Consultation Questionnaire for Companies

Consultation Questionnaire for Companies

Revision of Directive 2014/55/EU on Electronic Invoicing in Public Procurement
Introduction

The European Commission is preparing a revision of the EU rules on electronic invoicing (eInvoicing), with a legislative proposal expected by the end of 2026. The objective is to assess policy options aimed at improving interoperability, reducing administrative burden, and supporting the digitalisation of invoicing across the EU.

EInvoicing refers to invoices issued in a structured, machine-readable format that can be automatically processed by accounting and IT systems. Sending a PDF invoice by email is not considered eInvoicing. As part of the EU initiative VAT in the Digital Age (ViDA), eInvoicing is expected to become the default method of invoicing in the EU by 2030, in order to simplify digital VAT reporting by extracting relevant reporting data from eInvoices and improving efficiency.

Your feedback is essential to ensure that the future rules work well for companies. Your practical experience will help to develop solutions and to understand the impact of possible policy measures on organisations like yourselves.

Please note: Some of the questions in this questionnaire may be complex and are primarily designed for experienced companies. However, we kindly ask you to answer as many questions as possible based on the information and experience available to you.

The European Commission wants to better understand the practical impact of eInvoicing for companies, including possible costs, benefits, and challenges. You are welcome to suggest additional measures that could further reduce complexity or administrative burden. The Commission will assess impacts of each policy measure outlined in this questionnaire.

This survey aims to collect information on the following aspects:

(i) Current use and costs of eInvoicing for companies

(ii) Impacts of the proposed policy measures on companies

Your responses will contribute to shaping future EU eInvoicing policy.

You are welcome to attend an online explanatory session on 15 April, 2026, if you have any questions about completing the questionnaire. Please click here to register

This Questionnaire will be open until April 30, 2026.
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Respondent's profile
1. Which country is your business based in?*
2. What is the size of your business?*

Single person business/self-employedCompany with 1 to 9 employeesCompany with 10 to 49 employeesCompany with 50 to 249 employeesCompany with 250 to 749 employeesMore than 750 employees
3. Did you participate in public procurement contracts (e.g. by bidding for contracts with public authorities) in the years between 2022 and 2025?*

YesNo
(i) If yes, what is the average value of public procurement contracts for which your business was bidding (if applicable)?

Less than €10,000€10,000 - €50,000€50,001 - €140,000€140,001 - €1,000,000More than €1,000,000Do not know
(ii) If yes, in the past 12 months, how many public procurement contracts have you been awarded, and what was the approximate total value of these contracts?

0 contracts won (value €0)1 -2 contracts won (total value: under €50,000)3 -5 contracts won (total value: under €50,000 - €250,000)More than 5 contracts won (value: over €1,000,000)Do not knowOther
4. In which markets does your company participate in public procurement procedures? (Please select all that apply)

In the EU Member State where your company is establishedIn one or more other EU Member StatesIn non-EU countriesNoneDo not know
5. How many eInvoices did you send in 2025 (in total) for B2G (business to government) transactions? (eInvoicing refers to invoices issued in a structured, machine-readable format that can be automatically processed by accounting and IT systems. Sending a PDF invoice by email is not considered eInvoicing)

None1 - 1011 - 9991,000 - 10,00010,001 - 50,000More than 50,000Do not know
6. How many eInvoices did you send and receive in 2025 (in total) for B2B (businsess to business) transactions?

None1 - 1011 - 9991,000 - 10,00010,001 - 50,000More than 50,000Do not know
7. By what means does your company send and/or receive eInvoices? (Please select all that apply)

Through an intermediary or eInvoicing service providerThrough accounting or ERP softwareThrough a supplier portalOutsourced to a third party (e.g. accountant, bookkeeping service)Inhouse solutionWe do not send or receive eInvoicesDo not knowOther (please specify)
8. Do your public sector customers require you to use specific eInvoicing portals or platforms?

YesNoDo not know
(i) If yes, how many different portals or platforms do you use to issue eInvoices to the public sector in the EU?

