Unofficial translation
I am speaking here as an e-invoicing professional. Due to my experience of more than experience of more than 15 years in this sector and on an international scope, I have acquired a solid expertise of the business, regulatory and technical aspects of electronic invoicing. Moreover I actively participate in several associations and working groups (EESPA, FNFE and workshops of of the French Public Finance Department). I would like to specify that this point of view is I would like to specify that this point of view is personal and does not commit my current employer.
I welcome the initiative of the commission, especially the will :
- to harmonize the models which are more and more divergent between the member states;
- to allow a better sharing of information between member states on cross-border flows cross-border flows;
- to give new impetus to the development of electronic invoicing;
- to develop the use of structured formats, which is essential to allow a better
- to develop the use of structured formats, which is essential to allow better automation of both exchanges and the use of data by the tax authorities.
However, I would like to make several important comments on the current definition of the new rules. Not to contest them, but to clarify the framework of application and to adapt them to to the constraints of business activity.
The conditions for the prohibition of pre-clearance systems should be specified. For example For example, a system such as the one currently in place in France seems to me to be at the of non-compliance with this rule. Indeed, the tax authorities do not strictly oblige companies to submit invoices for validation before they are issued by the public platform that it operates, but it delegates this validation task to accredited third parties (PDPs – Platforms for accredited third parties (PDP – Platforms of Dematerialization Partners). This forces companies to to a limited choice between a public platform and a closed ecosystem, under the exclusive control of the tax authorities.
Strictly limiting the definition of electronic invoices to structured formats may of the definition of electronic invoicing to structured formats may be detrimental to small businesses that are not equipped with solutions to to use them.
The EN16931 standard is a good basis, but it is primarily adapted to a B2G context. In the B2B context, some data is missing (or some elements are not adapted). elements are not well adapted). It is not advisable to multiply extensions that will result in a return to result in a return to fragmentation of formats. Consequently, it would be preferable to foresee the evolution of the standard to take into account B2B needs and usage.
I think that at some point, we will have to choose collectively between the two syntaxes UBL and CII. I would make the analogy with the web, where the HTML format has allowed universal access, regardless of browser, regardless of operating system. The separation into two formats and multiple extensions leads to fragmentation and hinders interoperability.
Standardization of formats is essential but not sufficient. We need a common infrastructure, common protocols. In my opinion, we should guarantee
interoperability via a common exchange network like those of PEPPOL or EESPA.
I think it is important to adjust the definitions of signature, EDI and audit trail modes to realign the text of the 2010 directive with the state of the art and the transpositions of the for example by introducing the notion of qualified sealing which is massively used.
The prohibition of periodic invoicing will be problematic for many current use cases, especially when two companies carry out hundreds or thousands of transactions transactions per day. Businesses that use recurring invoices will see an increase in the number of invoices they This will lead to a significant increase in administrative and technical costs. It would probably be probably be necessary to make exceptions to this rule, or to limit the cases in which it applies.
The very short period of time for transmitting data to the tax authorities will cause great difficulties for difficulties for some companies because computerized invoicing processes are rarely real-time flows, but asynchronous and, when a problem occurs, require human intervention within hours. and, when a problem occurs, require human intervention during working hours.
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