With less than one month to go until the EU Directive 2014/55/EU enters into force, most European governments are now ready – or at least have put plans into motion to be ready – to receive e-invoices by April 18, 2019. All Member States’ sub and central contracting authorities and entities fall within the scope of the directive. That is, over 300 000 public administrations throughout Europe are affected. Below is a summary of the most important aspects of the new directives.

Important dates

Here are a couple of important dates to keep in mind:

  • Contracting authorities and entities are required to be e-invoice ready by the latest of April 18, 2019.
  • Sub-central contracting authorities and entities may be granted an extended deadline of April 18, 2020 if such optional deadline extensions have been exercised by the Member State.

Differing ways to fulfil the requirements

There are many unique ways in which Member States can, have and are planning to fulfil the directive’s requirements:

  • Some European governments have decided to build their own platforms to receive e-invoices. This includes Portugal, France, Italy and Croatia.
  • Others have chosen to outsource this function to service providers, such as Finland and Estonia.
  • A third option, which has become increasingly popular, is to connect to the PEPPOL (Pan-European Public Procurement On-Line) eDelivery Network. Governments taking this course of action include Sweden, Norway, UK, Austria, Netherlands and Ireland. PEPPOL has gained traction throughout Europe and beyond, with more than 110 000 public and private sector entities connected to the PEPPOL eDelivery network today.

Are PDF invoices compliant?

As long as the public administrations can accept and process electronic invoices compatible with the European Norm (EN 16931), they will be compliant. How an e-invoice, once received, is processed by the recipient is not specified by the directive, nor in the European standard. This allows the recipient to decide on the level of automation to be adopted within their own ERP environment. However, human-readable formats such as PDF, TIFF or JPEG are not accepted as valid tax e-invoices, as they are not capable of being automatically processed and thus fall outside of the EN core data model.

Mandate scope extension

The directive has pathed the way for complete adoption of B2G e-invoicing by public authorities within the EU. In an effort to rationalise governmental expenditure, many countries have implemented mandatory B2G e-invoicing on suppliers in public procurement as well.

From 2017, France compelled business with over 5000 employees to be e-invoice capable, and from April 2020, businesses with over EUR 50 million in revenue must be e-invoice capable in Portugal.
Other expected developments within B2G e-invoicing beyond the directive include:

  • Croatia – supplier B2G mandate from July 2019
  • Germany – supplier B2G mandate from November 2020
  • France – supplier B2G mandate final stage for micro businesses from January 2020
  • Poland – supplier B2G mandate from November 2020
  • Portugal – supplier B2G mandate from April 2020
  • Sweden – supplier B2G mandate from April 2019

Pagero helps you to comply

Pagero’s specialised in-house compliance team ensures our services meet local compliance requirements in all countries affected by the directive, now and in the future. As a trusted government advisor, we have supported the development and implementation of PEPPOL throughout Europe and Asia. Contact one of our representatives for further information about how we can help you to become and remain compliant in local markets throughout Europe and beyond.

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