EC’s latest roadmap on e-invoicing in public procurement

Hold up, hold up, hold up! Let’s take a minute here to realise what is going to happen in less than two months. 2010/45/EU will, among others, revise and simplify the rules on e-invoicing in the EU with a view to promote its usage. And as we all know, the EU has set out several more initiatives: “A Digital Agenda for Europe,” “Reaping the benefits of electronic invoicing for Europe,” and “A strategy for e-procurement”. We don’t know about you, but even we sometimes lose sight of the overall picture. That’s why we love the EC’s latest roadmap on e-invoicing in public procurement.

Question time

One of the first things that the EC makes clear in this roadmap is that it does not prejudge the final decision of the Commission on whether this initiative will be pursued or on its final content or structure. That sort of is too bad, but still, let’s take a look of some of the questions that are addressed:

  • What is the political context of the initiative?
  • How does it relate to past and possible future initiatives, and to other EU policies?
  • What are the main problems which this initiative will address?
  • Who will be affected by it?
  • Is EU action justified on grounds of subsidiarity? Why can Member States not achieve the objectives of the proposed action sufficiently by themselves? Can the EU achieve the objectives better?
  • What are the main policy objectives?
  • What are the policy options (including exemptions/adapted regimes e.g. for SMEs) being considered?
  • Could any or all of the options have significant impacts on (i) simplification, (ii) administrative burden and (iii) on relations with other countries, (iv) implementation arrangements? And (v) could any be difficult to transpose for certain Member States?
  • Which stakeholders & experts have been or will be consulted, how, and at what stage?

Four policy options

You’ll have to read the entire roadmap for yourself if you want an answer to all the above questions (and more), but we can’t deny you the answer to the question of what policy options the EC is considering. There are four options in total; no action, a ‘soft law’ approach, a legislative act or a mixed approach based on the second and the third option. The EC roadmap states that the third approach currently appears to be the most effective, but also the most far-reaching with resistance on the part of the Member States and service providers.

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