[UPDATE] Is Europe abandoning its single invoice standard strategy? Yes.

After publishing some impressions on the EU E-invoicing Multi Stakeholder Forum Kick-off [UPDATE2] we were able to get our hands on the minutes of the first meeting, called: “Minutes of The First Meeting of the European Multi-Stakeholder Forum on Electronic Invoicing.” And we received the minutes of the second meeting.

Going through the minutes, we noticed that the EU strategy is no longer heading towards a single invoice standard. In stead Europe is heading to a common data reference model. Allowing Member states to derive from it proprietary national standards…..


1. Vision of DG Enterprise and Industry

Daniel Calleja Crespo, Deputy Director General of the Enterprise and Industry DG presented the expectations of the European Commission. And this is what he said on the subject of standardisation:

  • Standardisation bodies must ensure that their standards respond to the needs of the business community and SMEs in particular.
  • There should be more flexibility to the recognition of standards developed outside the formal standardisation organisations, like CEN and UN/Cefact.
  • The co-existence of various standards should be addressed by further standard convergence OR by developing software applications which ensure compatibility without the need for user intervention.

2. Vision of DG Internal Market and Services

Mario Nava, Acting Director at the Internal Market and Services DG, gave a second keynote speech in which he focused on the potential benefits of e-invoicing for the Single Market. He off course focused on SEPA and e-procurement.

And he also stated: ”Cross-border e-invoicing still is a challenge. Legal and regulatory harmonisation/convergence between Member States is key and the Forum should identify the areas which represent obstacles in this respect.

That implies that standardisation is not envisioned as a key driver to achieve massive e-invoicing adoption.

3. EU Forum Working Program

What is going on here? Is Europe abandoning its single invoice standard strategy? It certainly feels like a major shift in the of thinking on standards versus the mass uptake of e-invoicing. Perhaps a successful mass uptake of e-invoicing, especially by SMEs, needs a different more hands-on approach.

Still, the working program of the EU forum contains the activity: “Migration towards a single e-invoice standard data model”.

However this group will not carry out standardisation activities but deliver policy/operational advice. In stead:

The group will assess the outstanding standardisation gaps and synergies among ongoing standardisation activities at European and international level. It will recommend specific actions that will attempt to resolve the identified problems.”

4. [UPDATE] Minutes of the 2nd EU E-invoicing Forum Meeting

The minutes of the second EU E-invoicing Forum contained the condensed version of this change in approach. The title of Activity 4 of the EU E-invoicing Forum still mentions that aim is to migrate to a single e-invoice data mode. However the explanatory notes mention a convergence towards a common semantic reference data model:

Activity 4: Migration towards a single e-invoice standard data model


The goal of the group is to provide some conclusions and recommendations on the following topics:

• Analysis of the convergence towards a common semantic reference data model (as suggested in COM(2010)712 Final) by 2020 (in line with the time frame set in the Communication on e-invoicing of December 2010), and documenting ways to contribute to the objective.

In fact both Italy and the Netherlands made clear that they believe that their national data model is different from each other but derives from the same data model.

Analysis of the convergence towards a common semantic reference data model (as

suggested in COM(2010)712 Final) by 2020 (in line with the time frame set in the

Communication on e-invoicing of December 2010), and documenting ways to

contribute to the objective.

Is Europe abandoning its single invoice standard strategy?

YES. From looking at it, it becomes more and more clear that standards are no longer envisioned as a ‘need to have’ but rather ‘a nice to have’.

Therefore the other activities seem to be that much more a ‘need to have’ for mass uptake of e-invoicing (by SME’s):

  • Activity 3: “Propose appropriate solutions for remaining cross-border barriers”
  • Activity 2: “Exchange of experiences and good practices”
  • Activity 1: “Monitoring the e-invoicing uptake in Member States and at EU level”

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  1. Roberto Cisternino

    There is still some confusion around about e-business document standards and their implementations.
    The main shift of EDI has been to move the interoperability problems from the syntax to the semantics. ISO 15000-5 CCTS (Core Components) is the specification that provides such innovation. It means that different bodies like CEFACT, UBL, GS1, … are allowed to implement and enrich the UN/CCL library so that their documents will contain several common core components and there will be semantic interoperability.
    The syntax of an Invoice can be different (a different assembly and number of components) but most of bricks will be semantically the same thanks to CCTS annotations on their XML schemas.
    Due to above reasons UBL-Invoice-2.0 and CII v.2 are both containing at least the same set of core components required by Europe.
    The convergence has been made mainly on these semantic components and the UN/CCL contains an harmonized set of components submitted by CEFACT, UBL, GS1, ….

    Europe is an implementation case this is why their efforts has been on building implementation profiles based on exising standards.
    - PEPPOL is based on an abstract implementation profile (CEN/BII) that can be easely mapped on any CCTS based vocabulary (UBL 2.0 has been successfully used).
    - The MUG effort is based on same CEN/BII concepts… an abstract implementation guide that can be mapped on any CCTS based business vocabulary.

    Non-CCTS based languages are far to be semantically compatible to BII or MUG.

    The market can safely choose to start today using PEPPOL BIS specifications and experimenting the MUG as well with any CCTS based vocabulary.

    If you are looking for a consistent and mature set of e-business messages, UBL is the best around. If we want a top e-invoice the upcoming UBL 2.1 is an impressive effort and it is promising many features for use within the whole Financial Supply Chain (see full Trade Financing support, external remittance, … etc).

    The MUG offers a mapping to CII v.2 that can be implemented as well, but it is not complemented by a consistent set of business messages (the source of the invoice…, quotation,catalogue,order,…) and there is not a message for advanced payment remittance advices (to be used externally to clearing systems but in a combined way with ISO20022 messages)

    The ICT market has enough material to provide the right instruments to facilitate SMEs on implementing new Standards.

  2. The author calls “standard” what in fact should be called “content standard” and this creates a lot of confusion.
    “Migration towards a single e-invoice standard data model” does not means (and never meant) “Migration towards a single e-invoice standard content”.
    This was one of the final recommendations of the expert group on e-invoicing (by all the experts minus one) as you can read in the 4th bullet of section 3 in the Communication by the Commission: “The adoption by all actors within both the private and public sector of a common invoice content standard and data model – the UN/CEFACT Cross-Industry Invoice (CII) v.2.”
    Again in the Communication, the introduction of 5.1.4 seems to me very is very clearly reflecting what is the approach of MSF: “One of the key challenges for e-invoicing deployment is to define a single and clear semantic data model describing the information elements required for e-invoices. One common data model will facilitate semantic interoperability and ensure technology neutrality.”