS1 in Europe highlights the significant role of open, global, non-proprietary product data standards, like GS1 Electronic Data Interchange (EDI), in 
the debate on future EU rules on e-invoicing. GS1 EDI provides global standards for electronic business messaging, allowing automation of business 
transactions across global supply chains. Existing use of GS1 EDI includes over three hundred million invoices in the German  retail sector and over 
one  billion  invoices  based  on  GS1  Standards  across  Europe  each  year.  The  introduction  of  mandatory  e-invoicing  for  B2G  has  extended  digital 
exchange to the public sector, providing benefits for administrations. However, the impact on B2B and business in general has been more limited. To 
achieve maximum efficiency, it is advisable to focus on harmonised semantics and a scalable data model, avoid unnecessary disruption of existing 
supply chain processes, and focus on basic requirements in terms of exchange infrastructure and security. 

Key findings 

As of today, for B2G eInvoicing, only a fraction of Belgian Contracting Authorities, mostly at the Flemish government and the Brussels government, 
have  implemented  eInvoicing  up  to  a  significant  level.  Flanders  has  launched  its  adoption  program  before  the  Directive  and  the  European  Norm. 
Brussels implemented the initiative in alignment with the timing of the Directive. Since the national law also mandates B2G eInvoicing for all public 
procurement, it is expected that adoption will significantly increase. 

In the call for evidence, GENA state that it might not be possible to fully cater for using standardised data for every B2B use case. GS1 state that to 
achieve maximum efficiency, it is advisable to focus on harmonised semantics and a scalable data model, avoid unnecessary disruption of existing 
supply chain processes, and focus on basic requirements in terms of exchange infrastructure and security. 

The eInvoicing strategy according to the Federal Public Service Policy and Support (BOSA) is to replicate the results of the  Flemish Government 
and the Brussels Government, to the broader scale of the Belgian Contracting Authorities. Beyond that (2025-2030), the main driver of tax collection 
will most probably be introduced (VAT in the Digital Age).  

As result of a B2G eInvoicing pilot project (2013-2015), BOSA identified the need to get rid of the costs of partners’ onboarding, that goes along 
with traditional, platform-centric approach. This project indicated that this need was covered by adopting Peppol. 

The  results  booked  by  the  Flemish  region  (80%  penetration  of  eInvoicing)  and  the  Brussels  region  (30%  penetration),  which  are  based  on  the 

183 

 
 
 
adoption of Peppol in combination with sensibilisation programs, indicate that this approach meets its objectives. 

184 

 
 
 
 
 
 
Bulgaria 

Legislation 

The amended Public Procurement Act (PPA) by the Law for Amending and Supplementing the Public Procurement Act (LASPPA 93) legislates the use 
of eInvoicing and the European standard in Bulgaria since 18 October 2018.  

The Public Procurement Agency created a dedicated portal94 detailing guidance for compliance.  

According to the Art. 115a. (new  – State Gazette (SG) 86/1895), in force from 1 November 2019, in the case of payment under public procurement 
contracts, all contracting authorities are obliged to accept and process eInvoicing, this to comply with the Directive 2014/55/EU96)97 and implement the 
European standard on electronic invoicing. 

On 1 July 2020, provisions entered into force regarding electronic means of communication for tender evaluation, conclusion of a contract, ordering, 
invoicing, and payment. 

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities, and Local authorities. 

o  Sending: The Bulgarian tax authority NRA (National Revenue Agency) along with industry stakeholders have been discussing 

the idea of introducing mandatory eInvoicing for private entities. 

Platform 

The LASPPA ensures the requirements of eInvoicing Directive transposition and the creation of the Central Automated Information System Electronic 
Public Procurement98 (CAIS EPP) as a national platform for electronic public procurement99. 

93 https://www2.aop.bg/wp-content/uploads/2019/08/ppa_26022019.pdf  
94 https://www2.aop.bg/  
95 https://ials.sas.ac.uk/eagle-i/bulgarian-state-gazette  
96 https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32014L0055  
97 https://www2.aop.bg/wp-content/uploads/2019/08/ppa_26022019.pdf  
98 http://app.eop.bg/  
99 https://www2.aop.bg/cais-eop-questions/  

185 

 
 
 
 
 
Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

It is specified that according to Article 9k, paragraph 3 of the Regulation for the Implementation of the Public Procurement Act101, the users of the 
platform are obliged to monitor their profiles for notifications, messages, and documents.  

The European standard on eInvoicing is fully implemented. 

• 

ISO 20022100 (technical specification used voluntarily, mostly used as 
a payment standard). 

N/A 

eInvoicing 

N/A 

Monitoring 

Strategy 

Structured 
uptake 

Percentage 
sending eInvoices 

of 

enterprises 

Percentage of enterprises sending eInvoices  
The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

The data102 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

100 https://www.iso20022.org/  
101 https://www.oecd.org/gov/public-procurement/publications/guide-public-procurement-legislation-bulgaria.pdf  
102 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

186 

 
 
 
 
 
 
 
 
 
 
Implementation 
16931 compliant eInvoices 

of 

EN 

6.3% 

9.4% 

8.6% 

8.8% 

10.2% 

12% 

12.5% 

10% 

Table 18 Sending eInvoices suitable for automatic processing in Bulgaria 

Approach  

The European standard is mandatory by law for all the contracting authorities.  

eInvoicing  in  Bulgaria  is  based  on  bilateral  agreements  between  economic  operators  (or  solution  providers  acting  on  their  behalf)  and  public 
administrations.  

The Regulation  for  the  Implementation  of  the  Public  Procurement  Act103 states  that  the  exchange  of  documents  and  communications  between 
contracting authorities, candidates, participants, and contractors is carried out through the national platform. 

The electronic signature is optional for eInvoices, and the archiving period amounts to 6 years104. 

eInvoicing services offered by 
(free  of 
the  government 
charge) 
Cost and Benefits 

N/A 

EU funding  

•  Requested funding (in euro): No funding requested. 

Call for evidence 

N/A 

Key findings 

Bulgaria provided no response to the Member State survey. 

103 https://www.oecd.org/gov/public-procurement/publications/guide-public-procurement-legislation-bulgaria.pdf  
104 https://www.pagero.com/compliance/regulatory-updates/bulgaria  

187 

 
 
 
 
 
 
 
188 

 
 
 
 
 
 
Croatia 

Legislation 

Act  on  eInvoicing  in  public  procurement105  (transposing  Directive  55/2014/EU)  entered  into  force  on  1  November  2018.  (OJ  94/2018). 
The  Act  obliged  all  public  procurement  entities  (purchasers/procurers)  to  receive  and  process EN-compliant  electronic  invoices  (eInvoices)  as  of  1 
December 2018. 

The Act also introduced mandatory issuance of structured eInvoices for suppliers /issuers of eInvoices to public administrations as of 1 July 2019. 

According to the Act, all eInvoices issued in public procurement must comply with the European standard on eInvoicing (EN 16931). 

Furthermore,  the  Act  broadened  the  scope  of  the  Directive  and  Croatia  has  made  eInvoicing  mandatory  for  procurement  procedures  below  the 
following thresholds: purchase of goods and services below HRK 200 000 (about EUR 26 000) and works below 500 000 (about EUR 66 000). The 
Act also made eInvoicing mandatory for all procurement using direct purchasing with purchase orders and other similar procedures. 

Mandatory for  

•  Receiving and processing: central and sub-central authorities and entities 
•  Sending: Suppliers of public bodies 

o  Mandatory below the EU thresholds: Yes 

105 https://narodne-novine.nn.hr/clanci/sluzbeni/2018_10_94_1817.html  

189 

 
 
 
 
 
 
 
 
 
 
Platform 

Servis eRačun za državu106. 

There is a central national platform for the exchange of eInvoices, Servis eRačun za državu. All B2G eInvoice exchanges must connect to this platform, 
which interconnects public purchasers, contracting authorities, sectoral contractors, and information intermediaries with their clients. The platform is 
also connected to Peppol (FINA107 Peppol Access Point connected to it) so that all Peppol members could send eInvoices via the central platform. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

Monitoring 

All  B2G  eInvoice  exchanges  are  monitored  through  the  central  eInvoicing  platform  Servis  eRačun  za  državu. The  Ministry  of  Economy, 
Entrepreneurship and Crafts, as the implementing body, may audit public procurement eInvoices, as well as the checking the conformity and operations 
of information intermediaries. 

The European Standard on eInvoicing (EN) is fully implemented in Croatia. The 
Croatian  government  recommends  the  use  of  the  OASIS  UBL  2.1  syntax  for 
B2G public procurement. However, the Cross-Industry Invoice (CII) is accepted 
as an alternative. 

106 https://www.fina.hr/e-servisi  
107 Financial Agency (central eInvoicing intermediary actor) 

190 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
More than 3.5 million eInvoices have been exchanged through the Croatian eInvoicing platform between July 2019 and mid-February 2020. 

Strategy 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Mandating an obligation B2B eInvoicing in upcoming years. 

Strategy for ensuring cross-border eInvoicing interoperability 
Croatian Financial Agency is the access point for Peppol, so Croatia is able to receive any cross-border eInvoice via Peppol. 

Structured 
uptake 

eInvoicing 

Number  of  Contracting  Authorities  using 
eInvoicing  

2020: 5 000 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2021: 5 789 

2021: 82 291 

Number  of  B2G  eInvoices  from  national 
suppliers  

The  number  of  eInvoices  exchanged  through  the  National  Central  Platform  for  eInvoice 
Exchange: 

2019: 2 674 531 

2020: 5 292 282 

2021: 5 700 887 

2022: 4 181 434 

191 

 
 
 
 
Table 19 Structured eInvoicing uptake in Croatia 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
sending eInvoices 

of 

enterprises 

The data108 from Eurostat does not distinguish between B2G or B2B transactions. 

2012 

2011 
11.3% 

2013 
12.1% 

2014 
10.3% 

2015 
10.1% 

2016 
9.9% 

2017 
11.2% 

2018 
12.3% 

2019 

2020 
43.0% 

Table 20 Sending eInvoices suitable for automatic processing in Croatia  

Implementation 
16931 compliant eInvoices 

of  EN 

The national eInvoicing model is required at both the central and sub-central levels. All contracting authorities and associated companies are required 
to implement eInvoicing for their public procurement processes. With the full implementation of the eInvoicing Act from 1 July 2019, all eInvoicing 
exchanges must comply with EN 16931 and be transmitted via the national platform. 

All central contracting authorities are required to connect directly to the central platform, while the sub-central entities may choose to either connect 
directly  to  the  platform  or  to  use  an  information  intermediary.  All  information  intermediaries  (service  providers)  are  required  to  comply  with  EN 
16931, and the technical specifications needed to connect to the platforms. Intermediaries are monitored and a list of compliant companies is published 
on the Ministry of Economy, Entrepreneurship and Crafts web page109. 

Croatia has a CIUS at the national level110 that ensures compliance with Croatian VAT legislation111.  

eInvoices sent through Peppol are not required to be electronically signed, and their archiving is mandatory for 11 years. 

Uptake of EN 16931 

According  to  the  Ministry  of  Economy  and  Sustainable  Development,  the  Directive  2014/55/EU,  and  the  introduction  of  EN  16931  contributed 

108 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
109 https://gospodarstvo.gov.hr/o-ministarstvu/uprave-samostalne-sluzbe/uprava-za-trgovinu-i-unutarnje-trziste/digitalno-gospodarstvo-i-potrosaci/e-racun-11257/11257  
110 https://www.fina.hr/documents/52450/242619/EN-UBL-HR-Specifikacija+upotrebe.pdf/994bf347-5212-6268-932e-4d0685a70927?t=1578052532521  
111 https://www.fina.hr/e-racun-u-javnoj-nabavi  

192 

 
 
 
 
 
 
 
 
 
 
 
significantly to increasing the adoption of eInvoicing in Croatia. 

Is Peppol / eDelivery used  

Yes, 5 176 eInvoices via Peppol in 2022 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

2020: 5 000 

2021: 5 789 

Cost and Benefits 

Table 21 Uptake of EN 16931 in Croatia  

EU funding  
Name of the EU funding programme:  CEF Telecom eInvoicing funding  

•  Requested funding (in euro): EUR 1 612 790. 
•  Year:  2015 - 2018 

eInvoicing was part of the three projects undertaken from 2015 to 2018, by the Ministry of Economy,  Entrepreneurship and Crafts, as a coordinator of 
Croatian  partner  consortia. Through  these  projects,  central  government  bodies,  private  companies  and  public  authorities  of  local  and  regional 
government were supported to prepare to receive and process an eInvoice. 

In cooperation with the Financial Agency (central eInvoicing intermediary actor) and the Croatian Association of Employers, more than 40 educational 
workshops through Croatian cities (Zagreb, Split, Osijek, Rijeka, Varaždin and Vukovar) have been organised. These initiatives aimed to promote and 
educate business entities and public administration bodies in receiving/issuing eInvoices. 

Through  November  and  December  2018,  and  January  2019,  the  Financial  Agency  organised  and  conducted  at  least  30  technical  workshops  for 
eInvoice issuers/suppliers, system integrators (issuing), and public purchasers (receiving and issuing).  

Benefits at the national level 
According  to  the  Ministry  of  Economy  and  Sustainable  Development,  Croatia  has  experienced  the  following  benefits:  automated  and  digitised 
procedures, archiving made easy, fiscal transparency is higher, no more unnecessary printing wasting paper. 

eInvoicing  services  offered 
by  the  government  (free  of 

The central national platform is available for all entities for eInvoicing. 

193 

 
 
 
charge 
Call for evidence 

Key findings 

N/A 

According  to  the  Ministry  of  Economy  and  Sustainable  Development  the  Directive  2014/55/EU  and  the  introduction  of  the  EN  16931  contributed 
significantly to increasing the adoption of eInvoicing in Croatia. 

In terms of effectiveness, the introduction of EN 16931 has created the possibility of wider harmonisation and acceleration of the global eInvoicing 
adoption process in the public sector at the national level of each Member State. The adoption of the eInvoicing Directive has also removed obstacles to 
cross-border procurement and trade. 

The Croatian authorities believe that the Directive has had a significant impact on the adoption of B2G eInvoicing. However,  in B2B, because of slow 
adoption, high investment, and no mandate on invoicing, the impact has been limited.  

The authorities also find that the Directive has increased operational effectiveness, had a beneficial impact on fiscal transparency.  

194 

 
 
 
 
 
 
Cyprus 

Legislation 

The Digital Strategy for Cyprus112, approved by the Council of Ministers of Cyprus on 8 February 2012, recommends the adoption of eInvoicing in 
the  context  of  promoting  the  use  of  ICT  to  enable  a  smart,  sustainable,  and  inclusive  economy  and  society. The Department  of  Electronic 
Communications113, with the guidance of the Advisory Committee for Information Society, developed the strategy for the period 2012 to 2020. This 
strategy is in line with the objectives and actions proposed by the Digital Agenda for Europe114. 

In  Cyprus,  Directive  2014/55/EU  has  been  transposed  via  the  law  of  26  June  2019  on  electronic  invoicing  (eInvoicing)  in  public  procurement. 
eInvoices in B2G public procurement are used on a voluntary basis by suppliers. Receiving and processing of compliant eInvoices is mandatory for 
central public sector bodies from 18 April 2019 on. Sub-central entities are mandated to receive and process compliant eInvoices from 18 April 2020. 

Mandatory for  

Platform 

Standard(s) 

•  Receiving and processing: Central (as of 26 June 2019) and Sub-Central Authorities (as of 19 April 2020) 
•  Sending: not mandated. 

Centralised eInvoicing platform (foreseen in 2024) 

National Standard in use (if any) 

EN 16931 compliant standard 

The  European  standard  on  eInvoicing  is  fully  implemented. There  is  no  monitoring 
strategy in place. 

112 http://ec.europa.eu/information_society/newsroom/cf/dae/document.cfm?doc_id=4831  
113 http://www.mcw.gov.cy/mcw/dec/dec.nsf/DMLindex_en/DMLindex_en?opendocument  
114 http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52010DC0245R(01)  

195 

 
 
 
 
 
 
Monitoring 

There is no monitoring strategy in place. 

Strategy 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The  goal  is  for  the  electronic  invoicing  to  start  to  be  become  mandatory  for  B2G  in  2024.  This  will  depend  on  the  planned  Enterprise  Resource 
Planning (ERP) which will facilitate the processing of eInvoices. Otherwise it may be postponed. In the long-term, the plan is for the elnvoicing to 
become mandatory for all public contracts and, at the same time, to intensify the efforts for mandatory eInvoicing in the other two areas, B2B and 
B2C. 

Structured 
uptake 

eInvoicing 

Number  of  Contracting  Authorities  using 
eInvoicing  

3 out of many 1 000s in 2021 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2021: 0% 

Number  of  B2G  eInvoices  from  national 
suppliers  

2019: 6 

2020: 208 

2021: 119 

Number  of  B2G  eInvoices 
suppliers  

from 

foreign 

2021: 0 

196 

 
 
 
 
 
 
 
Number  of  B2B  eInvoices  exchanged  at 
domestic level   

N/A 

Number  of  B2B  eInvoices  exchanged  at  cross-
border level   

N/A 

Table 22 Structured eInvoicing uptake in Cyprus 

Percentage 
of 
sending eInvoices 

enterprises 

The data115 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Implementation of EN 16931 
compliant eInvoices 

2011 

2012 

2013 

4.6% 

5.3% 

2014 

3.5% 

2015 

5.1% 

2016 

6% 

2017 

8.8% 

2018 

2019 

2020 

11.4% 

13.1% 

Table 23 Sending eInvoices suitable for automatic processing in Cyprus 

Approach  

Currently, economic operators submit eInvoices to the Treasury of the Republic116  on a voluntary basis via the eInvoicing Peppol Access Point and 
through  www.gov.cy,  the  Cyprus  Government  gateway  portal,  which  replaced  the  ARIADNE 117  digital  services  catalogue.  The  eInvoices  are 
processed  manually  (i.e.  non-automated  process).  This  process  will  be  updated  and  performed  in  an  automated  manner  once  the  centralised  ERP 
System of the Cypriot Government enters into operation (2024). 

Cyprus is  expected  to  develop a  centralised  eInvoicing  platform  to  process  eInvoices.  This  platform  will  serve  as  an Enterprise  Resource  Planning 
(ERP)  system  operated  in  a  hybrid  model  with  the  management  of  the  Treasury of  the  Republic  and  involvement  of  AC  Goldman  Solutions  & 

115 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
116 https://www.eprocurement.gov.cy/epps/home.do  
117 https://cge.cyprus.gov.cy/re/public/  

197 

 
 
 
 
 
 
 
 
 
 
Services Ltd as the service provider acting on behalf of public sector organisation.  

Uptake of EN 16931 

According to Treasury of the Republic of Cyprus, the Directive 2014/55/EU, and the introduction of EN 16931 contributed very little to increasing the 
adoption of eInvoicing in Cyprus.  

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  
How  many  B2G  eInvoices  are  exchanged  via 
PEPPOL. 

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   
Percentage  of  EN  16931  compliant  eInvoices 
vs. total number of B2B eInvoices   

Table 24 Uptake of EN 16931 in Cyprus 

Yes 

N/A 

2019: 6 

2020: 208 

2021: 119 
N/A 

N/A 

Cost and Benefits 

Implementation costs for EN 16931 

These costs have not materialised or incurred yet as there is no mandatory elnvoicing. 

Table 25 Implementation costs for EN 16931 in Cyprus 

EU funding  

•  Name of the EU funding programme: CEF - Connecting Europe Facility 
•  Requested funding (in euro): 2 projects for EUR 1 061 850. 
•  Year: 2018 

198 

 
 
 
 
government 

eInvoicing  services  offered  by 
the 
of 
charge) 
Call for evidence 

(free 

N/A 

N/A 

Key findings 

According to Treasury of the Republic of Cyprus, the Directive 2014/55/EU and the introduction of EN 16931 contributed very little to increasing the 
adoption of eInvoicing in Cyprus. In 2021 only 3 public bodies received eInvoices with a total of 119 eInvoices.  According to Eurostat in 2020 only 
13% of enterprises send structured eInvoices. 

The  strategic  goal  is  for  the  electronic  invoicing  to  start  to  be  become  mandatory  for  B2G  in  2024.  This  will  depend  on  the  planned  Enterprise 
Resource  Planning  (ERP)  which  will  facilitate  the  processing  of  e-invoices.  Otherwise,  it  may  be  postponed.  In  the  long-term,  the  plan  is  for  the 
eInvoicing to become mandatory for all public contracts and at the same time, to intensify the efforts for mandatory eInvoicing in the other two areas, 
B2B and B2C. 

Czechia 

Legislation 

Act  no.  134/2016  Coll.  on  Public  Procurement  transposes  EU  legislation  related  to  public  procurement,  including  the  Directive  2014/55/EU on 
electronic invoicing (eInvoicing) in public procurement, into the Czech national legislation. 

Section 221 of the Act stipulates that public contracting authorities shall not reject any eInvoice issued by an economic operator if it is issued in a 
format compatible with the European standard on eInvoicing. The Act became effective on 1 October 2016. 

Mandatory for  

•  Receiving and processing: Central, regional, and local contracting authorities 

199 

 
 
 
 
•  Sending:  (not verified information in EC Country Fact sheet) 
•  For B2B – for some bilateral agreements e.g. In some retail, automotive, and global companies. 

Platform 

Národní elektronický nástroj (NEN)118. Launched in 2015, the NEN platform enables central, regional, and local public contracting authorities to 
process the entire eProcurement life cycle. Developed by the Ministry of Regional Development,  it was fully deployed by the  end of 2017, the 
usage of the NEN is obligatory for all contracting authorities, unless they have the authorisation to use their own procurement tool. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

ISDOC119 

The  European  standard  on  eInvoicing  is  fully  implemented  under EDIFACT 
and UBL 2.1.  

Monitoring 

Strategy 

There is a monitoring mechanism in place but only at the central level.  

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The Ministry of the Interior state that the plan is to use ISDOC inside the PDF/A3 format i.e. a hybrid. 

Strategy for ensuring cross-border eInvoicing interoperability 
The Ministry of the Interior stated there is no information on a cross-border strategy for eInvoicing. 

Structured eInvoicing uptake 

On  16  October 2008,  14  major  Czech  economic operators  signed  a  Declaration  on  a  common  approach  to  electronic  invoicing  solutions  in  the 
Czechia, which contained a commitment to build and implement a common standard for eInvoicing within one year. The Ministry of Finance and 
the Ministry of Interior also signed this document.  This initiative leads to the launch of the national eInvoicing standard, ISDOC, on 19 March 
2009. 

The  process  of handling  eInvoicing  is  considered  as  mostly  automated.  The vast  majority  of  Enterprise  Resource  Planning  systems  (ERPs)  and 
accounting programmes enhance the usage of eInvoices. Some software providers are already working on their automatic distribution.  

118 https://nen.nipez.cz/  
119 http://isdoc.cz/ 

200 

 
 
 
 
 
All  economic  operators  must  issue  eInvoices  for  B2G  transactions  with  public  administrations.  For  receiving  eInvoices,  all  public  contracting 
authorities are mandated within a B2G context, while within a B2B context the buyer’s consent is required. An eSignature is not required and the 
archiving period for eInvoices amounts to ten years, while, archiving abroad is allowed under conditions. 

The following table refers  to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage  of  enterprises  sending 
eInvoices 

The data120 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

8.4% 

11.4%  11.1%  12.5%  12.9%  18.4%  14.4% 

12.2% 

Table 26 sending eInvoices suitable for automatic processing in Czechia 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The translation of the new European standard on eInvoicing (EN 16931) into Czech language and integration into the system of  national technical 
standards (ČSN) was completed and published on 8 January 2018. This activity is led by the Czech Office for Standards, Metrology and Testing 
(ÚNMZ) in cooperation with the National eInvoicing Forum, Ministry of Finance and Ministry of Interior. 

Uptake of EN 16931 

According to the Ministry of Interior, the Directive 2014/55/EU, and the introduction of EN 16931 did not contribute to increasing the adoption of 
eInvoicing in Czechia.  

According to Eurostat data, the number of enterprises using eInvoices declined slightly in the recent past. 

120 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

201 

 
 
 
 
 
 
 
 
 
Cost and Benefits 

The Ministry of Interior stated that the Central Authorities did not benefit from the Directive or the EN. The reason for not achieving high levels of 
eInvoicing adoption is because it is not in scope or priorities.  

EU funding  
CEF Telecom eInvoicing funding: No funds were requested. 

eInvoicing services offered by the 
government (free of charge) 
Call for evidence 

N/A 

N/A 

Key findings 

As can be seen by Eurostat data, the uptake of eInvoicing has plateaued and even declined slightly in the recent past. In a recent report from Czech 
Statistical Office121, eInvoicing data is not mentioned for 2022. This correlates with a comment from the Ministry of Interior stating that the Central 
Authorities did not benefit from this initiative and the reason  for not achieving high levels of eInvoicing adoption is because it is not in scope or 
priorities. 

The  Ministry  stated  that  economic  incentives,  and  accounting  integration  would  be  the  most  effective  measure  that  could  increase  eInvoicing 
adoption  followed  by  mandates  for  B2G  and  B2B.  The  key  drivers  are  a  common  standard,  process  automation  providing  faster  or  timely 
processing. 

121 https://www.czso.cz/csu/czso/elektronickafakturace 

202 

 
 
 
 
 
 
 
 
Denmark 

Legislation 

Platform 

Standard(s) 

Monitoring 

Strategy 

Law on use of electronic invoice no 1593 of 18/12/2018 transposes the Directive 2014/55/EU. 

Consolidation Law on public payments, etc. Act. No.798 of 02.28.2007122 

Order on electronic settlement with public administrations, Order No. 206 of 11.03.2011123 

Order  on  Information  and  transport  of  OIOUBL  electronic  invoice  used  for  electronic  settlement  with  public  authorities,  Order  No.  354  of 
03.26.2010. 

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities & Local authorities 
•  Sending: Economic operators 

NemHandel 

National Standard in use (if any) 

EN 16931 compliant standard 

OIOUBL (national UBL 2.0 standard) 

The European standard on eInvoicing is fully implemented under UBL 2.1. .  

There is a no systemic monitoring system in place. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030). 
National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030). 

While the country adopted eInvoicing in 2005, it hasn’t been mandatory for B2B organisations. Only the public administrators and (B2G) suppliers 

122 https://www.retsinformation.dk/eli/lta/2007/798  
123 https://www.retsinformation.dk/Forms/R0710.aspx?id=133430  

203 

 
 
 
 
 
were required to comply with electronic invoicing in Denmark. 

The  Danish  parliament  passed  the  Bookkeeping  Act  on  May  19th,  2022,  initially  slated  to  take  effect  on  July  1st,  2022.  The  Act  mandates  all 
companies of all sizes to issue, receive, process, and archive invoices electronically. 

All B2B businesses in Denmark will start using the approved system as of January 2024. 

By January 2026, All private companies in class A accounting class generating more than DKK 300,000 must comply with mandatory e-invoicing 
in Denmark. 

Implementation  of  EN  16931 
compliant eInvoices 

Strategy for ensuring cross-border eInvoicing interoperability 
Use of Peppol. 

Approach  

Economic operators can submit eInvoices using three main tools: 

fully integrated eInvoice-enabled Enterprise Resource Planning (ERP) solutions (software or web-based) 

• 
•  ERP solutions in combination with an open-source software provided by the Danish Business Authority, the NemHandel message handler 

client 

•  Manually created in the web-based invoicing portals (webform124).  

Overall, the Danish system is based on the same architectural principles to sign and almost identical open standards for payload.  

Uptake of EN 16931 

The Directive 2014/55/EU and the introduction of EN 16931 poorly contributed to increasing the adoption of eInvoicing in Denmark. 

124 https://virk.dk/myndigheder/stat/ERST/selvbetjening/NemHandel_Fakturablanket/  

204 

 
 
 
 
 
 
 
 
 
Cost and Benefits 

EU funding  
CEF Telecom eInvoicing funding: EUR 544 330 

eInvoicing services offered by the 
government (free of charge) 
Call for evidence 

N/A 

N/A 

Key findings 

In general, the Danish authorities consider their own national action moderately beneficial for the implementation of the Directive. However, the 
Directive itself has had a very low impact on the country’s adoption of eInvoicing in B2B, which is the subject of the latest eInvoicing legislation 
adopted in the country.  

205 

 
 
 
 
 
Estonia 

Legislation 

Platform 

Accounting Act (259 SE), 27.12.2016, Official publication: Riigi Teataja; Number: RT I, 27.12.2016, 3 ; Publication date: 2017-01-01. 

Accounting Act, Official publication: Riigi Teataja ; Number: RT I, 09.05.2017, 30 ; Publication date: 2018-01-0. 

Accounting Act Official publication: Riigi Teataja ; Number: RT I, 15.03.2019, 12 ; Publication date: 2019-01-07 - Currently valid. 

The Accounting Act states that eInvoicing is mandatory upon transfer of goods or services to a public sector accounting entity (local authority, 
legal person in public law or accounting entity which is directly or indirectly under the dominant influence of said persons. 

In addition, it mandates the use of specific formats, either the Estonian standard (national XML-based standard) or the European standard on e-
Invoicing. 

Mandatory B2G eInvoicing for 

•  Receiving and processing (for contracting authorities): since 1 March 2017 
•  Submitting (for economic operators): since the 1st of July 2019 

•  Billberry  
•  E-arveldaja 
•  Finbite 
•  Telema 
•  Unifiedpost 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

Monitoring 

Strategy 

EVS 923: 2014 (National XML-based Standard) 

The  European  standard  on  eInvoicing  is  fully  implemented  and  mandatory 
under UBL, UN/CEFACT CII.  

There is no systemic monitoring system in place for B2G eInvoicing. It is possible to view  from an eBusiness registry provided by the Centre of 
Registers and Information systems (RIK) if a private company (only) can receive eInvoices or not. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
While  the  country  adopted  eInvoicing  in  2005,  it  hasn’t  been  mandatory  for  B2B  organisations.  Only  the  public  administrators  and  (B2G) 

206 

 
 
 
suppliers were required to comply with electronic invoicing in Denmark.  

The Danish parliament passed the Bookkeeping Act on May 19th,  2022, initially slated to take effect on July 1st, 2022125. The Act mandates all 
companies of all sizes to issue, receive, process, and archive invoices electronically. 

All B2B businesses in Denmark will start using the approved system as of January 2024126. 

By January 2026, All private companies in class A accounting class generating more than DKK 300 000 must comply with mandatory eInvoicing 
in Denmark. 

According to the Danish Business Agency, eInvoicing is planned to be used for VAT digital  reporting. It is also planned to be used for decision-
making and policy purposes on the environmental impact. 

Strategy for ensuring cross-border eInvoicing interoperability. 
Use of Peppol.  

