The European Standard for an eInvoice (EN) that is being developed by the European Standards Organization (CEN) has now been accepted by the CEN members. What was accepted in this round of voting were two key parts of the standard.

  • The invoice semantic data model. Which includes the list of business terms, their cardinalities and rules.
  • A list of syntaxes. The syntaxes that are listed are UBL 2.1 and UN/CEFACT Cross Industry Invoice 16b

The standard itself is only the semantic model that is expressed in a syntax neutral way. That means that it can technically be implemented by using any syntax as long as all specifications for content and rules are respected.

The eInvoice standard is however closely linked to the EU directive on electronic invoices for public procurement, Directive 2014/55. This directive states that all public entities in EU and EEA must be able to receive and process electronic invoices that comply to this standards and in either of the syntax on the approved list. This syntax requirement thus only applies to public entities who must receive invoices. It does not apply to those who are sending or non-public entites who are receiving. They can use either of these syntaxes or any other as well. In practical terms this however means that a sender of electronic invoices should send invoices in either of the listed syntaxes (or both). That way he will be able to send electronic invoices to any public entity. This also means that a private entity that wishes to receive electronic invoices should support either or both of the listed syntaxes because then it is likely that any of his suppliers who also trade with pubic entities will be able to sent him electronic invoices. The EN or the directive does not mandate suppliers to send invoices that are compliant to the EN but many member states have passed own laws mandating such invoices and more countries are considering the same or enforcing that through tendering terms.

The voting on the EN is a major step in the timeline for adopting standardized electronic invoices in the European public sector but several steps remain. The key steps remaining are the following.

  • According to directive 2014/55 Members states must adopt legislation necessary to comply with the directive latest by November 27th. 2018 (this date is fixed)
  • Contracting authorities (meaning public entities who buy things) must be able to receive and process invoices based on this standard 18 months after the publication of a reference to the standard in the Official Journal of the European Union.
  • Members states may postpone this requirements for public entities on local level for additional 12 months after the publication.

A key point in this timeline is the publication of the reference in the OJEU. This date is not yet known. According to article 3 of the Directive this reference should be published no later than May 27 this year. Before that can be done CEN needs to finish the publication of the standard itself. There are some delays in that but that publication is expected to be during the summer. The publication of the reference can therefore be expected in late summer or early fall. 3-4 for months later than initially stated. Considering that the overall project of setting the standard and getting it implemented is about 5 years this delay is not significant. If the reference to the standard is published in OJEU in August then the deadlines for implementations will be the following.

  • Deadline for implementation March/April 2019.
  • Deadline for implementation in local government March/April 2020 in those countries where the postponement is provided. Otherwise the deadline for local government is 2019.

There are still a few loose ends with the most important one being formal publication of the syntax binding between the semantic model and the listed syntaxes. That binding has been developed but has not yet been formally circulated and approved.


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