The EU E-invoicing Forum reports are final. And these are the 32! recommendations

Some two years ago, the European Multi Stakeholder Forum on Electronic Invoicing was set up by the European Commission. The goals of the forum were to exchange experiences and best practices, to monitor the uptake of e-invoicing in all Member States, and to identify measures to facilitate the mass adoption of e-invoicing at both national, cross border and EU level.

During the forum’s last meeting the findings and reports from its working groups were made final and published. To make things easy on you, we’ve collected the 32 recommendations and listed them underneath.

Activity 1 “Monitoring the e-invoicing uptake in Member States and at EU level”

No final report was published. There is an interim report though.

Activity 2: “Exchange of experiences and good practices” : public procurement

The final report can be downloaded here. The activity group recommends Guiding Principles for an implementation architecture for electronic invoicing channels:

  • Think in terms of an open architectural framework to allow support for a range of features and functionality. Incorporate modularity to allow progressive development.
  • Capitalize on learning and adaptation from the private sector and other (country) public sector experience on a systematic basis
  • Take steps to minimize project implementation and financial risk and install relevant checks, balances and oversight and observing the usual good practices for open tendering and benchmarking.
  • Undertake a full appraisal of the value and benefits of the use of Shared Service Centres, which could be aligned with specific public sector activities and functional clusters.
  • Provide a reasonable choice of solutions for suppliers based on business benefits and take care regarding the privileging of particular solutions through a neutrality of approach and where possible maximizing the ruse of existing capabilities and tools.
  • Take steps to support ease of integration and onboarding for all players especially for SMEs and micro-enterprises
  • Ensure support for interoperability on a pan European and global basis. Supply solution and service providers with guidelines, tools and open source software to ease roll-out.

Activity 2: “Exchange of experiences and good practices” : SME’s

The European Commission Multi-Stakeholder forum Activity 2 sub-group offers the following recommendations to increase SME adoption of electronic invoicing:

  • The European Commission to mandate the use of electronic invoicing for European public sector administrations
  • Inclusion of different stakeholders within national e-invoicing Forums
  • National Forums to Promote e-Invoicing Education to Government
  • CEN Working group on the semantic data model to evaluate existing standards first
  • Service providers to adopt the EESPA model interoperability agreement, adopt OpenPEPPOL specifications and standards, or both
  • European Commission to further clarify how ‘business controls’ and ‘audit trail’ method of e-invoicing ensures tax compliance for emailed PDFs:
  • European Commission to investigate/promote the creation of e-invoicing certification programs

Activity 3: “Propose appropriate solutions for remaining cross-border barriers”

In summary  Activity 3 has concluded the following recommendations:

To Member States:

  • accounting and bookkeeping rules must be  adapted to the requirements of a digital economy in Europe.
  • provide appropriate solutions to be integrated into the new proposed Regulation on Protection of Personal Data in order not to restrict electronic invoicing.
  • use the explanatory notes provided by as guidance for the application of their national legislation in practice in order to ensure a uniform application of the legislation across the EU. This should be encouraged by national Fora and national associations.

To the European Commission:

  • Accounting and bookkeeping are to be addressed as key areas where administrative burdens for companies within the Union must  be further reduced in order to allow a simple and European wide acceptable process.
  • integrate electronic business processes like electronic invoicing into their initiatives on “Trusted Lists” and the revision of the Directive 1999/93.
  • continue to monitor VAT legislation and to continue monitoring the application of the VAT legislation across the EU.
  • set up and facilitate a process whereby experiences both as regards obstacles and best practices on the application of the 2013 e-invoicing rules across the EU can be identified with the aim to ensure a uniform application of the legislation across the EU.
  • simplify the access to legal information and to create a European wide network of national websites, supported by National Fora as wells as a “European Knowledge Base on Electronic Invoicing” in Europe (e.g. similar to the CEN e-invoicing Gateway)

To the Member States and the European Commission:

  • improve the transparency of bookkeeping rules in the EU Member States in order to reduce administrative burdens and to allow for a simple and European wide acceptable bookkeeping process.
  • define a common set of bookkeeping principles for electronic business transactions.
  • the protection of personal data must be guaranteed at any stage of electronic invoicing. If necessary there should be clarifications published as regards the processing of personal data in electronic invoicing processes.
  • make a clarification in the proposed Regulation on Data Protection as regards “business card information” in order to provide clear legal justification for processing basic work or business related personal data.
  • integrate the issue of interoperability of public eIDs into the on-going activities with a view to make public authentication system in the EU Member States accessible for all businesses.
  • issue guidelines for SMEs and micro-enterprises in order to provide concrete examples for large enterprises as well as for SMEs

To the European Commission and national e-invoicing Fora:

  • this information should be made easily accessible, e.g. on the relevant eInvoicing websites on the European level and the national eInvoice Fora level.

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

The recommendations of this activity group are intended to meet the needs of both the public and private sector on a neutral basis and addresses:

  • The recognition of an over-arching Interoperability Framework as defined in conceptual terms in the report.
  • The proposed development of a Semantic Data Model for the Core Section of an Electronic Invoice, to include definitions, the identification of existing building blocks and practical user guidance.
  • The identification of a methodology and implementation plan for the carrying forward of the development of the Core Section including the identification of an organizational approach to the work required. This third component will be completed by the Forum no later than the end of 2014.


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  1. There is a mistake: in the very last bullet the year is 2013 so the sentence should be:
    “This third component will be completed by the Forum no later than the end of 2013”

  2. Hello Andrea,

    Thank you for your comment. We checked the document and page 2 of the document clearly states ‘2014’. That is the area we ‘copied’ from.

    Perhaps this is fault in the document that needs to be addressed?

    Kind regards,

    The E-invoicing Platform team