1 - 23 - 56 - 10More than 10
9. If your company uses more than one platform, what are the main reasons? (Please select all that apply)

Different customers require the use of specific portals, platforms, or transmission methodsLack of interoperability between eInvoicing systemsDifferent technical formats required by customersCross-border requirements in other EU Member StatesInternal business or accounting system constraintsDo not knowOther (please specify)

10. What are the cost factors for your company when using eInvoicing? (For all that apply, please give an estimate percentage of each cost factor in your company's total eInvoicing-related costs)

Rows	Estimated Percentage (%)
Software or eInvoicing service provider fees
Accounting or ERP software upgrades
Registration or membership fees for portals or networks
IT integration costs
Administrative or staff time required to manage eInvoicing
Compliance or legal analysis costs
Other (please specify)
Do not know (enter "y")

11. What payment model does your company use for eInvoicing? (Please select all that apply)

Per eInvoice (pay per transaction)Lump sum (fixed, periodic fee)Free of charge solutionIncluded in accounting software with an eInvoicing module (at no additional cost)Provided by a third party as part of a broader service packageOther
(i) Please include additional information i.e. fees, frequency, other payment models
12. How much does your company pay for eInvoicing on average on a yearly basis?

€0.00Less than €500€500 - €1,000€1,001 - €5,000€5,001 - €10,000€10,001 - €50,000€50,001 - €100,000€100,001 - €200,000More than €200,000Do not knowNot applicable (we do not use eInvoicing)
13. If your company could only use one eInvoicing service provider or solution, what percentage of costs related to eInvoicing do you estimate you could save?

More than 50%26 - 50%11 - 25%1 - 10%No cost benefitDo not know
14. What is the time frame required to migrate to the new version of the EN 16931-1:2026, from the day it is available?

Less than 6 monthsLess than 1 year12 months18 months24 monthsMore than 24 monthsDo not know
15. What are the top five issues you find most burdensome when complying with B2G eInvoicing requirements? (Please select five issues)

Understanding the legal requirementsUnderstanding the technical requirements for sending and receiving eInvoicesSelecting a compliant eInvoicing service or solution providerCosts charged by eInvoicing service or solution providerIntegrating eInvoicing into existing accounting or IT systemsManual data entry or duplicate processing when creating or submitting eInvoicesAdapting eInvoices to different technical or format requirements requested by customersRegistering, onboarding, and managing multiple eInvoicing portals or platforms required by different customersLack of interoperability between eInvoicing systems or platformsRejection of eInvoices due to incompatibility between systems or platformsCross-border challenges when trading with customers in another EU Member State (e.g. resulting from differing technical formats, validation procedures or platform requirements)Insufficient time to adapt systems before new legal requirements applyI do not eInvoiceOther (please specify)
Impact of proposed policy measures

Explanatory Notes on each measure for further reference

Measure 1 - Obligation for suppliers to issue eInvoices for public procurement above EU thresholds

This measure implies that all companies must send eInvoices when supplying goods or services to the public sector for contracts above certain EU thresholds (e.g. above about €140,000 - €216,000 depending on the type of authority).

Measure 2 - Obligation for suppliers to issue eInvoices for public procurement below EU thresholds

This measure means that companies must send eInvoices when supplying goods or services to the public sector even for low-value contracts below EU thresholds (e.g. a €5,000 contract with a local municipality would still require an eInvoice).

Measure 3 - Mandatory and exclusive use of the European eInvoicing standard for B2G eInvoicing

This measure means that all invoices sent to public authorities must use the European eInvoicing standard only, with no alternative formats allowed (e.g. a supplier must submit an invoice in the EU standard format rather than as other domestic electronic formats).

Measure 4 - Technology-neutral obligation to ensure interoperability at the transmission level

This measure means that different eInvoicing systems must be able to send and receive invoices between each other regardless of the technology used (e.g. a company using one platform can send an invoice to a government system using another platform without compatibility issues).

Measure 5 - Mandatory EU technical specifications for transmission interoperability

This measure means that common EU technical rules must be implemented by all eInvoicing platforms in the EU (private and public) to ensure eInvoices can be transmitted smoothly between different systems (e.g. all platforms must follow the same EU-defined protocol so eInvoices can be exchanged across countries without issues).

Measure 6 - EU accreditation framework for eInvoicing service and solution providers

This measure means that eInvoicing service and solution providers must meet EU-defined requirements to be officially approved (e.g. a provider must be certified at EU level before offering eInvoicing services to businesses or governments).

Measure 7 - EU monitoring requirements for eInvoicing in public procurement

This measure means that governments and service providers must collect and report data on how eInvoicing is used in public procurement (e.g. tracking how many eInvoices have been received by public sector customers and reporting this at EU level).

Measure 8 - Recommendation to integrate eInvoicing functionality into accounting software, conformant to the European eInvoicing standard (EN 16931)

This measure means encouraging accounting software providers to include built-in eInvoicing features that follow the European standard (e.g. a company may create and send compliant eInvoices directly from its accounting software without needing a separate tool/service if eInvoicing is integrated).

