Regulatory updates - Singapore

On 14 April 2024, the Inland Revenue Authority of Singapore (IRAS) and Infocomm Media Development Authority (IMDA, also Singapore Peppol Authority) announced plans for a phased adoption of B2B e-invoices through InvoiceNow (“GST InvoiceNow Requirement”) at the InvoiceNow Industry Day event.

GST InvoiceNow Requirement

InvoiceNow is a nationwide e-invoicing network established based on the Peppol network introduced by IMDA in 2019, and it has become the default format for submitting B2G invoices.

GST InvoiceNow Requirement will leverage the Peppol 5-corner model (Peppol CTC) to enhance the current 4-corner model to connect to the tax authorities. Taxpayers will be able to transmit invoice data to IRAS through an accredited service provider. When businesses exchange e-invoices in PINT SG format with their trading parties via the InvoiceNow network, an invoice copy will be delivered to IRAS.  

IMDA will publish the list of InvoiceNow solutions that connect to IRAS by May 2025.

Implementation Timelines

The GST InvoiceNow Requirement will be adopted as follows:

• 1 May 2025: Soft launch. GST-registered businesses can voluntarily adopt GST InvoiceNow Requirement;
• 1 November 2025: Newly incorporated companies[1]that voluntarily register for GST;
• 1 April 2026: All new voluntary GST-registered, regardless of incorporation date.

Scope of the GST InvoiceNow Requirement

According to the announcement, GST taxpayers will be required to use InvoiceNow solutions to transmit invoice data to IRAS for tax administration, including the following transactions:

• Standard-rated supplies, excluding reverse charge supplies;
• Zero-rated supplies;
• Standard-rated purchases on which input tax claims are made or will be made, excluding reverse charge purchases;
• Point-of-sales supplies: businesses can choose to submit aggregated data to IRAS.

The businesses below are exempted from the GST InvoiceNow Requirement:

• Overseas entities (including overseas vendors that are registered under the Overseas Vendor Registration regime);
• Businesses registered under the Reverse Charge Regime.

GST InvoiceNow Requirement aligns with global trends, with governments worldwide actively promoting the implementation of e-invoicing for tax administration. IMDA and IRAS are reviewing the market demands for further support and measures to ease tax compliance and will provide more details later.

Businesses can already issue and receive e-invoices via the Peppol network in Singapore. Pagero has been IMDA accredited as both an Access Point Provider and Peppol-Ready Solution Provider to provide e-invoice services.

[1] These are companies that are incorporated within 6 months from the time they submit their application for GST registration.

Pagero Online has renewed its Peppol-Ready accreditation, meeting the below mandatory criteria:

• Register the business user on the Singapore Service Metadata Publisher (SMP);
• Send e-invoices on the Peppol network;
• Receive e-invoices on the Peppol network and display them correctly;
• Capture and maintain the Peppol IDs of your users’ business partners (i.e. customers and/or suppliers).

In addition to meeting mandatory criteria, Pagero's solution has also fulfilled preferred criteria that will become mandatory as of 1 April 2024:

• Receiving order on the InvoiceNow network;
• Converting an incoming order from the InvoiceNow network into an invoice;
• Sending invoice response on the InvoiceNow network;
• Receiving invoice response on the InvoiceNow network.

Pagero's Peppol-ready status, valid from 28 November 2023 to 28 November 2024, is listed on IMDA’s website as a Peppol-Ready Solution Provider.

The Peppol PINT-SG BIS Billing general data model's first version introduces features distinct from SG BIS Billing 3.0.

What are the new features?

The following features have been introduced:

• cbc:IssueTime - An optional element designed to capture the issued time;
• cac:InvoiceLine / cac:OrderLineReference / cac:OrderReference / cbc:ID - Enables referencing multiple PO numbers to the item line.

Implementation schedule of the PINT and PINT-SG upgrade

• July 2023: Phase In
• February 2024: Solution Uplift
• January 2025: Switch Over
• March to July 2025: Phase Out

Together with the implementation timelines, the following detailed schedule is provided.

2024 - PINT preferred

• Between February and October: all AP are mandated to upgrade to support PINT (two-way);
• Between February and December: all SPs and Companies will be updated to support PINT (two-way);
• PINT receiving capability update begins as each connection is upgraded with bulk upgrades for solution providers;
• Domestic PINT transaction can optionally begin if agreed between parties.