Structured eInvoicing uptake 

According to the Ministry of Finance, eInvoicing is mandatory B2G since 2019. Estonia moved a bit early (before EU standard became available), 
and therefore mostly the national standard is used still. In total around 75 million invoices circulate annually in Estonia,  around 45% of these are 
eInvoices. 

B2G eInvoicing transactions 
(Source State Shared Service Centre (RTK)) 

There is no central database for eInvoice sending capability, but Estonian eInvoice operators share this information among themselves. 

According to the RTK, all Estonian public authorities only accept eInvoices. There are also some authorities that have not specified an operator 

125 https://erhvervsstyrelsen.dk/bagom-bogfoeringsloven-gevinster-for-dansk-erhvervsliv  
126 https://www.unimaze.com/e-invoicing-in-denmark/  

207 

 
 
 
 
 
(11%), but those are mainly local government authorities that take care of their accounting at the local government level.  

On July 1, 2020, 1 year passed since the state of Estonia started accepting only eInvoices. Since then, the number of eInvoices received by state 
agencies increased by more than 400%127. 

eInvoices received by the public sector 

Year 

2019 

2020 

2021 

Total number of eInvoices 

50 000 

370 000 

Percentage of eInvoices 

96% 

100% 

Table 27 eInvoices received by the public sector in Estonia 2019-2021 

Contracting authorities (CAs) receiving eInvoices 

2021: 2 446 corresponding to 100% of all CAs. 

Enterprises sending eInvoices.  

2017: 35% of enterprises send eInvoices  

2018: 51% of enterprises send eInvoices  

2019: 73% of enterprises send eInvoices  

The eBusiness registry, where legal persons register their eInvoice operators, contains information about 10 800 persons. As there are approx. 130 
000 active businesses in Estonia according to Statistics Estonia, approx. 8% of businesses have the capability for receiving eInvoices.  

127 https://www.baltictimes.com/the_public_sector_e-invoicing_in_estonia_is_celebrating_its_first_anniversary/  

208 

 
 
 
 
 
 
 
Percentage  of  enterprises  sending 
eInvoices 
Implementation  of  EN  16931 
compliant eInvoices 

45% of invoices in the private sector are electronic (incl. B2B and B2C).  

B2B uptake 

For eInvoicing in the private sector there are no reliable statistics, however, it is estimated that B2B eInvoicing is at 23% of total 52 million B2B 
invoices. In settlements between micro and small enterprises, the share of eInvoices is only around 5%128. 

N/A 

Approach 

Economic  operators  must  have  an  accounting  software  or  ERP  in  place  to  generate  eInvoices  or  can  alternatively  outsource  the  generation  of 
eInvoices to different software providers. 

eInvoicing service providers provide eInvoicing management services including the creation of eInvoices. Economic operators are free to contract 
other private or public software providers such as Merit Tarkvara129 or the Centre of Registers and Information Systems (RIK130). 

In all cases, the service and software providers are mandated to use a national standard to exchange eInvoices. The European eInvoicing standard 
is also mandated in accordance with the Directive. This allows the usage of any standard compliant with the EN. 

Uptake of eInvoicing 

Is Peppol / eDelivery used  

Yes, use of Peppol is generally growing. 

Number  of  public  contracting  authorities  and 
entities using eInvoicing   

2 446 Authorities. 

128 Ibid, p.3.  
129 https://www.merit.ee/  
130 http://www.rik.ee/en  

209 

 
 
 
 
 
2019:100% 

2020:100% 

2021:100% 

Cost and Benefits 

The  transition  to  the  EU  eInvoicing  standard  would  not  be  accompanied  by  direct  financial  expenses  for  businesses,  but  the  expenses  on  the 
development of business software and operators may be indirectly transferred to businesses in the form of service fees131.  

Table 28 uptake of eInvoicing in Estonia 

No exact numerical data available, but public sector entities only accept eInvoices. 

The estimated cost for business software developers would amount to approx. EUR 30 000–50 000132. 

The costs of additional developments related to the internal systems of a company may be added to the estimated amount for certain businesses 
(such as large companies), and the extent of such costs would depend on the level of complexity of the existing system, potentially amounting to 
up to EUR 100 000 in the case of large businesses. 

The use of the EN 16931 may increase the accuracy of the data also required for the automatic generation of different reports (incl. sustainability 
reports)133. 

EU funding  

131 Ibid., p 35. 
132 Ibid. 
133 Ibid. 

210 

 
 
 
 
 
CEF Telecom eInvoicing: 

3 projects were funded totalling EUR 1 741 990. 

eInvoicing services offered by the government (free of charge) 
RIK134,  a  state  agency  working  under  the  Estonian  Ministry  of  Justice,  offers  an  automated  accounting  software  (e-Financials135),  helping 
entrepreneurs organise their accounting and allowing them to generate eInvoices. Unlike all service providers, RIK only charges for its services 
after one year, allowing the economic operators to use its e-Financials136 software free of charge during the first year. The Ministry of Finance and 
RIK agreed on the use of the e-Financials software free of charge from 2019 onwards. If a customer only uses e-Financials for sending eInvoices 
to public sector organisations, then there is no fee for the customer. 

Costs for Service and solution provider 

For the operators, the transition to the EU eInvoice standard would come with a relatively low financial cost, as the services of large operators 
already support the EU eInvoice standard since subscribing to the Peppol network.  

Costs for Accounting Service Providers/ considerations 

Accounting service providers have attempted to sway their clients and their suppliers to use more eInvoices to make their work simpler, but this 
activity has not had a significant effect. Accountants themselves see making eInvoices mandatory in the private sector as a solution, for example 
by giving the buyer the right to request an eInvoice from the seller if the business is marked as an eInvoice user in the commercial register. 

Larger accounting bureaus believe that wider use of eInvoices will reduce their workload, reduce errors, and simplify the process of drawing up 
reports, thereby increasing the efficiency of the sector. Larger bureaus have been promoting wider use of eInvoicing among their clients and their 
suppliers in recent years, but this has not yet resulted in a significant effect. However, the obligation to send eInvoices to the public sector has 

134 http://www.rik.ee/en  
135 http://www.rik.ee/en/e-financials/about-service-0  
136 http://www.rik.ee/en/e-financials/about-service-0  

211 

 
 
 
 
 
significantly increased the number of enterprises that can send eInvoices.  

eInvoicing services offered by the 
government (free of charge) 

The NemHandel platform is available for all entities to use. 

Call for evidence 

N/A 

Key findings 

The Ministry of Finance indicated that the Directive and European eInvoicing standard did not contribute to increasing adoption of eInvoicing for 
either B2B or B2G. The national standard was released in advance of the Directive requirements. According to uptake statistics 100% of public 
bodies receive eInvoices only while 73% of businesses send eInvoices. Therefore adoption rates are high albeit using the national standard. 

The strategy for the future is to replace the national standard with EN compliant standards and use Peppol for cross-border trade. 

The Estonian Chamber of Commerce and Industry assessed that the implementation of eInvoicing among SMEs is relatively low as they often lack 
the  necessary  technical  capability.  Also,  it  may  be  due  to  little  eInvoicing  awareness  among  SMEs.  As  a  result,  while  large  enterprises  in  the 
Estonian market tend to use eInvoices, SMEs, which form over 90% of the legal persons in Estonia, have often not even heard about eInvoices and 
are thus unable to quantify the benefit arising from using them.  

The large Estonian business software providers have mostly developed the  functionalities for processing eInvoices in  their solutions. However, 
activation  of  an  eInvoice  functionality  requires  a  certain  amount  of  configuration  and  calls  for  administrative  operations  by  the  business  or 
accountants,  which  are  deemed  complicated  and  also  relatively  time-consuming.  For  example,  a  business  may  have  concluded  a  contract  with 
eInvoice  operator,  but  their  accounting  service  provider  who  uses  a  business  software  application  may  have  a  contract  with  another  eInvoice 
operator. In this case, the business must undertake the burdensome process of changing its eInvoice operator to be able to use eInvoices.  

Smaller business software applications are often equipped with the capability to send eInvoices, but they may not be able to receive eInvoices.  

Business software providers (whose solutions enable sending and receiving eInvoices) did not highlight any specific issues or obstacles and tended 
to believe that they were not the party preventing wider use of eInvoices. Such business software developers are also not expecting support from 
the  state  for  eInvoicing-related  developments  in  their  software  applications.  It  was,  however,  found  that  the  other  links  of  the  chain  of  using 
eInvoices may have issues. 

212 

 
 
 
 
 
 
Another issue is the lack of interfaces between the business processes and business software related to issuing invoices. For example, businesses 
often  issue  invoices  in  a  certain  software  application  and  send  the  invoice  to  the  customer  and  the  accountant.  In  this  case,  the  outgoing  sales 
invoice is not located in the accounting system and data interoperability issues may arise. 

 Another issue identified was the potential psychological reluctance among accountants to eInvoicing, as this may require them to step out of their 
comfort zone and wider use of eInvoices would also directly mean a decrease in the workload of accountants from the temporal perspective, which 
is why they expect to start earning less in the case of volume-based pricing. All of the above gives rise to a decisive opposition against the wider 
use of eInvoices. 

Taking into consideration the current market of operators, it can be stated that the competition is reasonable, there is no monopoly position, and 
the market is not too fractured, which could pose a problem in a small market. 

213 

 
 
 
 
 
 
Finland 

Legislation 

Law  241/2019  on  electronic  invoicing137  ("Laki  hankintayksiköiden  ja  elinkeinonharjoittajien  sähköisestä  laskutuksesta"),  Official  publication: 
Suomen säädöskokoelma (SK) ; Number: 241/2019 ; Publication date: 2019-02-27 

This law requires public bodies to accept exclusively eInvoices compliant  with the European invoicing standard. It also requires using eInvoices 
below EU thresholds. 

In B2B invoicing, a buyer has the right to request EN-compliant eInvoices from the seller. The contracting entity and the trader shall have the right 
to receive, on request, an invoice from another contracting entity or trader as an EN-compliant eInvoice. 

Mandatory for  

•  Receiving and processing: Central, regional, and local contracting authorities. 
•  Sending: Economic operators 

o  Mandatory below the EU thresholds: Yes 

Platform 

•  Basware Supplier Portal 
•  Post Network Service 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

•  TEAPPSXML 3.0 
•  Finvoice 3.0 

The European standard on eInvoicing is fully implemented under UBL 
2.1 and CII.  

Monitoring 

The government has set specific targets for eInvoicing, and its uptake is monitored monthly. The monitoring includes the total number of invoices 
that are submitted electronically to public bodies. 

137 https://www.finlex.fi/fi/laki/alkup/2019/20190241#Pidp446241968  

214 

 
 
 
 
 
Strategy 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
It is expected that, in the medium term, Peppol-based electronic invoicing will increase in cross-border transactions in particular. Peppol is also 
strongly supported in order-delivery and logistics areas. The long-term target is to phase out the national eInvoice format usage and convert it into 
UBL/Peppol-based format. 

Strategy for ensuring cross-border eInvoicing interoperability. 
Enable and support Peppol infrastructure and usage of Peppol Bis 3.0 (and PINT138 format) invoices. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

100% 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2021: 98% 

Number  of  B2G  eInvoices  from  national 
suppliers  

2019:  

2020:  

138 https://test-docs.peppol.eu/poacc/pint/pint/guide/  

2021: 692 924 (Central Government) 

2022: 4 368 900 (Central Government) 

215 

 
 
 
 
 
 
 
 
 
Notes on above data  

Enquiry made by State Treasury for municipalities.   

2022: 66 743 093 (Sub-central authorities)  

2020: number of eInvoices for 199 municipalities was 4 548 697.  

2021: number of eInvoices for 233 municipalities was 4 641 005. 

Number  of  B2G  eInvoices  from  foreign 
suppliers  

Total number of municipalities in Finland is 309. 
2019:  

2020: 

2021: 5 000 

Number  of  B2B  eInvoices  exchanged  at 
domestic level   

2019: 

Number of B2B eInvoices exchanged at cross-
border level   

2020: 117 263 427 

2021: 139 402 994 

2019: 

2020: 

2021: 

Table 29 structured eInvoicing uptake in Finland 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage  of  enterprises  sending 
eInvoices 

216 

 
 
 
The data139 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012  2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

48.9% 

60% 

71.8% 

79.3% 

82.9% 

Table 30 sending eInvoices suitable for automatic processing in Finland 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The eInvoices sent to the government are centrally processed at the Finnish Government Shared Services Centre for Finance and HR. 

eInvoicing implementation is promoted at the Scandinavian level, in the Nordic Smart Government (NSG) project. In Finland, this project is led 
by the Finnish Patent and Registration Office (PRH) in cooperation with the Ministry of Finance and the Tax Authorities. The aim of the NSG 
project is to automate the financial flow of information between companies in Scandinavian countries.  

Uptake of EN 16931 

According to the Valtiokonttori (State Treasury), the Directive 2014/55/EU and the introduction of EN 16931 contributed moderately to increasing 
the adoption of eInvoicing in Finland. The main impacts came from service providers (operators and banks) and large corporates. 

Finland already experienced high usage before the entry into force of the Directive. However, the Directive and, in particular, the use of EN 16931 
have significantly increased the data quality of the eInvoices. 

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities  using  eInvoicing  compliant  with  the 
EN 16931, versus the total  

Yes 

2021: 100% 

139 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

217 

 
 
 
 
 
 
 
 
 
 
 
Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   

2021: 20% 

Percentage  of  EN  16931  compliant  eInvoices 
vs. total number of B2B eInvoices   

Table 31 Implementation of EN 16931 in Finland 

Feb/2023: 60% 
2021: 20% 

Cost and Benefits 

Costs for insuring that the national standard complies with European eInvoicing standard are estimated at EUR 250 000 but there is no estimate of 
the cost in the ERP system.  

EU funding  

•  Name of the EU funding programme: Internet of Business 
•  Requested funding (in euro): EUR 100 000  
•  Year: 2017 – 2018  

CEF Telecom eInvoicing funding  

•  Budget requested: EUR 265 050  

eInvoicing services offered by the government (free of charge) 
There are three free-of-charge platforms provided by the State Treasury: 

•  The Finnish Government’s eBilling service Handi produces and send eInvoices. 
•  The Post Network Service allows the creation and sending of eInvoices by Finnish companies. Once registered to the platform, economic 
operators can create and send eInvoices. The system verifies the correct provision of information by economic operators and guarantees 
the successful submission of eInvoices to the contracting authorities. 

•  The Basware Supplier Portal. To submit eInvoices via the Basware Supplier Portal, economic operators need to register as a supplier and 
must  be  approved  by  public  contracting  authorities  as  a  "supplier  candidate".  This  portal  allows  the  registration  of  both  Finnish  and 
foreign companies as suppliers. It also enables the storage of eInvoices in the database for three months after their creation. 

Benefits at the national level 

218 

 
 
 
 
The  quality  of  the  invoice  data  has  significantly  improved.  According  to  the  Finnish  authorities,  the  Standard  enables  invoice  processing 
automation. The driver behind the benefits achieved is the work-satisfaction indicated by the national authorities.  

Call for evidence 

Feedback from Finnish State Treasury 

Here  are  statistics  about  our  eInvoice  volumes  and  link  to  this  information.  https://www.valtiokonttori.fi/en/statistics-and-reports/statistics-on-
public-administration-services/state-e-invoicing-statistics/  

Key findings 

Finland  already  experienced  high  usage  before  the  entrance  into  force  of  the  Directive.  However,  the  Directive  and,  in  particular,  the  use  of 
European eInvoicing standard have improved the data-quality of the eInvoices.  

Figure 33 eInvoice VAT error rates in Finland (Source: Finnish Treasury study) 

In particular, the latest findings of the Finnish Treasury show that, while the percentage of VAT-errors was at over 70% in April 2021, it decreased 
to  40%  by  the  end  of  the  researched  period,  thanks  to  the  higher  adoption  of  EN  16931-compliant  eInvoices.  It  demonstrates  the  significant 
increase of data quality of using the eInvoicing standard. 

The use of B2G eInvoicing is increasing from 92% in 2018, to 98% in 2022. 

219 

 
 
 
 
Figure 34 eInvoice uptake in Finland (Source: Finnish study) 

220 

 
 
 
 
 
 
 
France 

Legislation 

•  Ordinance No. 2014-697140 of 26 June 2014 on the development of electronic invoicing repealed by the Law n°2019-486 of 22 May 2019. 
•  Business Growth and Transformation law n°2019-486 of 22 May 2019, Article 193141 )  – PACTE, official publication : Journal official de la 
République française (JORF), Publication date : 23 May 2019,which amended the Public Procurement Code142 to introduce provisions on 
electronic invoicing in public procurement (articles L.2192-1 to L. 2192-7, L.2392-1 to L.2392-7 and L. 3133-1 to L.3133-5). 

•  Decree  No  2019-748  of  18  July  2019  on  electronic  invoicing  in  public  procurement143,  Official  publication:  Journal  Officiel  de  la 

République Française (JORF) ; Publication date: 2019-07-21 

•  Article 26 of the amending finance law n°2022-1157 for 2022144 on B2B eInvoicing and the transmission of transactions data. 
•  Decree n°2022-1199145 and Order of 7 October 2022146 on the generalisation of electronic invoicing in transactions between taxable persons 
for  value  added  tax  and  the  transmission  of  transaction  data,  Official  publication:  Journal  officiel  de  la  République  Française  (JORF), 
Publication date: 2022-10-09. 

Article 193 of the Law n°2019-486 of 22 May 2019 codified in the Public Procurement Code stipulates that holders and subcontractors entitled to 
direct  payment  of  contracts  involved  in  public  procurement  shall  send  their  invoices  in  electronic  form,  which  have  to  be  accepted  by  all  public 
administrations. 

The  mandatory  submission  of  eInvoices  started,  on  a  gradual  basis,  from  January  2017.  According  to  the  latest  ordinance,  the  date  of 

140 https://www.legifrance.gouv.fr/loda/id/JORFTEXT000029140226  
141 https://www.legifrance.gouv.fr/loda/article_lc/LEGIARTI000038497517  
142 https://www.legifrance.gouv.fr/codes/section_lc/LEGITEXT000037701019/LEGISCTA000037703428/#LEGISCTA000037703428  
143 https://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000038793215&categorieLien=id  
144 https://www.legifrance.gouv.fr/jorf/article_jo/JORFARTI000046186698  
145 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000046383394  
146 https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000046383471  

221 

 
 
 
 
 
enforcement of the law for the suppliers varies according to the company size. 

Mandatory B2G  

•  Receiving and processing: Central authorities, Regional authorities, and Local authorities  
•  Sending: Economic operators 

o  Mandatory below the EU thresholds: Yes 

Mandatory B2B 

Article 26 of the amending finance law n°2022-1157 for 2022147 states an obligation for taxable persons to send eInvoices with mandatory fields in a 
structured form to be forwarded to the Tax Administration and to transmit data to the tax administration on Business to Consumers and cross-border 
transactions by means of a platform148. 

In December 2023, the French National Assembly amended the original implementation dates, foreseen under the amending finance law n°2022-1157 
for 2022, through an adopted amendment to the 2024 Budget. The revised proposals are outlined as follows: (i) by September 2026, all businesses 
must be capable of accepting eInvoices, with B2B eInvoicing and eReporting becoming mandatory for large and medium-sized companies. An 
optional extension is available for an additional three months, allowing flexibility until December 2026; and (ii) by September 2027, small businesses 
are required to adopt eInvoicing and eReporting, with an option to extend the deadline by a further three months until December 2027. 

Platform 

In France, due to compulsory legislation concerning eInvoicing, a national unique invoicing portal called Chorus Pro149 has been developed by the 
Agence  pour  l'Informatique  Financière  de  l’État  (AIFE),  the  French  national  public  agency  for  IT,  relying  of  the  Ministry  for  the  Economy  and 
Finance. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

147 https://www.legifrance.gouv.fr/jorf/article_jo/JORFARTI000046186698  
148 The implementation dates of the amending finance law n°2022-1157 for 2022 were the following: starting on 1 July 2024 for large companies; at the latest on 1 January 2025 for medium-size companies; at the latest on 1 
January 2026 for all companies. 
149 https://chorus-pro.gouv.fr/cpp/utilisateur?execution=e2s1  

222 

 
 
 
 
 
Monitoring 

Strategy 

Hybrid format called Factur-X which encapsulates both structured data and a pdf. 

The  European  standard  on  eInvoicing  is  fully  implemented 
under UBL 2.1 and CII. 

The Agency for State Financial  Information (AIFE) operates the central eInvoicing platform Chorus Pro that monitors the uptake of eInvoicing at 
both central and sub-central levels, including the number of suppliers using eInvoicing and the number of eInvoices submitted electronically. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
B2B eInvoicing will be mandated 2024 to 2026, starting with the large enterprises and finishing in 2026 with SMEs. 

Strategy for ensuring cross-border eInvoicing interoperability. 
ViDA (VAT in the digital age proposition of 8 December 2022) proposals will be the driver to consider cross border.  This could create additional 
complexity for companies. 

Structured eInvoicing uptake 

In 2013, the State was only able to process 34 000 eInvoices. The following tables show the eInvoicing uptake for France since then.  

Number  of  Contracting  Authorities  using 
eInvoicing  

2019: 100% 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

Number  of  B2G  eInvoices  from  national 
suppliers  

2020: 100% 

2021: 100% 

2022: 892,234 
Central Level  

2022: 4 368 900 

Sub-Central Level  

223 

 
 
 
 
 
Number  of  B2G  eInvoices 
suppliers  

2022: 66 743 093 

from 

foreign 

2019: 143 696 

2020: 247 140 

2021: 403 286 

2022: 532 734 

Table 32 Structured eInvoicing uptake in France 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

of 
Percentage 
sending eInvoices 

enterprises 

The data150 from Eurostat does not distinguish between B2G or B2B transactions. 

Implementation  of  EN  16931 
compliant eInvoices 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

9.3% 

9.5% 

14.9% 

25.3% 

23.4% 

Table 33 sending eInvoices suitable for automatic processing in France 

Approach  

eInvoicing  will  be  mandatory  for  B2B  transactions  from  1  July  2024  for  B2B  transactions  and  subject  to  a  transmission  of  data  to  the  tax 
administration. It will concern 4 million companies. Therefore, the B2G system has been adapted so as to meet the standards of the B2B system. 

The current Chorus Pro solution supports the following: 

•  B2G: Invoicing to public bodies from a national or foreign company (These invoices are sent to their recipient (or made available) directly 

150 The data description can be found at https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm.  

224 

 
 
 
 
 
 
 
 
 
 
 
by the Chorus Pro platform). 

•  A user interface for managing eInvoices issued and received (portal).  
•  APIs for the deposit, retrieval, and management of invoices 
•  Multiple transmission protocols such as using the PeSIT HS E, AS2 and SFTP protocols. 
•  PEPPOL as a receiving access point. 
•  The accepted invoice formats are CII, UBL, CPP Invoice (proprietary format) simple PDF and Factur-X. Invoices are sent in CPP Invoice 

format (proprietary format)  
Invoice lifecycle data is transmitted via flows in CPPStatut format (proprietary format) 

• 

From July 1, 2024, the Chorus Pro solution will also cover the following use cases. 

•  B2B (eInvoicing): Receiving and issuing invoices between private companies (French or foreign) subject to VAT in France. 

o  This case also covers B2G (Invoices to the French public sphere sent by a French or foreign company). 
o  This case also covers the G2B (Invoices to private companies (French or foreign) subject to VAT in France addressed by the French 

public sphere). 

o  These invoices will be transmitted to their recipient (or made available), directly (via the Chorus Pro platform) or indirectly (via a 

private partner platform chosen by the recipient). 
Invoice data will be used by the administration to pre-fill the VAT return. 

o 

• 

International  B2B:  Receipt  of  invoices  received  or  sent  by  a  company  subject  to  VAT  in  France,  issued  or  intended  for  a  company  not 
subject to VAT in France. 

•  These invoices will not be transmitted to their addressee (exploitation of the data by the administration for the pre-filling of the VAT return). 
•  B2C: Receipt of invoices issued by a company subject to VAT in France to a final consumer. 

o  These  invoices  will  not  be  transmitted  to  their  recipients  (data  processing  by  the  administration  for  the  pre-filling  of  the  VAT 

return) 

The Chorus Pro solution will also allow the addition of AS4 protocol management to the flow exchange solution (EDI). 

It will require compliance with the EN16931 standard for exchanged invoices and will limit the accepted input and output formats to UBL, CII and 
Factur-X (simple PDF will be depreciated and then rejected within 3 years). 

It will use a new format for exchanging invoice life cycle data (UN/CEFACT SCRDM CI Cross Domain Application Response message). 

Uptake of EN 16931 

225 

 
 
 
 
 
According to the Ministère de l'économie - Direction générale des finances publiques (DGFiP), the Directive 2014/55/EU and the introduction of EN 
16931  had  a  very  significant  impact  to  increasing  the  adoption  of  B2G  eInvoicing  according  to  the  French  authorities.  In  B2B  eInvoicing,  the 
Directive contributed moderately.  

Is Peppol / eDelivery used  

Yes   

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices  

Access point Pagero 
2019: n/a 

2020:  

Other: 16 503 342  

Factur-X = 414 015  

Total: 16 917 357 

Percentage Factur-X: 2.45% 

2021: Other: 22 938 762 

Factur-X: 675 844  

Total: 23 614 606 

 Factur-X percentage: 2.86% 

Table 34 Uptake of EN 16931 in France 

Cost and Benefits 

France did not incur costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. There was also no cost 
burden ensuring the national format complied with the EN. They did not seek funds to ensure compliance.  

226 

 
 
 
The French Ministry stated that overall benefits greatly outweighed the costs. A very high level of legal certainty was introduced by the Directive and 
significant  technical  simplification  was  provided  through  the  use  of  a  common  EU  eInvoicing  standard.  There  was  a  considerable  cost  reduction 
because of the Directive and the EN 16931.  

The impact study, related to Ordinance 2014-697 ,estimates the potential for recurring gains, once electronic invoicing is generalised (2021) at  EUR 
710.2  million  per  year,  which  can  be  broken  down  into  financial  gains  of  EUR  121  million  and  overall  time  savings  representing  11,925  FTE 
equivalents.    

France did not incur costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

CEF Telecom eInvoicing funding   

•  Budget requested: EUR 243 490. 

eInvoicing services offered by the government (free of charge) 
The usage of Chorus Pro (processing compliant documents against the EN) is free for any business partners. Consequently, the implementation of the 
European eInvoicing standard had no direct financial impact on public administrations and suppliers 

Benefits of the EN 16931 at the national level 
Operational efficiency:  

One of the aims of the directive 2014/55/UE is to reduce late payments. The average payment time is less than 14 days for state accountants in 2022. 

eInvoicing  services  offered  by 
the government (free of charge) 

N/A 

Call for evidence 

Feedback from French Building Federation 

The  quality  of  the  payment  process  and  compliance  with  payment  deadlines  by  the  contracting  authority  are  crucial  for  construction  companies’ 
response to public contracts. Late payments are a significant obstacle for SMEs and micro-enterprises access to public contracts. In France, Chorus 
Pro is the invoice tracking portal for the public sphere, and all companies supplying public entities must send their invoices electronically. However, 
late payments are often due to non-compliance with Chorus Pro regulations. Some suppliers or prime contractors use Chorus Pro to a lesser extent, 
creating informal steps in the payment process, leading to hidden payment delays. When the Chorus Pro procedure is followed, companies recognize 

227 

 
 
 
 
an improvement in deadlines. 

Feedback from EU Citizen 

The writer, a professional in electronic invoicing with over 15 years of experience, actively participates in several associations and working groups. 
They would like to draw the Commission’s attention to the fact that the EN16931 standard is primarily adapted to a B2G context and may need to 
evolve to take into account B2B specificities. The governance of this standard should be reviewed as changes currently seem difficult. The EN16931 
standard  allows  for  interoperability  of  formats,  but  it  is  important  to  also  standardize  exchanges  of  statuses  after  the  issuance  of  an  invoice.  The 
EN16931  standard  allows  for  the  use  of  two  syntaxes,  UBL  and  CII,  but  the  PEPPOL  network  only  supports  UBL.  The  writer  suggests  either 
favouring  the  use  of  one  syntax  or  guaranteeing  support  for  both  syntaxes  by  all  actors  and  the  possibility  of  performing  exhaustive  conversions 
between them. 

Feedback from a Business association - FNFE-MPE 

Directive  2014/55/EU  has  been  instrumental  in  the  deployment  of  electronic  invoicing  in  the  EU,  allowing  for  the  development  of  a  Semantic 
Standard  for  essential  invoice  data.  However,  deployment  has  remained  relatively  low,  except  in  countries  with  an  obligation.  In  France,  the 
obligation to issue and centralize flows for the public sector around ChorusPro has resulted in over 80 million electronic invoices issued to the public 
sector per year since 2021. Flexibilities have been introduced, allowing for hybrid invoices. In practice, EN16931 Standard syntaxes are still rarely 
used. The proposed ViDA Directive has encountered difficulties, including a different definition of electronic invoicing than Directive 2006/112/EC 
and difficulties in evolving the EN16931 Standard to address the private sector and all invoicing use cases. 

Feedback from National Federation of Public Works (FNTP) 

In France, all companies supplying public entities have been required to send their invoices electronically via Chorus Pro since 1 January 2020. The 
platform, built by the Agency for State Financial Informatics (AIFE), allows companies to submit or enter an invoice, follow  its processing, and add 
additional documents. However, difficulties have been noted, with employees having to modify their working methods and follow training. In 2023, 
difficulties of use are still noted among large public buyers. The positive points include better traceability of invoice follow-up, but negative points 
include the possibility for buyers to reject invoices without specific justification, requiring companies to resubmit a new invoice and causing a new 
payment period to run. 

Key findings 

Since 2013, when the vast majority of the 95 million annual invoices received by the State, local authorities and public institutions were issued and 
transmitted in paper format, France has successfully promoted the use of B2G eInvoicing through national policy that gradually mandated suppliers to 

228 

 
 
 
eInvoice the public sector from 2017 to 2020.  

According to the Ministère de l'économie - Direction générale des finances publiques (DGFiP), the Directive 2014/55/EU and the introduction of EN 
16931 had a very significant impact to increasing the adoption of B2G eInvoicing. 

From  2019,  the  eInvoices  received  from  foreign  suppliers  to  France’s  public  sector  have  also  been  on  an  upward  trend,  from  143,696  in  2019  to 
532,734 in 2022. 

The use Peppol eDelivery network has gradually increased. 

The Government did not experience any cost in the implementation of the Directive. 

A  high  level  of  adoption  is  expected  in  B2B  sector  thanks  to  the  introduction  of  the  B2B  mandate,  from  2024  to  2026,  which  will  impact 
approximately four million companies. 

In the call for evidence, two business organisations state that although Chorus Pro has benefits, the lack of experience or training by Buyers can delay 
payments. There is also the request to consider syntaxes, specifically the hybrid. 

