Current State of Mandatory e-Invoicing in Europe

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As local e-invoicing compliance requirements increase, so too does the corresponding technical complexity needed to implement them. This is especially true for Business to Government suppliers (B2G) and for Business to Business invoices with Tax authority clearance (B2Tax). Here you can find all the details for the new e-invoicing requirements for more major countries in the European Union.

Current State of Mandatory e-Invoicing in Europe

Electronic invoicing is quickly becoming more than just a common practice worldwide. After all, with the advantages of speed, affordability, and accuracy being well established, it’s difficult to justify using paper-based methods. In fact, the practice is so widespread that some nations, notably the EU, have made e-invoicing mandatory.

The major instances of this may be seen in South and Central America, where B2B e-invoicing has been regulated for many years in Brazil, Chile, and Mexico. The necessity to close the unpaid tax gap through better VAT reporting and payment systems drove these early examples.

Any naysayers about the effectiveness of these programs should examine the fact that since implementing e-invoicing, Mexico’s tax yields have increased by 34%. A convincing argument, to be sure.

Mandatory B2G e-invoicing in the EU

With the strong odor of money in the air, it wasn’t long before the early e-invoicing adopters’ success sparked changes in the EU. Governments across the continent followed Brazil’s lead and began mandating business-to-government-B2G electronic invoicing for suppliers to Italian government entities as early as 2014.

Governments, contrary to popular belief, prefer to embrace efficiency whenever possible. Many African governments have made electronic invoicing mandatory as a result of the eInvoicing Directive 2014/55/EU. Governments have been able to create laws mandating electronic invoicing for public procurement thanks to specific wording from section 35 of this directive:

However, this directive should not preclude the Member States from requiring the submission of only electronic invoices in the context of public procurement.

Here’s a snapshot of what mandatory eInvoicing looks like in some of the larger EU economies is as follows:

Italy – B2G e-invoicing requirements

The use of electronic invoices in Italy’s public procurement has been mandatory for ministries, tax authorities, and national security authorities since June 2014. Mandatory by all public institutions since March 31st, 2015.
The eInvoice format is an XML called FatturaPA.
Connectivity is through the countrywide online hub, through internet services, called Sistema di Interscambio (SDI).
E-Invoicing issuers and recipients have to maintain their digital files for five years minimum.

France – B2G e-invoicing requirements

The French government is gradually increasing the use of electronic invoices from 2017 to 2020, depending on the company’s size.

01/01/2017 for any company including more than 5000 employees
01/01/2018 for any company including 250 to 5000 employees
01/01/2019 for any company including 10 to 250 employees
01/01/2020 for any company including less than 10 employees

Electronic invoices must be sent to public authorities via ChorusPro, a portal developed by AIFE. This portal centralizes the processing of all electronic invoices addressed to the French public sector.
Chorus Pro can use the UBL Invoice 2.1 standard for various formats, including structured UBLs and minimal UBLs. Beginning April 2018, the UN / CEFACT XML CII 16B standard will be available standalone and in Facturx hybrid format.
There is a legal obligation to preserve invoices for six years, although the issuer and recipient often keep the original documents for at least a decade.

Spain – B2G e-invoicing requirements

The use of e-invoices with state administrative agencies has become an obligation since January 15th, 2015.
Public sector suppliers must submit their e-invoices to PGEFe-Common Point of Entry for Electronic Invoices.
According to this law, all invoices delivered to government bodies must be submitted electronically, have a structured XML format (Facturae V3.2.X), and be signed with an electronic signature using a qualified certificate as of January 15th, 2015.
The original electronic documents must be preserved by recipients for at least five years.

Germany – B2G e-invoicing requirements

When Germany implements the PEPPOL network for its public procurement processes in November 2020, B2G e-invoicing will become mandatory.
XRechnung and ZugFeRD 2.0 are standards that make up a Core Invoice User Specification (CIUS) and adhere to the European Norm-EN 16931 on e-invoicing. In addition to XRechnung, national authorities can accept alternative forms. The PEPPOL CIUS could possibly be used by Germany.
Invoices must be kept for at least ten years after they are issued, starting from the end of the year in which they were issued.