Measure 9 - Obligation to integrate EN 16931-conformant eInvoicing functionality into accounting software including functional and technical requirements

This measure means obliging accounting software providers to include built-in eInvoicing features that follow the European standard (e.g. a company shall always be able to create and send compliant eInvoices directly from its accounting software without needing a separate tool/service, as every accounting software will have eInvoicing functionality integrated).

16. For each of the following measures, please indicate how beneficial (including possible cost savings) you would expect them to be for your business when issuing eInvoices for public procurement?

Rows	High benefits	Moderate benefits	No benefits	Do not know
Measure 1: Obligation for suppliers to issue eInvoices for large public procurement contracts (above EU procurement thresholds*)
Measure 2: Obligation for suppliers to issue eInvoices for small public procurement contracts (below EU procurement thresholds*)
Measure 3: Standardisation - Mandatory and exclusive use of the European eInvoicing standard (EN 16931) when issuing eInvoices to public sector customers
Measure 4: Interoperability - Obligation to ensure interoperability between IT systems used to send and receive eInvoices (technology-neutral approach)
Measure 5: Interoperability - Mandatory use of common EU technical specifications or networks for transmitting eInvoices across the EU
Measure 6: Provider accreditation - EU accreditation framework for eInvoicing services and software solutions
Measure 7: EU monitoring and reporting requirements for B2G eInvoicing (e.g. uptake in public procurement and use of the European Standard), to be implemented by governments and service/solution providers
Measure 8: Recommendation to integrate eInvoicing functionality into accounting software, compliant to the European eInvoicing standard (EN 16931)
Measure 9: Obligation to integrate EN 16931-compliant eInvoicing functionality into accounting software including functional and technical requirements

*NOTE: EU procurement thresholds determine when EU public procurement rules apply, generally for higher-value contracts. For example, they are currently around €140,00 - €216,000 for supplies and services contracts and around €5.4 million for construction works (excluding VAT).
(i) If you wish, please describe the main benefits these measures could bring to your business and indicate which specific measures they relate to

17. For each of the following measures, please also indicate the level of additional (above business as usual) costs you would expect them to cause to your business when issuing eInvoices in public procurement

Rows	High costs	Moderate costs	No costs	Do not know
Measure 1: Obligation for suppliers to issue eInvoices for large public procurement contracts (above EU procurement thresholds*)
Measure 2: Obligation for suppliers to issue eInvoices for small public procurement contracts (below EU procurement thresholds*)
Measure 3: Standardisation - Mandatory and exclusive use of the European eInvoicing standard (EN 16931) when issuing eInvoices to public sector customers
Measure 4: Interoperability - Obligation to ensure interoperability between IT systems used to send and receive eInvoices (tehcnology-neutral approach)
Measure 5: Interoperability - Mandatory use of common EU technical specifications or networks for transmitting eInvoices across the EU
Measure 6: Provider accreditation - EU accreditation framework for eInvoicing services and software solutions
Measure 7: EU monitoring and reporting requirements for B2G eInvoicing (e.g. uptake in public procurement and use of the European Standard), to be implemented by governments and service/solution providers
Measure 8: Recommendation to integrate eInvoicing functionality into accounting software, compliant to the European eInvoicing standard (EN 16931)
Measure 9: Obligation to integrate EN 16931-compliant eInvoicing functionality into accounting software including functional and technical requirements

*NOTE: EU procurement thresholds determine when EU public procurement rules apply, generally for higher-value contracts. For example, they are currently around €140,00 - €216,000 for supplies and services contracts and around €5.4 million for construction works (excluding VAT).
(i) Please indicate which of the policy measures you prefer. You may indicate more than one

Measure 1 - Obligation for suppliers to issue eInvoices for large public procurement contracts (above EU procurement thresholds)Measure 2 - Obligation for suppliers to issue eInvoices for small public procurement contracts (below EU procurement thresholds)Measure 3 - Mandatory and exclusive use of the European eInvoicing standard (EN 16931) when issuing eInvoices to public sector customersMeasure 4 - Obligation to ensure interoperability between IT systems used to send and receive eInvoices (technology-neutral approach)Measure 5 - Mandatory use of common EU technical specifications or networks for transmitting eInvoices across the EUMeasure 6 - EU accreditation framework for eInvoicing services and software solutionsMeasure 7 - EU monitoring and reporting requirements for B2G eInvoicing (e.g. uptake in public procurement and use of the European Standard), to be implemented by governments and service providersMeasure 8 - Recommendation to integrate eInvoicing functionality into accounting software, compliant to the European eInvoicing standard (EN 16931)Measure 9 - Obligation to integrate EN 16931-compliant eInvoicing functionality into accounting software including functional and technical requirements
(ii) Please briefly explain your choice(s)
18. Please provide your view on the expected costs and benefits of the following policy measures (expressed in EUR, for the totality of your relevant transactions)
NOTE:

Adjustment costs: investments and expenses companies have to bear to adjust their activity to the requirements contained in a legal rule such as direct labour costs, equipment costs, material costs, costs of external services (including fees), implementation costs, and overhead costs). In the eInvoicing context, adjustment costs may entail the establishment of a national eInvoicing infrastructure and all related organisational, technical, and compliance costs, etc.