229 

 
 
 
 
 
Germany 

Legislation 

Act transposing Directive 2014/55/EU on electronic invoicing in public procurement151/ e-Bill law152 (E-Rechnungsgesetz153); Federal level, Official 
publication: Bundesgesetzblatt Teil 1 (BGB 1); Number: 19; Publication date: 2017-04-10.  

Federal Regulation  on  electronic 
publication: Bundesgesetzblatt Teil 1 (BGB 1) ; Number: 68 ; Publication date: 2017-10-18 ; Page: 03555-03557. 

in  public  procurement  of 

invoicing 

the  Federal  Government154 (E-Rechnungs-Verordnung), Official 

Since 18 April 2020, federal states have implemented mandatory eInvoicing in public procurement of the state authorities. 

Since 27 November 2020, the receiving of eInvoices by state authorities is mandatory to all public contracting authorities on the state level (Länder). 

Mandatory for  

•  Receiving  and  processing:  Central  authorities,  Regional  authorities,  and  Local  authorities  since  18  April  2020  for  all  federal,  and  state 

contracting authorities. 

•  Sending: From November 2020, issuing of eInvoices is mandated for all suppliers to all federal and Bremen contracting authorities, only for 

contracts above the threshold. 

o  Mandatory below the EU thresholds: Yes, for federal government and some federal states. 

Based on E-Rech-VO and decisions by the IT Planning Council, Germany implemented the Procurement Directive in the following way155 

151 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:272704  
152 http://www.verwaltung-innovativ.de/SharedDocs/Publikationen/Organisation/e_rechnung_BGB_e-Rechnung.pdf?__blob=publicationFile&v=2  
153 https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/eInvoicing+in+Germany#_ftn1  
154 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:272702  
155 Pagero and Crossinx “e-Invoice format best practice: Germany” (2019) 

230 

 
 
 
 
 
 
 
•  Mandatory for receiving and processing by public authorities. 

o  General readiness: 

▪  From 27 November 2018 for certain federal authorities such as constitutional bodies and federal ministries, 
▪  From 27 November 2019 for all other federal authorities, 
▪  From 18 April 2020 for all other authorities in federal states and municipalities 

o  Peppol readiness: 

▪  From 18 April 2019 for federal authorities, 
▪  From 18 April 2020 for all other authorities who choose to offer automated data exchange capabilities 

•  Exempted from the mandate: 

“Organleihen” (German), 

o  Direct orders with anticipated net order value of max EUR 1.000, 
o 
o  Foreign procurements, and 
o  Defence and security related contracts. 

Platform 

A shared portal (E-Rechnungs-Portal) was created on the federal level. Some federal states (Länder) use this shared portal too while others built their 
own portal or do not use any portal. The obligation on suppliers to use a specific eInvoicing platform depends on which  public authority is receiving 
the eInvoice. All authorities at federal and national level are mandated to always offer Peppol as an alternative for B2G eInvoicing. 

Standard(s) 

National Standard in use (if any) 

•  XRechnung and  ZugFeRD  are  the  national  CIUS  for  eInvoicing  and  are  compliant  with  the 
EN  16931.  XRechnung  can  be  represented  in  either  UBL  or  CII,  while  an  eInvoice  in 
ZUGFeRD  2.0  is  the  CII  syntax  embedded  in a  human-readable  document  in  the  form  of  a 
PDF, aka a hybrid invoice.  

•  XRechnung  was  developed  by  Kosit156  based  on  a  decision  from  the  national  IT  Planning 

Council157, while the ZugFeRD is developed by the national eInvoice forum, Ferd158. 

EN 16931 compliant standard 

The  European  standard  on  eInvoicing  is 
fully implemented under CII and PDF/A-3. 

.  

156 KoSIT is responsible for coordinating the development and operation of IT standards for sharing data within the public administration. 
157 The responsibilities of the IT Planning Council include coordination of federal and state cooperation on information technology issues. 
security standards 

231 

 
 
 
 
 
Monitoring 

Strategy 

• 

In  accordance  with  the  German  IT  Planning  Council,  Public  authorities  that  automatically 
process eInvoices must also accept Peppol BIS Billing 3.0. 

According to the Hessen Ministry of Finance, to date, no data have been collected for Germany as a whole. In the Member State survey, Germany had 
no response to specific questions on quantities for central or sub-central authorities. 

National eInvoicing strategy 
According to the Hessen Ministry of Finance, B2G in different federal states is planned.  

On October 25, 2022, the German Congress (Deutscher Bundestag) published a document in which the Federal Ministry of Finance informs about the 
measures it is taking to reduce tax fraud in the country. The government intends to modernise the tax system to create, verify, and send invoices and 
improve communications between public administrations and businesses. The Ministry is examining the structure and effectiveness of the eInvoicing 
models adopted by other countries of the European Union such as Italy, Belgium, and other parts of the world like Mexico, South Korea, and Turkey. 

For B2B transactions, the German Bundestag parliament has called for the adoption of B2B mandatory eInvoicing to help combat  VAT fraud. They 
expect to be consistent with the VAT in the Digital Age (ViDA) initiative, which involves utilising the European eInvoicing standard. Germany has 
requested a derogation based on Article 395 of Council Directive 2006/112/EC to make electronic invoicing mandatory for B2B. 

Strategy for ensuring cross-border eInvoicing interoperability. 
According to the Hessen Ministry of Finance, the strategy for cross border interoperability is to use invoices compliant with EN 16931. 

Structured eInvoicing uptake 

In a 2019 survey159 it projected that about 32 000 million eInvoices are transacted every year in Germany. The survey showed that approximately 
33% of larger enterprises (employing more than 500), has already been using eInvoicing, while only 20% of smaller enterprises did so.160   

In a Bitkom survey161 of enterprises with 20 or more employees who send eInvoices (including PDFs); 44% use EDI, 11% use ZugFeRD, 9% use 

158 https://www.ferd-net.de/about-us/ferd-and-competence-centers/index.html  
159 (E-Invoicing in Germany: progress and current status, 2019) 
160 (Zahorsky, 2020) 

232 

 
 
 
 
 
 
XInvoice (xRechnung). The study also found that 44% of enterprises believe that the exchange of structured electronic documents is highly relevant. 

According to the Seeburger survey “Results E-Invoicing plus Autumn 2020 survey”162, addressed to German enterprises, 44% of respondents sent 
fewer than 100 000 on an annual basis. Only 22% of those surveyed gave a higher value. Around a third of those surveyed stated that they processed 
fewer than 10 000 incoming invoices a year (35%). 76% of the respondents preferred structured eInvoices such as ZUGFeRD, XRechnung, or EDI. 
While 13% preferred email and only 4% preferred paper. 

55%  of  the  respondents  do  business  with  public  or  government  bodies  or  would  be  doing  so  in  the  near  future.  They  are  or  will  be  required  to 
exchange structured invoices with this client base. 

41% of the respondents preferred to use the XRechnung format for B2G in Germany, followed by ZUGFeRD (21%). Due to the fact it is not yet 
wide-spread and possibly due to the costs it incurs, Peppol was not really on the respondents’ radar (8%). 

Only a few prefer entering invoice data into a public administration portal (11%). Manual entry could be an option if there aren’t enough invoices to 
justify investing in an eInvoicing system. 

of 
Percentage 
sending eInvoices 

enterprises 

The data163 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

7% 

9.4% 

12% 

13.5%  15.6%  17.2%  16.5% 

17.7% 

Table 35 sending eInvoices suitable for automatic processing in Germany 

161 Digital Office Index 2022 (bitkom.org) 
162 Seeburger study link.  
163 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

233 

 
 
 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Approach  

Most  eInvoicing  operations  are  conducted  following  bilateral  agreements  between  public  entities  and  economic  operators  (or  solutions  providers 
acting on their behalf). 

The  approach  for  receiving  and  processing  eInvoices  submitted  by  economic  operators  is  decentralised.  Public  entities  receiving  eInvoices  decide 
whether to process eInvoices as structured data or otherwise. For structured data, the Peppol network can be used as well as the federal level shared 
portal (E-Rechnungs-Portal). 

Within the B2G context, issuing of eInvoices is mandated for all suppliers to all federal and Bremen contracting authorities.  

Electronic invoices do not need to be electronically signed and need to be archived for ten years, which, under conditions, is possible abroad164. 

In  2019  it  was  projected  that  about  32,000  million  eInvoices  are  transacted  every  year  in  Germany.  A  survey  in  December  2019  showed  that 
approximately  every  third  enterprise,  employing  more  than  500  people,  has  already  been  using  eInvoicing,  while  among  smaller  enterprises  only 
every fifth did so[15].  As federated state authorities have been mandated to accept eInvoices in November 2020 only, more up-to-date statistics need 
to be awaited. 

Uptake of EN 16931 

According to the Hessen Ministry of Finance, the Directive 2014/55/EU, and the introduction of EN 16931 has significantly contributed to increasing 
the adoption of eInvoicing in Germany. 

XRechnung and ZugFeRD are supported on the federal platform and are fully compliant with EN 16931.  

In  October  2018,  the  German  IT  Planning  Council  made  an  obligation  for  all  authorities  to  always  offer  PEPPOL,  if  an  automated  data 
submission/exchange is provided for the delivery of eInvoices.  

164 (Compliance updates Germany, 2021) 

234 

 
 
 
 
 
 
 
 
Based on the Bitkom survey of 2022, 20% of businesses with 20 or more employees use compliant eInvoices i.e. ZUGFeRD or XRechnung. 

Cost and Benefits 

According to the Hessen Ministry of Finance Germany, the cost reduction as a result of the Directive and EN 16931 was low, however the extent of 
the costs has yet to be determined.  

According to the authors of the Seeburger survey, as a rule, a bookkeeper  can only process 7 000-16 000 invoices a year. The personnel costs alone 
for  this  area  work  out  at  EUR  5  –  EUR  15  per  invoice.  In  a  paper-based  workflow,  there  are  further  costs  incurred  for  approving  the  invoice, 
clarifying discrepancies in amount or price, and then archiving the document. Analysis carried out in some organisations showed that an average of 
five  copies  of  each  invoice  were  made  then  redundantly  archived  (secretary,  cost  centre  manager  etc.).  As  the  information  in  eInvoices  is  read 
automatically, it doesn’t need to be entered manually into the recipient’s ERP system. Furthermore, this reduces the amount of errors made in data 
entry, or even the amount of invoices lost. At the same time, structured invoices noticeably speed up and improve the whole purchase to pay process. 
Seeburger has discovered that the savings potential for the invoice recipient works out at around EUR 4.50 per invoice. 

EU funding 
Germany did not seek EU funding. 

eInvoicing services offered by the government (free of charge) 
E-Rechnungs-Portal is used for eInvoicing with the  federal government. Some federal states use this shared portal too, while others use their own 
portal.  

All authorities at federal and national level are mandated to always offer Peppol as an alternative for B2G eInvoicing. 

The obligation on suppliers to use a specific eInvoicing platform depends on which public authority is receiving the eInvoice. 

Benefits at the national level 
According to the Hessen Ministry of Finance Germany, these figures were not collected. 

eInvoicing  services  offered  by 
the government (free of charge) 

N/A 

235 

 
 
 
 
Call for evidence 

Feedback from: Global Legal Entity Identifier Foundation (GLEIF) 

The Legal Entity Identifier (LEI) is a global ISO standard (ISO 17442) for  unique, unambiguous legal entity identification. It offers a supra-sectoral 
and  supra-EU  solution.  It  also  ensures  interoperability  across  Member  States  as  well  as  firms  participating  from  non-EU  countries  The  GLEIF 
suggested to include the LEI as a mandatory data element within the semantics of the European standard for eInvoicing. 

Feedback from DATEV eG 

The  EN  16931  is  considered  to  be  a  solid  framework  for  the  creation  of  electronic  invoices  in  the  B2G  environment,  which  needs  to  be  further 
specified  and  expanded  regarding  the  planned  application scenario  in  the  B2B  context,  based  on  the  requirements  of  the  VAT  in  the  Digital  Age 
(ViDA) proposal. It is necessary to add fields to the core data set that were previously only used as options or, if necessary or to develop extensions. 
These points, which are essential for the standardisation of electronic invoices, should be analysed, discussed, and implemented by DG GROW and 
the responsible standardisation committees with regard to the desired automated invoicing process. 

Feedback from an EU Citizen 

The transmission of eInvoices should ensure the protection of personal data, notably in the context of services being invoiced that are subject to the 
medical secret (invoicing of services rendered by hospitals, laboratories, doctors, etc.). Access by non-authorised people to such sensitive information 
must be excluded. 

Key findings 

The Hessen Ministry of Finance in Germany was the authority that answered the survey on behalf of Germany.  They stated that the Directive and the 
European eInvoicing standard has significantly contributed to increasing the adoption of eInvoicing in Germany.  

While eInvoicing is mandatory for suppliers sending eInvoices to federal public authorities, this is not the case elsewhere. The key driver in the future 
will be dealing with tax fraud. The government intends to modernise the tax system to create, verify, and send invoices and improve communications 
between public administrations and businesses. 

Eurostat figures do not show an increase in the number of enterprises sending eInvoices, however as the B2G mandate did not start effectively until 
2021, this was not unexpected. 

All German formats are now compliant with the EN, but adoption is still not high overall as seen by Eurostat where in 2021 it was less than 19%. 
Also the 2020 Seeburger survey showed low usage of Peppol at 8%. 

For B2B transactions, the German Bundestag parliament has called for the adoption of B2B mandatory eInvoicing to help combat VAT fraud. They 

236 

 
 
 
expect  to  be  consistent  with  the  European  VAT  in  the  Digital  Age  (ViDA)  initiative,  which  involves  utilising  the  European  electronic  invoice 
standard. Germany has requested a derogation based on Article 395 of Council Directive 2006/112/EC to make electronic invoicing mandatory for 
B2B. 

237 

 
 
 
 
 
 
Greece 

Legislation 

The transposition of the Directive 2014/55/EU165 into Greek law was adopted in the first quarter of 2019 (Law 4601/2019). The transposition aligns 
with the text and scope of the Directive however it mandates the issuance of two Joint Ministerial Decisions (JMDs), i.e. secondary level legislation, 
in order to stipulate the details regarding the adoption of the semantic data model of eInvoices and the architecture of eInvoicing in Greece. 

The Ministerial Decision No. 1017 / 14.02.2020166 (National Gazette, Issue B, Sheet 457) was issued by the Ministry of Finance, which is specifies 
the eInvoice format for B2B transactions (fully compliant to the European standard on eInvoicing and the chosen Peppol CIUS for B2G),  

Also, the Ministerial Decision No. A.1035 / 18.02.2020167 (National Gazette, Issue B, Sheet 551) was issued by the Ministry of Finance, which is 
stipulating rules and regulations regarding eInvoicing Service Providers. 

For the alignment of the European semantic data model specifications of eInvoice with the procurement rules and financial procedures in Greece, two 
Joint  Ministerial  Decisions  have  been  issued  for  further  specifying  and  providing  guidance  on  how  to  use  it  in  public  procurement  (Government 
Gazette 2338 B' 02-06- 2021). In these Ministerial Decisions the four corner model interoperability architecture of Peppol eDelivery  network was 
adopted (Government Gazette B '2425 18-06-2020). 

On September 23, 2022, Greece published Law 4972/2022168, which includes a mandate on the use of the electronic invoice for all sales made to the 
government,  regardless  of  the  value  involved  in  the  transaction.  The  law  further  incorporates  new  sanctions  for  not  transmitting  the  e-invoice 
information  and  other  data  via  the  myDATA  system.  In  addition  to  the  current  penalties,  the  tax  authorities  are  now  allowed  to  suspend  the 
operations of non-compliant taxpayers that can go from 48 to 96 hours, depending on the severity of the violation. 

Mandatory for  

•  Receiving and processing: National, regional, and local contracting authorities 

165 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0055  
166 https://www.vatupdate.com/wp-content/uploads/2020/02/2020-02-16-Greece-einvoicing-EN.pdf  
167 https://www.vatupdate.com/wp-content/uploads/2020/02/2020-02-21-Greece-Einvoicing-English.pdf  
168 https://www.kodiko.gr/nomothesia/document/821127/nomos-4972-2022  

238 

 
 
 
 
 
o  Mandatory below the EU thresholds: Yes 

Platform 

“MyData”  application  i.e.  a  digital  financial  information  application  for  taxation  managed  by  the  Independent  Authority  of  Public  Revenue  in 
Greece.  A  Web  application  is  available  to  allow  suppliers  to  send  eInvoices  to  the  competent  Contracting  Authorities.  This  is  managed  by  the 
General Secretariat for Information Systems of Public Administration (GSIS PA) at the Ministry of Digital Governance. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented. 

Monitoring 

Strategy 

N/A 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
B2G eInvoicing will be obligatory in the medium term (2023  - 2024) for all Economic Operators that have contracts with the  public authorities. In 
the long term, as part of the Fiscal reform and Digital Transformation of the State, eInvoicing will play a major role towards the implementation of 
Accrual Accounting. 

Strategy for ensuring cross-border eInvoicing interoperability. 
Cross-border  eInvoicing  interoperability  for  any  foreign  B2G  supplier  is  ensured  by  implementing  PEPPOL  BIS  CIUS  and  PEPPOL  eDelivery 
network specifications. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

Until 2021: 0 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

Until 2021: 0 

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  
How  many  B2G  eInvoices  from  foreign 
suppliers  

Until 2021: 0 

2022: 3043 
Until 2021: 0 

239 

 
 
 
 
B2B eInvoices exchanged at domestic level   

N/A 

B2B eInvoices exchanged at cross-border level    N/A 

Table 36 Structured eInvoicing uptake in Greece 

Percentage 
of 
sending eInvoices 

enterprises 

The data169 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012  2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

11.3% 

12.1% 

10.3%  11.3% 

9.2% 

Table 37 sending eInvoices suitable for automatic processing in Greece 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The Greek authorities have completed the development and testing of their own Peppol Access Point (AP) implying the usage of Peppol BIS Billing 
3.0 which is based on the European standard on eInvoicing (EN 16931). The necessary fields and items of an eInvoice are outlined in the publication 
of the A. 1017/27-01-2020170, which is the EN-compliant format used as well as in the relevant information regarding the semantic model. 

The  Peppol  Access  Point  (AP)  exclusively  facilitating  the  issuers  of  the  eInvoices  enables  the  receiving  of  eInvoices  from  their  ERP  systems. 
Additionally,  other  systems,  including  the  Peppol  Access  Point  for  the  Public  Administration  Authorities  are  part  of the  National  Interoperability 

169 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
170 https://www.aade.gr/egkyklioi-kai-apofaseis/1017-27-01-2020  

240 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Centre of the General Secretariat for Information Systems of Public Administration at the Ministry of Digital Governance. Other Enterprise Resource 
Planning systems and standalone applications of the Public Authorities allow further processing of eInvoices, until their liquidation and payment. 

The main eInvoice process flow scenario for public procurement includes the following steps: 

1.  Preparation of eInvoice data by the supplier/contractor and transmission to an eInvoicing service provider. 

2.  The eInvoicing service provider validates invoice data before submitting it, using the respective Interoperability Centre services. 

3.  The eInvoicing service provider reports and registers the eInvoice, for taxation reasons, to “MyData” application i.e. to a digital financial 

information application for taxation operated by the Independent Authority of Public Revenue in Greece. 

4.  The eInvoicing service provider prepares the eInvoice based on a) the European standard semantic model, b) the national specification that 

derives from the Joint Ministerial Decisions, and the Peppol BIS. 

5.  The eInvoicing service provider submits the eInvoice to the access point of the Interoperability Centre through the Peppol network. 

6.  The Interoperability Centre receives and validates the eInvoice, according to the European and national rules for eInvoicing, 

7.  The Interoperability Centre routes the eInvoice to the competent contracting authority or competent IT system of the public body, 

8.  The competent contracting authority and financial service handle the invoice according to their internal procurement and payment practices 
using one of the IT systems or web application mentioned in the previous section. The competent authorities send the appropriate messages 
regarding  the  status  of  the  processing  of  the  eInvoice  through  the  Interoperability  Centre  and  the  eInvoicing  service  providers  to  the 
supplier/contractor. 

6. 

Uptake of EN 16931 

According to the General Secretariat of Information Systems of Public Administration the Directive 2014/55/EU and the introduction of EN 16931 
has contributed to increasing the adoption of eInvoicing in your country. They had a very high impact on B2G but a very low impact on B2B. 

Is Peppol / eDelivery used  

Yes. The Peppol eDelivery network is used for B2G eInvoicing. 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

Up to 2021: 0 

2022: 100% (all B2G eInvoices received are compliant with the EN 16931) 

241 

 
 
 
Percentage use vs other formats for B2G?  
Percentage use vs other formats for B2B?  

Up to 2021: 0 
Up to 2021: 0 

Table 38 Uptake of EN 16931 in Greece 

Cost and Benefits 

Greece did not incur costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

They perceive a high cost-reduction because of the Directive and EN 16931. 

Greece did not experience a cost burden associated with ensuring their national format complied with EN 16931. 

Implementation costs for EN 16931 

•  Purchase  software/hardware:  Adapting  software  especially  for  SMEs  and  contracting 

authorities. Complementary actions for that are being implemented.   

•  Training costs: Especially for contracting authorities at this stage 
•  Test environment: It has been centrally implemented. 
•  Service  providers’  fees:  Only  for  the  Economic  operators  for  using  eInvoicing  service 

providers.  

Table 39 Implementation costs for EN 16931 in Greece 

EU funding  

•  Name of the EU funding programme: 2016 CEF Telecom Call - eInvoicing (CEF-TC-2016-3) 
•  Requested funding (euro): 946,753. 
•  Year: 2017. 

eInvoicing services offered by the government (free of charge) 
The National Interoperability Centre is responsible for receiving all the eInvoices. 

Suppliers send eInvoices through certified eInvoice Service Providers or the Peppol network. 

As  mentioned  in  the  Member  States  survey,  Greece  are  implementing  complementary  actions  for  SMEs  and  contracting  authorities  to  adapt  their 

242 

 
 
 
 
 
 
 
software for eInvoicing. 

Benefits at the national level 
According to the General Secretariat of Information Systems of Public Administration, operational efficiencies are expected. There will be improved 
transparency especially in B2G eInvoicing. Social benefits will be achieved through bureaucracy containment and environmental benefits will occur 
from a paper-less environment and an increase in tax revenues is expected. 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

N/A 

N/A 

Key findings 

The General Secretariat of Information Systems of Public Administration stated that the Directive 2014/55/EU and the introduction of EN 16931 has 
a very high impact on B2G but a very low impact on B2B.  

Greece started with voluntary participation in eInvoicing but that was not very effective as up to 2021 there was no B2G eInvoices and just over 3 
000 in 2022. At this stage the national policy is to gradually mandate suppliers as this is expected to accelerate the adoption of eInvoices in the Greek 
Market. A Joint Ministerial Decision is pending approval for this. 

It is expected, based on the government strategy, that B2G will be mandated between 2023 and 2024. There are no plans to mandate B2B. 

243 

 
 
 
 
 
 
 
 
 
244 

 
 
 
 
 
Hungary 

Legislation 

According to section 174 of the Act CXXVII of 2007 on Value Added Tax171, an invoice may be printed on paper or issued electronically. 

Section  175  of  the  aforementioned  Act  lays  down  the  rules  related  to  electronic  invoicing  (eInvoicing).  According  to  this  section,  contracting 
authorities should accept eInvoices if the authenticity of the origin of the eInvoice and the integrity of its content are guaranteed.  

Economic  operators  can  ensure  these  requirements  by  using  an electronic  signature172 and  time  stamps  or  by  making  eInvoices  available  through 
Electronic Data Interchange (EDI) systems. 

On 1 July 2018, the Hungarian real-time invoice reporting (RTIR) obligation came into force (Act LXXXIII of 2018 amending Act CXLIII of 2015 
on public procurement173) for domestic eInvoices (and later amended in 2021 to include intra-community transactions). The 2018 obligation requires 
any taxpayer to register for VAT purposes in Hungary (issuing an invoice with a VAT amount greater than or equal to HUF 100 000) to report the 
eInvoice  data  immediately  and  without  human  intervention  to  the  Hungarian  tax  authority  (NAV).  The  new  live  reporting  scheme  replaces  the 
existing  domestic  sales  ledger  listing,  which  is  filed  monthly  with  the  VAT  return. This  obligation  requires  companies  to  adapt  their  invoicing 
processes  and  Enterprise  Resource  Planning  (ERP)  systems  in  order  to  produce  the  XML  file  that  must  be  transmitted  to  the  Hungarian  tax 
authorities’ website without human intervention. 

Mandatory for  

•  Receiving and processing: Central, regional, and local contracting authorities 
•  Sending:  Economic Operators. From 1 January 2021, all B2B and B2C transactions must be reported to Hungarian tax authorities in real-

171 
https://encrypted.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0ahUKEwjDtP7WsIvWAhVIvhQKHewkBOUQFgglMAA&url=http%3A%2F%2Fwww.icnl.org%2Fresearch%2Flibrary%2Ffiles%2FHungary
%2Fvatact_ENG.pdf&usg=AFQjCNFeFKqydxMQWfab3hnEeJ15Hoymnw  
172 https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/eSignature  
173 https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=NIM:271618&qid=1581428917945  

245 

 
 
 
 
 
 
Platform 

NAV Online Invoicing System – as a centralised platform enabling real-time eInvoice reporting. 

time, regardless of the transaction amount. 

o  Mandatory below the EU thresholds: No 

The  Hungarian  Tax  Authority  has  a  centralised  real-time  invoice  reporting  (RTIR)  model.  Initially  introduced  in  July  2018,  the  anti-VAT  fraud 
measure requires that all invoices be reported to authorities live and by electronic means.   

As of June 2021, National Tax and Customs Administration of Hungary174 it is mandatory for all taxpayers to use the NAV Online Invoicing System 
to submit their invoice data. 

Using a technology provider, the exported data from the Enterprise Resource Planning (ERP) system will be treated and transformed to the required 
format by the NAV, in accordance with the requirements specified by the NAV.  

More technical information on the NAV Online Invoicing System can be found on the NAV website175, along with the technical information176 of the 
currently supported version. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented. 

Monitoring 

Hungary’s eInvoicing regulations are part of the country’s efforts to reduce its large VAT Gap and ensure collection of indirect taxes. As reported in 
2018, these efforts have reduced the country’s VAT gap by 10.7% since 2013, with a bigger reduction anticipated now that eInvoicing is in place. 

These latest eInvoicing changes linked to VAT purposes aim at enabling the Tax Authority to prepare and propose draft VAT returns to taxpayers 

174 https://nav.gov.hu/  
175 https://onlineszamla.nav.gov.hu/api/files/container/download/Online Szamla_Interfesz specifikacio_EN_v3.0.pdf  
176 https://onlineszamla.nav.gov.hu/dokumentaciok  

246 

 
 
 
 
 
 
 
from the 12th day of the month following the tax assessment period. This will be available based on VAT data for July 2021. (WTS global, 2021). 

With  the  changes  brought  to  Hungary’s  eInvoicing  law  in  2021  (Act  LXXXIII  of  2018),  the  Hungarian  Government  has  taken  a  significant  step 
forward on the path to invoicing digitisation. A possible next step could be the adoption of a mandatory CTC model inspired by Italy. However, the 
Hungarian Government would first need to obtain the EU Council’s authorisation to introduce a special measure derogating  rules from the EU VAT 
Directive177. 

Strategy 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
B2G eInvoicing will be obligatory in the medium term (2023 - 2024) for all Economic Operators that have contracts with the public authorities. In the 
long  term,  as  part  of  the  Fiscal  reform  and  Digital  Transformation  of  the  State,  eInvoicing  will  play  a  major  role  towards  the  implementation  of 
Accrual Accounting. 

Strategy for ensuring cross-border eInvoicing interoperability. 
Cross-border  eInvoicing  interoperability  for  any  foreign  B2G  supplier  is  ensured  by  implementing  PEPPOL  BIS  CIUS  and  PEPPOL  eDelivery 
network specifications. 

Structured eInvoicing uptake  According to szamlazz.hu178, (a service providing some free eInvoicing), there are 354 389 120 invoices issued involving 805 328 users. 

Hungary has a single centralised platform at the national level via NAV. Sub-Central contracting authorities and economic operators decide on the 
eInvoicing  solution  to  use  in  a  prior  written  agreement  with  a  detailed  technical  description  of  EDI  data,  system,  and  format  to  use.  In  addition, 
economic operators should ensure that a summary document is sent to the contracting authority reporting on the eInvoices issued during the given 
month. No electronic signature is required for eInvoices. The archiving period amounts to 5 years179. 

177 https://sovos.com/blog/vat/hungary-expands-real-time-vat-controls/  
178 https://www.szamlazz.hu/  
179 https://www.pagero.com/compliance/regulatory-updates/hungary  

247 

 
 
 
 
 
of 
Percentage 
sending eInvoices 

enterprises 

The data180 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

1.5% 

5.2% 

6.1% 

8.1% 

8.4% 

9.8% 

13.5% 

Table 40 sending eInvoices suitable for automatic processing in Hungary 

Implementation  of  EN  16931 
compliant eInvoices 

According to the Prime Minister’s office, electronic invoicing is not mandatory. Electronic reporting to the tax  administration on every invoice  is 
mandatory since 2020, promoting the use of electronic invoice. They state that there is no significant use of EN 16931. 

Peppol is not used in Hungary. 

Cost and Benefits 

EU funding  

•  Name of the EU funding programme: CEF Telecom 
•  Requested funding (in euro):  EUR 1 383 720 

eInvoicing services offered by the government (free of charge) 
The online Szamla web application181 is provided free of charge. 

eInvoicing  services  offered  by 
the government (free of charge) 

N/A 

180 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
181 https://onlineszamla.nav.gov.hu/a_rendszerrol  

248 

 
 
 
 
 
 
 
 
 
 
Call for evidence 

N/A 

Key findings 

According to the Prime Minister’s office, In Hungary, they do not see any significant effect of the Directive and the Standard. They state that there is 
no significant use of EN 16931 and Peppol is not used.  

For  B2G,  contracting  authorities  should  accept  eInvoices  if  the  authenticity  of  the  origin  of  the  eInvoice  and  the  integrity  of  its  content  are 
guaranteed. Economic operators  can ensure these requirements by using an electronic signature and time stamps or by making eInvoices available 
through Electronic Data Interchange (EDI) systems. 

The  requirements182  published  for  the  Hungarian  central  system  (NAV),  specify  the  requirements  for  submission  to  the  tax  authority  but  do  not 
specify requirements for sending to the Buyer. Therefore, the Supplier can send any format to the Buyer including paper. 

Iceland 

Legislation 

Regulation  505/2013183  on  electronic  billing,  electronic  accounting,  messaging,  message  services,  storage  of  electronic  data  and  minimum 
requirements for electronic accounting and accounting systems. 

