One month after its formal approval on October 23, 2025, the updated European e-invoicing standard EN 16931 remains unpublished. This prolonged silence is causing serious uncertainty for businesses. Companies across Europe are now rolling out e-invoicing systems to comply with new mandates, but they are forced to do so based on the old 2017 version of EN 16931 – all while knowing that a new version of the standard has been approved and could kick in soon. The result is a looming scenario of double work and rework: processes and software configured today may need to be changed in a few months when the new norm finally arrives. This situation is unfair, inefficient, and costly for the private sector. It is imperative that the authorities involved – particularly CEN’s Technical Committee 434 (CEN/TC 434) and the European Commission – publish and implement the updated EN 16931 as soon as possible. At the same time, they must improve transparency around this process, because right now the status of the new standard is verging on the “world’s best kept secret.” Businesses are being treated like a ball in a game, tossed between players who are trying to score points, instead of being treated as partners in this digital transition. We need a more business-friendly approach to regulatory updates, and we need it fast.
The Cost of Delay: Businesses in Procedural Limbo
From a business perspective, the current situation is highly problematic. Many countries (such as Belgium, France, and others) have e-invoicing mandates taking effect in early 2026, requiring companies to issue invoices in a structured electronic format. These mandates implicitly rely on EN 16931 as the content standard (often implemented via the Peppol BIS format). Because the updated EN 16931 standard is not available yet, companies have no choice but to configure their systems according to the old 2017 version in order to comply with the law.
However, everyone knows the old standard is about to be superseded. The revised EN 16931 was meant to address several gaps and limitations in the original – especially to better support business-to-business (B2B) transactions and new VAT reporting requirements. For example, under the current EN 16931 standard, certain invoice scenarios are cumbersome or impossible:
- If an invoice contains some items that are outside the scope of VAT (“O” code) and others that are exempt from VAT (“E” code), the old rules do not allow those to appear on the same invoice. Businesses have to issue separate invoices for each category.
- If a seller needs to reference multiple purchase orders on one invoice (common in B2B transactions), the current standard again does not support this; it requires one invoice per order.
- If different line items on an invoice fall under different VAT exemption reasons, the old standard insists all exempt lines share the same reason; otherwise, separate invoices are needed.
The new EN 16931 standard is expected to fix these issues – allowing mixed tax categories, multiple orders per invoice, multiple exemption reasons, and more. But until it is published and adopted, companies are stuck with inefficient workarounds. In Belgium, for instance, authorities have temporarily permitted businesses to fudge these rules: e.g., treating outside-the-scope items as “exempt” and adding a text note, or listing multiple orders in an invoice using a special workaround, even though it violates the letter of the current standard. These interim fixes are explicitly temporary. They let business continue operations during the transition, but they also mean that processes will have to change once again when the revised standard is finally in force.
For companies, this is a nightmare of rework and uncertainty. IT teams and finance departments must implement changes now (to meet the mandates using the old rules) and then brace to implement another set of changes when the new rules become official. This double implementation entails:
- Additional costs: Budget spent on configuring and testing systems twice.
- Resource strain: Teams have to divert time to a second compliance project immediately after finishing the first.
- Risk of errors: Each reconfiguration carries the chance of mistakes or glitches, potentially leading to invoice processing errors or compliance issues with trading partners.
- Training and documentation: Staff and suppliers might have to be re-trained on new invoicing formats and guidelines twice in quick succession.
All these factors translate to a hit on productivity and efficiency. Businesses thrive on planning and predictability; what they have now is a moving target. The frustration in the business community is palpable. Many feel that changing the norm so soon after mandates take effect is simply not business-friendly. After investing time and money to meet the January 2026 requirements, being told that those requirements will soon change comes across as a breach of faith. It’s the kind of scenario that makes even compliant companies question the process – a sentiment captured by one observer’s remark that the new standard’s timeline has become “the world’s best kept secret” and companies are being used as a plaything in a larger game.
Why Changing the Standard Post-Mandate is a Bad Idea
Regulatory stability is crucial. When governments impose a major change like mandatory e-invoicing, there is an implicit understanding that the ground rules will remain stable for a while so that businesses can adapt and operate with confidence. In this case, that understanding has been shaken. We have a situation where:
- Mandates: fixed dates by which businesses must comply.
- Standard: the detailed rules of compliance, which are in flux.