2025 - PINT mandatory

• Between January and March 2025: All parties should begin sending PINT as default, alternatively BIS 3.0 format;
• From March 2025, SG BIS 3.0 will begin to be removed from the network.

The Singaporean Peppol Authority IMDA has plans to migrate from the current Peppol BIS specifications to the PINT SG specifications. This will be accomplished in a phased-out approach, with the technical specifications planned to be released by the end of February 2024.

The key milestones of the migration plans are as follows:

Uplift Phase (1 March 2024 to 31 December 2024)

• C2/C3 must be ready to send and receive PINT SG with wildcard capabilities by 30 September 2024;
• All Peppol Authority Specific Requirements (PRSPs) to support PINT SG and PINT (C1/C4) by 3 December 2024;
• Registration of SG BIS 3.0 receiving capability continues to be mandatory during this period;
• All businesses to support PINT-SG and PINT receiving capabilities by 31 Dec 24;
• All C1 will use SG BIS 3.0, unless pre-agreed between the sending and receiving parties.

Switch Over Phase (1 January 2025 to 31 March 2025)

• Registration for SG BIS 3.0 will be removed from the SGNIC-SMP;
• Registration of PINT-SG receiving capability will be mandatory.

Phase Out (1 April 25 to 30 May 2025)

• All SG BIS 3.0 participant receiving capabilities will be removed from the SGNIC-SMP
• C1/C4 and PRSPs to remove systems' handling of SG BIS 3.0 (encouraged but optional)

It is worth mentioning that Peppol PINT is not a specification but rather a new approach to designing specifications. The core idea of the PINT design is to enable interoperability between related specifications out of the box, while affording flexibility to support the unique requirements of a jurisdiction or industry.

Stay tuned with Pagero, as we closely monitor the regulatory developments in Singapore.

The Infocomm Media Development Authority (IMDA) is the Peppol Authority in Singapore. As a Peppol Authority, they control the registration of Peppol IDs for businesses and organizations. Furthermore, IMDA maintains the centralized Service Metadata Publisher (SMP) in which Peppol IDs are published.

It is mandatory for Peppol Service Providers who wish to provide Access Point services in Singapore to comply with the Peppol Authority Specific Requirements (PASR).

What has changed in the new PASR version?

On 28 September 2023, IMDA submitted a revised version of the PASR to the Managing Committee for approval. The review period finishes on 20 October 2023, and once approved, the new PASR will be included in the Peppol Interoperability Framework.

Section 6, “Use of local interoperability specifications”, was the only section that underwent amendments and is now subject to review.

The existing formulation sounds as follows:

Service Providers shall comply with the Singapore Peppol BIS specifications at www.peppolguide.sg, which apply when offering services to End Users residing in Singapore.

The statement is proposed to be replaced with the following text:

The business documents below are mandatory to be supported by Service Providers accredited by the Singapore Peppol Authority:

1. SG Peppol BIS Billing 3.0 Invoice
2. SG Peppol BIS Billing 3.0 Credit Note
3. Peppol BIS Invoice Response 3
4. Peppol BIS Order Only 3

The business documents below are mandatory to be registered by Service Providers for End Users who are receivers residing in Singapore:

1. SG Peppol BIS Billing 3.0 Invoice

Specifications and guidance for SG business documents are on www.peppolguide.sg.

Expressing opinion on other PASR aspects

For comments on other parts of the PASR of Singapore, a Request for Comments (RFC) must be submitted by the Peppol Authorities and Service Providers through the service desk.

Parties with comments must use the comment template and send it to [email protected]. All comments submitted in the review period will be processed and made available to the Peppol Authority of Singapore and the Managing Committee.

For a more seamless and convenient taxpaying experience, Inland Revenue Authority of Singapore (IRAS) together the Infocomm Media Development Authority (IMDA) and other relevant stakeholders have concluded to implement Peppol CTC framework for a more efficient provision of GST data to IRAS.

In Singapore, Peppol is known under the name InvoiceNow. As the first step, it is planned to become the default e-invoice submission channel for all Government vendors within the next few years, to increase the usage and its network effect. In parallel, IRAS will continue working with IMDA, the Accountant-General's Department and businesses to increase the adoption of InvoiceNow for GST administration.