Regulation 44/2019184 on electronic billing in public procurement. Mandating public authorities to accept invoices compliant to EN 16931. 

Declaration by city of Reykjavík185. As of 1 January 2015, the City of Reykjavík, including all its organisations, will only accept invoices that are in 
electronic format compliant to an EN 16931 CIUS (TS-236).  

Declaration by Icelandic Accounting Authority (FJS)186. As of 1 January 2020, the Icelandic Government, including all its organisations, will only 
accept invoices that are in electronic format compliant to an EN 16931 CIUS (TS-236). 

182 https://opd.hu/blog/id/nav_szamlazo_program_kovetelmenyek  
183 https://www.reglugerd.is/reglugerdir/allar/nr/505-2013  
184 https://www.reglugerd.is/reglugerdir/allar/nr/044-2019  
185 https://reykjavik.is/sjalfvirkir-rafraenir-reikningar  

249 

 
 
 
 
 
Platform 

Standard(s) 

Monitoring 

Strategy 

Mandatory for  

•  Receiving and processing: Central, regional, and local contracting authorities 
•  Sending: Economic Operators.  

o  Mandatory below the EU thresholds: Yes 

Peppol eDelivery Network 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented under UBL 2.1 
and CII. 

There is no specific approach mentioned toward the eInvoicing monitoring yet. The monitoring so far should be via the Enterprise Resource Planning 
(ERP) systems in place.  

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
There  is  no  specific  national  eInvoicing  strategy  but  the  digital  strategy  for  Iceland187  includes  the  following  policy  objective:  "Increased 
competitiveness with emphasis on that public sector data be accessible and in usable format." The B2G invoice data is published on an open web: 
"Government Invoice Open Data" where certain data is published and downloadable188.  

In addition the strategy for sustainable procurement emphasises the use of data for better contracting and the eInvoice data is collectively used by the 
Central Procurement Agency for analysis and preparation of contracting189.  

Strategy for ensuring cross-border eInvoicing interoperability. 

186 https://www.fjs.is/fraedsla-og-verklagsreglur/rafraenir-reikningar/  
187 https://island.is/en/o/digital-iceland/digital-strategy  
188 https://opnirreikningar.is/  
189 https://www.stjornarradid.is/library/02-Rit--skyrslur-og-skrar/Sj%c3%a1lfb%c3%a6r%20innkaup%20-%20stefna%20r%c3%adkisins%20(002).pdf  

250 

 
 
 
 
 
The Financial Management Authority handles all payments for central government and agencies and is registered as a Peppol Authority190.  

Structured eInvoicing uptake 

In 2014 Icelandic government recommended that all invoices sent for government services should be electronic. In 2019 they made it mandatory to 
use electronic XML invoices. 

Number  of  Contracting  Authorities  using 
eInvoicing  

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2019: All 

2020: All 

2021: All 
2019: All 

2020: All 

2021: All 

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

The figures below represent both domestic and foreign suppliers. 

2019: 442 000 

2020: 552 500 

2021: 585 000 

B2B eInvoices exchanged at cross-border level    Not available  

Table 41 Structured eInvoicing uptake in Iceland 

190 https://www.fjs.is/media/rafraenirreikningar/FJS-Peppol-guidelines_en_103.pdf  

251 

 
 
 
 
 
of 
Percentage 
sending eInvoices 

enterprises 

The data191 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Implementation  of  EN  16931 
compliant eInvoices 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

21.8% 

23.2% 

33.1% 

37.4% 

Table 42 sending eInvoices suitable for automatic processing in Iceland 

Approach  

There  is  a  distinction  made  between  the  central  and  the  sub-central  levels.  All  public  authorities  have  to  follow  the  guidelines  of  the  Regulation 
44/2019. Within the B2G context, all public contracting authorities are mandated to receive and issue electronic XML invoices. In 2022, about 92% 
of B2G received invoices were electronic and in XML format, as the law allows certain industries may use paper invoices. There is no plan to make 
electronic  invoicing  mandatory  for  B2B  and  B2C,  but  the  usage  of  eInvoices  is  widespread  in  B2B  and  B2C  procurement.  Within  the  B2B 
environment, the buyer’s consent is needed for receiving eInvoices. 

No electronic signature is required for eInvoices, and the archiving period amounts to 7 years. 

Uptake of EN 16931 

The Ministry of Finance and Economic Affairs in Iceland indicated that the Directive 2014/55/EU and the introduction of EN 16931 has significantly 
contributed to increasing the adoption of eInvoicing in Iceland  

191 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

252 

 
 
 
 
 
 
 
 
 
 
 
 
 
Is Peppol / eDelivery used  

Yes.  

The  Financial  Management  Authority,  that  handles  all  invoices,  invoicing  and  payments  for 
central level is a Peppol Authority. 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

2019: All 

2020: All 

Percentage use vs other formats for B2G?  

2019:  

2021: All 

2020:  

2021: 

2019:  

2020:  

2021: 

Percentage use vs other formats for B2B?  

Table 43 Uptake of EN 16931 in Iceland 

National Survey 2019 
Source: National Survey192  

192 https://static1.squarespace.com/static/5ab282a69d5abb391e7e7225/t/5fd7990685a9ac3632ac8a5c/1607964936240/2019+Survey+on+the+usage+of+einvoiceing+in+Iceland.pdf 

253 

 
 
 
 
 
Survey data was performed in 2019. 

Iceland  has  more  than  one  syntax  in  use,  which  has  caused  various  problems.  Users  are  unwilling  to  update  their  ERP  systems  as  their  current 
systems  still  serve  them  well.  Therefore,  Service  Providers  have  taken  on  the  role  of  transforming  eInvoices  between  syntaxes  (formats)  in  cases 
where the sender and the recipient are not using the same syntax, thus reducing the need for users to upgrade to the latest syntax. 

The following XML formats were in use: 

• 
• 
• 

42% of respondents use TS-136 (CENBII) 
23% of respondents use TS-135 (NESUBL) 
12% of respondents use TS-236 (BISENUBL) 

Adoption was high among large enterprises and public entities. 

• 

82% of respondents receive eInvoices. 

o  95% of large enterprises receive eInvoices. 
o  89% of Public entities receive eInvoices. 

• 

71% of respondents send eInvoices. 

o  84% of large enterprises send eInvoices. 
o  64% of Public entities send eInvoices. 
o 

The percentage of eInvoices over other forms e.g. PDF or paper 

•  The percentage of eInvoices of all issued invoices is on average 30.5% 
•  The percentage of eInvoices received is, on average, 55.4% 
• 

29% of entities with more than 11 employees send or receive eInvoices from abroad. 

There is a high rate of ERP integration. 

• 
• 

78.4% of respondents import eInvoices automatically into their accounting or approval system. 
11.8% of respondents import eInvoices manually. 

254 

 
 
 
 
 
 
 
A high number of respondents see the benefits of eInvoicing. 

• 

• 
• 
• 

80% of respondents replied that their accounting process has gotten moderately simpler, considerably simpler, or much simpler following 
the uptake of eInvoice documents. 
4% of respondents replied that the process has become more complicated. 
4% of respondents think nothing has changed. 
12% replied ‘not applicable’. 

Cost and Benefits 

Iceland did not incur costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

Iceland perceived a moderate cost reduction because of the Directive and EN 16931. 

According to the 2019 survey over 80% of respondents (enterprises and public bodies)  replied that their accounting process has gotten moderately 
simpler or considerably simpler.  

Iceland  experienced  a  cost  burden  associated  with  ensuring  the  national format  complied  with  the  EN  16931.  The  estimated  cost  is  EUR  38  000. 
Their Standards body put together a technical group to work on this that had members from the bigger IT companies and appropriate stakeholders. 
The two ministries (Business and Ministry of Finance) paid for this standardisation work. Iceland have stated that benefits have outweighed the costs. 
No other cost has been identified specifically, but of course there has been costs involved.   

Implementation costs for EN 16931 

 Upgrading national format to EN: EUR 38 000 

Table 44 Implementation costs for EN 16931 in Iceland 

EU funding 
No funding requested.  

Benefits at the national level 
Operational efficiencies 

Yes,  but  it  is  very  hard  to  put  actual  monetary  values  on  this.  The  Financial 
Management Authority has estimated that 1/3 of efficiencies is for the sender and 2/3 
for the buyer and is estimating conservatively ISK 3 000 per invoice. (approx. EUR 

255 

 
 
 
 
Tax revenues 

20) 

N/A 

Improved transparency 

High 

Social benefits 

N/A 

eInvoicing  services  offered  by 
the government (free of charge) 

Call for evidence 

Environmental benefits 

Based  on  B2G  volumes  for  central  government  alone,  using  the  CO2  emissions 
calculator193 provided by one of the bigger Peppol Access Point service providers the 
estimated emissions impact of about 600 000 eInvoices is about 11 000kg CO2 per 
year 

Table 45 eInvoicing benefits at national level in Iceland 

(FJS) on behalf of the Ministry of Finance and Economic affairs.  

The eInvoicing platform used in Iceland is the Peppol eDelivery Network. 

Icelandic government has decided to make it mandatory from 2019 to submit eInvoices when doing business with the government.  This requirement 
has spearheaded the use of eInvoices throughout the country and businesses and other government levels are also getting almost all of their invoices 
submitted electronically. To help SMEs submit eInvoices there is an open free gateway to send individual invoices electronically by manually typing 
the invoice information into a form that then generates eInvoices automatically. All invoices sent to government entities go to one central Financial 
Management  Authority.  They  are  members  of  the  Peppol  network.  There  are  several  different  business  entities  in  the  market  providing  the  tech 
solutions to market to send the xml invoices from accounting software through the Peppol network.  

Data: eInvoices received at central government level (B2G): 

The tables below show that as the requirement for B2G for suppliers got stricter, the rate of adoption increased. 

193 https://www.advania.is/vorur-og-thjonusta/skeytamidlun/  

256 

 
 
 
 
 
Voluntary from 2009-2014 

2009 

2010 

2011 

2012 

2013 

2014 

0.9% 

2.4% 

5% 

10% 

18% 

25% 

Table 46 Voluntary eInvoices received at central government level (B2G) in Iceland 

Requirement 2014-2019 

2015 

2016 

2017 

2018 

41% 

47% 

54% 

62% 

Table 47 Requirement eInvoices received at central government level (B2G) in Iceland 

2019 Mandatory 

2019 

2020 

2021 

2022 

68% 

85% 

90% 

92% 

Table 48 Mandatory eInvoices received at central government level (B2G) in Iceland 

Key findings 

The Ministry of Finance and Economic Affairs in Iceland indicated that the Directive 2014/55/EU and the introduction of EN 16931 has significantly 
contributed to increasing the adoption of eInvoicing in Iceland.  

In  2014  Icelandic  government  recommended  that  all  invoices  sent  for  government  services  should  be  electronic.  The  requirement  got  stricter 
culminating in a legal obligation in 2019.  As can be seen from the Call for Evidence data, the adoption rate increased significantly in line with this 
where it is now over 92%. 

According to Eurostat, the number of enterprises sending eInvoices increased from 22% in 2013 up to 33% in 2016 and in 2020 the number increased 

257 

 
 
 
 
 
to 37.4%. This seems to be corroborated by a study in 2019 that stated that the percentage of eInvoices of all issued invoices is on average 30.5%. 
However, this adoption rate is not as dramatic as in B2G.  

In  the  Call  for  Evidence,  the  Ministry  states  that  to  help  SMEs  submit  eInvoices  there  is  an  open  free  gateway  to  send  individual  invoices 
electronically.  There  are  several  different  business  entities  in  the  market  providing  the  tech  solutions  to  market  to  send  the  xml  invoices  from 
accounting software through the Peppol network. 

258 

 
 
 
 
 
 
Ireland 

Legislation 

•  Statutory  Instrument  354,  in  effect  from  1  January  2013,  established  electronic  invoices  on  an  equal  footing  with  paper  invoices  and 

incorporates the definition of an electronic invoice's processing. 

•  Statutory  Instrument  258194,  in  effect  from  12  June  2019,  transposed  the European  Directive  on  eInvoicing  (2014/55/EU)195 in  public 

procurement. The legislation is in line with and does not exceed the scope of the Directive. 

There is no legal obligation on economic operators to submit invoices electronically in public procurement at this point in time. 

Mandatory for  

Platform 

•  All public bodies are expected to be able to receive and process eInvoices via the Peppol network. 

•  Receiving and processing: Central authorities, Regional authorities & Local authorities  

o  Mandatory below the EU thresholds: No 

•  The  Office  of  Government  of  Procurement  has  established  a national  framework  agreement196 with  some  of  service  providers  for  the 

provision of eInvoicing and Peppol networking services and solutions. 

Financial Management Shared Services systems are expected to be the main eInvoicing processing points across the public sector as they are rolled 
out over the coming years. 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

The  European  standard  on  eInvoicing  is  fully  implemented. The  National  approach  to 
implementing  the  eInvoicing  Directive  recommends  that  contracting  authorities  and 
entities implement support for the Peppol BIS (UBL-XML based syntax standard). 

One  or  more  of  the  following  standards  are  supported  by  various  eInvoicing 

194 S.I. No. 258/2019 - European Union (Electronic Invoicing in Public Procurement) Regulations 2019 (irishstatutebook.ie) 
195 http://data.europa.eu/eli/dir/2014/55/oj  
196 https://www.gov.ie/en/publication/9bee8-einvoicing-framework/  

259 

 
 
 
 
 
 
 
Monitoring 

Monitoring of eInvoice volumes is not in place. 

implementations that currently exist within the public sector: 

•  UBL (UBL-XML based syntax standard). 

•  UN/CEFACT CII (XML-based syntax standard) 

•  EDIFACT (EDI mnemonic-based syntax standard). 

Strategy 

At the end of March 2023, the OGP’s Multi Supplier Framework Agreement for the provision of PEPPOL networking and eInvoicing Systems and 
Services to the Irish Public Sector (‘eInvoicing Framework’) reached its full term. No new contracts can be entered into off the framework. 

There is now greater maturity and understanding of public sector needs in the eInvoicing services and solutions available on the market that will help 
public  bodies  meet  their  legal  obligations  arising  from  the  European  eInvoicing  Directive.  In  many  cases,  eInvoicing  services  can  now  be  easily, 
swiftly and cost effectively procured compliantly by a public sector body (PSB) directly from the market. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The national eInvoicing strategy in the medium term is to leverage the financial shared services systems in each of public service sectors in order to 
provide centres of eInvoicing capability for public bodies and to encourage the adoption of eInvoicing by suppliers in public procurement. The main 
finance shared services systems continue to gradually increase the number of public bodies they serve and provide an eInvoicing capability for. All 
the main finance shared services systems support the EU standard for eInvoicing through the Peppol network. 

In  the  longer  term,  options  are  being  considered  to  introduce  measures  that  will  assist  the  main  shared  services,  and  individual  public  bodies,  in 
driving  uptake  of  eInvoicing  in  public  procurement  among  suppliers.  This  may  include,  among  other  things,  additional  communications  on  the 
national  approach  and  benefits  of  eInvoicing,  targeting  of  high-volume  invoice  suppliers  that  are  common  to  multiple-public  bodies  and  the 
facilitation of eInvoicing via clauses in public procurement contracts. 

eInvoicing is also expected to feature in the B2B domain in  the coming years, on foot of the recent the European Commission's proposed series of 
measures to modernise and make the EU’s Value-Added Tax (VAT) system work better for businesses and more resilient to fraud by embracing and 

260 

 
 
 
 
 
promoting digitalisation. 

Strategy for ensuring cross-border eInvoicing interoperability. 
The  national  approach  to  eInvoicing  in  public  procurement,  which  is  supported  by  all  the  main  public  service  sector  finance  shared  services 
management and systems, is to support the EU eInvoicing standard via the Peppol network. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

No data provided 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

No data provided 

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

2019: 48 000 

2020: 48 000 

Notes on above data  

2021: 48 000 
The  number  of  eInvoices  provided  relates  to  Peppol/EN  16931  compliant  eInvoices  and  is 
predominately  accounted  for  by  a  Business  Shared  Services  function  in  the  Education  sector. 
While other Shared Services systems in the health, central and local government sectors support 
Peppol/EN 16931 compliant eInvoicing they are still rolling out initiatives to onboard suppliers 
to submit eInvoices. Other public service and sector bodies are also receiving eInvoices, but no 
data is available to confirm the volume. 

How  many  B2G  eInvoices  from  foreign 
suppliers  

N/A 

B2B eInvoices exchanged at domestic level   

N/A 

B2B eInvoices exchanged at cross-border level    N/A 

Table 49 Structured eInvoicing uptake in Ireland 

261 

 
 
 
of 
Percentage 
sending eInvoices 

enterprises 

Percentage of enterprises sending eInvoices  
The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

The data197 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

8% 

14.5% 

14.2% 

15.4% 

19.9% 

18.7% 

Table 50 sending eInvoices suitable for automatic processing in Ireland 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

At the sub-central level, Ireland has adopted an open-standards-based hybrid model, facilitating implementations by shared services functions and by 
individual public bodies. All implementations must be able to receive and process European Standard compliant eInvoices via the Peppol eDelivery 
network.  

Sub-central  government  bodies  receive  the  services  they  need  from  the  Local  Government  Management  Agency  (LGMA)  Shared  Service.  This 
enables them to receive and process European Standard-compliant eInvoices via the Peppol network. 

Many public bodies are scheduled to be on-boarded to a single finance shared services system for invoice processing over the next few years. Until 
this on-boarding is completed, it makes it more  difficult to drive  the  uptake of eInvoicing, as public bodies are less likely to individually invest in 
longer-term integrated eInvoicing solutions. 

eInvoicing communication mainly goes through the national eInvoicing Ireland Programme198. The Steering Committee comprises Senior Business 
and Finance Management representatives from across the Public Sector. 

The benefits being targeted by the adoption of eInvoicing include the reduction of administrative burden, cost savings and enabled the better use of 

197 The data description can be found at https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
198 https://www.eolasmagazine.ie/einvoicing-digital-transformation-in-action/  

262 

 
 
 
 
 
 
 
 
 
 
data for more informed decision making and better outcomes for the public and businesses. The implementation of eInvoicing is varied across the 
sub-central  level  in  Ireland  with  pockets  of  excellence,  for  example  in  some  areas  of  the  education  and  health  sectors.  A  number  of  eInvoicing 
implementations are underway as a result of the impetus created by the EU Directive. 

Uptake of EN 16931 

According to the Office of Government Procurement under the Department of Public Expenditure and Reform that while the Directive has had a very 
significant  impact  on  the  capability  of  public  bodies  to  be  able  to  process  eInvoices,  suppliers  are  still  reluctant  to  move  away  from  unstructured 
eInvoicing formats even when presented with the option to do so by Public sector buyers. 

Is Peppol / eDelivery used  

Yes.  The  national  approach  for  eInvoicing  in  public  procurement  is  for  all  public  bodies  to 
support the receipt of EU standard eInvoices via Peppol. 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

All  four  government  Shared  Services  have  procured  a  Peppol  Service  Provider.    It  is 
Government policy to use these shared services for Central and sub-central. Public contracting 
authorities connected to these Shared Services are 100% compliant. 

Percentage use vs other formats for B2G?  

Percentage use vs other formats for B2B?  

All  public  contracting  authorities  have  now  adopted  European  eInvoicing  standard  compliant 
eInvoice formats. However the Irish Health Service also receives eInvoices through SAP Ariba 
in parallel with the Peppol system. 
2019: <1% 

2020: <1% 

2021: <1% 

Table 51 Uptake of EN 16931 in Ireland 

Cost and Benefits 

According to the Office of Government Procurement under the Department of Public Expenditure and Reform, Ireland incurred moderate costs solely 
related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

Implementation costs for EN 16931 

•  Purchase software/hardware: EUR 894 863 

263 

 
 
 
•  Change management: EUR 250 000 

Table 52 Implementation costs for EN 16931 in Ireland 

EU funding   

•  Name of the EU funding Programme: CEF Programme 
•  Requested funding (euro): EUR 973 836. 
•  Year: 2017, 2018, 2019. 

eInvoicing services offered by the government (free of charge) 
Financial Management Shared Services systems are connected to Peppol service providers.  

Suppliers  submit  eInvoices  using  Peppol  service  providers.  Some  Peppol  service  providers  provide  a  free  option  where  a  supplier  can  key  in  the 
eInvoice. 

Benefits at the national level 
Benefits are expected in time, but they have yet to be realised due to the limited Shared Services capability in some sectors resulting in low volumes 
of centralised eInvoicing processing and lack of uptake by suppliers. 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

N/A 

Feedback from Atlantic Technological University (ATU) Ireland. 

The proposed EU VAT regulations will mandate intra EU eInvoice transactions. At the moment EN 19631 is focused on B2G transactions. A review 
is required of EN19631 to ensure that it is capable of support for B2B requirements. It should also require a common community communications 
network,  such  as  provided by  PEPPOL  and  eDelivery  Building  Block.  With  these  technical  supports  in  place,  a  further  set  of  supports  should  be 
provided to help SMEs adopt eInvoicing. Included in this would be awareness for the SME sector and training for their IT providers. When this is 
completed, to drive adoption, member Governments should mandate eInvoicing in a phased manner. 

264 

 
 
 
 
Key findings 

The Directive has had a very significant impact on the capability of public bodies to be able to process eInvoices, however, suppliers are still reluctant 
to move away from unstructured eInvoicing formats even when presented with the option to do so by Public sector buyers.  

According  to  the  Eurostat  figures  the  number  of  enterprises  sending  eInvoices  has  stayed  flat  since  2013  at  between  14%  and  15%.  Without  a 
mandate on suppliers the adoption rate is likely to stay low. 

As in many other countries, the vast majority of structured eInvoices would be in the Retail and Pharmaceutical sectors. Some hospitals have also 
adopted eInvoicing. The most common format is EANCOM based on EDIFACT.  

Benefits are expected in time once the adoption rates are increased through further initiatives. The ViDA proposals will be the next opportunity for 
Ireland to drive these initiatives, particularly for B2B. 

In the call for Evidence, ATU states that before mandating B2B, several steps need to be taken in advance to ensure readiness and then it should be 
phased in. 

265 

 
 
 
 
 
Italy 

Legislation 

Multiple legislation. 

• 

Italian  law  number  244199  of  24  December  2007,  provisions  for  drafting  the  annual  and  longer-term  financial  statements  of  the  State 
(Finance Act 2008). 

•  Decree of 7 March 2008200, identification of the Provider of the Exchange System for electronic invoicing and the relative attributions and 

duties. 

•  Decree of 3 April 2013201, regulation on the issue, transmission, and receipt of electronic invoices to be applied to public authorities. 
•  Decree law of 24 April 2014202, n. 66. Urgent measures for the competitiveness and social justice (Article 25). 
•  Circular of the State General Accounting Office number 37203 of 4 November 2013, First Operating Instructions for the implementation of 

the Regulation on the issue, transmission, and receipt of electronic invoices to be applied to public administrations. 

•  Legislative decree n. 148/2018204, Transposition of Directive 2014/55/EU. 
•  Provvedimento 18 aprile 2019205 - Core Invoice Usage Specification. 
•  Decree law of 30 April 2022206, n. 30 including, effective July 1, 2022, electronic invoicing applicable to taxpayers who adopt the flat-rate 
tax regime and, effective in 2024, taxpayers with annual revenues up to EUR 25 000 will be required to issue and clear electronic invoices 
through the Sistema di Interscambio system eInvoicing platform and eInvoicing management solutions. 

Mandatory for  

•  Receiving and processing: Central, regional, and local authorities and entities. 

199 http://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2007-12-24;244!vig=  
200 http://def.finanze.it/DocTribFrontend/getAttoNormativoDetail.do?id=%7B5AF01086-2D68-46D2-8FD6-FB0B1C744F1C%7D  
201 http://www.normattiva.it/uri-res/N2Ls?urn:nir:ministero.economia.e.finanze:decreto:2013-04-03;55%21vig=  
202 http://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2014-04-24;66!vig=  
203 http://www.fatturapa.gov.it/export/fatturazione/sdi/Circolare_RGS_n._37.pdf  
204 Legislative decree n. 148/2018 
205 Provvedimento 18 aprile 2019 
206 https://www.gazzettaufficiale.it/eli/id/2022/04/30/22G00049/sg  

266 

 
 
 
 
 
Platform 

Standard(s) 

•  Submitting: Economic operators.  

o  B2G eInvoicing is mandatory since 31 March 2015. 
o  B2B and B2C eInvoicing is mandatory since January 2019. 
o  Mandatory below the EU thresholds: Yes 

Exchange system (Sistema di Interscambio) 

National Standard in use (if any) 

EN 16931 compliant standard 

FatturaPA (national XML standard) National CIUS implementing 
the EN 16931 

The European standard on eInvoicing is fully implemented.  

Monitoring 

There is a monitoring strategy in place at the central and sub-central levels, with the usage of Sistema di Interscambio for eInvoice processing.  

The control information is based on the number of suppliers using eInvoicing, number of invoices that are submitted electronically and the number of 
eInvoices submitted in a specific syntax. More than 800 000 suppliers have sent eInvoices, and the eInvoices represent almost 100% of the invoices 
exchanged.  

Strategy 

National eInvoicing strategy in the medium and long-term 
The Italian Government mandated the use of a centralised national platform, SDI, and the use of a national format, FatturaPA.  

When a European eInvoicing standard compliant invoice is received, Sistema di Interscambio translates it to the FatturaPA syntax and forwards it, 
together with the translated eInvoice and a translation report, to the receiving public administration. The public administration can choose to process 
either the translated invoice in the FatturaPA syntax, for which they are equipped since 2015 or the original European eInvoicing standard compliant 
eInvoices. 

The use of Peppol for eInvoicing and eOrdering is mandatory in the Region of Emilia Romagna. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The Italian Government will maintain the current obligations for B2B, B2G, B2C eInvoicing. 

eInvoice data are used to facilitate compliance. 

267 

 
 
 
 
Strategy for ensuring cross-border eInvoicing interoperability. 
The Italian Government supports the use of the EN 16931. There is freedom of choice for suppliers in relations to the transmission method. 

Structured eInvoicing uptake  The following table shows the eInvoicing uptake from 2019 to 2021. 

Number  of  Contracting  Authorities  using 
eInvoicing  

2019: 22 800 out of 43 000 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2020: 22 800 out of 43 000 

2021: 22 800 out of 43 000 

2019: 800 000 out of 5 000 000 

2020: 800 000 out of 5 000 000 

2021: 800 000 out of 5 000 000 

Number  of  B2G  eInvoices  from  national 
suppliers  

Central authorities 

2019: 8 500 000 

2020: 8 500 000 

2021: 8 500 000 

Sub-central authorities 

2019: 22 500 000 

2020: 22 500 000 

2021: 22 500 000 

268 

 
 
 
Number  of  B2B  eInvoices  exchanged  at 
domestic level   

2019: 2 000 000 000 

2020: 2 000 000 000 

2021: 2 000 000 000 

Table 53 Structured eInvoicing uptake in Italy 

of 
Percentage 
sending eInvoices 

enterprises 

The data207 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

4.9% 

6.7% 

5.4% 

30.3% 

41.6% 

94.9% 

Table 54 sending eInvoices suitable for automatic processing in Italy 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The Italian approach is based on the use of a  centralised exchange system, Sistema di Interscambio (SDI). The Revenue Agency manages the SDI 
with technology and operational support provided by Sogei, an IT provider owned by the Italian Ministry of Economy and Finance. 

Economic operators submit eInvoices based on the FatturaPA format through the SDI. The SDI operates as an eDelivery service, transmitting each 
eInvoice to the receiving administration based on a unique identifier. Only formal controls are performed by the Sistema di Interscambio. Economic 
operators and public entities may use a solution provider for submitting/receiving invoices and check messages to/from the Sistema di Interscambio. 

Uptake of EN 16931 

207 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

269 

 
 
 
 
 
 
 
 
 
 
The Ministero dell'Economia e delle Finanze, stated that the national standard was already in place before EN 16931 was published and vat subjects 
did not decide to switch to EU standard. 

Is Peppol / eDelivery used  

Yes, at local level by region Emilia-Romagna 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  
Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   
Percentage  of  EN  16931  compliant  eInvoices 
vs. total number of B2B eInvoices   

Table 55 Uptake of EN 16931 in Italy 

2021: a few dozen 

2021: 0 

2021: 0 

Cost and Benefits 

From the Government’s perspective, the major cost is related to the implementation of the national eInvoicing platform and was paid by the public 
administration. 

Italy experienced benefits from the adoption of eInvoicing. However, as B2G eInvoicing was mandated to suppliers before  implementing directive 
2014/55/EU, it has not been possible to evaluate benefits directly linked to the Directive. 

CEF Telecom eInvoicing funding  
Budget requested: EUR 3 609 170. 

However, two CEF eInvoicing funded projects were implemented for the alignment of the national standard to the EN 16931: eIGOR with funding 
of EUR 1 252 500 and EeISI EUR 1 136 942. 

Expected results of the eIGOR project: 

1.  Update  of  the  national  electronic  invoice  exchange  system  (Interchange  System  -  SDI)  managed  by  the  Revenue  Agency  to  ensure  that 
Italian public administrations can receive invoices conformant to the European standard. In particular, a translation engine  was expected to 
be  integrated  into  the  SDI  to  allow  the  translation  of  the  xml  invoice  in  the  FatturaPA  format  to  and  from  the  two  UBL  2.1  and 
UNCEFACT/CII syntaxes, so that the public administration could receive eInvoices in their chosen format. SDI would be able to receive 
electronic invoices from the traditional transmission channels, and also from the Peppol network through a Peppol Access Point. 

2.  Definition of a semantic mapping for electronic invoicing, from the national format to / from what is foreseen by the Directive 2014/55/EU 

270 

 
 
 
eInvoicing  services  offered  by 
the government (free of charge) 

and  related  syntaxes  selected  by  the  CEN  Technical  Committee  434  (CEN/TC  434),  together  with  the  implementation  of  a  conversion 
framework. 

3.  Update  of  the  Unioncamere  (Italian  Chamber  of  Commerce  Union)  e-Invoicing  tool  which  allows  economic  operators  and  contracting 
authorities to exchange invoices conformant to the European standard for e-Invoicing, making it available free of charge to Italian SMEs. 
This involves the integration of the electronic invoice converter into the Unioncamere system. 

4.  Update of the Intercent-ER platform (Peppol partner and one of the leading Italian providers of electronic procurement services for public 

administrations) by integrating the electronic invoice converter. 

The main deliverables of the EeISI project are: 

1.  The specifications of the Italian Core Invoice Usage Specifications (CIUS) which define the adoption of EN 16931 in the Italian domain, 

ensuring compatibility with the PEPPOL Billing 3.0 specification and the Peppol cross-border network. 