This misalignment undermines the very goals of the mandates. The intention of moving to e-invoicing is to increase efficiency, reduce errors, and improve tax compliance. But if the standard is a moving target, the early phase of implementation could be less efficient and more error-prone, as discussed above. Companies might have to resort to manual interventions and exceptions (the opposite of streamlined automation) to meet requirements during the gap.
Moreover, frequent changes erode trust and buy-in. Businesses need to feel that regulators understand their challenges. Right now, the perception is that the planning was flawed – that those in charge of the standard should have ensured its timely release or coordinated better with the rollout of mandates. It’s not that businesses oppose the new standard; in fact, they want it, because it promises improvements. But they understandably wish it had been available before the mandates started, not after. Rolling it out late creates a kind of “now fix what you just did” mandate, which can be demoralizing.
Another aspect causing concern is the lack of clear communication. Aside from a few technical circles and insiders, most businesses have heard little official word on when the new EN 16931 will be published or what exactly will change. Instead, they hear through unofficial channels that it might take up to six more months (which could mean around April or May 2026) for the updated standard to be fully released and referenced by authorities. Indeed, an indicative timeline circulating in the industry suggests formal publication by the end of May 2026. If true, this means the gap between approval and publication would be over half a year. Keeping companies in the dark for so long is counterproductive. It prevents effective preparation and fuels rumor and speculation.
On top of that, there’s a governance concern being voiced: it turns out that some of the very individuals leading the development of the EN 16931 standard within CEN are also prominent leaders in the Peppol network – the community responsible for implementing e-invoicing infrastructure. For example, the convenor of the CEN workgroup on the core invoice model is simultaneously a leader in Peppol’s post-award community. While expertise is valuable, this overlap in roles is prompting questions about potential conflicts of interest. When the same people writing the rules are deeply involved in one of the main platforms that uses those rules, it’s fair to ask whether decisions are being made with the whole market’s interest in mind or tilted towards specific ecosystems. At a minimum, such dual roles call for extra transparency to reassure all stakeholders that the standard-setting process is impartial. Businesses need to trust that the standards they must follow are shaped by broad, neutral consensus, not by a select few with multiple hats.
In sum, changing the e-invoicing norm immediately after a mandate rollout – and doing so in an opaque way – is a recipe for disruption. It creates avoidable costs for companies, risks undermining the benefits of e-invoicing in the short term, and can cast doubt on the integrity of the process. This is why a swift correction and a change in approach are needed now.
Time for Transparency and Swift Implementation
The first and most urgent order of business is straightforward: CEN/TC 434 and the European Commission need to release the updated EN 16931 standard without further delay. The content has been approved; any remaining editorial or administrative steps should be expedited. Every week of delay adds to the uncertainty and may force more companies to roll out stop-gap measures they’ll later have to undo. If there are legitimate reasons for the holdup (like finalizing translations or agreements), those should be openly communicated. Which brings us to the second point: drastically improve communication. It’s unacceptable that a standard so crucial — one that will eventually underpin compliance across the EU — is shrouded in mystery at this stage. The responsible bodies should provide regular public updates on:
- The expected timeline for publication and official adoption of the new standard.
- The key changes in the revised EN 16931 (so businesses and software providers know what to anticipate).
- Guidance on how to handle the interim period.
Such information should be circulated through official channels, industry forums, and in collaboration with national authorities, so it reaches a wide audience. Right now, the knowledge is largely confined to experts and those who dig through technical communities. That’s not good enough when every VAT-registered business in some countries will be affected. Greater visibility and clarity will ease anxiety and help companies plan more effectively, even if the new standard’s release is still a few months away.
In parallel, the European Commission should consider issuing a formal notice or decision regarding the acceptance of the updated standard. For example, it could state that invoices complying with the approved (but not yet published) EN 16931 will be considered valid once the standard is out, and perhaps outline a transitional arrangement. Ideally, the Commission and member state governments would coordinate an approach so that businesses are not penalized or forced into instant compliance the day the standard is published. Regulators might allow a grace period where either the old or new standard is acceptable, or where minor deviations (such as those interim solutions currently tolerated) remain acceptable for a short time after the new rules take effect. Such measures would cushion the switch and acknowledge that, practically, not everyone can turn on a dime.
There is also a need to address the perception of conflict of interest and ensure an inclusive governance of the standard going forward. CEN and the Peppol community should openly address how they interact. It could be beneficial to introduce or highlight any checks and balances that exist (for instance, wide consultation within CEN, or the involvement of independent experts) to assuage concerns. Ensuring that other stakeholder groups – like enterprise software providers, large corporate users, SMEs, and tax authorities – have a voice in the standard’s evolution is key. By broadening participation and being transparent about leadership roles, the standard setters can rebuild trust and demonstrate that no single interest is dominating the agenda.
