Final report of the European Commission Expert Group on E-Invoicing

In November, 2009, The European Commision Expert Group on e-Invoicing presented in its final report a set of recommendations for an European Electronic Invoicing Framework, supporting the uptake of cross-border interoperable e-Invoicing solutions, with a particular focus for uptake among SMEs. One member of the Expert Group, Gianfranco Tabasso, did not vote in favor of the final report

The report was open to consultation until 26 February 2010. A total of 51 % of the replies agreed with the report’s main messages, recommendations and conclusions; 23 % of the replies disagreed and 26 % have no opinion.

Respondents reconfirmed that VAT is the main legal barrier to the uptake of electronic invoicing. However, stakeholders’ views varied as to the direction in which the existing legal framework should be changed in order to facilitate the uptake of electronic invoicing. With regard to the recommendations of the Expert Group on how to resolve these regulatory aspects, stakeholders’ views differ as to the appropriateness of the Code of Practice and the 11 core principles. Overall responses can be divided into three categories:

  • A first large group of respondents fully supports the proposal for a Code of Practice and the concept of equal treatment between paper and electronic invoices from a VAT perspective. These respondents take the view that enterprises should have a free choice on how they exchange electronic invoices.
  • A second group of stakeholders consider that the Code of Practice is a good basis which should be further elaborated and clarified, offering more guidance to enterprises and tax authorities. Some respondents consider that there should be a clear reference made to technology options such as e-Signatures and EDI. One respondent considered that improvements should be made regarding what should be guaranteed (Authenticity and Integrity). Another respondent pointed out that the improvement of the Code of Practice should be made in close collaboration with Member State Tax authorities to ensure legal certainty in the application of the rules.
  • A third and smaller group of respondents, consisting of a specific segment of the supply side of e-invoicing service providers, opposes the proposed Code of Practice which, in its view, could complicate matters and therefore further hinder the uptake of e-invoicing. This group of respondents considers that a limited set of clearly defined technological tools such as e-Signatures and EDI, in which this stakeholder group is often specialised, are the best way forward to improve standardisation and harmonisation within the EU and it opposes the concept of free choice for enterprises and internal business controls.

The majority of the respondents confirmed that VAT is the main regulatory issue that has to be resolved in order to ensure the widespread adoption of electronic invoicing, particularly among SMEs. Some respondents pointed to other factors such as harmonising archiving requirements, accounting rules, e-Signatures (trusted lists or mutual recognition), customs laws and implementation of the (VAT) Directive in the Member States.

May, 10 th, 2010, Brussels, Belgium


Source: European Commission,,


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