2.  The translator from the formats required by EN 16931 (OASIS UBL and UN/CEFACT CII) into the  national FatturaPA format and vice 

versa. 

The project provides for the evolution of the Interchange System (SdI) and of the electronic invoicing systems of Intercent-ER, UnionCamere and 
Infocert which will integrate the CIUS and the translator. 

“Fatture e corrispettivi” is a section of the Revenue Agency website, aimed at businesses and professionals (subjects with a VAT number) where the 
following services are available: 

• 
• 
• 
• 
• 
• 

generate, transmit and store electronic invoices (B2C, B2B and B2G) 
consult the data of the invoices issued and received. 
consult the data of the cross-border invoices issued and received. 
transmit and consult the data of the quarterly communications of periodic VAT settlements. 
transmit and consult the fiscal receipt data (now transmitted by retailers using Electronic cash registers) 
view and access the functions relating to pre-compiled VAT documents. 

The target users are micro-enterprises and professionals approaching electronic invoicing who usually manage a limited number of invoices.  This 
service is of course not ideal for high e-invoicing volumes. 

eInvoicing 

The invoice online editor can be used to generate, validate, and transmit electronic invoices according to the Italian FatturaPA xml format. 

271 

 
 
 
 
This tool allows the creation of any invoice and credit note (B2G, B2B and B2C) as well as the reporting of invoices received in the passive cycle, 
either from Intra-EU or Extra-EU. 

For the passive cycle, the same FatturaPA xml document is used to: 

• 

• 

Issue a supplementary information about an Intra-EU cross-border operation (e.g. with VAT due as per reverse charge) with reference to the 
original received invoice. 
Issue  a  self-Invoice  about  an  Extra-EU  cross-border  operation  (e.g.  with  VAT  due  as  per  reverse  charge)  with  reference  to  the  original 
received invoice. 

Alternatively, the Revenue Agency provides through the SDI hub a series integration services for transmitting invoices using  PEC, SFTP or Web 
Services.  This integration services can be implemented by end-users or software solution providers. 

eArchiving 

Optionally, a user of the Revenue Agency website can join a legal digital archiving facility hosted by the Minister of Finance software house, SOGEI 
S.p.A. 

Once  the  digital  archiving  has  been  activated  all  outgoing  and  incoming  invoices  will  be  automatically  archived  for  8  years  after  the  related  tax 
declaration.  

The Revenue Agency acts as Data Controller in the processing of generation, storage and transmission of electronic invoices and makes use of Sogei 
S.p.A. 

The Revenue Agency assumes the role of Data Processor for consultation and conservation processing and is authorised to make use of Sogei S.p.A., 
as sub-processor. 

Benefits at the national level 
The Ministero dell'Economia e delle Finanze stated that B2G eInvoicing was adopted before implementing Directive 2014/55/EU.  For this reason, 
they are not able to evaluate benefits directly linked to the Directive. 

Call for evidence 

Feedback from A-Cube s.r.l. 

Three  points  of  view  should  be  taken  into  consideration.  Government  entities  are  of  course  the  first  to  get  advantage  of  e-invoices  thanks  to  the 

272 

 
 
 
obvious optimisations that such automation brings (no more manual entry, automatic monitoring, data reporting, etc...). The private citizen benefit is 
the enhanced transparency of the relationship between private  companies and public administrations. This is an important point.  More digitisation 
must be introduced to ensure this transparency, from the pre-award phases (see tenders) to the post award (see electronic orders). Regarding private 
companies, electronic invoicing sometimes is seen as a useless obligation, especially when the document flow is just outgoing to PA. But when a 
B2B obligation comes then private  companies must manage  incoming flows too. It's here where everyone can see how powerful,  time-saving and 
disruptive the document digitisation revolution is. 

Feedback from a business association - Confartigianato Imprese 

In Italy, the electronic invoicing system, which today also includes B2B and B2C relationships, was launched precisely with invoicing to the Public 
Administration. This method of invoicing, over time, has been modified and perfected, to the point that it can be defined as  a winning bet, to which 
the EC could look in order to identify any best practices for future regulatory developments. 

Key findings 

According  to  the  Italian  Ministry  of  Finance,  the  Directive  represents  a  milestone  for  the  development  of  the  European  standard  on  eInvoicing. 
However, the standard should reach critical mass in order to exploit its full potential.  

eInvoicing  was  already  mandatory  in  B2G  at  national  level  at  the  time  of  the  introduction  of  the  Directive.  Therefore,  the  intervention  was  not 
relevant for Italy. 

During COVID pandemic emergency, it has been possible to use eInvoices data in order to determine loss in turnover compared to 2019. Thus it has 
been possible to distribute grants even without request directly to those enterprises which had evident difficulties. 

Existing issues 

• 
• 

eInvoicing is not mandatory in B2G for cross-border transactions. 
eInvoicing is rarely used in B2B for cross-border transactions. 

In the call for evidence, an SME, states benefits such as enhanced transparency dealing with public administrations. B2B brings additional benefits 
such as time saving. According to the business association, Confartigianato Imprese, Italy should be used as an example of best practices. 

273 

 
 
 
 
 
 
Latvia 

Legislation 

•  Public procurement law208  
•  Law on the Procurement of Public Service Providers209,  
•  Defense and Security Procurement Law210 
•  Law on Public-Private Partnership211 
•  Cabinet regulation No.154212 “Applicable standard of electronic invoicing and specification of its basic elements and order of circulation". 
Adopted  on  9  April  2019,  it  imposes  an  obligation  that  the  public  contracting  authority,  public  service  provider  or  public  partner  or  its 
representative  shall  accept  an  eInvoice  which  is  prepared  and  issued  in  electronic  form  and  complies  with  the  Directive  2014/55/EU 
mentioned standard of electronic invoicing. 
•  Cabinet Regulation No.877213 “Accounting rules” 

The  Law  on  Official  Electronic  Address  prescribes  mandatory  use  of  electronic  address  account  for  governmental  institutions,  registered  legal 
entities and reserve soldiers gradually throughout late 2018 and 2019, transition period ending January 2020. 

The institutions of direct administration shall accept an eInvoice starting from 18 April 2019, but the other contracting authorities and public service 
providers shall do so starting from 18 April 2020. 

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities & Local authorities. 

o  Below the EU Thresholds: Yes 

208 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:270633  
209 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:270634  
210 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:270639  
211 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:270638  
212 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:271801  
213 
p0vGuANMbITycWF2B6DplomTYCblHZ7e7_tEetLmMY4-RpFjKQneRJq4$  

https://urldefense.com/v3/__https://likumi.lv/ta/id/328707-gramatvedibas-kartosanas-noteikumi/__;!!DOxrgLBm!E7pPCNKAFYJlNFylduOWjxpp9PGysT1MPiprfZcDLx-

274 

 
 
 
 
 
 
Platform 

Standard(s) 

Monitoring 

Strategy 

latvija.lv214 (for citizens and entrepreneurs), eAddress (for government bodies) 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented. 

On October 12, 2021, Latvia announced that it plans to start requiring eInvoicing in accordance with the Peppol standard effective 2025 for B2B and 
B2G transactions. The requirement is intended to ensure convenient and uniform preparation and storage of documents, enabling a faster and more 
secure flow of information between taxpayers, as well as simultaneous transfer of data to the tax authority215. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Latvian  government  is  planning  to  implement  mandatory  use  of  e-invoices  between  merchants  (B2B)  and  merchants  and  state  and  municipal 
institutions (B2G) starting from 2025. According to the developed concept, it is expected that the e-invoices will be mandatory from January 1, 2025, 
if all necessary regulations and technical solutions have been provided. 

• 

• 

2023 – 2024: Start the development of the e-invoice circulation system (including documentation). 

2025 – 2030: Establish a mandatory requirement for the use of e-invoices between merchants (B2B) from 2025. 

Strategy for ensuring cross-border eInvoicing interoperability 
In  Latvia,  when  implementing  goals  related  to  the  mandatory  introduction  of  e-invoices  for  domestic  B2B  transactions,  they  must  be  viewed  in 
conjunction with the ViDA proposals of the EC, which refer to e-invoices in cross-border transactions. To be able to start the development of an e-

214 http://latvija.lv/  
215 https://www.fm.gov.lv/lv/jaunums/valdiba-atbalsta-obligatu-e-rekinu-aprites-ieviesanu?utm_source=https%3A%2F%2Fwww.orbitax.com%2F  

275 

 
 
 
 
 
 
 
 
 
invoice circulation system that is consistent with currently ongoing work on the introduction of the Latvian e-invoice electronic circulation system, it 
is important that a mandatory e-invoice standard is introduced for e-invoices that meets Pan-European Public Procurement On-Line (PEPPOL) BIS 
Billing 3.0. 

Structured eInvoicing uptake  According to Digital Economy and Society Index (DESI) 2017, Latvia holds 10th rank in EU in terms of B2B/B2G/G2B eInvoicing usage with 19% 

usage rate.  

In DESI 2020, Latvia is ranked 5th in the field of accessibility of eGovernment services, meaning that there is a growing tendency in  Latvia to use 
services remotely. 

Percentage 
of 
sending eInvoices 

enterprises 

The data216 from Eurostat does not distinguish between B2G or B2B transactions 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

17.1% 

18.1%  10% 

18.9% 

6.9% 

14.9% 

Table 56 sending eInvoices suitable for automatic processing in Latvia 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The European standard on eInvoicing is implemented through public procurement and accounting legislation and has been  transposed in a national 
standard status. 

According to Cabinet Regulation Nr. 154 “The applicable standard of the electronic invoice and the specification of the use of its basic elements and 
the  order  of  circulation”  person  registered  or  permanently  resident  in  a  foreign  country  uses  the  Pan-European  Public  Procurement  On-Line 
(PEPPOL) cross-border invoice delivery system to submit electronic invoices to the direct administration authority. 

216 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

276 

 
 
 
 
 
 
 
 
 
 
Uptake of EN 16931 

According  to  the  Ministry  of  Finance,  implementation  of  the  Directive  has  contributed  to  the  fact  that  an  integral  stage  of  the  e-invoicing 
implementation process is taking place regarding the promotion and revitalisation of the habit of using the e-invoice delivery infrastructure (PEPPOL 
BIS Billing 3.0 standard and eAddress217) in the public sector. 

Cost and Benefits 

EU funding  

•  Name of the EU funding programme: CEF Telecom eInvoicing funding 
•  Requested funding (in euro): 205 480 

N/A 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

Feedback from the Ministry of Finance 

Benefits  of  using  eInvoicing include  a  secure  way  of  receiving  invoices,  reduced manual  work  and  risk of  errors, options  for  automating  invoice 
processing, and timely receipt of invoices.  eInvoices are received in the accounting system CRVS Horizon, maintained by the Treasury. The State 
Revenue  Service  did  not  participate  in  developing  the  technical  invoice  standard.  Following  amendments  to  the  Public  Procurement  Law,  the 
Procurement Monitoring Bureau incorporated validation in public procurement notices that electronic invoices are mandatory for authorities. 

Key findings 

According  to  the  Ministry  of  Finance,  implementation  of  the  Directive  has  contributed  to  the  fact  that  an  integral  stage  of  the  eInvoicing 
implementation process  is  taking  place  regarding  the  promotion  and  revitalisation  of  the  habit  of  using  the  eInvoice  delivery  infrastructure  in  the 
public sector. In the call for evidence they describe benefits such as security, reduction of manual labour and errors and timeliness. 

In the Call for Evidence, the Ministry highlighted the benefits such as  a secure way of receiving invoices, reduced manual work and risk of errors, 
options for automating invoice processing, and timely receipt of invoices. 

217 https://mana.latvija.lv/e-adrese/  

277 

 
 
 
 
 
However, adoption levels are low, as seen in the Eurostat data, which may be explained through the lack of a mandate on business to use eInvoicing. 

The plan is to mandate the use of eInvoices B2B and B2G starting from 2025. It is expected that the eInvoices will be mandatory from January 1, 
2025, if all necessary regulations and technical solutions have been provided. 

278 

 
 
 
 
 
 
Lithuania 

Legislation 

Platform 

Standard(s) 

Monitoring 

Strategy 

•  Law No XII-328 amending Law No XIII-2159 on procurement by contracting entities in the field of water management, energy, transport, 

or postal services. Official publication218: Teisės aktų registras; Number: 2017-07551; Publication date: 2017-05-04.  

•  Law No. XIII-1491 amending the Law on Public Procurement of the Republic of Lithuania No. XIII-2158219. Official publication: Teisės 

aktų registras; Number: 2019-09411; Publication date: 2019-06-10.  

•  Law  No  I-1510  amending  Articles  3,  22  and  23  and  Annex  7  to  Law  No  XIII-2160  on  concessions220.  Official  publication:  Teisės  aktų 

registras; Number: 2019-09413; Publication date: 2019-06-10. 

Mandatory for:  

•  Receiving and processing: Central, regional, and local authorities and entities. 
•  Submitting: Economic operators.  

o  Mandatory below the EU thresholds: Yes, except for oral contracts below EUR 5 000. 

eSaskaita221, an eInvoicing system connected to the European Peppol platform. 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented under 
UBL v2.1. 

No  

B2G National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 

218 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:273936  
219 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:273935  
220 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:273937  
221 http://www.esaskaita.eu/  

279 

 
 
 
 
 
 
 
All suppliers to public contracting authorities are obliged to issue only EN-compliant eInvoices namely Peppol BIS Billing 3.0. 

The  eSaskaita  is  a  central  information  intermediary  that  performs  the  service  of  receiving  and  sending  eInvoicing  and  accompanying  documents 
between suppliers and public contracting authorities in Lithuania. The suppliers can submit their invoices in three ways: 

•  Manually, by keying in the invoice information in an online portal.  
•  By uploading files in XML syntax, which requires that the economic operator’s accounting system is suitable for storing eInvoices in this 

language, and 

•  By submitting eInvoices via a Peppol-certified Access Point using AS4 communication protocol.  

B2B National eInvoicing strategy 
In November 2022, The Lithuanian Government announced its intention to develop an eInvoicing exchange system to promote digitalisation in the 
country and a harmonious approach for exchanging European eInvoicing standard standard eInvoices between companies.  

Currently,  eInvoicing  in  B2B/B2C  is  not  mandatory  in  Lithuania.  The  introduction  of  the  eInvoicing  system  is  not  only  a  step  towards  a  more 
harmonised eInvoicing exchange within the country but also with the European Union. Moreover, it could lead to further countrywide regulations 
being implemented in the future. 

Technical requirements for the new eInvoicing exchange system:  

•  must meet Peppol Network requirements (AS4 profile, Business Message Envelope (SBDH)) 
• 
sent/received electronic records must comply with Peppol BIS 3.0 Post-Award requirements 
• 
the created information technology solution must ensure Peppol KYC (Know Your Customer) requirements 
• 
solution  tests  must  be  performed  with  at  least  3  business  management  systems  (ERP  -  Enterprise  Resource  Planning)  /  e.  invoicing 
(eInvoicing) solution manufacturers using an access point (Access point) connected to Peppol and SMP/SML* and submitted documents 
confirming a successful test (*SML – Service Metadata Locator; SMP – Service Metadata Publisher). 

Strategy for cross-border interoperability 
According to the Ministry of the Economy and Innovation, using decentralised access points i.e. Peppol is the cross-border strategy.  

Structured eInvoicing uptake 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2019: 4  

2020: 330  

280 

 
 
 
 
2021: 432 

B2G eInvoices received from national suppliers  

 N/A 

B2G eInvoices received from foreign suppliers   2019: 0 

2020: 23 

2021: 107 

Table 57 Structured eInvoicing uptake in Lithuania 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

of 
Percentage 
sending eInvoices 

enterprises 

The data222 from Eurostat does not distinguish between B2G or B2B transactions 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

15.6% 

14.8%  18.1%  20% 

24.4%  23.6%  29.4% 

26.7% 

Table 58 sending eInvoices suitable for automatic processing in Lithuania 

Implementation  of  EN  16931 
compliant eInvoices 

Approach 

Lithuania made B2G eInvoicing mandatory in July 2017. Peppol BIS Billing 3.0 is adopted although the previously used national XML-based format 
is also still accepted.  

222 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

281 

 
 
 
 
 
 
 
 
The  eSaskaita  is  a  central  information  intermediary  that  performs  the  service  of  receiving  and  sending  eInvoicing  and  accompanying  documents 
between suppliers and public contracting authorities in Lithuania. The suppliers can submit their invoices in three ways: 

•  Manually, by keying in the invoice information in an online portal.  
•  By uploading files in XML syntax, which requires that the economic operator’s accounting system is suitable for storing eInvoices in this 

language, and 

•  By submitting eInvoices via a Peppol-certified Access Point using AS4 communication protocol.  

Uptake of EN 16931 

The Ministry of the Economy and Innovation stated that the Directive was the impetus for the development of the national system, eSaskaita. This 
service fully implements Peppol as a four corner model and fully complies with the eInvoicing Directive. 

Is eDelivery /Peppol used  

Yes 

Contracting authorities receiving  eInvoices  

2019: 4 out of total 4 000 

2020: 330 out of total 4 000 

2021: 432 out of total 4 000 

The extent that EN 16931 is used in eInvoicing 
versus other formats. 

2019: 9 out of 1 195 000 

2020: 20 700 out of 1 121 000 

2021: 34 500 out of 1 268 000 

Cost and Benefits 

Implementation costs for EN 16931  

Table 59 Uptake of EN 16931 in Lithuania 

•  Purchase software/hardware: EUR 68 500 
•  Training costs: 0 
•  Change management: EUR 16 720  
•  Test environment: EUR 38 000  
•  Service providers fees: EUR 7 500 

282 

 
 
 
 
 
 
• 

for legal and solution analysis, publicity, user guides, support, and security audit: EUR 129 
800 

Table 60 Implementation costs for EN 16931 in Lithuania 

EU funding  

•  Name of the EU funding program: Duomenų mainų įrankio sukūrimas (ir privatus sektorius) (Lit.: Development of a data exchange tool 

(in the private sector)) 223 

o  Requested funding (in euro): EUR 627 700 
o  Year: 2022-2023 

•  Name of the EU funding program: eInvoicing cross-border LT224 

o  Requested funding (in euro): EUR 744 553 
o  Year: 2017-2019 

Benefits at the national level 
According to the Ministry of the Economy and Innovation, since the transposition of the Directive 2014/55/EU and the EN 16931. Lithuania has 
experienced greater transparency, more effective contract control and less paper used for printing invoices. 

The eSaskaita portal, operational since 2015, enables the preparation and submission of eInvoices to public contracting authorities and to promptly 

eInvoicing  services  offered  by 

223 https://2021.esinvesticijos.lt/kvietimai/skatinti-duomenu-prieinamuma-ir-pakartotini-naudojima  
224 https://wayback.archive-it.org/12090/20190615092902/https://ec.europa.eu/inea/en/connecting-europe-facility/cef-telecom/2016-lt-ia-0104 

283 

 
 
 
 
 
 
the government (free of charge) 

receive information on the payment of a submitted eInvoice. There are two ways to submit eInvoices via the portal: 

•  Economic operators can submit eInvoices by via eSaskaita following a necessary registration to the website. 

• 

If an economic operator issues or receives a large number of invoices, it is recommended to establish an interface225 between the eSaskaita 
portal and the economic operator’s financial management and accounting information system. 

The development of an IT invoicing solution is expected in September 2022 and will be fully paid for by the Lithuanian government. The developer 
will provide it free of charge to businesses for the first 5 years. 

Call for evidence 

Feedback from the Ministry of Finance 

Key findings 

Benefits  of  using  eInvoicing include  a  secure  way  of  receiving  invoices,  reduced manual  work  and  risk of  errors, options  for  automating  invoice 
processing, and timely receipt of invoices. eInvoices are received in the accounting system CRVS Horizon, maintained by the Treasury. The State 
Revenue  Service  did  not  participate  in  developing  the  technical  invoice  standard.  Following  amendments  to  the  Public  Procurement  Law,  the 
Procurement Monitoring Bureau incorporated validation in public procurement notices that electronic invoices are mandatory for authorities. 

The Ministry of the Economy and Innovation stated that the Directive was the impetus for the development of the national system, eSaskaita. This 
service fully implements Peppol as a four corner model and fully complies with the eInvoicing Directive. They are also developing an eInvoicing 
solution that will be made freely available to enable e-invoices to be sent, received, and processed on a large scale in accordance with the European 
standard for e-invoices. For the last two years all public procurement contract notices include an eInvoicing requirement. The Ministry stated that as 
far  as  using  eInvocing  in  B2B  is  concerned,  it  needs  time  to  adapt  to  the  new  format.  They  also  state  that  future  measures  should  include  the 
obligation to use eInvoicing for B2B. 

225 
fakturu?_101_INSTANCE_8cAm88D1DS1K_redirect=https%3A%2F%2Fwww.esaskaita.eu%2Fweb%2Fesaskaita%2Fpraktiniai-
patarimai%3Fp_p_id%3D101_INSTANCE_8cAm88D1DS1K%26p_p_lifecycle%3D0%26p_p_state%3Dnormal%26p_p_mode%3Dview%26p_p_col_id%3Dcolumn-
2%26p_p_col_count%3D1&redirect=https%3A%2F%2Fwww.esaskaita.eu%2Fweb%2Fesaskaita%2Fpraktiniai-
patarimai%3Fp_p_id%3D101_INSTANCE_8cAm88D1DS1K%26p_p_lifecycle%3D0%26p_p_state%3Dnormal%26p_p_mode%3Dview%26p_p_col_id%3Dcolumn-2%26p_p_col_count%3D1  

https://www.esaskaita.eu/web/esaskaita/praktiniai-patarimai/-/asset_publisher/8cAm88D1DS1K/content/integracija-su-fvais-jei-israsoma-daug-saskaitu-

284 

 
 
 
 
 
 
 
Luxembourg 

Legislation 

• 

In Luxembourg, Directive 2014/55/EU has been transposed via the law of 16 May  2019 on electronic invoicing in public procurement and 
concession contracts226. Receiving and processing of compliant eInvoices are mandatory for central public sector bodies as of 18 April 2019. 
Sub-central public sector bodies are mandated to receive and process compliant eInvoices as of 18 April 2020. 

•  On 14 December 2021, the law of 13 December 2021 amending the law of 16 May 2019 on electronic invoicing in the context of public 
procurement and concession contracts227 was published together with the Grand-Ducal Regulation of 13 December 2021 fixing the common 
delivery network and alternative technical solutions used for electronic invoicing in public procurement and concession contracts228. 

•  The  law  of  13  December  2021  amending  the  law  of  16  May  2019  on  electronic  invoicing  in  the  context  of  public  procurement  and 
concession  contracts229  makes  it  mandatory  for  economic  operators  to  send  compliant  electronic  invoices  to  public  sector  bodies  in  the 
context of public procurement and concession contracts. Businesses were given different deadlines to comply with the law: 

o  deadline for large companies: 18 May 2022 
o  deadline for medium-size companies: 18 October 2022 
o  deadline for small companies and newly created businesses: 18 March 2023 (source). 

•  The Grand-Ducal Regulation of 13 December 2021 determining the common delivery network and the alternative technical solutions used 
for electronic invoicing in public procurement and concession contracts230 selects as the common eDelivery network to be used by  public 
sector bodies for the automated receipt of electronic invoices the European Peppol Network231. 

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities & Local authorities 
•  Submitting: Enterprises are obliged to send electronic invoices for B2G within different timeframes based on size: 

o 

large companies: 18 May 2022. 

226 http://legilux.public.lu/eli/etat/leg/loi/2019/05/16/a345/jo  
227 https://legilux.public.lu/eli/etat/leg/loi/2021/12/13/a869/jo  
228 https://legilux.public.lu/eli/etat/leg/rgd/2021/12/13/a870/jo  
229 https://legilux.public.lu/eli/etat/leg/loi/2021/12/13/a869/jo  
230 https://legilux.public.lu/eli/etat/leg/rgd/2021/12/13/a870/jo  
231 http://peppol.org/  

285 

 
 
 
 
 
 
 
Platform 

Standard(s) 

Monitoring 

Strategy 

o  medium-size companies: 18 October 2022. 
o 
small companies and newly created businesses: 18 March 2023 
o  Mandatory below the EU thresholds: Yes, for big suppliers. 

•  B2B eInvoicing: eInvoices are allowed, however the buyer’s consent is needed for receiving. 

Peppol eDelivery Network 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented under Peppol 
BIS Billing 3.0 and UBL 2.1  

There is a monitoring strategy in place only at the central level via exploiting statistics from the 2 most important access  points, the one of CTIE and 
the one of SIGI. More than 700 public sector bodies are connected to Peppol in July 2023 and it is expected that in 2023 approximately 1 million B2G 
electronic invoices will be received. 

•  Using Peppol beyond pure eInvoicing: eOrder, Invoice response, Message response, etc. 
•  Getting businesses to do B2B eInvoicing and starting to use eInvoicing in the framework of VAT. 

Strategy for ensuring cross-border eInvoicing interoperability. 
The Luxembourg strategy for cross border is the usage of Peppol and also offering online forms that can also be used by cross-border users232 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

Out of approximately 700 Contracting authorities 10 were receiving eInvoices.  The  remaining 
were capable to receive but were not sent any. 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2019: Less than 10 

2020: Less than 10 

2021: Less than 50 

232 https://digital.gouvernement.lu/en/dossiers/2021/facturation-electronique.html  

286 

 
 
 
 
 
 
How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

Up to 2021, less than 50. Public sector bodies will probably receive this year close to 700 000 
electronic invoices.  

This increase is only due to the introduction of the obligation for economic operators to invoice 
electronically in the context of public procurement. 

How  many  B2G  eInvoices  from  foreign 
suppliers  

Up to 2021,less than 20 

B2B eInvoices exchanged at domestic level   

Up to 2021, near to 0 

B2B eInvoices exchanged at cross-border level    Up to 2021, near to 0 

Table 61 Structured eInvoicing uptake in Luxembourg 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
of 
sending eInvoices 

enterprises 

The data233 from Eurostat does not distinguish between B2G or B2B transactions 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

6.1% 

7.4% 

6.6% 

10.9% 

15.8% 

13.6% 

Implementation  of  EN  16931  Approach  

Table 62 sending eInvoices suitable for automatic processing in Luxembourg 

233 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

287 

 
 
 
 
 
 
 
 
 
 
 
 
compliant eInvoices 

The European standard on eInvoicing is fully implemented by the usage of  Peppol BIL Billing 3.0 (UBL 2.1). Each electronic invoice must comply 
with European standard EN 16931-1 :2017234 and one of the following two syntaxes: 

•  XML UBL235 (Universal Business Language). 
•  XML UN/CEFACT CII236 (Cross Industry Invoice). 

B2G eInvoices are shared via the Peppol network.   

Uptake of EN 16931 

According to the Ministry for Digitalisation in Luxembourg, the most effective measures to drive uptake is mandatory B2G and  B2B. They also see 
that integration with ERP systems and aligning to one transmission method such as using Peppol is critical. The most positive impact of the Directive 
was  the  creation  for  the  first  time  of  a  common  semantic  standard  and  an  obligation  for  public  sector  bodies  to  receive  and  process  compliant 
electronic invoices.  

Is Peppol / eDelivery used  

Yes 

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

Peppol is mandatory for transmission of eInvoices. 
2019: ~10 

2020: ~10 

2021: ~10 

234 https://ilnas.services-publics.lu/ecnor/displayStandard.action?id=223359&pattern=EN+16931-1%3A2017+&published=true&project=false&cancelled=false&enquiry=false&resultsPerPage=10  
235 http://docs.oasis-open.org/ubl/  
236 https://unece.org/trade/uncefact/xml-schemas  

288 

 
 
 
 
 
 
 
 
 
Percentage use vs other formats for B2G?  

2019: 100% 

Table 63 Uptake of EN 16931 in Luxembourg 

2020: 100% 

2021: 100% 

Cost and Benefits 

According  to  the  Ministry  for  Digitalisation,  Luxembourg  incurred  costs  solely  related  to  transposing  the  Directive  2014/55/EU  and  ensuring 
compliance with EN 16931.  

There was a moderate cost reduction because of the Directive and EN 16931.  

Luxembourg does not have a national format, so they did not experience a cost burden associated with ensuring a national format complied with EN 
16931. 

The following table shows the breakdown of costs to implement the EN. As a significant uptake is only starting, Luxembourg have not realised the 
full benefits yet, such as, staff reduction or redeployment. 

Implementation costs for EN 16931 

•  Training costs: ~ EUR 10 000 
•  Service providers fees: ~ EUR 100 000 
•  Technical implementation costs: ~ EUR 35 000 
•  Higher  electricity usage due to processing power and data storage space: Certainly, but  no 

figures available 
Increase in long term of electronic waste products: Probably. 

• 

Table 64 Implementation costs for EN 16931 in Luxembourg 

EU funding  

289 

 
 
 
 
eInvoicing  services  offered  by 
the 
of 
charge) 

government 

(free 

No funding requested 

SMEs can avail of free options from Peppol Service Providers. However, this involves keying the eInvoice. 

In Luxembourg, eInvoices are submitted and processed  using a central Peppol Access Point237 as well as sector-specific dispatching and accounting 
solutions.  The  maintenance  of  the  Peppol  Access  Point  is  outsourced  by  the  Government  IT  Centre  (CTIE)  to  an  external  service  provider.  The 
Peppol  Access  Point  is  to  be  used  by  all  central  government  organisations  and  can  also  be  used  by  local  organisations,  given  that  they  integrate 
Peppol with their accounting systems238. They would have to individually integrate the Peppol Access Point as currently the accounting back office of 
the government is not used by the local municipalities and only available for the central government.  

Call for evidence 

N/A 

Key findings 

Luxembourg stated that having a common standard for eInvoicing was very important.  However, they also see the need for one transmission such as 
eDelivery as is used in Peppol. They further state that the new EU Commission proposal on digital VAT of December 2022 foresees the mandatory 
use of eInvoicing for cross-border invoices. Peppol would be the ideal candidate to implement on EU level. 

Uptake is still flat but mandates for suppliers sending to public bodies is only starting and therefore there should be significant increases in the near 
future. 

Their strategy for the future is getting businesses to do B2B eInvoicing and starting to use eInvoicing in the framework of VAT. 

237 https://peppol.eu/who-is-who/peppol-certified-aps/   
238 https://www.inposia.com/en/list-of-countries-e-invoicing/  

290 

 
 
 
 
 
 
 
 
 
Malta 

Legislation 

In  Malta,  the  eInvoicing  Directive  has  been  transposed  via  Legal  Notices 403239 and 404240 of  2018.  This  Directive  was  transposed  under  the 
Financial Administration and Audit Act and also under the Local Councils Act. This was warranted since Local Councils in Malta have separate 
financial regulations that are listed in a dedicated act for these local authorities. Moreover, the extra year for sub-central entities applied. There is 
rather  a  fragmented  picture  at  the  sub-central  level  for  accounting  reporting  since  most  entities  and  local  councils  use  different  accounting 
systems or packages. 

