OpenPEPPOL’s opinion on the concept EU Directive on E-invoicing in public procurement

OpenPEPPOL has published their opinion on the proposal for a Directive on electronic invoicing in public procurement. In essence OpenPEPPOL welcomes the European Commission’s proposal for a Directive on electronic invoicing in public procurement1, and the focus on shifting towards a paperless public administration, particularly its crossborder dimension.

And OpenPEPPOL strongly supports the objective of the Directive to remove market access barriers in crossborder public procurement, in order to improve the internal market.

However, OpenPEPPOL also have suggestions and recommendations regarding this directive. Underneath is a summary from their 12 page opinion paper.

The Directive should acknowledge, in its preamble, the efforts made by the EC co-funded Large Scale Pilot PEPPOL (Pan-European Public Procurement Online) to facilitate cross border e-invoicing in public procurement.
In particular, the results achieved through use of the PEPPOL Business Interoperability Specifications (BIS), its network ensuring secure and reliable transmission of einvoices and other business documents between trading partners, as well as the legal framework, established to facilitate seamless many-to-many interoperability, should be recognised as the platform for the further development of end-to-end e-procurement in the public sector in Europe.
Considering the specific scope of the draft Directive which focuses only on electronic invoices in public procurement and in the light of the Commission’s objective to achieve end-to-end electronic procurement to modernise public administrations4, it is important to note that the CEN WS BII is the only relevant standardisation initiative in Europe that supports not only e-Invoicing but also thecomplete end-to-end procurement cycle.
OpenPEPPOL recommends that the results from the CEN WS BII, and in particular that the CEN Workshop Agreement (CWA) 16562, is used as basis for the establishment of the European standard for the semantic data model.
OpenPEPPOL recommends limiting the number of syntaxes that contracting authorities in Europe must be able to receive and process based on the European standard for the semantic data model.
This in order to reduce the cost and complexity of conversion from one syntax to another, that are significant even if the syntaxes are based on a common semantic data model.
OpenPEPPOL recommends that the Commission shall be empowered to adopt delegated acts. As within the proposed public procurement directive the possibility to adopt delegated acts should be given to ensure the interoperability of technical formats as well as of process and messaging standards, especially in a cross-border context to establish the mandatory use of such specific
technical standards.
OpenPEPPOL recommends as a minimum that Contracting Authorities are given the right to mandate the use of e-Invoicing from their suppliers. Ideally, it should be mandatory for all Economic Operators to send invoices to their public sector customers electronically as has been done in Denmark.
OpenPEPPOL recognises that the time required to develop and transpose the common semantic data model into a European standard will be between 2 to 3 years. For this reason, the European Commission should publish a clear and concise roadmap by the end of 2013, providing guidance to the market in the interim period. OpenPEPPOL also recommends that the Commission consider
reducing the transposition period from 48 to a maximum of 24 months.

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