UK – B2G e-invoicing requirements

The NHS is the first public sector organization in the UK to test electronic formats and processes.
This program has two requirements: the deployment of PEPPOL as a network and a GDSN e-catalog for product data synchronization.
To participate in this project, healthcare vendors must automate the exchange of invoices, purchase orders, and dispatch advice messages.
Ministers now have the authority to control the use of electronic invoicing in the sector of public procurement in England, thanks to the Small Business, Enterprise and Employment Act of 2015. To date, no explicit regulations under the Act have been issued by the Ministries.

Portugal – B2G e-invoicing requirements

When working with the government, e-invoicing will be required starting in April 2020. This includes electronic credit and debit note forms as well.
The format will be UBL 2.1, which is a European standard that has already been authorized.
The Portal BASE platform can be used by central, regional, and local governments to process contracts in the context of public procurement.
The connection is established using the AS2 protocol or Web Services.
Both the issuer and the recipient must keep invoices for at least ten years.

Belgium – B2G e-invoicing requirements

Since January 1st, 2017, e-invoicing has been required for new contracts in B2G procurement. From January 1st, 2018, it will be required for enterprises bidding on bids worth more than €135,000. As of 2020, the federal government will only accept e-invoices.
PEPPOL BIS INVOICE is the format utilized.
Mercurius, a Peppol-aligned e-mailroom that may be used by any Belgian contracting authority to receive their e-invoices, is one way the Belgian public sector supports this method.
Invoices must be preserved for a period of seven years at the very least.

The Netherlands – B2G e-invoicing requirements

Since January 1st, 2017, government providers must use electronic invoicing.
In the Netherlands, public bodies can receive electronic invoices in three different formats:

UBL-OHNL is a messaging standard for public procurement of all goods and services, with the exception of temporary staffing. The UBL-OHNL standard is based on the UBL international standard. NLCIUS will eventually replace the UBL-OHNL invoicing.
Simplerinvoicing follows the SI-UBL standard. SI-UBL is a subset of the UBL specification (200 components) (2400 items). NLCIUS will eventually replace the regular SI-UBL.
The SETU (HR – XML) standard defines messages (including eInvoices) for data interchange in the context of recruiting temporary workers. This is the biggest volume of invoices to the central government at the moment. NLCIUS is an extension of SETU.

Invoices must be preserved for seven years at the very least.

Poland – B2G e-invoicing requirements

The sending of e-invoices is currently optional, but the receiving of them is required by the eInvoicing directive (2014/55/EU). Every public authority must create an account on the National eInvoicing platform (PEF), and every invoice sent in a structured electronic format must go via PEF.
From November 2020, B2G e-invoicing will be required.
EN-16931 and PEPPOL BIS Billing 3.0 compliance is required for electronic bills.
Invoices must be kept for a minimum of five years.

Mandatory B2B e-invoicing in the EU

While EU Directive 2014/55/EU presents a strong case for governments mandating that e-invoices be filed for public procurement, no equivalent language exists for B2B transactions. As one might expect, the problem of required B2B electronic invoicing has become more complicated.

If e-invoicing is mandated for business-to-business transactions, provisions of the EU VAT Directive (and amendment 2010/45/EU) may be violated. A classic case of bureaucratic inconsistency

This hasn’t stopped Italy from moving ahead with a mandate that all B2B invoices be issued electronically (beginning of January 2019) using the ‘Sistema di Intercambio’ system. This allows the Italian Revenue Agency to collect information on all e-invoices before they are given to clients, allowing them to compute the tax required on each invoice precisely.

The EU Commission recognized Italy’s unconventional approach, granting a deviation from the EU VAT Directive. Other countries that want to follow in the United States’ footsteps must seek a similar exception to entrench mandatory B2B e-invoicing in their legislation.