The  Maltese  government  promotes  the  adoption  of  eInvoicing  in  its  Digital  Malta  national  strategy  entitled: Digital  Malta  2014-2020241.  The 
central government's action to promote the adoption of eInvoicing is an encouragement for local actors' implementation of eInvoicing. 

The introduction of eInvoicing was also reflected within “Mapping Tomorrow242”, the strategic plan for the digital transformation of the public 
administration for 2019-2021. 

Furthermore, as part of the activities of the eInvoicing4Islands project, Malta committed to deploy a new eInvoicing service for Government and 
its  sub-central  authorities  taking  into  account  the  on-going  development  for  central  authorities  and  the  required  connection  to  the  eDelivery 
Building Block243. 

Mandatory for  

•  Receiving and processing: Central authorities, Regional authorities & Local authorities 

o  Below the EU Threshold: No 

239 https://legislation.mt/eli/ln/2018/403/eng/pdf  
240 https://ec.europa.eu/digital-building-blocks/wikis/display/DIGITAL/eInvoicing+in+Malta#scroll-bookmark-1  
241 https://digitalmalta.org.mt/en/Documents/Digital Malta 2014 - 2020.pdf  
242 https://publicservice.gov.mt/en/Documents/MappingTomorrow_StrategicPlan2019.pdf  
243 https://ec.europa.eu/digital-building-blocks/wikis/x/jQTvB  

291 

 
 
 
 
 
Platform 

Standard(s) 

Monitoring 

Strategy 

eInvoicing platform to be put in place 

National Standard in use (if any) 

EN 16931 compliant standard 

There is no monitoring system in Malta to track the use of eInvoices.  

Peppol BIS 3 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Medium-term  Malta  is  striving  to  further  communicate  the  eInvoicing  initiative  so  that  more  Government  suppliers  start  sending  eInvoices.  
Malta is also striving for those entities that still do not have ERPs or Accounts Payable systems that are able to automatically process eInvoices, 
for them to upgrade their systems. 

Long-term, it is being considered whether to either lower the thresholds for which eInvoicing applies and/or whether to establish a threshold from 
which eInvoicing would become mandatory. 

Strategy for ensuring cross-border eInvoicing interoperability 
Malta’s strategy is to use Peppol for cross-border. 

Structured eInvoicing uptake 

Malta’s eInvoicing system was put in place in 2022 so no statistics are available for B2G. 

Percentage  of  enterprises  sending 
eInvoices 

The data244 from Eurostat does not distinguish between B2G or B2B transactions 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

244 The data description can be found at https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

292 

 
 
 
 
 
 
 
 
2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

11.5% 

13% 

8.8% 

7.9% 

9% 

18% 

22.1% 

Table 65 sending eInvoices suitable for automatic processing in Malta 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

Since Malta will adopt the Peppol BIS Billing 3.0 it will be able to receive eInvoices via the  Peppol eDelivery network. Moreover, a suppliers' 
portal will be made available, and suppliers can input their invoice details and send to the relative Ministry, Department, Entity or Local Council. 
This portal is needed as most suppliers still do not have their systems ready to automatically generate an eInvoice. 

There are communication channels to raise awareness about the upcoming mandatory eInvoicing implementation at the sub-central level. More 
specifically, there is a dedicated contact person in each Ministry and the National Forum on eInvoicing.  

Since sub-central entities have different ERP/Accounting packages, not all will be immediately able to adopt an automated approach.  

No electronic signature is required for eInvoices, and the archiving period amounts to 6 years. 

Uptake of EN 16931 

The use of Peppol ensures that all eInvoices B2G will be fully compliant with EN 16931. 

The Ministry for Finance and Employment stated that it is too early in the implementation stages to decide if the  Directive 2014/55/EU and the 
introduction of EN 16931 contributed to increasing the adoption of eInvoicing in Malta 

Cost and Benefits 

Implementation costs for EN 16931 

•  Purchase software/hardware:  EUR 34 750 
•  Training costs:  included above. 
•  Change management: included above. 
•  Test environment: included above. 
•  Service providers’ fees: included above. 

There  will  then  be  a  cost  per  eInvoice  received  that  will  be  charged  according  to  pre-
established bands.  

293 

 
 
 
 
 
 
 
Table 66 Implementation costs for EN 16931 in Malta 

EU funding  

•  Name of the EU funding programme: CEF Telecom 
•  Requested funding (in euro): 100 000 (partially paid) 
•  Year: 2020/2021 

Benefits at the national level 
According to the Ministry for Finance and Employment, it is too early to assess. 

eInvoicing  services  offered  by  the 
government (free of charge) 
Call for evidence 

N/A 

N/A 

Key findings 

According  to  Ministry  for  Finance  and  Employment  it  is  too  early  for  them  to  assess  the  impact  or  benefits,  but  it  is  envisaged  that  process 
automation and having a common standard have a substantial impact. 

As can be seen from Eurostat figures about 20% of businesses send structured eInvoices. This probably only includes B2B as a B2G system was 
not setup until 2022. 

Currently there are no plans to mandate business to send eInvoices, the focus is on creating awareness of the eInvoicing potential to public. 

294 

 
 
 
 
 
 
Norway 

Legislation 

Platform 

Standard(s) 

Monitoring 

Regulation  on  electronic  invoicing  in  public  procurement245 (FOR-2019-04-01-444), Established  by  the  Ministry  of  Local  Government  and 
Modernization on 1 April 2019 

Digitisation circular H-5/19 (Digitaliseringsrundskrivet246), Official publication :  2019-12-20 

Reference 
Mandatory for  

directory 

for 

IT 

standards 

in 

the 

public 

sector247 (“Referansekatalogen 

for 

IT-standarder 

i 

offentlig 

sektor”) 

•  Receiving and processing: Central, regional, and local public contracting authorities since 2012. 
•  Sending: Economic operators since 2019. 

o  Mandatory below the EU thresholds: Yes 

Peppol eDelivery Network 

National Standard in use (if any) 

EN 16931 compliant standard 

Legacy format: EHF248 (Elektronisk Handelsformat) 

The European standard on eInvoicing is fully implemented. 

From  2020,  a monitoring  system249 has  been  implemented  with  the  aim  of  tracking  the  use  of  eInvoices  with  central  and  non-central  bodies  in 
Norway250. 

The monitoring strategy is in place at both central and sub-central levels. The available data is expressed in number of invoices that are submitted 

245 https://lovdata.no/dokument/SF/forskrift/2019-04-01-444  
246 https://www.regjeringen.no/no/dokumenter/digitaliseringsrundskrivet/id2683652/  
247 https://www.difi.no/referansekatalogen  
248 https://ecosio.com/en/blog/e-invoicing-in-norway/  
249 https://www.anskaffelser.no/public-procurement/e-procurement/about-e-procurement/e-procurement-statistics  
250 https://www.anskaffelser.no/public-procurement/e-procurement/about-e-procurement/e-procurement-statistics  

295 

 
 
 
 
 
electronically.  

Strategy 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Medium term : To further improve use of EHF/Peppol BIS and the Peppol Network for B2G invoicing with a target of 100%, increasing from today's 
88%251 (in central government, - no comparable figures for municipal or regional level available).  

Long term: Work with the Tax Administration on B2B mandate and consider B2C involvement. 

Strategy for ensuring cross-border eInvoicing interoperability 
Use of Peppol BIS and the Peppol Network. 

Structured eInvoicing uptake  According to the 2019 survey252, there is great uncertainty associated with the total invoice volume in Norway, overall and for each of the segments. 
There are central payment statistics, but this does not distinguish between invoices and other types of transactions. It is therefore necessary to make a 
number of uncertain assumptions in order to estimate the invoice volume in Norway. Our estimate indicates in excess of 136 million invoices per year 
in the B2B/B2G segment and just under 250 million annual invoices in the B2C/G2C segment. 

Number  of  Contracting  Authorities  using 
eInvoicing  

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

The figures below represent both domestic and foreign suppliers combined253. 

2019: approx. 10 million 

2020: approx. 10 million 

251 https://dashboard.dfo.no/reports/main_statistics_for_invoices  
252 (page 4, https://www.regjeringen.no/globalassets/departementene/nfd/dokumenter/rapporter/oe-rapport-2020-37-elektronisk-faktura.pdf) 
253 https://www.regjeringen.no/globalassets/departementene/nfd/dokumenter/rapporter/oe-rapport-2020-37-elektronisk-faktura.pdf (page 11). 

296 

 
 
 
 
 
 
B2B eInvoices exchanged at domestic level   

The figures below include both domestic and cross-border eInvoices. 

2021: approx. 10 million 

2019: approx. 38 million 

2020: approx. 46 million 

2021: approx. 65 million 

Table 67 Structured eInvoicing uptake in Norway 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
of 
sending eInvoices 

enterprises 

The data254 from Eurostat does not distinguish between B2G or B2B transactions. 

Implementation  of  EN  16931 
compliant eInvoices 

2011 

2012  2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

13.7% 

17.5%  21.1%  30% 

47.4%  56.9%  53.5% 

64.9% 

Table 68 sending eInvoices suitable for automatic processing in Norway 

Approach  

Economic  operators  can  submit  eInvoices  either  by  using  their  internal Enterprise  Resource  Planning  (ERP)255 or  accounting  systems  or  by 
using approved  eInvoicing  solution  providers256.  The  Norwegian  eProcurement  infrastructure  is  built  around  the  Peppol  Business  Interoperability 
Specifications (BIS) and the Peppol eDelivery Network. 

254 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
255 https://en.wikipedia.org/wiki/Enterprise_resource_planning  

297 

 
 
 
 
 
 
 
 
In  addition  to  Peppol  BIS  document  format, EHF  (Elektronisk  Handelsformat)257 format  is  also  recognised  by  Norwegian  public  bodies.  Both  are 
based on UBL (Universal Business Language). 

The Norwegian Government Agency for Financial Management (DFØ) receives invoices on behalf of nearly 200 of the country's central government 
entities. 

The DFØ (Norwegian Agency for Public and Financial Management) authorises Norwegian-registered Access Points (AP) and operates the ELMA 
registry258 (a Peppol Service Metadata Publisher), with nearly 200,000 receivers, containing the identities and receiving capabilities of all Norwegian 
public entities and economic operators that communicate using the Peppol eDelivery Network. 

The eInvoicing process is mostly automated. Most public entities have an economic system that can handle Peppol invoices. The electronic follow-up 
systems (invoice flow systems) are used for the approval of the invoice before it is paid. While most of the payments are done electronically for all 
sub-central levels, the use of eOrder259 is still in its beginning. The use of Peppol has made the public administration more interested in the use of 
electronic  solutions.  The  possibility  to  automate  more  processes  by  using  eOrder, eCatalogue260 and  eInvoice  together  is  a  goal  for  the  public 
administration. 

No electronic signature is required for eInvoices, and the archiving period amounts to 5 years, and 15 years for the petroleum recovery and pipelining 
industry261. 

Uptake of EN 16931 

According to The Norwegian Agency for Public and Financial Management (DFØ), the eInvoicing penetration has not been significantly changed 
because of the implementation of the Directive and the EN. They don't have data on this development, but a survey was conducted in spring 2022. 

256 https://www.anskaffelser.no/verktoy/veiledere/erp-leverandorer  
257 https://docs.microsoft.com/en-us/dynamics365/business-central/localfunctionality/norway/ehf-electronic-invoicing-in-norway  
258 https://www.anskaffelser.no/public-procurement  
259 https://www.anskaffelser.no/public-procurement/e-procurement/about-e-procurement/e-procurement-statistics  
260 https://www.anskaffelser.no/public-procurement/e-procurement/about-e-procurement/e-procurement-statistics  
261 https://www.pagero.com/compliance/regulatory-updates/norway  

298 

 
 
 
 
 
The  report  can  be  found  on  https://anskaffelser.no/sites/default/files/2022-06/Anskaffelsesundersokelsen_hovedrapport_2022.pdf  (Norwegian  only) 
showing  a  high  response  rate  (88%  central  government,  80%  regional  authorities,  68%  municipalities  and  28%  public  sector  owned  companies). 
Total number of respondents was 520, out of that 493 (93%) confirmed that they use eInvoicing tools. Background numbers (not published) show :  

93% usage of eInvoicing in central government entities 

100% usage in regional authorities 

97% usage in municipalities.  

Public sector owned companies has the lowest penetration with 88% usage of eInvoicing tools. 

The combined number of EHF/Peppol BIS invoices B2B and B2G over the Peppol Network from 2019 until 2021 (with incomplete 2022 numbers 
included) is as follows : 

2019: 57 705 153 (24% increase from 2018), estimated total number of invoices B2G and B2B in Norway: 136 300 000 

2020: 66 358 484 (14% increase from 2019), estimated total number of invoices B2G and B2B in Norway: 135 800 000 

2021: 84.713.628 (26% increase from 2020), estimated total number of invoices in Norway B2G and B2B in 2021 not yet calculated.  

2022 (including November): 96 843 693 (14% increase from November 2021), estimated total number of invoices in Norway B2G and B2B in 2022 
not yet calculated. 

All suppliers to the public sector are expected to have access to an eInvoice-generating tool either as part of their ERP-system, accounting system, 
their  bank  (if  they  are  an  SME)  or  as  commercially  available  invoicing  portals  (some  offering  low  volume  eInvoicing  for  free).  In  the  Peppol 
Network,  only  eInvoicing  recipients  are  listed,  not  senders.  However,  the  following  figures  give  an  indication  on  the  EHF/Peppol  BIS  based 
eInvoicing capabilities in Norway (figures from ELMA, the government operated SMP in the Peppol Network): 

2014: 30 695 (31.12.2014) of total entities: 280 263 = 11% 

2019: 154 401 (31.12.2019) of total entities: 324 367 = 48% 

2020: 181 734 (31.12.2020) of total entities: 330 530 = 55% 

299 

 
 
 
2021: 220 716 (31.12.2021) of total entities: 342 811 = 64% 

2022: 250 959 (30.11.2022) of total entities: 361 338 = 69% 

Number  of  entities  from  https://www.ssb.no/en/statbank/table/10308/tableViewLayout1/.  Households  and  non-profit  institutions  as  well  as 
unspecified sectors/other are not included. 

Is Peppol / eDelivery used  

Percentage use vs other formats for B2G?  

Yes. Use of the Peppol Network has been mandated from 2011 for central government entities. 
Mandatory  for  all  Contracting  Authorities  from  April  2019  with  the  introduction  of  the 
regulation on e-invoicing in public procurement (FOR-2019-04-01-444, implementing Directive 
2014/55/EU). 
2019: 100% 

Percentage use vs other formats for B2B?  

2020: 100% 

2021: 100% 
2019: approx. 85% 

2020: approx. 90% 

2021: approx. 95% 

Cost and Benefits 

Norway incurred costs solely related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

Table 69 Uptake of EN 16931 in Norway 

They perceive a low cost-reduction because of the Directive and EN 16931. 

Norway experienced a cost burden associated with ensuring the national format complied with the EN 16931. The estimated cost  was approximately 
EUR 450 000. 

The benefits outweighed the costs because the costs were relatively low, and this was just an update of already implemented solutions. 

300 

 
 
 
Implementation costs for EN 16931 

•  Purchase  software/hardware:  Upgrade  from  earlier  versions  of  EHF/Peppol  BIS  to  the 

EN16931 compliant version. 

•  Training costs: Negligible. 
•  Change management: Negligible. 
•  Test environment: Negligible. 
•  Service providers’ fees: Negligible. 

Table 70 Implementation costs for EN 16931 in Norway 

EU funding  

•  Name of the EU funding programme: CEF (2016-EU-IA-0119, CEF-TC-2016-3 - eInvoicing) 
•  Requested funding (in euro): 887 879. 
•  Year: 2016 

Benefits at the national level 
Operational efficiencies: This is the most important driver for the Norwegian e-invoicing efforts. Estimates indicate a yearly socio-economic saving 
of NOK 4,2 billion annually262 

The time gain from the transition to electronic invoice is estimated at approximately 1 minute for the sender and 3 to 5 minutes for the recipient in the 
B2B and B2G markets. These estimates are  consistent with previous estimates, taking into account that processing of outgoing and incoming non-
electronic invoices already takes place digitally. Previously - and far higher - estimated time gains, based on a fully manual invoice processing that 
today has largely been replaced with digital processing. 

We estimate that society's total time gains from the transition to an electronic invoice result in potential savings of NOK 4.2 billion per year. Gains 
related to reduced distribution costs contribute with an additional potential of NOK 1 billion per year. The estimates are based on estimated shares 
and time gains from 2019, and the uncertainty is considerable. Our view is that the share of electronic invoices will continue to increase in the years 

262 page 4 https://www.regjeringen.no/globalassets/departementene/nfd/dokumenter/rapporter/oe-rapport-2020-37-elektronisk-faktura.pdf) 

301 

 
 
 
 
 
 
to come, so that the use of paper and PDF invoices will gradually decrease without the introduction of measures and will largely disappear over a 
period of years. A gradual transition to electronic invoicing means that the potential annual savings will be reduced year by year.    

eInvoicing  services  offered  by 
the government (free of charge) 

Norway  is  dependent  on  both  the  Peppol  BIS  3.0  standard  and  the  Peppol  eDelivery  Network  –  particularly  for  cross-border  transactions.  Both 
economic operators and contracting authorities in Norway rely on Peppol Access Point (AP) service providers to achieve compliance with national 
regulations. These service  providers offer solutions for creating, submitting, transmitting, receiving, and processing eInvoices.  A list of eInvoicing 
service providers263 is publicly available. 

Call for evidence 

N/A 

Key findings 

Norway has a high adoption rate:  

• 
• 
• 

93% usage of eInvoicing in central government entities 
100% usage in regional authorities 
97% usage in municipalities.  

Norway had already high adoption rates before the Directive came into force and so did not see a significant impact by the EN. 

Future plans include a B2B mandate. They believe that the EN will not need to be extended for this mandate. 

263 https://www.anskaffelser.no/verktoy/aksesspunkter-ehf-og-bis-formater  

302 

 
 
 
 
 
 
 
 
 
 
 
Poland 

Legislation 

The  law  transposing  the eInvoicing  Directive  (2014/55/EU) was  introduced  in  November  2018  as  the Act  of  November  9,  2018,  on  electronic 
invoicing in public procurement, concessions for construction works or services and public-private partnerships. It has been in force since 18 April 
2019. 

Poland is advancing on the use of B2B electronic invoicing. According to the plans, the Polish Ministry of Finance will launch a National eInvoicing 
System  (KSeF),  which  will  be  a  central  government  platform  for  the  issuance  and  reception  of  electronic  invoices.  Companies  must  send  all 
electronic invoices to the KSeF, where a digital time stamp will be applied. The goal of this system is to enable the exchange of electronic invoices in 
the B2B relationship and fit into the CTC monitoring model. In October 2021, a test period began when service providers could participate in system 
testing with KSeF.  In January 2022, a voluntary phase started, where companies could begin issuing "structured" invoices to KSeF and benefit from 
fiscal benefits. The Ministry of Finance has conducted extensive public consultations and, via a statement264 with changes to the KSeF system, Poland 
aims to postpone the implementation date of the B2B electronic invoicing in the country to July 1, 2024, when the use of B2B electronic "structured" 
invoice (XML) will be mandatory. 

Mandatory for 

•  Receiving and processing: Central authorities, Regional authorities & Local authorities since April 2019 
•  Sending: Optional for suppliers of public administrations but will become mandatory for B2B transactions as of July 2024. 

o  Mandatory below the EU thresholds: No 

Platform 

Standard(s) 

National eInvoicing platform (PEF) supported by two service providers. It was launched on 1 April 2019. 

National Standard in use (if any) 

EN 16931 compliant standard 

From 2022: KSeF Interface Specification265 (planned to be mandatory for 
B2B from 1st of July 2024) 

The European standard is fully implemented under UBL 2.1 and CII in 
the PEF platform.  

264 https://www.gov.pl/web/finanse/zmiany-w-projekcie-krajowego-systemu-e-faktur-ksef-po-uwagach-biznesu  
265 https://ksef.mf.gov.pl/document/InterfaceSpecification/1.2/EN  

303 

 
 
 
 
 
Monitoring 

Strategy 

There  is monitoring in place for both the central and sub-central levels. The number of suppliers using PEF and the number of eInvoices that are 
submitted via PEF are monitored.  

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The Ministry of Finance is working on the implementation of mandatory B2B/B2G eInvoicing from 1 July 2024. 

A standard for eInvoices in public procurement has been in place for several years. At the same time, from January 1, 2023, a voluntary system based 
on  the  national  standard  developed  by  the  Ministry  of  Finance  has  been  in  operation.  From  July  1,  2024,  it  is  planned  that  the  systems  will  be 
integrated, and that eInvoicing will become mandatory. In the years 2025-2026, the system should operate as a mature one. 

Strategy for ensuring cross-border eInvoicing interoperability. 
Cross-border invoices will be exempt from the national obligation, but they will be still possible to be exchanged electronically, for example using the 
Peppol network. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

no information 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

no information 

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

Central  level  and  sub-central  from  domestic  and  foreign  suppliers  for  central  and  sub-central 
authorities. 

 2019: 3 356 

2020: 90 979 

2021: 263 829 

Notes on above data  

Source:  eInvoicing  platform  report  which  is  the  only  access  point  for  structured  invoices  in 
Poland. 

How  many  B2G  eInvoices  from  foreign 
suppliers  

no information 

304 

 
 
 
 
B2B eInvoices exchanged at domestic level   

no information 

B2B eInvoices exchanged at cross-border level    no information  

Table 71 Structured eInvoicing uptake in Poland 

Percentage 
of 
sending eInvoices 

enterprises 

The data266 from Eurostat does not distinguish between B2G or B2B transactions. 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

4% 

5.6% 

13.7% 

12.8% 

13.2% 

15.7% 

13.2% 

Table 72 sending eInvoices suitable for automatic processing in Poland 

Implementation  of  EN  16931 
compliant eInvoices 

Approach  

Currently B2G eInvoicing is implemented via Peppol. The current PEF platform and KSeF platform, which will be available for both B2G and B2B, 
will be integrated before 1st of July 2024. It means that the economic operator will be obliged to use KSeF platform to handle B2B invoices and will 
be free to choose which one platform (PEF or KSeF) to use for handling B2G invoices. 

As a consequence, it is planned to use the national standard in the platform to be developed by the Ministry of Finance that will support B2G and 
B2B eInvoicing, in parallel with the PEF platform which will continue to be used. 

Uptake of EN 16931 

According to the Polish Ministry of Economic Development and Technology, the Directive 2014/55/EU, and the introduction of the EN 16931 have 
moderately contributed to increasing the adoption of eInvoicing. 

266 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

305 

 
 
 
 
 
 
 
 
 
At  the  end  of  2020,  over  16 000  entities  were  registered  on  the  PEF  platform,  including  almost  15 000  from  the  public  sector. At  the  same  time, 
almost 100 000 Post-Award electronic documents were exchanged using PEF, mostly eInvoices (over 97% of all documents). 

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

Yes, Ministry of Economic Development and Technology (MRiT) performs the duties of Peppol 
Authority 
2019: 13 477 out of a total of 32 101 

2020: 14 880 out of total of 32 958 

2021: 15 361 out of total of 38 618 

Percentage use vs other formats for B2G?  

Percentage use vs other formats for B2B?  

lack  of  information  about  total  number  of  eInvoices,  because  for  every  contract  >1  eInvoices 
may be issued 
2019: ~0 

Cost and Benefits 

Table 74 Implementation costs for EN 16931 in Poland 

Table 73 Uptake of EN 16931 in Poland 

2020: ~0 

2021: ~0 

EU funding  

•  Name of the EU funding programme: CEF Telecom 
•  Requested funding (in euro): 100 000 (partially paid) 
•  Year: 2020/2021 

Benefits at the national level 
According to the Ministry for Finance and Employment, it is too early to assess. 

Poland incurred costs related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

306 

 
 
 
According to the national authorities, the Directive and EN 16931 resulted in a low cost-reduction. 

There was a cost burden associated with ensuring the national format complied with the EN 16931  estimated at ~EUR 1.5M. It was necessary to 
implement an extension to the EU-norm, which enables the inclusion of representatives of specific sectors of mass services (such as energy or gas) in 
the e-invoicing process. They are responsible for issuing millions of invoices, and the basic standard according to EU-norms was too narrow for them 
and  made  it  impossible  to  include  many  important  information  on  the  invoice.  Cost  benefit  is  expected  to  be  achieved  in  the  coming  years  -  the 
extension was implemented in mid-2022.  

Implementation costs for EN 16931 

•  Purchase software/hardware: 5 000 000 euro 
•  Training costs: 100 000 euro 
•  Change management: 1 000 000 euro 
•  Test environment: included in software category. 
•  Service providers’ fees: included in software category. 

Table 75 Implementation costs for EN 16931 in Poland 

EU funding  

•  Name of the EU funding Programme: Operational Program Digital Poland 
•  Requested funding (in euro): 5 000 000. 
•  Year: 2016-2019 

Benefits at the national level 
According to the Polish Ministry of Economic Development and Technology, the implementation of the Directive facilitates operational efficiency 
and environmental benefits, but research in this area has not been conducted. 

eInvoicing  services  offered  by 
the government (free of charge) 
Call for evidence 

Key findings 

The new KSeF system is available free of charge for B2B and B2G.  

N/A 

According to the Polish Ministry of Economic Development and Technology, the Directive 2014/55/EU, and the  introduction of the EN 16931 have 
moderately contributed to increasing the adoption of eInvoicing. 

307 

 
 
 
At  the  end  of  2020,  over  16 000  entities  were  registered  on  the  PEF  platform,  including  almost  15 000  from  the  public  sector. At  the  same  time, 
almost 100 000 Post-Award electronic documents were exchanged using PEF, mostly eInvoices (over 97% of all documents). 

From  2022,  the  KSeF  Interface  Specification  is  planned  to  be  mandatory  for  B2B  from  1st  of  July  2024.  This  is  a  new  national  format  with  a 
proprietary syntax specifically developed for Polish enterprises for B2B transactions. 

308 

 
 
 
 
 
 
 
 
Portugal 

Legislation 

•  Decree-Law 123/2018267 of 28 December sets out the governance model for the implementation of eInvoicing in public procurement. 
•  Official publication: Diario da Republica I; Number: 250/2018; Publication date: 2018-12-28; Page: 05960-05962. 
•  Order No 289/2019 of 5 September — regulating the supplementary aspects of the electronic invoice268. 
•  Official publication: Diario da Republica I; Number: 170/2019; Publication date: 2019-09-05; Page: 00277-00279. 
•  Decree-Law no. 14-A/2020269 adopted a series of exceptional and temporary measures on 7 April 2020. 
•  Lei n. ° 12/2022270 introduces important changes regarding the digital reporting obligations of taxpayers. 

Mandatory for  

•  Receiving and processing: Central, regional, and local authorities 
•  Sending: economic operators 

o  Large Enterprises – January 2021.  
o  SME – January 2023. 

Platform 

•  Portal BASE (general eProcurement) 
•  Plataforma Eletronica de Compras (eSPap platform) 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

Monitoring 

eInvoicing monitoring is ensured regarding the content of the eInvoices for tax compliance purpose. Suppliers and entities, when transferring and 
receiving eInvoices, must connect to the eSPap’s portal FE-AP, the gateway of the state to financial documents. The documents are transferred 

The  European  standard  on  eInvoicing  is  fully  implemented  and 
mandatory for usage under UBL 2.1 or/and XML-GS1. 

267 https://dre.pt/web/guest/pesquisa/-/search/117514514/details/normal?q=123%2F2018  
268 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:276986  
269 https://dre.pt/application/conteudo/131228424  
270 https://dre.pt/dre/legislacao-consolidada/lei/2022-185325094  

309 

 
 
 
 
 
 
through a secure online connection (web-service). 

Strategy 

B2G eInvoicing in Portugal is operated by different service providers under the licence from IMPIC, supervised centrally by the State through the 
Centro de Gestão da Rede Informática do Governo (CEGER) and technically accredited by the Gabinete Nacional de Segurança (GNS).  

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
The Portuguese Government continues accrediting new suppliers, since the current legislation and the COVID context do not include any penalties 
for non-compliance with deadlines. 

Strategy for ensuring cross-border eInvoicing interoperability 
For exchanges with other countries, the current strategy involves using the Peppol network, however with some limitations associated with the 
automatic processing of these invoices.  

This occurs due to the specification of national tax legislation, VAT being mandatory, and invoices cannot be negative, for example, and which 
are rules that are also configured in accounting systems.  

Structured eInvoicing uptake 

In Portugal, 49% of the contracting authorities use eInvoicing and supplier mandates have been gradually introduced since 2021271.  

The following table shows the uptake in eInvoicing from 2019 to 2021. 

Number  of  Contracting  Authorities  using 
eInvoicing  

2019: 136  

271https://www.bportugal.pt/page/lista-de-entidades-para-fins-estatisticos  

2020: 1 256 

2021: 1 768 

2022: 2 174 

310 

 
 
 
 
 
Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

Number  of  B2G  eInvoices  from  national 
suppliers  

2019: 107  

2020: 352 

2021: 2 202 

Notes on above data  

2022: 4 980 
Given  that  there  are  no  national  studies,  the  data  presented  refer  to  the  solution  of  the 
Portuguese Ministry of Finance (FE-AP) in which adherence by entities is mandatory only for 
the central public administration.  

All  the  central  government  contracting  authorities  using  EN  16931-compliant  eInvoicing 
standard. 

Table 76 Structured eInvoicing uptake in Portugal 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage  of  enterprises  sending 
eInvoices 

The data272 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

4% 

5.6% 

13.7% 

12.8% 

13.2% 

15.7% 

13.2% 

Table 77 sending eInvoices suitable for automatic processing in Portugal 

272 The data description can be found at  https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

311 

 
 
 
 
 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Approach  

The Instituto Português da Qualidade273 (IPQ) established a technical committee to follow up on the activities performed at European level by the 
European Committee for Standardization (CEN274) and the European Commission. This committee brings together public and private entities to 
support and prepare compliance with the  Directive 2014/55/EU and the European standard on eInvoicing. It is composed of public and private 
entities such as GS1 Portugal275, itSMF276 (Associação Portuguesa de Gestores de Serviços TI), among 20 other entities. 

The two European eInvoicing standard formats were  adapted to the national B2G  eInvoicing context via the creation of two CIUS,  i.e. OASIS 
UBL 2.1 “CIUS-PT” and CEFACT “CIUS-PT”. Users connect to the platform via AS2 or Web Services. Portuguese eInvoicing issuers as well as 
recipients are required to keep documents for 10 years. 

Uptake of EN 16931 

According  to  the  Ministry  responsible,  the  Directive  2014/55/EU  and  the  introduction  of  EN  16931  contributed  significantly  to  increasing  the 
adoption of B2G eInvoicing in Portugal. In B2C, the Portuguese Government perceived that the Directive’s contribution was limited.  

