Regulatory updates - Sweden

In this request, the above agencies emphasize the vital benefits of mandatory e-invoicing, referring to the latest developments in the EU regulatory landscape – the ViDA initiative proposals published on 8 December 2022.

There are no clear timelines yet for Sweden to impose the e-invoicing obligation. According to the proposal, it is stated that the investigation shall be done as soon as possible.

It is also worth mentioning that earlier in January, Finland became the first Member State to formally accommodate the ViDA initiative, submitting a formal request to the parliament to take action.

Headquartered in Gothenburg, Pagero strongly supports Sweden’s initiative and believes that mandatory e-invoicing adoption will help local businesses streamline their order-to-cash and purchase-to-pay processes while unlocking the full potential of accurate and reliable business data.

Pagero continues to monitor the developments in the country and will keep its stakeholders updated.

With the background against the VAT in the Digital Age initiative by the European Commission, the Swedish Tax Agency (Skatteverket) has initiated a study of how digitalizing VAT processes can bring benefits to both tax authorities and businesses; for example, reducing VAT fraud and minimizing the administrative burden for companies.

Current status

Skatteverket is currently reviewing strategies regarding quality assurance, reporting and its role in a countrywide digitalization. Generally driven by the need to stop the tax evasion gap, boosting digitalization is the most important driver to adopt an e-invoicing/e-reporting mechanism for Sweden.

During the spring of 2022, the Swedish Tax Agency aims to discuss further some options of adopting Digital Reporting Requirements (DRR) with relevant stakeholders. These include Periodic Transaction Control (PTC), i.e., VAT listings and SAF-T, Continuous Transaction Controls (CTC), such as real-time invoice reporting and mandatory e-invoicing.

Next steps

These are the key questions going forward:

• Digitalization is a priority - should the B2B sector be the starting point for designing VAT digital-enabled processes?
• Mandatory e-invoicing - should Skatteverket be the driving force behind e-invoicing requirements in the B2B sector and adopt the international Peppol standard?
• Transaction-based reporting - should Skatteverket work to switch to transaction-based reporting?

The cooperation between Skatteverket, businesses and other stakeholders would be vital for addressing the above questions for the necessary change towards digitalization in Sweden.

DIGG prescribes the regulations on the governmental ordering process and electronic information exchange standards with the support of section 3 of the ordinance (2003:770).

Since the new rules have taken effect, all authorities shall provide a supplier platform for the seller that does not have the e-invoice information exchange capability. For public entities with more than 50 employees, the platform shall also enable electronic information exchange for catalogues and orders.

Invoicing requirements for all authorities

• Invoices between authorities shall be issued and received electronically;
• In case of sending e-invoices to non-governmental recipients, their consent is required;
• Authorities issuing only a few customer invoices are allowed to use a supplier platform for e-invoice transmission;
• Simplified invoices are allowed in paper form; no conversion to electronic format is needed.

All public entities shall be able to send and receive an invoice in Peppol infrastructure.

Standards for authorities with more than 50 employees

When handling ordering and invoicing processes, an authority with an annual workforce of more than 50 shall have the capacity to use the following standards:

1. Peppol BIS Catalog Without Response 3
2. Peppol BIS Punch Out 3
3. Peppol BIS Ordering 3
4. Peppol BIS Order Agreement 3
5. Peppol BIS Despatch Advice 3
6. Peppol BIS Billing 3

In case the authority needs to strengthen its e-commerce and e-invoicing processes, it may adopt special processes, such as SFTI Item Availability Check and Coordinated goods distribution. In addition, the following standards may be adopted:

1. SFTI Scenario 6.1 Call-off against framework agreement Version 2.7-2.9
2. SFTI Scenario 6.3 Call-off against framework agreement with delivery notification Version 2.7-2.9
3. SFTI Full Text Invoice Version 2.3-2.4, (only in combination with other e-commerce messages within SFTI Scenario 6)
4. SFTI Svefaktura 1.0 (only in business relationships established before 1 March 2021)

Handling of orders is limited to purchases subject to VAT in accordance with Chapter 11 of the VAT Act.

Orders with simplified invoices or purchases made through personal expenses or paid for with a card where the authority is responsible for payment are not covered by the requirement to process orders for goods and services electronically.

Sweden’s public sector e-procurement initiative, SFTI, will stop recommending e-invoicing standards such as Svefaktura 1.0 and 2.0 as of 1 April 2021. According to e-invoice law 2018:1277, contracting authorities and units in Sweden must be able to accommodate e-invoices in Peppol BIS Billing version 3.0, which follows European standard EN 16931.

With Peppol in place as the mandatory infrastructure for public authorities in Sweden, Peppol BIS 3.0 overtook versions 1.0 and 2.0 as the prevailing format in May 2020.

Svefaktura 1.0 and 2.0 still used

While new agreements and purchases with the contracting authorities in Sweden must be made with the new standard of Peppol BIS 3.0, older standards such as Svefaktura 1.0 and 2.0 are not regulated between trading partners in the B2B environment. Svefaktura 1.0 is a commonly used standard between business partners as well as between service providers.

There is little expectancy that this will change radically in the foreseeable future. Rather, it is expected that newer standards will be implemented and progressively take over the old ones.

SFTI recommendations and deprecations

Starting 1 April 2021, the following standards will no longer be recommended by SFTI:

• Svefaktura 1.0;
• SFTI Fulltextfaktura 2.3 and 2.4;
• ObjectEnvelope: the special technical envelope created to enable packaging of external attachments in a separate XML file aside the Svefaktura 1.0 with object references between them will be replaced by SBDH;
• SFTI Transportprofil Bas/Utökad 2.0: communication protocol/specification layered on top of HTTP/S with SOAP-enveloping.

The following standards have already been deprecated by SFTI:

• Svefaktura BIS 5A 2.0: Peppol BIS 4A/5A 2.0 equivalent which has been deprecated for use within the Peppol network as well;
• Svekatalog 2.0: based on Peppol BIS Catalogue;
• Sveorder BIS 28A 1.0; both order and order response, i.e. Peppol BIS 28A 1.0;
• PEPPOL Punch Out 1.0;
• PEPPOL BIS 42A Order Agreement 1.0;
• Sveleveransavisering BIS 30A 1.0: despatch advice based on Peppol BIS 30A 1.0.

More information can be found on SFTI’s website.