With so much money on the line, it’s difficult to imagine any country refusing to join in. Here’s what’s going on right now:

Greece – B2B e-invoicing requirements

With a VAT gap of 29 percent, Greece has one of the biggest VAT gaps in Europe (see European Commission VAT Gap report here). As a result, the Independent Authority for Public Revenue Authority (IAPR) suggested an e-invoicing mandate similar to that used in Italy in August 2018. However, because this would require the EU Commission to grant exemptions from specific terms of the directive, a different approach was selected. The IAPR proposed a new model that requires electronic invoices to be sent to the IAPR and focuses on the buyer’s ability to account for purchase bills accurately.

Furthermore, Greece’s Ministry of Finance declared in April 2018 that starting January 1st, 2020, all Greek entrepreneurs will be required to use electronic invoicing and bookkeeping. This is now being implemented in Greece as the first step toward broader and required B2B e-invoicing.

Spain – B2B e-invoicing requirements

Because Spain has yet to secure a dispensation from the EU Commission to execute the B2B mandate, it is hard to predict when it will be implemented.

However, in July 2017, the Spanish Tax Authority mandated that over 62,000 enterprises use the Immediate Information Sharing system to disclose VAT records electronically (SII). All VAT reports and record books for qualifying enterprises should be sent to the AEAT electronic office in XML format. This format has a header with information about each record book’s holder and a block containing invoice details.

The following companies are affected by the prompt information sharing requirement:

Large businesses (those with an annual turnover of more than €6,010,121.04 in Euros).
For VAT purposes, companies are divided into groups.
Those who have opted for a monthly reimbursement are referred to as monthly refunders (REDEME)

Because Spain has already implemented SII, it will only be a matter of time until a political choice is made about whether to pursue e-invoicing or e-reporting.

France – B2B e-invoicing requirements

From January 2023, France has said that mandatory e-invoicing for B2B transactions will be implemented. The proposed procedure will take the same method as Italy’s: Before being issued to the consumer, invoices must be pre-approved through the government’s Chorus Pro site.

France will request a waiver from the EU VAT Directive, which typically requires customers to submit written consent to the receipt of e-invoices.

One of the following methods can be used to upload invoices to Chorus Pro:

Manual entry
PDF or XML invoice uploading
EDI or API connection

The information gathered would subsequently be used to prepare draught VAT returns, including sales and purchase invoices, and would be made accessible to taxpayers for review and adjustment requests. As a result, the current model of taxpayers filling out and submitting VAT returns would end.

Turkey – B2B e-invoicing requirements

The following dates have been set for mandatory digitization of invoicing and related activities in Turkey:

Middlemen or merchants trading fruits or vegetables → 01.01.2020
Companies with 2018 year-end gross sales more than 5 Mio TRY → 01.07.2020 (the rule repeatedly applies for further accounting years, practically creating an obligation on July 1st of every consecutive year)
Companies licensed by EPDK (Turkish Energy Market Regulatory Authority) (including dealers, i.e., gas stations included) → 01.07.2020
Motor vehicle manufacturers, importers, dealers → 01.07.2020
Companies acting as middlemen in Internet sales → 01.07.2020
Internet banner publishers and web advertisers → 01.07.2020

Portugal – B2B e-invoicing requirements

Portugal has been slower to require B2G e-invoicing than other countries. They are, however, about to make e-invoicing mandatory for B2B transactions as well. The following are important dates to keep in mind:

Current State of Mandatory e-Invoicing in Europe

Current State of Mandatory e-Invoicing in Europe

The major instances of this may be seen in South and Central America, where B2B e-invoicing has been regulated for many years in Brazil, Chile, and Mexico. The necessity to close the unpaid tax gap through better VAT reporting and payment systems drove these early examples.