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities  using  eInvoicing  compliant  with  the 
EN 16931, versus the total  

273 http://www1.ipq.pt/PT/Pages/Homepage.aspx  
274 https://www.cen.eu/Pages/default.aspx  
275 http://www.gs1pt.org/  
276 https://www.itsmf.pt/  

Yes,  Portugal  is  operationalizing  the  Peppol  network  with  the  national  rules  and  platform 
already in place, with some adjustments still in progress to ensure integration with automated 
processes. 
2019: 136  

2020: 1 256 

312 

 
 
 
 
 
2021: 1 768 

2022: 2 174 

2021: 100% 

2021: 100% 

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   
Percentage  of  EN  16931  compliant  eInvoices 
vs. total number of B2B eInvoices   

Table 78 Uptake of EN 16931 in Portugal 

Cost and Benefits 

EU funding  
CEF Telecom eInvoicing funding  

Budget requested: 5 projects totalling EUR 1 223 910 

Benefits at the national level 
In the case of shared services, the possibility of concentrating efforts and capitalizing on a knowledgeable team capable of supporting the market. 

eInvoicing  services  offered by  the 
government (free of charge) 

eInvoicing services offered by the government (free of charge) 
For  B2G  eInvoicing,  there  is  Plataforma  Eletrónica  de  Compras,  a  cost-free  platform  that  enables  the  launch  and  management  of  all  public 
procurement processes, including eInvoicing, in the context of the framework agreements established by eSPap. 

Call for evidence 

N/A 

Key findings 

In Portugal, ESPAP as a shared services entity was responsible for eInvoicing governance. This structure could concentrate efforts, monitoring the 
market, and boosting dissemination. It resulted in economies of scale and clear savings for public entities, operators, and suppliers. 

Semantic  challenges:  compliance  with  some  fiscal  and  public  procurement  requirements  that  may  be  different  than  other  countries:  retention, 
budgetary commitment number, negative prices (energy); fields that have one cardinality in semantics, and a different one in UBL2.1 syntactics. 

313 

 
 
 
Regarding transmission, the Portuguese authorities often face the EDI’s obligation of adding certificates in files.  

Regarding governance,  the  Portuguese  government  perceives  the  need of  a  clarification  regarding  the  possibility  of  a  public  entity  to  require a 
supplier to pay to adhere to the platform where it receives the eInvoice. 

Effective measures for a further increase in of eInvoicing adoption  
The FE-AP platform has already been integrated with the software. However, due to certain activity sectors and specific issues, full integration is 
not possible. For example, there are discrepancies in codes, units of measure, and invoice line details that prevent automation. A portal may be 
necessary for effective collaboration. 

314 

 
 
 
 
 
 
Romania 

Legislation 

Directive 2014/55/EU has been transposed through the Law 199/2020 on electronic invoicing in public procurement277, on 8 September 2020. 

The Fiscal Code278, in force from 1st of January 2016, and its implementing rules approved by Law 227/2015279 are governing the electronic invoicing 
(eInvoicing) in Romania. 

Additional  legislation  may  apply  if  electronic  signature  (eSignature)  or  electronic  archiving  (eArchiving)  is  used  in  the  process  of  electronic 
invoicing: 

•  Law 455/2001280 on electronic signature. 

•  Law 135/2007281 on electronic archiving of documents. 

•  Law 139/2022282 approves Government ordinance 120/2021283 focusing on the administration, functioning, eInvoicing, and implementation 
of the RO e-factura system through the national invoicing system RO e-Factura in UBL 2.1 format, as well as makes the issuing of e-invoices 
mandatory for specific taxpayers. 

In  January  2019,  the  work  related  to  the  eInvoicing  Directive  transposition  started.  In  June  2019,  the  Parliament  received  the  proposal  of  the 
legislation. The law was passed by the Parliament in August 2020, promulgated on 8 September, and published on 9 September 2020. 

Mandatory for 

•  Receiving and processing: Central, regional, and local contracting authorities. 

277 https://ec.europa.eu/digital-building-blocks/wikis/pages/viewpage.action?pageId=399115161  
278 https://static.anaf.ro/static/10/Anaf/legislatie/Cod_fiscal_norme_31072017.htm  
279 https://static.anaf.ro/static/10/Anaf/Prezentare_R/Law227_11042018.pdf  
280 https://www.comunicatii.gov.ro/wp-content/uploads/2016/01/LEGE-nr-455.doc  
281 https://www.comunicatii.gov.ro/wp-content/uploads/2016/01/LEGE-nr-135.doc  
282 https://legislatie.just.ro/Public/DetaliiDocument/260213  
283 https://legislatie.just.ro/Public/DetaliiDocumentAfis/247243  

315 

 
 
 
 
 
•  Submitting: as of July 2022 

The Romanian Government have asked for a derogation to VAT Directive for B2B mandatory eInvoicing starting from 2024.  

Platform 

Standard(s) 

RO e-Invoicing 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented under EN 16931 
with national CIUS on top – the standard will be applied in full for all B2B 
and B2G transactions. 

Monitoring 

On April 11, 2022, the Romanian Ministry of Finance implemented the RO e-Transport electronic system for tracking the road transportation of high-
tax-risk goods. This introduces a mandatory Transport system to monitor specific goods.  

The e-Transport is connected to the existing systems of the Ministry of Finance, the National Agency for Fiscal Administration (ANAF), and/or the 
Romanian Customs Authority. Taxpayers must declare  the transportation of high-risk products three days before the start of shipment. The system 
then generates a unique code that must accompany the goods. The deadline to comply with the mandate was postponed until 1 January 2023.  

To  facilitate  the  implementation  of  the  mandate,  the  ANAF  published  the  technical  documentation  for  the  e-Transport  system  including  the  XSD 
schema, the XML structure, APIs, as well as samples files of the XML, schema, and validation sheets This system will control  the transportation of 
high tax risk goods between two locations within Romania, relating to intra-community purchases, intra-community deliveries, imports, exports, and 
intra-community transactions where goods are in transit in Romania. 

Strategy 

B2B National eInvoicing strategy 
(Source: Romanian Government284 and National Agency for Fiscal Administration285) 

284 https://legislatie.just.ro/Public/DetaliiDocumentAfis/249349  
285 https://legislatie.just.ro/Public/DetaliiDocument/250346 

316 

 
 
 
 
 
 
eInvoicing  will  be  implemented  as  a  standard  for  all  transactions  B2B  starting  from  2024  if  the  derogation  from  VAT  Directive  is  obtained  and 
expanded to B2C as a long-term objective.  

Government ordinance 130, published on December the 17th 2022, introduces mandatory issuance as of July 2022 for companies whose activity is 
linked to product categories considered susceptible to tax evasion (ANAF 12/2022 ordinance published on January 6th, 2022): Fruit and vegetables, 
alcohol, construction, mineral products, and clothing and footwear.  

Romania has dropped plans for a phased rollout to all companies of mandatory B2B e-invoicing. Instead, it will aim for a single 2024 introduction of 
mandatory eInvoicing for B2B286. 

Structured eInvoicing uptake  N/A 

of 
Percentage 
sending eInvoices 

enterprises 

The data287 from Eurostat does not distinguish between B2G or B2B transactions 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Implementation of EN 16931 
compliant eInvoices 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

5.7% 

7.9% 

7.2% 

8.7% 

10.9% 

20.3% 

16.9% 

Table 79 sending eInvoices suitable for automatic processing in Romania 

Approach 

The  transposition  of  the  European  standard  was  done  in  2018  :  (EN  16931)  by ASRO288 - In  conformity  with  Law  355/2002,  the  Romanian 
Government  granted  ASRO  governmental  recognition  as  a  National  Standardisation  Body  developing  standardisation  activities  in  all  fields  of 
European and international standardisation as member of ISO, the IEC, CEN, CENELEC and ETSI289.  

286 https://www.avocatnet.ro/articol_63037/e-Factura-obligatoriu-pentru-toate-firmele-Derogarea-ar-trebui-s%C4%83-vin%C4%83-in-perioada-imediat-urm%C4%83toare-conform-MF.html  
287 The data description can be found at https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

317 

 
 
 
 
 
 
 
 
 
As a bottom-up action, the adoption of the EN standard is promoted by the Romanian IT industry (Cluj IT Cluster290). 

The  Minister  of  Finance  Order  no.  1366/2021291  approved  the  CIUS  (RO_CIUS)  for  eInvoicing  and  specific  operational  rules  applicable  at  the 
national level, in compliance with the EN 16931 European standard for e-invoicing. 

Percentage of EN 16931-compliant eInvoicing over the total number of invoices 

2021: <0,1% 

Number of contracting authorities using EN 16931: N/A 

Number  of  contracting  authorities  using 
eInvoices 
Is eDelivery /Peppol used  
Number  of  suppliers  sending  eInvoices  for 
public procurement contracts 

2021: 15 out of 15 065 (0.1%) 

No 
2021: 13/600 000 (0.002%)  

Number of B2G eInvoices 

<0.1% 

Cost and Benefits 

Implementation costs for EN 16931  

Table 80 Uptake of EN 16931 in Romania 

•  Purchase software/hardware: 68 500 EUR  
•  Training costs: 0 
•  Change management: 16 720 EUR 
•  Test environment: EUR 38 000  

288 https://www.iso.org/member/2058.html  
289 https://www.iso.org/member/2058.html  
290 https://www.clujit.ro/#despre-noi/  
291 https://legislatie.just.ro/Public/DetaliiDocument/248303  

318 

 
 
 
 
 
 
•  Service providers fees: EUR 7 500  
• 

for legal and solution analysis, publicity, user guides, support, and security audit: EUR 129 
800  

Table 81 Implementation costs for EN 16931 in Romania 

N/A 

N/A 

government 

eInvoicing  services  offered  by 
the 
of 
charge) 
Call for evidence 

(free 

Key findings 

The  uptake  in  Romania  as  of  2021  is  low.  But  the  Government  planned  to  implement  mandatory  B2G  eInvocing  in  2022.  So,  the  volumes  are 
expected to be higher. Also, the  Romanian Government has asked for a derogation at the EC to make B2B eInvoicing mandatory as of 2024. The 
introduction of B2B eInvoicing is a long-term objective. As a bottom-up action, the adoption of the EN standard is promoted by the Romanian IT 
industry.  

319 

 
 
 
 
 
Slovakia 

Legislation 

Act  No.  2015/2019292 on  Guaranteed  Electronic  Invoicing  and  the  Central  Economic  System  is  in  force  from  01  August  2019.  The  act  specifies 
regulation for the requirements of eInvoicing for public administrations and their suppliers.  

The  law  above  covers  the  transposition  as  stated  in  Article  11(1)  of  Directive  2014/55/EU,  however,  eInvoicing  is  not  yet  fully  implemented.  The 
obligations  of  the  entities  involved  in  eInvoicing  will  be  introduced  incrementally,  according  to  the  readiness  of  the  eInvoicing  platform  called 
Information System for Electronic Invoicing (IS EFA) 293 

In February 2021, the Ministry of Finance in Slovakia revealed a new draft law294 on sending invoice data to the Financial Administration. According 
to the authorities’ preliminary statements, the aim is to introduce real-time invoice reporting that is supposed to be mandatory for all transactions (i.e. 
including B2B too) over time. 

A public consultation on the above-mentioned measure was conducted until the end of March 2021. Preliminarily, the validity of the law is proposed at 
the beginning of 2022. Subsequently, there will be room for testing technical solutions. The latest date for the start of live operations can be expected 
in January 2023. 

Mandatory for  

•  Receiving  and  processing:  Central  authorities,  Regional  authorities  &  Local  authorities.  They  are  obliged  to  use  eInvoicing  if  the 

invoice amount issues by a public supplier is higher than EUR 5 000. 

•  Sending: The use of eInvoicing in Slovakia, in the private sector, is on a voluntary basis. 

Platform 

The national centralised eInvoicing platform, Information System for Electronic Invoicing (IS EFA) is currently in the initial stages of being released.  

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

292 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=NIM:275943  
293 https://wtsklient.hu/en/2021/05/13/electronic-invoicing-information-system-in-slovakia  
294 https://www.skdp.sk/webnew/main.nsf/0/430C1ADDC6CA5CEDC125865C003D7496?opendocument  

320 

 
 
 
 
 
Monitoring 

Strategy 

Structured 
uptake 

There  is  a  Web  API  service  for  eInvoice  users  based  on  the  Open  API 
specification  

However the invoice content uses JSON as the syntax that is not standardised 
and is therefore proprietary to Slovakia. 

It is not foreseen that the IS EFA, the central eInvoicing solution will monitor the eInvoicing uptake. 

N/A 

eInvoicing 

Most of the data represented below, in the Eurostat data, is based on traditional EDI e.g. EDIFACT, such as is used in the retail sector. However the 
Ministry of Finance295 is planning the roll-out of a new system. The Information System for Electronic (IS EFA)296 will gradually be mandatory for all 
state and public administration bodies in Slovakia and business who supply them with goods or services. The schedule for its implementation consists 
of four phases, which will be implemented progressively over the course of 2023. 

•  Q3 2023 – Ministry of Finance of the Slovak Republic and Datacentrum and its suppliers 
•  Q4  2023  –  Budget  organisations  of  the  Ministry  of  Finance  of  the  Slovak  Republic,  including  the  Financial  Administration  of  the  Slovak 

Republic 

•  Q1 2024 – Other government and public administration entities 
•  Engaging entrepreneurs for transactions with government and public administration institutions 

Percentage 
sending eInvoices 

of 

enterprises 

The data297 from Eurostat does not distinguish between B2G or B2B transactions 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

295 https://www.mfsr.sk/en/  
296 https://web-einvoice-demo.mypaas.vnet.sk/  
297 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

321 

 
 
 
 
 
 
 
2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

11.4% 

13.8% 

11.3% 

14.5% 

17.9% 

15.4% 

16.5% 

Table 82 sending eInvoices suitable for automatic processing in Slovakia 

Based on data gathered from Desk Research, there are no EN 16931 compliant eInvoices being used in Slovakia. The new system from the Ministry of 
Finance, which is in Beta, is not yet compliant. 

Implementation 
16931 compliant eInvoices 

of 

EN 

Cost and Benefits 

EU funding  

•  Name of the EU funding programme: CEF telecom 
•  Requested funding (in euro): 118 030 

eInvoicing services offered by 
the  government 
(free  of 
charge) 
Call for evidence 

N/A 

N/A 

Key findings 

Although Slovakia has legislation that transposes the Directive, there is no evidence of any system that is compliant.  

In the Country Factsheet, it states that, the EN will be implemented by using the  centralised eInvoicing solution (IS EFA) following Stage II. It was 
forecasted  to  be  fully  introduced  in  July  2022.  However,  to  date,  this  is  not  implemented.  The  current  specifications298  are  based  on  JSON  in  a 
proprietary format, which is at odds with the legislation.  

The conclusion is that they have not reached the compliance stage yet and the roll-out of the national system is continuing albeit behind schedule. 

298 https://api-einvoice-demo.mypaas.vnet.sk/ 

322 

 
 
 
 
 
 
 
 
 
 
323 

 
 
 
 
 
Slovenia 

Legislation 

Platform 

Standard(s) 

Monitoring 

Strategy 

eInvoicing has been mandatory in Slovenia since 1 January 2015. Provision of Payment Services to Budget Users Act299 mandates the 
use of eInvoices in billing for public procurement. The use of eInvoices is fully applied in the public sector (B2G and G2G). The law 
further mandates the use of the Public Payments’ Administration of the Republic of Slovenia (PPA) eInvoicing system and details its 
tasks. 

The  transposition  of  the  eInvoicing  Directive  (2014/55/EU)  into  Slovenian  law  is  contained  in  Act  Amending  the  Provision  of 
Payment Services to Budget Users Act300. 

Mandatory for  

•  Receiving and processing: Central, regional, and local authorities 
•  Sending: B2G and G2G eInvoicing is mandatory in Slovenia since 1st January 2015. 

Mandatory below the EU thresholds: No 

PPA eInvoicing system301  (UJP eRačun302) 

National Standard in use (if any) 

EN 16931 compliant standard 

e-SLOG 2.0, XML based on EDIFACT and EANCOM. 

The monitoring is ensured by the PPA eInvoicing system. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 

299 http://www.pisrs.si/Pis.web/pregledPredpisa?id=ZAKO7120  
300 https://www.uradni-list.si/glasilo-uradni-list-rs/vsebina/2019-01-2291?sop=2019-01-2291  
301 http://www.ujp.gov.si/  
302 https://eracuni.ujp.gov.si/  

324 

 
 
 
 
 
 
Between 2023 and 2024, the strategy is to mandate eInvoicing for B2B. 

Strategy for ensuring cross-border eInvoicing interoperability. 
cross-border eInvoicing interoperability will be achieved by using Service providers, and Peppol. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

2021: 3 030 

Number of suppliers sending eInvoices for public 
procurement contracts  

N/A 

How  many  B2G  eInvoices 
from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

Including data from Central + Sub-central authorities 

2019: 432 894 

2020: 403 859 

2021: 437 212 

How many B2G eInvoices from foreign suppliers   2021: 360 

B2B eInvoices exchanged at domestic level  

2019: 7 000 000 

2020: 7 000 000 

2021: 7 000 000 

B2B eInvoices exchanged at cross-border level  

2021: 140 000 

Table 83 Structured eInvoicing uptake in Slovenia 

325 

 
 
 
of 
Percentage 
sending eInvoices 

enterprises 

The  following  table  refers  to  the  percentage  of  enterprises  with  more  than  10  employees  sending  eInvoices  suitable  for  automatic 
processing. 

The data303 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

5.4% 

9.8% 

5.8% 

16.3% 

56.7% 

61.9% 

58.4% 

Table 84 sending eInvoices suitable for automatic processing in Slovenia 

The following graphs are taken from the Rose2 project report named Digitalisation of business from order to payment - Standardisation of eInvoicing 
and eOrdering304.  This was funded by the EU CEF Telecom initiative. 

303 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
304 https://epos.si/assets/docs/ROSE_Zbornik2020_EN_Web.pdf  

326 

 
 
 
 
 
 
 
 
 
Figure 35 Percentage of companies using eInvoices in Slovenia (Source Rose2 project) 

327 

Figure 36 Number of eInvoices received in Slovenia (Source Rose2 project) 

 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Approach  

Slovenia uses the eSlog eInvoice305 which is an XML format, but it is not UBL or UN/CEFACT XML formats. However, they state it is in line with 
the EN 16931, which infers it is semantically interoperable. 

According to the ROSE 2 project funded by the EU CEF Telecom, there are two certified PEPPOL access points in Slovenia, the PPA for budget 
users and the ZZI for other users. Therefore they also support the Peppol formats which are fully compliant with the EN. 

In the report Slovenia state that a very important step towards cross-border transactions with eInvoices was provided by Directive  2014/55/EU on 
eInvoicing in public procurement, which introduces a single European standard for eInvoices. For the introduction of the European semantic standard 
EN 16931 in Slovenia, the ROSE “Readiness of Slovenian eInvoicing” project was established in 2017306. One of the main objectives of the project 
was to upgrade the eSLOG eInvoice standard to version 2.0, which is in line with the European standard. 

The  project  also  included  the  establishment  of  the  eRegistry  of  eInvoice  recipients,  an upgrade  of  the  environment  for  the  exchange  of  eInvoices, 
inclusion of Slovenia in the European PEPPOL4 network for the exchange of eInvoices and promotional activities in the form of conferences and 
workshops. 

In 2019, under the auspices of the Chamber of Commerce and Industry of Slovenia, the Slovenian National eBusiness Centre (EPOS) was launched, 
which combines various activities in the field of eBusiness, which until then had been carried out separately. The National Forum became actively 
involved in the technical committees of the Slovenian Institute for Standardisation (SIST) and the European Committee for Standardisation (CEN). At 
the annual meeting in 2019, the National Forum proposed that the mandatory exchange of eInvoices between legal entities in Slovenia be regulated by 
law. 

As of October 1, 2020, only the eSLOG eInvoice 2.0 is valid, as the eSLOG eInvoice 1.6 and 1.6.1 ceased to be used. This assures full compliance 
with EN 16931. 

According to the Country Factsheets, 

305 https://epos.si/assets/docs/e-SLOG-2.0-08-2020-EN.zip  
306  The ROSE and ROSE 2 projects are co-financed through the Connecting Europe Facility (CEF) 

328 

 
 
 
 
 
In Slovenia, economic operators send all eInvoices to the PPA through its central eInvoicing system (PPA eInvoicing system).  

Suppliers can submit eInvoices: 

•  Manually via the web-portal PPA eInvoicing (UJP eRačun).  

•  Automatically  via  eInvoicing  solution  providers  that  have  successfully  obtained  certification  from  the  PPA  eInvoicing  system  and  have 
established  a  direct  link  with  it.  This  method  for  sending  eInvoices  is  recommended  for  medium  and  large-sized  enterprises  due  to  the 
process automation and the data integration with the companies’ in-house management systems. 

•  Automatically through Bankart307 eInvoicing solutions provided by banks participating in the eInvoicing inter-bank exchange in Slovenia. It 
is used in the eInvoicing inter-bank exchange with the PPA. The Bankart allows the participating banks and the PPA to submit and receive 
electronic invoices to and from their clients using their own solutions (e.g. electronic banking services). 

No electronic signature is required for eInvoices, and the archiving period amounts to 10 years, and it increases to 20 years for immovable property. 

Uptake of EN 16931 

The Ministry of Finance, Public Payments Administration of the Republic of Slovenia indicated that the Directive 2014/55/EU and the introduction of 
EN 16931 contributed very significantly to increasing the adoption of eInvoicing in Slovenia 

307 http://www.bankart.si/en/services/simp/  

329 

 
 
 
 
 
Is Peppol / eDelivery used  

Yes, 

Number of public contracting authorities 
and  entities  using  eInvoicing  compliant 
with the EN 16931, versus the total  
Percentage  use  vs  other  formats  for 
B2G?  

Percentage  use  vs  other  formats  for 
B2B?  

Public Payments Administration is linked to the PEPPOL only for budget users. 
2021: 3 121 

2019: 100% 

2020: 100% 

2021: 100% 
2019: 98% 

2020: 98% 

2021: 98% 

Cost and Benefits 

Table 85 Uptake of EN 16931 in Slovenia 

Slovenia incurred costs related to transposing the Directive 2014/55/EU and ensuring compliance with EN 16931. 

According to the national authorities, the Directive and the EN 16931 resulted in a low cost-reduction.  

There was no cost burden associated with ensuring the national format complied with the EN 16931. 

330 

 
 
 
Implementation  costs 
for EN 16931 

•  Purchase software/hardware: No 
•  Training costs: No 
•  Change management: No 
•  Test environment: No 
•  Service providers fees: Public Payments Administration of the Republic of Slovenia pays an annual membership 

fee for Peppol. 

•  Reduced number of staff working on manual invoicing: No 
•  Number of staff redeployed in value added  No 
•  Higher electricity usage due to processing power and data storage space: No 
• 

Increase in long term of electronic waste products: No 

Table 86 Implementation costs for EN 16931 in Slovenia 

EU funding  

•  Name of the EU funding programme: ROSE and ROSE 2 
•  Requested funding (in euro):  

o  ROSE: 50635 EUR for PPA, total: 570 248 EUR.   
o  ROSE2: 37772 EUR for PPA, total:  645 075 EUR 
•  Year: 1.6.2017-1.6.2018 (ROSE) and 1.10.2019-30.9.2020 (ROSE 2) 

Benefits at the national level 

Since the transposition of the Directive 2014/55/EU and the EN 16931, Slovenia experienced higher levels of automation for eInvoice processing, 
reduced operational costs and improved transparency. 

Access to the national platform is free of charge.  Suppliers may submit eInvoices manually via the web-portal PPA eInvoicing (UJP eRačun). This 
service is provided for small businesses that submit up to 60 eInvoices per year. 

Suppliers may also use certified solution providers that include Banks. 

eInvoicing  services  offered  by 
the 
of 
charge) 

government 

(free 

Call for evidence 

N/A 

331 

 
 
 
 
Key findings 

The  Ministry  of  Finance,  Public  Payments  Administration  of  the  Republic  of  Slovenia  stated  that  the  Directive  and  EN  16931  contributed 
significantly to both B2G and B2B increase of adoption. Looking at the statistics from Eurostat and the ROSE 2 project, it was the mandating of B2G 
in  2015  that  drove  the  adoption  10-fold  from  5.8%  to  56.7%  of  enterprises  sending  eInvoices.  However,  they  subsequently  updated  the  national 
format to be aligned to the EN Semantic Model and introduced Peppol. Peppol is seen as part of their strategy for cross-border eInvoicing. 

Since the transposition they state that there is more automated eInvoice processing. They believe that Large Enterprises, large Contracting Authorities 
and Service Providers bore the highest costs, while Micro-enterprises had the lowest costs. 

There are no current plans for B2B, however in the Member State survey, they did indicate that it is part of their medium-term strategy to mandate it. 

332 

 
 
 
 
 
 
Spain 

Legislation 

Law  25/2013308 establishing the obligation of the electronic invoicing and the creation of the entry registration point.  In accordance with  the law, 
B2G eInvoicing is mandatory in Spain since 2015. 

Law 18/2022309 establishes that all B2B transactions should be exclusively supported by electronic invoices, and the solutions and platforms used by 
taxpayers to generate, process, and validate those invoices should be in accordance with the regulations. Businesses with total revenues of EUR 8 
million or more a year will be required to comply with the mandate one year from the date the eInvoicing technical regulations are enacted by the 
central government/tax administration. The remaining businesses will have two years from the date the eInvoicing technical regulations are enacted 
by the central government/tax administration.  

Mandatory for  

•  Receiving and processing: Central, regional, and local authorities, as well as economic operators with regard to B2B transactions. 
•  Sending: Economic operators with regard to B2G and B2B transactions. 

Platform 

In the context of B2G, FACe310 is the general eInvoicing entry point.  

Some regional governments manage their own eInvoicing entry point. Contractors can choose between both means at their convenience. 

FACeB2B, is the platform allowing B2B electronic invoicing in the very limited case of subcontractors of public administrations. 

In the general context of B2B, it is important to note that the Law  18/2022 established a  period of 6 months from the publication of the law (29 
September 2022) for the administrations involved to determine the technical and information requirements to be included in the electronic invoice for 
all B2B transactions. The procedure to approve technical requirements has started and is advanced, but the mentioned period has been exceeded. 

308 https://www.boe.es/diario_boe/txt.php?id=BOE-A-2013-13722&lang=en  
309 https://www.boe.es/diario_boe/txt.php?id=BOE-A-2022-15818  
310 https://face.gob.es/  

333 

 
 
 
 
 
Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

Facturae311 –  XML  based  national  standard  (used  in  association  with  an 
eSignature following the XAdES standard). 

The draft technical regulations of the Law 18/2022 have already undergone 2 
rounds of public consultation but have not been enacted yet. The draft allows 
Facturae, UBL, CII and EDIFACT syntaxes. 

The European standard on eInvoicing is fully implemented.  

The  European  standard  on  eInvoicing  is  required  by  the  draft 
regulations irrespective of the syntax used. 

Monitoring 

The  B2G  eInvoicing  monitoring  is  ensured  via  the  platform  FACe.  The  monitoring  is  based  on  the  analysis  of  the  number  of  invoices  that  are 
submitted electronically and submitted in a specific syntax. The data is publicly available and continually updated in OBSAE312. 

Strategy 

N/A 

Structured eInvoicing uptake 

(Source: FACe313)  

No. 
of 
presented in FACe 

invoices 

2014 

884 

2015 

2016 

6M 

7.9M 

2017 

9.8M 

No.  of 
attached 
production (FACe) 

local  entities 
in 

and 

2 389 

7 571 

7 779 

7 882 

311 http://www.facturae.gob.es/formato/Paginas/formato.aspx  
312 http://dataobsae.administracionelectronica.gob.es/  
313 https://dataobsae.administracionelectronica.gob.es/cmobsae3/dashboard/Dashboard.action?request_locale=en  

334 

 
 
 
 
 
 
 
 
No.  of  organisations 
received 
that  have 
invoices 
FACe 
in 
(accumulated) 

%  of  population  with 
access to FACe 

132 

11 591 

14 116 

15 769 

72.84% 

93.24% 

94.07% 

94.26% 

Table 87 eInvoicing uptake in Spain  

2018 

2019 

2020 

2021 

2022 

11.5M 

12.7M 

12.8M 

14.4M 

15.9M 

7 991 

8 060 

8 112 

8 181 

8 356 

17 215 

18 516 

19 877 

20 982 

21 618 

94.54% 

94.91% 

94.99% 

95.29% 

95.48% 

of 

No. 
invoices 
presented in FACe 

No. of local entities 
attached  and 
in 
production (FACe) 

No. 
of 
organisations  that 
received 
have 
invoices  in  FACe 
(accumulated) 

%  of  population 
with 
to 
FACe 

access 

Table 88 eInvoicing uptake in Spain  

Total  number  of 
invoices (Millions) 

Percentage 

Amount 
invoices 
Millions) 

of 
(EUR  

Percentage 

335 

 
 
 
 
 
General 
Administration 

State 

8.7  

9.25% 

97 850  

22.10% 

Autonomous 
Administration 

Local 
Management 

40.3  

42.44% 

195 779  

44.21% 

41.1  

43.34% 

135 219  

30.54% 

Universities 

4.1  

4.34% 

9 957  

2.25% 

Other 
institutions 

0.6  

0.64% 

4 003  

0.90% 

Table 89 Structured eInvoicing totals in Spain  

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
of 
sending eInvoices 

enterprises 

The data314 from Eurostat does not distinguish between B2G or B2B transactions. 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

6.4% 

6.8% 

10% 

25% 

31.7% 

31.7% 

32.8% 

Table 90 sending eInvoices suitable for automatic processing in Spain 

314 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

336 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Implementation  of  EN  16931 
compliant eInvoices 

Status on the implementation of the European Standard on eInvoicing (EN)  

The implementation of European eInvoicing standard in public entities is accomplished through FACe, the general single-entry point for eInvoices. 
This  platform  provides  a  translation  mechanism  to  the  national  format  (Facturae315)  allowing  any  public  entity  to  process  European  eInvoicing 
standard invoices with the current set of tools and applications available. 

In order to strengthen this translation process a dedicated CIUS316 has been developed applying national regulations and conventions for eInvoicing 
to the public sector and restricts data formats in compliance with the eInvoice national format. 

The draft technical regulations for mandatory B2B electronic invoicing require all electronic invoices to comply with the EN16931 standard, while 
allowing the use of different eInvoicing syntaxes. 