Building a Business-Friendly Path Forward
Beyond the immediate fix, this episode offers important lessons on how to better manage regulatory updates in the digital compliance space. It is critical to adopt a more business-friendly approach, one that achieves policy goals while minimizing unnecessary burden on companies. Here are a few key recommendations:
- Align Standard Releases with Mandate Deadlines: When new compliance mandates are planned, ensure the supporting standards and specifications are finalized well before those mandates take effect. If a needed update to a standard is running behind schedule, policy-makers should consider adjusting the mandate’s timeline accordingly. In other words, don’t force businesses to implement a requirement based on draft or outdated specs that will change shortly after. In this case, had the EN 16931 update been published by mid-2025, companies could have implemented everything in one go. Conversely, if it was known that the standard would only be ready in mid-2026, perhaps the mandate start dates (where possible) could have been set a bit later or with phased requirements.
- Introduce Transition Periods: A new standard doesn’t always have to mean an overnight switchover. Especially for something as fundamental as the invoicing format, regulators should allow a transition period. For example, for a certain number of months, invoices conforming to either the old or the new standard could be accepted. This gives laggards time to catch up and early adopters the freedom to move ahead, without either being penalized. Transition windows are common in technical implementations; they provide a safety net that ensures continuity of business while changes roll out.
- Proactive Communication and Guidance: As soon as changes are on the horizon, start talking about them. Provide businesses with as much lead time as possible to understand what’s coming. This could include publishing draft specifications or summaries of expected changes, holding webinars or info sessions, and updating FAQs. The Belgian authorities’ FAQs (which openly discuss how certain rules “will change with the revision of the European Standard”) are a good example of transparency at a national level. That kind of proactive guidance should be mirrored at the European level. When companies know what’s coming, they can prepare more efficiently (for instance, by building flexibility into their systems, or scheduling developer time for the expected update).
- Stakeholder Engagement and Feedback: Engage with the business community in shaping implementation plans. This doesn’t mean businesses dictate standards, but their feedback can highlight practical challenges and timelines. For instance, if many companies say they need six months to adapt to a new schema, pushing a change through in three months will lead to problems. Regular dialogue through industry groups or public consultations can surface issues early and create a sense of shared mission. In the case of EN 16931, broader consultation might have flagged the timing issue sooner, prompting either faster standard work or a rethink of mandate dates. At the very least, it could have prepared everyone for the possibility of a gap.
- Ensure Clear Governance and Independence: Finally, maintain clear lines and perhaps some separation between those setting the standards and those implementing them commercially. Cooperation is fine (indeed essential to ensure standards are practical), but oversight or independent review can help avoid any perception of bias. Rotating leadership roles or having co-chairs from different stakeholder groups might be ways to ensure no single community has outsized influence. The goal is a standard that serves all of Europe’s businesses and administrations, not any one network or solution provider.
Conclusion: Act Now to Support Businesses
The delayed publication of the new EN 16931 standard is a preventable stumbling block on Europe’s path to digital invoicing. We are at risk of turning a positive initiative (standardizing e-invoices for efficiency and interoperability) into a source of frustration and wasted effort for the very businesses it’s meant to help. It’s time to rectify that. CEN and the European Commission must act decisively: publish the updated standard, make it accessible, and coordinate its deployment with the ongoing e-invoicing mandates. Every additional day of delay forces more companies to implement temporary fixes and face the prospect of doing everything twice.
The call for action is not about assigning blame; it’s about recognizing the very real impact on businesses and adapting accordingly. By responding swiftly and communicating openly, the responsible bodies can still regain the confidence of the business community. They can show that Europe’s digital transformation is a collaborative effort, not a one-sided game. And by learning the lessons of this episode, future regulatory updates – whether for e-invoicing or other digital compliance measures – can be handled in a way that puts businesses’ practical needs front and center alongside policy goals.
In the end, what enterprises large and small want is fairly simple: clear rules, delivered in a timely way, that stay consistent long enough to recoup their investment in compliance. That’s a reasonable ask. It’s also something that benefits regulators and the economy as a whole. Let’s make sure that as we push forward into the era of mandatory e-invoicing, we carry everyone forward together – with standards and mandates walking in lockstep, and with businesses feeling supported rather than squeezed. The updated EN 16931 is ready to help achieve that future; it just needs to be set free. The time to act is now.
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