Any naysayers about the effectiveness of these programs should examine the fact that since implementing e-invoicing, Mexico’s tax yields have increased by 34%. A convincing argument, to be sure.

Mandatory B2G e-invoicing in the EU

However, this directive should not preclude the Member States from requiring the submission of only electronic invoices in the context of public procurement.

Here’s a snapshot of what mandatory eInvoicing looks like in some of the larger EU economies is as follows:

Italy – B2G e-invoicing requirements

The use of electronic invoices in Italy’s public procurement has been mandatory for ministries, tax authorities, and national security authorities since June 2014. Mandatory by all public institutions since March 31st, 2015.

The eInvoice format is an XML called FatturaPA.

Connectivity is through the countrywide online hub, through internet services, called Sistema di Interscambio (SDI).

E-Invoicing issuers and recipients have to maintain their digital files for five years minimum.

France – B2G e-invoicing requirements

The French government is gradually increasing the use of electronic invoices from 2017 to 2020, depending on the company’s size.

01/01/2017 for any company including more than 5000 employees

01/01/2018 for any company including 250 to 5000 employees

01/01/2019 for any company including 10 to 250 employees

01/01/2020 for any company including less than 10 employees

Electronic invoices must be sent to public authorities via ChorusPro, a portal developed by AIFE. This portal centralizes the processing of all electronic invoices addressed to the French public sector.

Chorus Pro can use the UBL Invoice 2.1 standard for various formats, including structured UBLs and minimal UBLs. Beginning April 2018, the UN / CEFACT XML CII 16B standard will be available standalone and in Facturx hybrid format.

There is a legal obligation to preserve invoices for six years, although the issuer and recipient often keep the original documents for at least a decade.

Spain – B2G e-invoicing requirements

The use of e-invoices with state administrative agencies has become an obligation since January 15th, 2015.

Public sector suppliers must submit their e-invoices to PGEFe-Common Point of Entry for Electronic Invoices.

According to this law, all invoices delivered to government bodies must be submitted electronically, have a structured XML format (Facturae V3.2.X), and be signed with an electronic signature using a qualified certificate as of January 15th, 2015.

The original electronic documents must be preserved by recipients for at least five years.

Germany – B2G e-invoicing requirements

When Germany implements the PEPPOL network for its public procurement processes in November 2020, B2G e-invoicing will become mandatory.

XRechnung and ZugFeRD 2.0 are standards that make up a Core Invoice User Specification (CIUS) and adhere to the European Norm-EN 16931 on e-invoicing. In addition to XRechnung, national authorities can accept alternative forms. The PEPPOL CIUS could possibly be used by Germany.

Invoices must be kept for at least ten years after they are issued, starting from the end of the year in which they were issued.

UK – B2G e-invoicing requirements

The NHS is the first public sector organization in the UK to test electronic formats and processes.

This program has two requirements: the deployment of PEPPOL as a network and a GDSN e-catalog for product data synchronization.

To participate in this project, healthcare vendors must automate the exchange of invoices, purchase orders, and dispatch advice messages.

Ministers now have the authority to control the use of electronic invoicing in the sector of public procurement in England, thanks to the Small Business, Enterprise and Employment Act of 2015. To date, no explicit regulations under the Act have been issued by the Ministries.

Portugal – B2G e-invoicing requirements

When working with the government, e-invoicing will be required starting in April 2020. This includes electronic credit and debit note forms as well.

The format will be UBL 2.1, which is a European standard that has already been authorized.

The Portal BASE platform can be used by central, regional, and local governments to process contracts in the context of public procurement.

The connection is established using the AS2 protocol or Web Services.

Both the issuer and the recipient must keep invoices for at least ten years.

Belgium – B2G e-invoicing requirements

Since January 1st, 2017, e-invoicing has been required for new contracts in B2G procurement. From January 1st, 2018, it will be required for enterprises bidding on bids worth more than €135,000. As of 2020, the federal government will only accept e-invoices.

