• Consultation Questionnaire for Service Providers

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

  • Introduction

    The European Commission is currently 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.

    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.

    As a Service Provider, your feedback is essential to ensure that the future rules work well for all enterprises. Your practical experience will help us to develop solutions and to understand the impact of possible policy measures.

    This survey aims to collect information on the following aspects:

    1.  Current use and costs of eInvoicing for companies
    2.  Impacts of the proposed policy measures on companies

    Your responses will directly contribute to shaping future EU eInvoicing policy and ensuring that the revised rules are practical, proportionate and supportive of all organisations including SMEs across the Single Market.

    This Questionnaire will be open until April 30, 2026.

  • Please provide the following information:

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  • Q3. What types of services does your organisation provide?*

  • Market Structure and Interoperability

  • Q4. What transmission infrastructures do you currently support?*
  • Q5. To what extent do differences in national eInvoicing implementations create barriers to scaling services across the EU?*
  • Q6. How many different invoice formats does your organisation currently support across the EU?*

  • European eInvoicing standard (EN 16931)

  • Q7. What percentage of eInvoices processed in the EU by your organisation are compliant with EN 16931?*
  • Q8. What are the main challenges associated with supporting both EN 16931 and national formats?
  • Q9. What is the maintenance cost of supporting EN 16931? What are the maintenance costs of supporting additional national formats on average?
  • Q10. Would restricting B2G eInvoicing to exclusive use of EN 16931 (phasing out national formats) reduce complexity for service providers?*
  • Q11. If EN 16931 became the only allowed standard for B2G eInvoicing, what timeframe would you recommend for service providers to phase out national formats for B2G eInvoicing?*
  • Q12. What is the timeframe required to migrate to the new version of the EN 16931-1:2026, from the day it is available?*

  • Interoperability

  • Q13. What costs arise from integrating with multiple national eInvoicing platforms?*
  • Q14. What are the set up costs of integration to a national platform in a Member State without an accreditation scheme?*
  • Q15. What are the annual maintenance costs of integration to a national platform in a Member State without an accreditation scheme?
  • Q16. To what extent do you agree that EU-level requirements for interoperable transmission methods would improve cross-border eInvoicing?*
  • Q17. Which transmission model would best support EU-wide interoperability?*

  • Accreditation and Governance Requirements

  • Q19. Would an EU-level accreditation framework for eInvoicing service providers reduce barriers to operate across borders?*
  • Q20. What risks could arise from introducing an EU-level accreditation framework?*
  • Q21. Would establishing a single EU-level accreditation framework for eInvoicing service providers generate overall benefits that outweigh the associated costs, compared with the current system of multiple national accreditation schemes?*
  • Q22. Please indicate the average cost to your organisation to obtain an accreditation under national eInvoicing schemes (For example, in countries such as Italy, France, Greece, Romania, etc).
  • Q23. Please indicate the average cost to your organisation to maintain an accreditation under national eInvoicing schemes (For example, in countries such as Italy, France, Greece, or Romania).
  • Q24. Would an EU-level monitoring system for eInvoicing adoption improve transparency and policymaking? (For example, by requesting Member States to provide data on eInvoicing uptake, and common reporting methods.)

  • Accounting Software Integration

  • Q25. Based on your market experience, to what extent is EN16931-based eInvoicing functionality currently integrated into mainstream accounting or ERP software?
  • Q26. If accounting software providers were obliged to fully support EN16931 for both outbound and inbound invoices, would eInvoicing adoption increase significantly for large companies?
  • Q27. If accounting software providers were obliged to fully support EN16931 for both outbound and inbound invoices, would eInvoicing adoption increase significantly for SMEs?
  • Q28. If accounting software providers were obliged to fully support EN16931-based eInvoicing for both outbound and inbound invoices, would the cost of providing implementation services to customers reduce significantly?
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  • eInvoicing Mandates

  • Q30. Based on your experience, to what extent do mandatory sending obligations for suppliers to public sector organisations below thresholds contribute to increasing the uptake of eInvoicing in public procurement?

  • Costs and Scalability 

  • NOTE:

    Adjustment costs: investments and expenses service providers have to bear in order 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 service providers as a result of administrative activities performed to comply with administrative obligations included in legal rules, e.g. gathering and processing of information, reporting, etc.

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

    Benefits: operational cost savings due to process automation (as receiver of eInvoices, reduction of VAT fraud, improved cashflow management).

    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 and reporting requirements for B2G eInvoicing (e.g. uptake in public procurement and use of the European Standard)

    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).

  • Q31. Please provide your view on the expected costs and benefits for each policy measure for service providers (expressed in EUR, for the totality of your relevant transactions):

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  • Q32. In your experience, how do the additional costs outlined in Q31 influence the prices charged to SMEs for eInvoicing services?
  • Q33. How would introducing a default transmission method for B2G eInvoicing (beyond other existing ones) across the EU affect the costs of providing your services?
  • Q34. How would introducing a common standard for B2B eInvoicing affect the prices charged to SMEs for eInvoicing services?
  • Q35. If a fully harmonised EU framework for eInvoicing were introduced, to what extent do you estimate this would reduce your organisation’s compliance costs?*
  • Q36. To what extent do you consider that a harmonised EU framework for B2B and B2G eInvoicing would facilitate expansion of your business into new markets within the EU?
  • Q37. To what extent would a harmonised EU framework for B2B and B2G eInvoicing reduce the annual cost of eInvoicing services for SMEs?

  • Future Outlook

  • Q38. Which EU-level policy actions would most improve the interoperability of eInvoicing services across the EU? (Please select the top three actions)*
  • Q39. Which EU-level policy actions would most improve the scalability of eInvoicing services across the EU? (Please select all that apply)*
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  • Note: The EU Business Wallet is a regulated digital identity framework under eIDAS 2 that allows businesses to store verified information, share data securely, and reuse the same data across different processes. It would also support smoother digital interactions between businesses and authorities across countries.

  • Q41. Do you provide services for re-use of eInvoice data for VAT reporting for intra-Community and/or domestic transactions?
  • Q42. Are you providing (or planning to provide) services for using eInvoice data for Sustainability reporting (e.g. ESG indicators, CO2 emissions, etc.)?*
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  • Q43. Do you provide services for eInvoice data to be used for other reporting obligations?*
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