Approach  

FACe is the general entry point of eInvoices for central government. Local and regional governments can either develop their own solutions or use a 
reception system provided by other administrations. In most cases the system of choice is FACe. Suppliers can retrieve ‘eInvoicing addresses’ for 
any public administration (even those not connected to FACe) using the directories and query services available in the FACe portal. All eInvoice 
reception systems are integrated with the specific Accounting Register of Invoices in each administration, which acts as a centralised mechanism of 
the payment process control.  

Electronic invoicing services provided by FACe can be accessed through the platform’s portal. A web services interface is also provided in order to 
support direct integration of invoice processing applications. Its services include, directory of financial units and discovery of invoice presentation 
points, submission of eInvoices and tracking and management of presented eInvoices.  

This  open  approach  has  contributed  to  the  success  of  eInvoicing  in  Spain.  The  FACe  system  processes  more  than  12  million  eInvoices  annually 
(updated information is available in OBSAE317), providing considerable savings for the public and private sectors due to the use of a fully automated 

315 http://www.facturae.gob.es/formato/Paginas/formato.aspx  
316 https://administracionelectronica.gob.es/ctt/face/descargas  

337 

 
 
 
 
 
Cost and Benefits 

EU funding  

invoicing process. 

•  Name of the EU funding Programme: CEF Telecom eInvoicing funding. 
•  Requested funding (in euro):  3 950 010 

Benefits at the national level 
The main identified benefits are cost and operational savings, the reduction of administrative burden and optimisation of time to payments and the 
contribution to process automation 

eInvoicing  services  offered  by 
the government (free of charge) 

The General State Administration offers an eInvoicing entry point (FACe) to all public entities as a free of charge service. 

Feedback from EU Citizen 

Public administration suppliers can create eInvoices using any compliant invoicing application; using an eInvoicing service provider (e.g. banks); or, 
especially in the case of SMEs processing low volumes of invoices, using the free eInvoicing client318 software provided by the Spanish Ministry of 
Industry. This free eInvoicing client software is fully integrated into the FACe platform through the aforementioned web services interface. 

Call for evidence 

N/A 

Key findings 

The European eInvoicing Directive and the EU Standard has had a significant impact on streamlining invoicing processes in Spain and promoting 
digitalisation in both the public and private sectors. 

The level of B2G eInvoicing uptake in Spain has been high, primarily driven by national policies mandating its use since 2015. The implementation 
of the FACe platform as a centralised entry point for eInvoices, combined with the availability of open and free automated interfaces, has facilitated 
widespread  adoption  among  public  administration  suppliers.  FACe  is  mandatory  for  central  government,  while  optional  for  regional  and  local 

317 http://dataobsae.administracionelectronica.gob.es/  
318 http://www.facturae.gob.es/formato/Paginas/descarga-aplicacion-escritorio.aspx  

338 

 
 
 
 
 
 
governments. 

In the B2B sector, eInvoicing in Spain has seen steady growth. According to Eurostat, in 2020, 32.8% of Spanish enterprises were using eInvoicing 
for both B2G and B2B transactions, compared to only 6.4% in 2011. The implementation of a B2B eInvoicing mandate, starting from 12 months 
after the approval of the technical regulations needed, for taxpayers with an annual turnover of EUR 8 million or greater and 24 months after the 
approval of the technical regulations needed for remaining taxpayers, is expected to significantly increase adoption rates. 

In terms of future plans and strategy, Spain has demonstrated a commitment to eInvoicing by implementing the EN 16931 standard and leveraging 
the FACe platform as a key infrastructure. The increasing number of structured eInvoices presented in FACe each year, as well as the growing count 
of  organisations  receiving  eInvoices  through  the  platform  show  growth.  The  availability  of  EU  funding  and  the  perceived  cost  saving  potential 
through the fully automated invoicing process provided by FACe should also drive adoption over the years. 

In the Call for Evidence, a Spanish citizen stated that the existing systems of each State while should be respected, while establishing a standard of 
exchange for intra-Community invoicing. 

339 

 
 
 
 
 
 
Sweden 

Legislation 

1.  Ordinance for accounting319(Förordning (2000:606) om myndigheters bokföring §21f). 

2.  Ordinance  for  electronic  information  exchange320(Förordning  (2003:770)  om  statliga  myndigheters  elektroniska  informationsutbyte  §  3). 
The  law  has  been  amended multiple  times,  with  the  latest  amendment  in  2021. It  also  includes  the  mandated  use  of  eProcurement  in  the 
procurement processes. 

3. 

(SFS 2018:1277)321. The law implemented the EU eInvoicing directive  into national law. More information regarding the Act is provided 
below.  

The Act regarding eInvoicing in public procurement: 

• 
• 
• 
• 

became effective 1 April 2019. 
it covers the complete public procurement process, above and below EU threshold and includes direct procurement.  
the law makes it mandatory for public sector suppliers to send eInvoices for all contracts signed after 1 April 2019.  
public sector must be able to receive  and process eInvoices according to the European standard, EN 16931. However, there are  some 
exceptions which includes national security, specific privacy situations, etc. 

•  DIGG, the Agency for Digital Government, can impose fines to suppliers that do not comply with the law. 
• 
•  DIGG has issued accompanying regulation, which mandates all public entities to be registered in Peppol. 

the law permits the use of other/older formats, which may be set out in bilateral agreements. 

Mandatory for  

•  Receiving and processing: All public sector contracting authorities 

•  Submitting: Suppliers to the public sector 

319 http://www.esv.se/ea-boken/?page=eabok_ch_4_sec_Myndigheters%2520bokf%25C3%25B6ring  
320 https://www.riksdagen.se/sv/dokument-lagar/dokument/svensk-forfattningssamling/forordning-2003770-om-statliga-myndigheters_sfs-2003-770  
321 https://www.riksdagen.se/sv/dokument-lagar/dokument/svensk-forfattningssamling/lag-20181277-om-elektroniska-fakturor-till_sfs-2018-1277  

340 

 
 
 
 
 
Platform 

Standard(s) 

Monitoring 

Strategy 

o  For contracts below the EU thresholds: Yes 

N/A 

National Standard in use (if any) 

EN 16931 compliant standard 

Svefaktura version 1 (a national subset of UBL 1.0 defined in 2004) - old 
legacy format. Not recommended by SFTI as of 1 April 2021. 

The European standard on eInvoicing is fully implemented.  

SFTI  Fulltextfaktura  (an  EDIFACT  D96A  invoice  adjusted  to  GS1 
EANCOM  specifications)  -  old  legacy  format.  Not  recommended  by 
SFTI as of 1 April 2021. 

The Swedish government does not have a systemic approach towards eInvoicing monitoring. However, there are several systems and tools in place to 
monitor the uptake and implementation of eInvoicing. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Medium term: getting average adoption rates over 90% B2G 

Long term: expanding target groups involving B2B and G2B 

Strategy for ensuring cross-border eInvoicing interoperability 
Implementation of the Peppol specifications and establishment of a Peppol authority. 

Structured eInvoicing uptake 

Number  of  Contracting  Authorities  using 
eInvoicing  

2019: 500/500 

2020: 500/500 

Number  of  suppliers  sending  eInvoices  for 
public procurement contracts  

2021: 500/500 
The data below represents the percentage of invoices, Sweden has no data regarding the no. of 
suppliers. 

341 

 
 
 
2019: 60% 

2020: 70% 

2021: 80% 
2019: 4 000 000 

2020: 4 200 000 

2021: 4 300 000 

How  many  B2G  eInvoices  from  national 
suppliers does the Public Sector in your country 
receive on a yearly basis?  

Table 91 Structured eInvoicing uptake in Sweden 

B2G eInvoicing uptake 
DIGG322  published the results of a survey323 on eInvoicing and eCommerce in 2022 addressed to the public sector, including the state, municipalities, 
and regions, with 357 respondents (the response rate was 71%). 

On average over 80% of incoming invoices (supplier invoices) are handled as an eInvoice in public administration. The eInvoice act (2018:1277) has 
been in force for almost four years and the share of eInvoices should continue to rise as new procurements replace older agreements. 

Peppol’s infrastructure is mainly used for handling supplier invoices as close to 70% of the respondents’ state that these flows are entirely or largely 
via Peppol. 

In  the  figure below,  the  average  use  of  eInvoicing  for  B2G  in  Sweden  for  2022  is  at  82%  among  all  the  levels  of  public  administration.  As  seen 
below, the average for the state is 84%, the average for regions is 80%, and municipalities is 82%. The value for the State was similar in 2021. The 

322 Digg (Agency for Digital Government) is tasked with supporting and increasing the use of e-commerce in public administration. 
323 https://www.digg.se/analys-och-uppfoljning/publikationer/publikationer/2022-12-09-e-fakturering-och-e-handel-i-offentlig-forvaltning  

342 

 
 
 
 
 
 
total volume is 24 700 000 eInvoices. 

Figure 38 The average use of eInvoicing for B2G in Sweden for 2022 (Source Swedish study) 

eInvoicing in municipalities and regions 
SKR’s324 task is to support and contribute to the development of Swedish municipalities and regions' activities. SKR conducts recurring surveys. The 
current report325 is based on a survey conducted from April to June 2022.  

188 municipalities and 20 regions answered the survey. 

324 Swedish Association of Local Authorities and Regions (SALAR) (skr.se) 
325 https://skr.se/download/18.ba5afac18482ebd585116a1/1668783132660/E-handel,%20e-fakturering%20och%20e-upphandling.pdf 

343 

 
 
 
 
 
 
 
The diagram below shows the distribution of the share of eInvoices for municipalities and regions in 2021. 

Among the municipalities, several only indicated how many supplier invoices they received in total in 2021, but not quantify the number of those that 
were eInvoices. 

Figure 39 The average use of eInvoicing for B2G in Sweden for 2022 (Source Swedish study) 

The  diagram  shows  that  in  2021  the  majority  of  municipalities  and  regions  received  most  of  their  invoices  as  eInvoices.  In  particular,  138 
municipalities and 15 regions received more than 75% of invoices as eInvoices. Of those 138 municipalities, 51 received over 90% of their invoices 
as eInvoices, and among the 15 regions 12 received more than 80% as eInvoices. 

344 

 
 
 
 
Compared  to  previous  years'  surveys  there  has  been  a  sharp  increase  in  the  share  of  eInvoices  received  for  both  municipalities  and  regions.  For 
municipalities, the average share of eInvoices was 79% and for regions 74%. In the previous survey, the average was 56% for both municipalities and 
regions. 

The next diagram shows the distribution of the share of eInvoices compared to previous years at municipalities and regions. 

Figure 40 Distribution of the share of eInvoices in Sweden compared to previous years at municipalities and regions (Source Swedish study) 

The survey uses data from 2021, which is after the law that transposed the Directive on eInvoices that came into force on 1 April 2019.  

345 

 
 
 
 
of 
Percentage 
sending eInvoices 

enterprises 

The data326 from Eurostat does not distinguish between B2G or B2B transactions 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Implementation  of  EN  16931 
compliant eInvoices 

2011 

2012  2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

18.5% 

21.8% 

23.2% 

33.1% 

35.7% 

45.4% 

Table 92 sending eInvoices suitable for automatic processing in Sweden 

Approach  

Solution providers, on behalf of public sector organisations, operate the access  point to receive eInvoices from economic operators. For the central 
government,  the Legal,  Financial  and  Administrative  Services  Agency327 manages  framework  agreements  for  the  provision  of  a  common 
infrastructure  for  central  government  organisations.  Currently, Visma328 and CGI329 are  the  solution  providers  operating  these  framework 
agreements. These framework agreements can be used by all central government agencies and approximately 120 municipalities and regions, which 
have given consent to use them. 

Several  platforms  are  in  use  by  the  public  sector.  In  Sweden,  the  solutions  used  are  based  on  the  recommendations  by  Single  Face  To  Industry 
(SFTI330) regarding standards for both messages and other infrastructure. SFTI recommends Peppol for the Swedish public sector and its suppliers. 

No electronic signature is required for eInvoices, and the archiving period amounts to 7 years331. 

Uptake of EN 16931 

326 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  
327 https://www.kammarkollegiet.se/en  
328 http://www.visma.se/commerce/  
329 https://www.cgi.com/en  
330 http://www.sfti.se/utbildningarochstod/englishpages.4193.html  
331 https://www.pagero.com/compliance/regulatory-updates/sweden  

346 

 
 
 
 
 
 
 
 
 
 
The Agency for Digital Government (DIGG) indicated that the Directive 2014/55/EU and the introduction of EN 16931 had a high impact on B2G 
eInvoicing whereas it had a low impact on B2B in Sweden. 

B2B is not regulated in any way, however, EN16931 has replaced the Swedish national format Svefaktura. EN 16931 is perceived  as the preferred 
standard by authorities. 

Is Peppol / eDelivery used  

Number  of  public  contracting  authorities  and 
entities using eInvoicing compliant with the EN 
16931, versus the total  

Percentage of eInvoices based on the EN 16931 
vs other formats for B2G  

Table 93 Uptake of EN 16931 in Sweden 

Yes. Sweden has a Peppol Authority (DIGG), 27 contracted service providers and around 70000 
End-users connected in Sweden. 
2019: 450/500 

2020: 490/500 

2021: 500/500 

2019: 40% 

2020: 50% 

2021: 60% 

Cost and Benefits 

The  Agency  for  Digital  Government  (DIGG)  indicated  that  Sweden  incurred  costs  solely  related  to  transposing  the  Directive  2014/55/EU  and 
ensuring compliance with EN 16931. 

They also indicated that the Directive and EN 16931 resulted in costs that will diminish over time. Although there was a cost burden upgrading the 
national  format  to  European  eInvoicing  standard  compliance,  Sweden  perceive  that  the  benefits  still  outweigh  the  costs.  Actual  costs  were  not 
available. 

EU funding 
No funding requested. 

Benefits at the national level 

347 

 
 
 
eInvoicing  services  offered  by 
the government (free of charge) 

Call for evidence 

According  to  a  business  case  study  conducted  by  Visma  in  September  2019  in  the  Nordic  countries  (Norway,  Sweden,  Denmark,  Finland),  the 
introduction of eInvoicing (B2G/B2B/B2C) could result in annual potential savings of 9,159,391,103 EUR332. 

According to DIGG, environmental benefits are estimated at 10 000 ton less CO2 for over 7 years. 

Other  perceived  benefits  include  operational  efficiencies,  improved  control,  enhanced  communication  and  improved  transparency  for  the  public 
sector and to most of their suppliers. 

There  is  no  central  solution  or  platform.  Service  providers  are  offering  services  both  to  the  public  sector  and  to  private  suppliers.  Peppol  is  the 
preferred solution. Suppliers submit eInvoices using Peppol service providers. 

Sweden encourages the use of Peppol for electronic procurement, enabling  connected public entities and economic operators to communicate with 
each other. Legacy eProcurement solutions based on EDIFACT (GS1 EANCOM) are still supported by the central, regional and municipalities. 

Feedback provided by Pagero 
Pagero believes that the introduction of the Directive 2014/55/EU has had a significant impact on eInvoicing adoption in the  EU both specifically for 
B2G transactions and overall for B2B. The effect of the introduced harmonisation and standardisation efforts cannot be underestimated. As outcome 
of the evaluation, Pagero believe that the Commission could be less modest if revising the Directive and propose more far-reaching changes aimed on 
harmonisation and standardisation, such as extension of the EN 16931 or introduction of eDelivery Building Blocks, as the market has become more 
mature to take the next step within the eInvoice digitalisation journey.  

Feedback from DIGG 
Within the government, there is already relatively high average figures for the proportion of eInvoices of all invoices received. With the introduction 
of the law, there has been a  clear increase in the  share  of  eInvoices also in other parts of public administration. Today, the average proportion of 
eInvoices in public administration is 82%. However, many have a share of eInvoices of over 90%. DIGG believe it is crucial for continued success 
that the EU works to ensure that the European standard can be handled as uniformly as possible in order to facilitate cross-border trade and that the 

332 Visma Business case: E-invoicing across the Nordics, September 2019  

348 

 
 
 
 
 
 
standard remains free to use. A recent DIGG survey333 shows that Peppol's network is increasingly used for the distribution of incoming invoices. See 
also results for the central government sector334.  

DIGG see a need to steer B2B invoicing more  towards eInvoices instead of paper invoices or PDF. ViDA  will significantly affect many SMEs in 
Sweden and it needs to be communicated several years in advance how an eInvoice  should be defined and give time to prepare both systems and 
entrepreneurs and their organisations' routines and working methods. DIGG also believe that  Peppol is suitable for B2B to handle eInvoices given 
that the network and messages are established, transparent and standardised communication solutions. 

Key findings 

The Directive 2014/55/EU and the introduction of EN 16931 had a high impact on B2G eInvoicing whereas it had a low impact on B2B. EN 16931 is 
perceived as the preferred standard by public authorities. 

Sweden  incurred  costs  solely  related  to  transposing  the  Directive  2014/55/EU  and  ensuring  compliance  with  EN  16931,  including  upgrading  to 
European eInvoicing standard compliance. However, benefits still outweigh costs. 

The  SKR  survey  shows  that  eInvoicing  has  continued  to  increase  in  the  last  few  years.  The  most  recent  survey  shows  that  for  municipalities  the 
average percentage of eInvoices is 79% and for regions 74%. In the previous survey the average was 56% for both municipalities and region. The 
previous survey was based on responses from the 2018 financial year, which was before the Act that transposed the Directive. The current survey is 
based on responses from the business year 2021, which is after the law came into force. A comparison of the results from the  two surveys clearly 
shows that the entry into force of the law had a major impact on the share of eInvoices among municipalities and regions. 

Eurostat also showed an increase in line with the adoption of EN 16931. In 2020 45% of enterprises were sending invoices. This included both B2B 
and B2G. 

The future strategy is, in the medium term, getting B2G average rates over 90%. In the longer term it is to target B2B and G2B. 

In the Call for Evidence, Pagero sees a maturing market that now needs more far-reaching changes aimed on harmonisation and standardisation, such 

333 https://www.digg.se/analys-och-uppfoljning/publikationer/publikationer/2022-12-09-e-fakturering-och-e-handel-i-offentlig-forvaltning  
334 https://www.digg.se/kunskap-och-stod/e-handel/att-forvalta-e-handel/uppfoljning-av-myndigheternas-e-handel  

349 

 
 
 
 
 
as extension of the EN 16931 or introduction of eDelivery Building Blocks.  

DIGG  states  that  ViDA  will  significantly  affect  many  SMEs  in  Sweden.  It  needs  to  be  communicated  to  them  several  years  in  advance  how  an 
eInvoice should be defined. Time should be given to prepare both organisations and their systems. Sweden also believe that Peppol is suitable for 
handling B2B eInvoices given that the network and messages are established, transparent and standardised communication solutions. 

350 

 
 
 
 
 
 
The Netherlands 

Legislation 

According  to  the  law  of  20  December  2017  amending  the  Public  Procurement  Law  2012  to  include  Directive  2014/55/EU,  the implementation 
deadline for B2G eInvoicing for all public authorities in The Netherlands was 18 April 2019. 

The  Dutch  government  had  already  implemented  part  of  the  Directive  2010/45/EU  in  national  law  in  2012  (Implementation  of  the  Billing  rules 
Directive  of  15  March  2012335),  simplifying  rules  in  the  field  of  billing  regarding  the  levying  of  VAT  and  harmonising  the  requirements  for  the 
invoicing and electronic invoicing (eInvoicing). 

Mandatory for 

•  Receiving and processing:  

o  Submitting, receiving, and processing: Central government agencies, since January 2017. 
o  Receiving and processing: local government and all other contracting authorities since 18 April 2019. 

•  Sending: suppliers to the Dutch central Government  

Platform 

Multiple platforms are available:  

•  Management of the Dutch substandard NLCIUS: STPE 
•  National Forum on eProcurement policy: NMBF 
•  Management Peppol BIS standards and Peppol infrastructure: Netherlands Peppol authority (NPa) 

Standard(s) 

National Standard in use (if any) 

EN 16931 compliant standard 

The European standard on eInvoicing is fully implemented:  

•  UBL-OHNL (national UBL) 
•  SI-UBL is the National implementation of the NLCIUS (Dutch CIUS) 
•  SETU (HR – XML) 

Peppol BIS 3.0 is a subset of the European Standard EN 16931 for 
use  in  Europe.  Country-specific  rules,  based  on  NLCIUS,  are 
planned to be added to Peppol BIS 3.0 in 2021. 

335 https://www.eerstekamer.nl/behandeling/20120322/publicatie_wet_2/document3/f=/viy0gs2a6rhh.pdf  

351 

 
 
 
 
 
Monitoring 

Strategy 

At  the  moment,  there  is  only  a  monitor  on  registrations,  not  on documents  exchanged. This  will  change under  the  new  Peppol  contracts,  although 
Open Peppol needs to put in place a process to be able to receive and process the monitoring data they are going to receive from the Service Providers. 

In 2020, The Netherlands Peppol Authority (NPa) published its roadmap which is a multi-year programme describing the ambitions of the NPa for the 
coming years. 

There are three focus points of the NPa, defined as tracks in this roadmap: 

• 
• 

• 

improving the Peppol framework: ensure the correctly executed and applied Peppol framework on a national level. 
expanding post-award domain: conduct an analysis of the existing Peppol BIS standard, and possibly country specific additions, and align 
these developments with the service providers, stakeholders and OpenPeppol. 
communication and marketing: increase the awareness and the use of Peppol. 

National eInvoicing strategy in the medium (2023-2024) and long term (2025-2030) 
Focus  upon  the  use  of  open  standards  and  Peppol  as  the  main  open  infrastructure  for  B2G  and  G2B.  Because  of  the  Open  characteristic  of  the 
network, the Dutch authorities expect it to connect other open networks that use open standards. 

Strategy for ensuring cross-border eInvoicing interoperability 
Use of Peppol.  

Structured 
uptake 

eInvoicing 

The following table shows the uptake for data for eInvoices received by the central government and the percentage compared to the  total number of 
invoices. 

Number  of  B2G  eInvoices  from  national 
suppliers  

2019: 1 176 044 (59%) 

2020: 1 290 275 (66%) 

2021: 1 646 106 (77%) 

352 

 
 
 
 
 
Table 94 Structured eInvoicing uptake in The Netherlands 

The following table refers to the percentage of enterprises with more than 10 employees sending eInvoices suitable for automatic processing. 

Percentage 
sending eInvoices 

of 

enterprises 

The data336 from Eurostat does not distinguish between B2G or B2B transactions 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

10.9% 

15.3% 

18.8% 

19% 

21.9% 

25.4% 

Table 95 sending eInvoices suitable for automatic processing in The Netherlands 

Implementation of EN 16931 
compliant eInvoices 

Approach  

All government organisations (such as Ministries, municipalities, provinces, and non-departmental public bodies) are obliged to be able to receive and 
process eInvoicing. 

eInvoices can be submitted to the centralised government in the following ways: 

• 

• 

• 

via  the  secure  Peppol  network.  Most  administration  software  that  Dutch  companies  use  is  suitable  for  sending  eInvoices  via  the  Peppol 
network. The Access Point of the national government automatically converts the Peppol invoice into an eInvoice in the government format. 
The invoice will then be sent via Digipoort to the relevant National Service. Peppol is the preferable channel for exchanging e-invoices, the 
other options are temporarily or meant as a back-up. 
via the Logius eInvoice portal. It is suitable for suppliers who send a limited number of invoices, have no objection to manual entry into a 
portal,  do  not  want  to  incur  extra  costs  for  sending  an  eInvoice,  and  who  do  not  have  the  (technical)  possibilities  for  an  extensive  ICT 
infrastructure. 
eInvoicing manually using the online portal of an ICT service provider. Suppliers can submit eInvoices for central government via solution 
providers that have established direct link with the central hub. Logius provides a list of solution providers on their website. eInvoicing via 
service  is  suitable  for  those  suppliers  who  are  sending  mid-volume  invoices,  have  a  fully  automated  eInvoicing  process  or  that  have  no 

336 https://ec.europa.eu/eurostat/cache/metadata/en/isoc_e_esms.htm  

353 

 
 
 
 
 
 
 
 
 
 
• 

possibility for direct connection to the central hub. 
via Digipoort, which is the ICT centre where message traffic for the government is handled. eInvoicing via a direct link with Digipoort is 
suitable for suppliers who send large volumes of invoices (approximately more than 50 per week), want to fully automate eInvoicing; want a 
direct connection with Digipoort; have an extensive automated ICT infrastructure, or the ability to set it up. 

•  No  electronic  signature  is  required  for  eInvoices  and  the  archiving  period  amounts  to  7  years,  with  the  exception  of  invoices  related  to 

Immovable Property whose archiving period is 10 years. 

Uptake of EN 16931 

According to the Dutch authorities, the Directive 2014/55/EU and the introduction of EN 16931 did not contribute to increasing the adoption of either 
B2G  or  B2B  eInvoicing  in  The  Netherlands.  However,  they  indicate  that  it  has  increased  legal  certainty  for  eInvoicing  requirements  and  reduced 
technical complexity, providing a clear legal basis and common specifications. 

Is Peppol / eDelivery used  

Percentage  of  eInvoices  EN  16931  compliant 
vs. total number of B2G eInvoices   

Yes,  Peppol  is  used  for  B2G,  with  some  exception  at  the  municipality  level,  the  standard  for 
exchanging  e-invoices  B2G.  As  a  spin-off  of  having  nationalised  The  Netherlands  Peppol 
authority  (Minister  of  the  Interior  is  the  PA)  there  is  an  increase  in  large  companies  and  their 
suppliers that have switched, try to switch or are in the process of switching to Peppol.  
Central government:  

2019: 100% 

2020: 100% 

2021: 100% 

Cost and Benefits 

Table 96 Uptake of EN 16931 in The Netherlands 

CEF Telecom eInvoicing funding  

•  Budget requested: 1 207 670 

Benefits at the national level 
According to the Ministry of the Interior and Kingdom Relations Central authorities have benefitted the most, while sub-central and service providers 

354 

 
 
 
 
government 

eInvoicing  services  offered  by 
the 
of 
charge) 
Call for evidence 

(free 

have not benefitted. The mandate and the process running up to this mandate made it a new reality to formulate and invest in eInvoicing.  

N/A 

Feedback from FedEx (Netherlands) 

The EN16931 is not able to combine elements, such as import VAT and duties paid for a customer, with elements of a different VAT treatment on one 
invoice. If implemented for mandatory B2B eInvoicing, it would increase the administrative burden and require more invoices/documents to be issued 
and tracked. An earlier proposal included a change request to amend the standard to combine out of scope elements and elements with a different VAT 
treatment on the same eInvoice, but it was rejected. The respondent is in favour of automation and digitalisation of invoicing, but not if it leads to 
disruption or negative commercial impact and asks to consider implementing the change request. 

Feedback from an EU Citizen 

It is suggested to include the following topics as a part of standardisation discussion: other information/document exchanges, three/four-way match, 
business budget cycles, targeted stakeholder involvement, etc. A broader approach could further help adoption and reaping of benefits. 

Feedback from Invest BV 

In  The  Netherlands,  the  EU  rules  on  eInvoicing  are  minimally  implemented.  The  central  government  has  made  e-invoicing  mandatory  for  new 
agreements, but local authorities have not. Companies have the right to send eInvoices based on EU rules but are not informed about this. Many local 
authorities  still  invest  in  OCR  solutions  and  receive  XML  invoices  by  email.  Adoption  depends  on  clear  government  communication.  The  Dutch 
Peppol  authority  has  been  established,  giving  confidence  in  the  government's  ambitions,  and  ensuring  greater  reliability  of  Peppol's  active  service 
providers.  However,  the  government  often  leaves  the  used  channel  free,  resulting  in  most  exchange  by  email.  The  adoption  of  e-invoicing  in  The 
Netherlands  would  accelerate  if  the  government  clearly  communicated  one  preferred  channel,  stopped  investing  in  OCR  solutions,  and  set  a  good 
example by sending eInvoices. The EU regulations have been important for the development of the EN, which could now be better aligned with global 
developments within Peppol. 

Key findings 

According  to  the  Ministry  of  the  Interior  and  Kingdom  Relations,  the  impact  of  the  Directive  and  the  European  eInvoicing  standard  has  not 
contributed significantly to the increase in adoption B2G.  

According to the Ministry, simply mandating is more a  business model for companies to be  able to set prices to their advantage. Instead, a policy 

355 

 
 
 
should be made regarding the use of open networks. It will be decisive for a cost-effective adoption. In this way, larger companies using existing ERP 
solutions and document exchanges systems will be capable of relatively easy (through a Service  Provider/Access Point) connect to open networks. 
This will make a positive business case for business partners that have intensive relations with a multinational (Supermarkets chains for example) and 
because of the 'connect once, connect to all' principle, it will be also possible to reach any other receiver on the Open Networks. 

Although most government entities have been investing in an e-invoicing solution, it is mostly dormant. 

According  to  the  Dutch  authorities,  only  the  government  entities  that  have  mandated  eInvoicing,  adopted  Peppol  as  their  Open  infrastructure  and 
invested in onboarding of their suppliers have been successful in the Directive’s adoption. Usually, those were the entities that had larger circulation of 
invoices tend to better perceive the advantages of eInvoicing and switch faster.  

The Dutch Government perceives several measures that might increase eInvoicing adoption:  

•  Add valuable functionalities such as BLR/MLR (message responses). 
•  Make a positive business case for software solutions to build in a connection with an open network, using open standards. 
•  Mandate  closed  networks  to  open  up  in  order  to  stimulate  unrestricted  exchange  of  procurement  documents  between  public  and  private 

sectors. 

•  Mandating eInvoicing top down. 

In the Call for Evidence, FedEx states that the standard needs to include features required for cross-border transport systems.  

An  EU  citizen  highlights  a  document  developed  by  the  MSFeI  which  includes  topics  like  other  information/document  exchanges,  three/four-way 
match, business budget cycles, targeted stakeholder involvement, etc. A broader approach could further help adoption and reaping of benefits. 

A  Dutch  company  states  that  the  EU  rules  on  e-invoicing  are  minimally  implemented  and  the  adoption  of  e-invoicing  in  The  Netherlands  would 
accelerate if the government would stop investing in solutions such as OCR and set a good example by sending e-invoices. 

Most effective measures that could further increase eInvoicing adoption at EU and national level  

The Dutch authorities perceive that the most effective measure would be a policy regarding the use of open networks. The Netherlands considers that 
such an action will be decisive for eInvoicing adoption itself and for its cost-effectiveness.  

The Government finds that the measure will make larger companies use existing ERP solutions and document exchanges systems being capable to 

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easily to open networks through a service provider/access Point.  

Moreover,  the  Dutch  authorities  assume  that  this  will  make  a  positive  business  case  for  business  partners  that  have  intensive  relations  with 
multinationals (i.e. supermarket chains) and because of the 'connect once, connect to all' principle, it will be also possible to reach any other receiver 
on the Open Networks. 

The authorities in The Netherlands find that simple mandating will encourage companies to set prices to their advantage. 

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