The first deliverable of the cooperation between EESPA and OpenPEPPOL is a fact. They issued the joint position paper: “Requirement to receive electronic invoices in the ‘listed syntaxes’ under Directive 2014/55/EU”.

EESPA and OpenPEPPOL are very concerned by the provision in the Directive 2014/55/EU (the Directive) that all public sector contracting authorities (over 300,000 in Europe have been mentioned) will need to be able to receive electronic invoices expressed in any of a list of up to four syntaxes (technical languages) to be recommended by CEN TC 434 during the preparation of the standard for a European core invoice

EESPA and OpenPEPPOL expect the sheer scale and burden of imposing such a complex requirement on all public authorities is a massive challenge, many of which will be embracing e-invoicing for the first time as the Directive is implemented.

In essence the soon to be delivered European Norm (EN), with multiple syntaxes, format conversions and extensions, will be far from a single ‘operating’ solution at the invoice exchange level, and if all this jeopardises adoption of the standard, it would be a pity.

Therefore EESPA and OpenPEPPOL recommend:

• that CEN TC 434 and its affiliated National Standards Organisations give consideration to recommending a Plan A proposal in which contracting entities would only be required to support a maximum of two syntaxes on the receiving side. This should be based on a holistic impact analysis of multiple syntaxes and extensions and on consideration of the real effort required for format conversion.
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• that in the event of CEN TC 434 recommending a wider List of Syntaxes that the Commission takes forward an initiative to implement a Plan B, under which Member States are granted a derogation to allow contracting entities to specify to invoice senders one or more of the listed syntaxes in which they are prepared to receive and process electronic invoices.
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• to engage in the test scenario planning and test implementation and other efforts to make implementation of the new EN a success.

View the Joint Position Paper here. Download a PDF version here.