Administrative costs: borne by companies as a result of administrative activities performed to comply with administrative obligations included in legal rules, e.g. reporting obligation.

Enforcement costs: associated with activites linked to the implementation of an initiative such as monitoring and audits.

Benefits: operational cost savings due to process automation as issuer of eInvoices, improved cashflow management.

If you cannot provide an estimate of the EUR costs, please enter "Y" in the "difficult to assess" column.

(i) Measure 1: Obligation for suppliers to issue eInvoices for public procurement above EU thresholds

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(ii) Measure 2: Obligation for suppliers to issue eInvoices for public procurement below EU thresholds

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(iii) Measure 3: Mandatory and exclusive use of the European eInvoicing standard for B2G eInvoicing

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(iv) Measure 4: Technology-neutral obligation to ensure interoperability at the transmission level

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(v) Measure 5: Mandatory EU technical specifications for cross-border transmission interoperability (e.g. eDelivery)

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(vi) Measure 6: EU accreditation framework for eInvoicing service and solution provider

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(vii) Measure 7: EU monitoring and reporting requirements for B2G eInvoicing (e.g. uptake in public procurement and use of the European Standard), to be implemented by governments and service providers

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(viii) Measure 8: Recommendation to integrate eInvoicing functionality into accounting software, conformant to the European eInvoicing standard (EN 16931)

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(ix) Measure 9: Obligation to integrate EN 16931-conformant eInvoicing functionality into accounting software including functional and technical requirements

Rows	One-off	Recurrent per year	Difficult to Assess
Benefits
Adjustment costs
Administrative costs
Enforcement costs

(x) Please provide any data or information that you may deem useful.
(xi)Please upload any data or information that you may deem useful

Cancelof
19. How burdensome would it be for your company to comply with different domestic eInvoicing requirements when sending eInvoices to another Member State for B2G eInvoicing?

Very burdensomeModerately burdensomeNot burdensomeDon't know
(i) Please briefly explain your choice (optional)
20. How burdensome would it be for your company to comply with different domestic eInvoicing requirements when sending eInvoices to a trading party in another Member State for B2B eInvoicing?

Very burdensomeModerately burdensomeNot burdensomeDo not know
(i) Please briefly explain your choice (optional)
21. How beneficial would it be to have an eInvoice message status from your customers that is applicable across Europe in the same way and why?

Highly beneficialModerately beneficialNot beneficialDo not know
(i) Please briefly explain your choice (optional)
22. If your company could share proof that a public sector eInvoice has been approved for payment, how useful would this be to obtain financing from financial institutions?

Very usefulModerately usefulNot usefulDo not know
(i) If useful, how would your company most likely use this information? (Please select all that apply)

To obtain cheaper invoice financing or factoringTo obtain short-term loans based on approved eInvoicesTo improve cash-flow planningTo reduce financing costsDo not knowOther (please specify)
23. Does your company currently use invoices issued to customers (public or private) to obtain financing (e.g. factoring or supply chain finance)?

YesNoDo not know
24. How beneficial would it be for your company if a harmonised pan-European eInvoicing service or solution could be used and accepted across the EU for both public sector (B2G) and private sector (B2B) transactions?

Very beneficialModerately beneficialNot very beneficialDo not know
(i) If you wish, please explain how this could simplify cross-border trade for your business.
25. To what extent has your company experienced fraud related to eInvoicing in public procurement?

Several timesOnce or twiceHave not experienced fraud but are aware of cases in our sectorHave not experienced fraudDo not knowOther

26. How important are the following aspects related to data included in your eInvoices?

Rows	Very important	Somewhat important	Not important
Knowing where your business data is stored (e.g. within the EU or outside the EU)
Ensuring that your data is not used by intermediaries for other purposes (e.g. analytics, resale, or commercial use)
Ensuring that your business data is not shared or sold to third parties
Ensuring that your data remains subject to EU rules and standards
Ensuring that your data is not transferred to companies located outside the EU

Other aspect, please specify
27. Final Comments - If you wish, you may provide further input
28. Company name (optional)
Thank you for participating
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