The Singaporean government has now announced plans to establish InvoiceNow as the sole means of issuing electronic invoices with all vendors providing goods and services to public sector recipients. InvoiceNow would effectively replace the vendors@gov portal over the next few years, further requiring solution providers to equip capabilities for issuing invoices via the new obligatory method.

The Accountant-General’s Department has already made clear that InvoiceNow is the preferred channel for e-invoice submission, but looking to the future, acknowledges that there are aspects to be introduced to optimize its use further.

The recognition of the importance of adapting invoice responses and purchase orders is also addressed by the initiative to promote InvoiceNow. For solution providers, it is recommended that the minimum capabilities be enabled:

*M – Mandatory, R – Recommended

While the timelines for complete conversion to InvoiceNow are not finalized, IMDA and AGD strongly recommend that entities acknowledge the upcoming changes' notifications. Stay tuned with Pagero as we monitor the upcoming timelines.

With the introduction of the new document types, such as Electronic Orders and Invoice Response, to be used via Peppol, Singapore enhances document flow and procurement efficiencies.

Learn how the new developments will benefit businesses in the latest news.

The Infocomm Media Development Authority of Singapore (IMDA) issued a statement announcing that they are cooperating with the government agencies such as the Housing and Development Board (HDB), Jurong Group (JTC), and Maritime and Port Authority (MPA) to allow them to issue electronic invoices directly to corporate customers through InvoiceNow. The purpose of e-invoicing adoption by the government is to promote digital transformation and assist Singaporean companies in seizing opportunities in the digital economy.

According to IMDA, HDB, JTC, and MPA make up around 70% of the outbound invoices from the public sector in Singapore, meaning private businesses can now leverage e-invoicing not only by their outbound transaction with the government but also by their inbound flows.

Since January 2020, contracting authorities behind the state-owned Vendors@Gov platform have been able to receive Peppol e-invoices from their suppliers.

Businesses that still have not obtained the ability to receive e-invoices via the Peppol Network should follow the trend to automate and standardise the invoicing flows.

Pagero has been a Peppol accredited provider since the IMDA became a Peppol authority in 2018. In recent years, e-invoicing in Singapore has grown dramatically, with over 40 000 Singaporean businesses now connected to the Peppol Network for the electronic invoice exchange.

The announcement by Dr Yaacob Ibrahim, Minister for Communications and Information (MCI) revealed that e-invoicing is a crucial step forward for Singapore’s businesses. Among other things, he said that “Without an invoice, businesses do not get paid. But invoicing can be very tedious and manual, with many inherent errors. E-invoicing can change that.”

What system is currently in place?

Since May 2008, Singapore has enforced e-invoicing for suppliers of government agencies (B2G). The introduction of mandated e-invoicing has been very successful in reducing the costs of processing governmental supplier invoices, as well as increasing the handling speed and accuracy. However, at present business-to-business (B2B) invoicing has multiple fragmented standards in operation with no mandate in place.

This may soon to change as the Info-communications Media Development Authority (IMDA), which oversees the development and regulation of info-communications in Singapore, will be co-operating with industry partners, government agencies and Singapore Business Federation to examine the various standards of e-invoicing that are currently implemented around the world.

The authority has indicated that the quintessential standard should fit both Singapore’s domestic requirements while having an international outlook. We anticipate that the IMDA will provide more details later this year.

From industry sources, PEPPOL is being considered as a very likely infrastructure and format to be implemented in Singapore. Pagero is closely following the developments of Singapore’s plan to develop e-invoicing and will continue to publish updates as their implementation plan is revealed.

What this means for Singapore’s businesses

Businesses in Singapore will need to prepare their systems to send and receive e-invoices in a structured format such as XML. A structured format is different from digitised invoices like PDF, Word, and scanned paper invoices, as it allows machines to automatically read the data into ERP and accounting software without the need for human interaction.

Potential benefits include:

• Faster payment cycles via improved integrity and authenticity of invoices
• Operating costs reduction
• Speeding up business transactions
• Minimising disputes and error reduction

Pagero Online

Pagero is following Singapore’s developments closely. We will stand ready to support businesses of any size. Our platform already provides connectivity with many of the most common standards adopted around the world including PEPPOL. The solutions offered by Pagero support both domestic and cross-border e-document exchange regardless of the software you use, the processes you apply or the size of your company. We help our customers maintain compliance around the globe.