PEPPOL BIS INVOICE is the format utilized.

Mercurius, a Peppol-aligned e-mailroom that may be used by any Belgian contracting authority to receive their e-invoices, is one way the Belgian public sector supports this method.

Invoices must be preserved for a period of seven years at the very least.

The Netherlands – B2G e-invoicing requirements

Since January 1st, 2017, government providers must use electronic invoicing.

In the Netherlands, public bodies can receive electronic invoices in three different formats:

UBL-OHNL is a messaging standard for public procurement of all goods and services, with the exception of temporary staffing. The UBL-OHNL standard is based on the UBL international standard. NLCIUS will eventually replace the UBL-OHNL invoicing.

Simplerinvoicing follows the SI-UBL standard. SI-UBL is a subset of the UBL specification (200 components) (2400 items). NLCIUS will eventually replace the regular SI-UBL.

The SETU (HR – XML) standard defines messages (including eInvoices) for data interchange in the context of recruiting temporary workers. This is the biggest volume of invoices to the central government at the moment. NLCIUS is an extension of SETU.

Invoices must be preserved for seven years at the very least.

Poland – B2G e-invoicing requirements

The sending of e-invoices is currently optional, but the receiving of them is required by the eInvoicing directive (2014/55/EU). Every public authority must create an account on the National eInvoicing platform (PEF), and every invoice sent in a structured electronic format must go via PEF.

From November 2020, B2G e-invoicing will be required.

EN-16931 and PEPPOL BIS Billing 3.0 compliance is required for electronic bills.

Invoices must be kept for a minimum of five years.

Mandatory B2B e-invoicing in the EU

While EU Directive 2014/55/EU presents a strong case for governments mandating that e-invoices be filed for public procurement, no equivalent language exists for B2B transactions. As one might expect, the problem of required B2B electronic invoicing has become more complicated.

If e-invoicing is mandated for business-to-business transactions, provisions of the EU VAT Directive (and amendment 2010/45/EU) may be violated. A classic case of bureaucratic inconsistency

The EU Commission recognized Italy’s unconventional approach, granting a deviation from the EU VAT Directive. Other countries that want to follow in the United States’ footsteps must seek a similar exception to entrench mandatory B2B e-invoicing in their legislation.

With so much money on the line, it’s difficult to imagine any country refusing to join in. Here’s what’s going on right now:

Greece – B2B e-invoicing requirements

Furthermore, Greece’s Ministry of Finance declared in April 2018 that starting January 1st, 2020, all Greek entrepreneurs will be required to use electronic invoicing and bookkeeping. This is now being implemented in Greece as the first step toward broader and required B2B e-invoicing.

Spain – B2B e-invoicing requirements

Because Spain has yet to secure a dispensation from the EU Commission to execute the B2B mandate, it is hard to predict when it will be implemented.

The following companies are affected by the prompt information sharing requirement:

Large businesses (those with an annual turnover of more than €6,010,121.04 in Euros).

For VAT purposes, companies are divided into groups.

Those who have opted for a monthly reimbursement are referred to as monthly refunders (REDEME)

Because Spain has already implemented SII, it will only be a matter of time until a political choice is made about whether to pursue e-invoicing or e-reporting.

France – B2B e-invoicing requirements

From January 2023, France has said that mandatory e-invoicing for B2B transactions will be implemented. The proposed procedure will take the same method as Italy’s: Before being issued to the consumer, invoices must be pre-approved through the government’s Chorus Pro site.

France will request a waiver from the EU VAT Directive, which typically requires customers to submit written consent to the receipt of e-invoices.

One of the following methods can be used to upload invoices to Chorus Pro:

Manual entry

PDF or XML invoice uploading

EDI or API connection

The information gathered would subsequently be used to prepare draught VAT returns, including sales and purchase invoices, and would be made accessible to taxpayers for review and adjustment requests. As a result, the current model of taxpayers filling out and submitting VAT returns would end.