E-invoicing compliance update, March 2024

As the global landscape of electronic invoicing continues to evolve, it's imperative for businesses to stay abreast of the latest developments and regulatory changes. In this review, we delve into significant updates from various countries around the world, shedding light on mandatory e-invoicing mandates, postponed launches, and new initiatives aimed at streamlining B2B transactions.

On February 19th, the European Commission published a report detailing the impact of the eInvoicing Directive 2014/55/EU. Among the significant conclusions is that the Directive has promoted smoother cross-border transactions and reduced fragmentation in public procurement across the Internal Market.

Furthermore, its influence extends beyond the public sector by fostering e-invoicing adoption in B2B transactions. While the EU has reaped substantial benefits from this initiative, persistent challenges remain. The report underscores the need for further actions to boost e-invoicing adoption within the EU and improve interoperability.

On January 5, 2024, Belgium officially released a draft law requiring the use of e-invoicing for specific transactions, following several pre-draft bills. On January 17, the Commission granted approval for the draft regulation, and on February 20, the law was published in the Official Gazette of Belgium.

Starting on January 1, 2026, electronic invoicing will be mandatory for domestic B2B transactions under the Belgium VAT law. Registered taxpayers who are residents of Belgium will be obligated to send and receive structured electronic invoices through the Peppol network. This means that paper invoices and unstructured formats like PDFs will become obsolete.

Foreign taxpayers who are registered for VAT in Belgium won't need to comply with the new requirements unless they have a physical establishment in Belgium. Exceptions are made for taxpayers who are part of the flat-rate scheme (phased out in 2028), those who only carry out VAT-exempt transactions, and bankrupt taxpayers, in respect of activities related to their bankruptcy proceedings.

The Estonian Ministry of Finance has recently introduced a draft law to encourage and expand the adoption of e-invoices in B2B transactions. Currently in the discussion phase, the draft law must undergo the legislative process before it can be enacted.

Under the proposed changes to the Accounting Law, businesses that register as recipients of e-invoices will have the ability to request electronic invoices from their suppliers for the payment of purchased goods and services. These invoices will adhere to the European EN-16931 standard.

In France B2B e-invoicing was supposed to start in July 2024, but the government decided to delay that regulation. In October 2023, a new amendment bill was circulated, with updated tentative dates.

* Each of these dates is subject to change and could be postponed by up to three months via a potential decree.

B2B e-invoicing rollout in Germany remains uncertain despite the publication of a final law proposal with important deadlines. On February 21, 2024, the Conciliation Committee failed to reach an agreement. The Bundestag targets a 2027 implementation, while the Bundesrat proposes 2028 as the preferred timeline.

No specific timeline has been set for the B2B invoice exchange mandate yet. However, it is crucial for the supplier's ERP system(s) to have the capability to send any produced invoice in real-time to the myDATA portal via API. The system should then create a QR code based on the myDATA message, embed it into the PDF, and send it to the buyer. Integration with an accredited service provider is not mandatory.

Greece has initiated the enforcement of e-invoice issuance for specific B2G transactions involving vital governmental entities like the Greek NHS headquarters, Police Department headquarters, Schooling System headquarters, and more. From June 1, 2024, all remaining sub-governmental bodies will also be included in this requirement. This process involves an accredited service provider, crucial when submitting the actual invoice to the GSIS platform, which operates under Peppol rules. Notably, the GSIS platform only accepts documents from accredited service providers..

Israel's Internal Revenue Service has postponed the launch of B2B e-invoicing from April 2024 to May 5, 2024.

To address the significant issue of fictitious invoice fraud, the Ministry is suggesting a gradual implementation of the threshold for valid invoices to be sent to the Tax Authority in real-time for verification, along with the assignment of a distinctive digital invoice number. The absence of this number will prevent the deduction of input VAT.

The Latvian Ministry of Finance has recently released a draft plan aimed at tackling the shadow economy for the period 2024-2027. The plan outlines the implementation of a mandatory e-invoicing system for all B2B transactions, with full completion expected by December 30, 2025.

According to the draft plan, the issuance and receipt of structured e-invoices for B2B transactions will be made compulsory, accompanied by real-time reporting. These measures are designed to enhance transparency and combat illicit economic activities.

The Malaysian Peppol Authority MDEC has released the long-awaited Peppol MY PINT BIS specifications, which have been localized for Malaysia to cater to the country's business and tax requirements. This will enable businesses to exchange e-invoices via the Peppol network seamlessly.

There’s also the launch of an e-invoice pilot project in May to test the system's effectiveness and ensure smooth integration between company and Inland Revenue Board (IRB) systems before implementation in August.

The Mauritius Revenue Authority (MRA) plans to roll out a national e-invoicing system gradually. Under this new system, suppliers of goods and services must validate their invoices or receipts in real-time with the MRA before providing them to customers.

In our last e-invoicing compliance update, we talked about a grace period of sanctions for failure to timely report. This grace period has not been formalized; it remains a topic of discussion between the tax authorities and businesses.

New updates have been rolled out in the e-factura system, with a key addition being the self-invoicing feature. This function now enables users to send invoices on behalf of the supplier.

The implementation of an e-invoice as real time reporting (system e-faktura) was postponed indefinitely. No further timelines have been communicated.

The United Arab Emirates government has unveiled more specifics about its upcoming requirement for e-invoicing starting in July 2026. The approach is modeled after the decentralized system in France, where companies will need to engage certified service providers to handle e-invoice transactions. These designated providers will take responsibility for submitting the data to the tax authorities.

The Digital Business Networks Alliance (DBNAlliance) has recently introduced its own open exchange network. This network enables a secure and efficient exchange of B2B e-invoices and e-documents for companies in the United States.

The nonprofit organization, established by participants from the Business Payments Coalition's E-Invoice Exchange Market Pilot, aims to streamline B2B document exchanges, promoting efficiency and eliminating traditional invoicing challenges.

The Zambia Revenue Authority (ZRA) has announced its new e-invoice program requirements, setting a deadline of July 1, 2024 for all taxpayers to adopt mandatory electronic invoicing.

This initiative will use the new Smart Invoice system, which replaces the previously mandatory Electronic Fiscal Devices (EFD), and is awaiting approval from the National Assembly. Taxpayers will only be able to claim input VAT or deductions based on invoices generated under the new system.

If you are looking for a way to improve your business's financial processes, e-invoicing is a great option to consider. It offers a number of benefits, including cost savings, increased efficiency, improved accuracy, improved security, and compliance. E-invoicing can also help your business improve cash flow, customer satisfaction, visibility and control, and environmental sustainability.

Want to learn more about mandatory e-invoicing? Read our report “E-invoicing interoperability and compliance."

The information presented and timelines provided are accurate as of the date of publishing. Due to the dynamic nature of regulations and legislation, these timelines may change accordingly.