The mid-term report of the Expert Group on e-invoicing

July 15, 2009  |  Adoption, Publications

Most of the respondents welcomed the report and endorsed the vision of proposing a framework which facilitates the provision of integrated e-invoicing solutions at EU level. Generally, respondents agreed with the work priorities of the Expert Group, the barriers which had been identified in the current e-invoicing environment, and also with the initial recommendations as to how these barriers could be removed. Several respondents said that they were now looking forward to a more detailed final report and proposal for an EEI framework.

Practically all responding stakeholders emphasised the importance of harmonised legal and regulatory requirements for electronic invoicing across the EU, in particular concerning VAT legislation. Opinions diverged however on the question how prescriptive such requirements should be. While the principle of equal treatment between electronic and paper invoices was explicitly endorsed by 7 of 13 respondents, others shared their concern that this principle without further specification would lead to differing interpretations across Member States and thereby add to fragmentation. These latter respondents highlighted the proven value of advanced electronic signatures in that
context.

Beyond the VAT aspect, some respondents specifically called for more clarity and harmonisation of archiving requirements, in particular relating to accounting legislation. Conversion of electronic invoicing documents was another point for which legal clarity should be encouraged. Two respondents supported the reference of the midterm report to the CEN/Fiscalis guidelines.

Five of 13 respondents stressed the necessity of a common and robust semantic standard for e-invoices. It was strongly recommended that the major international standard bodies should agree on a converging model. It was highlighted that especially from an SME perspective the need for manual conversions between different semantic standards should be avoided. In this context, the vision of a ‘core’ e-invoice as suggested in the midterm report was endorsed by one respondent.

In terms of infrastructure and networks, respondents endorsed the need for interoperability between different models, avoiding the emergence of ‘silo’ solutions. One response criticised the focus on 3- and 4-corner network models in the midterm report and called for inclusion of peer-to-peer solutions, especially from an SME point of view.

Several feedbacks highlighted that an EEI framework would need to be ‘SME friendly’ in terms of implied investments and ease-of-use. It was pointed out that the current e-invoicing landscape from an SME perspective was still very fragmented preventing the mass adoption of integrated e-invoicing solutions on a broader scale.

Two reactions highlighted the link between invoices and payments and called for ensuring that the EEI framework should be in line with existing payment legislation and were an integral part of a broader e-procurement process. In that context, it was highlighted that strong cooperation should be ensured with other EU e-business initiatives, such as PEPPOL and CEN BII.

Feedback on comments received on the mid-term report of the Expert-Group on e-invoicing


Mid Term Report of the European Commission Expert Group on e-Invoicing

Here some other comments:
- From BDC EDV Consulting - Austria
- Mr Jean-Yves Muylle, European Commission
- Jan Vermeulen
- Henk Wildeboer and Gerhard Heumer
- European Banking Federation
- Osservatorio 2009 - Collection of the opinions
- Mikael Svensson
- Iris Vissers
- Swedish Bankers´ Association
- Hans Ekman and Peter Björebo
- Pavol Matyasovszky
- OFS Portal, LLC
- American Petroleum Institute


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