European Commission – EU e‑Invoicing Consultation

• Commission announcement & background
  https://single-market-economy.ec.europa.eu/news/commission-launches-public-consultation-revision-einvoicing-directive-2026-03-18_en [single-mar….europa.eu]
• Direct link to the “Have Your Say” consultation page (to submit feedback)
  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14792-Electronic-invoicing-revision-of-EU-rules_en [eencyprus.org.cy]

Key practical details (for context)

• Scope: Revision of Directive 2014/55/EU on e‑invoicing in public procurement, aligned with ViDA
• Consultation period: 18 March – 10 June 2026
• Platform: “Have Your Say” (EU Login required) [single-mar….europa.eu], [eencyprus.org.cy]

Questions:

1. Relevance of the Evaluation Findings

Purpose:
To validate whether the Commission’s ex post evaluation conclusions (on the current Directive) still reflect today’s reality.

Question:

To what extent do you consider that the following findings from the evaluation are still relevant?
(Scale: 1 = not relevant → 5 = very relevant)

You are asked to rate the relevance of:

• The European eInvoicing standard has contributed to harmonising invoicing in Europe
• Limited use of the European eInvoicing standard
• Persistent interoperability challenges, particularly at the transmission level
• Complex national governance arrangements
• Uneven uptake of eInvoicing across Member States
• Other (open text)

Why this matters:
This section anchors the justification for legislative change and determines whether deeper intervention is needed.

2. Scope of the Revised Directive

Purpose:
To identify which transaction types should be covered going forward.

Question:

Based on your experience, what should the revised eInvoicing Directive address?

You indicate whether the Directive should cover:

• ✅ B2G public procurement above EU thresholds
• ✅ B2G public procurement below EU thresholds
• ✅ Government‑to‑Business (G2B), e.g. tax-related communications
• ✅ Business‑to‑Consumer (B2C)
• Other (open text)

Why this matters:
This question explicitly tests support for scope expansion beyond classic B2G procurement, in light of ViDA and broader digitalisation.

3. Ranking of Specific Policy Objectives

Purpose:
To prioritise what the revised Directive should mainly achieve.

Question:

Please rank the importance of the following potential objectives.
(Scale: 1 = lowest priority → 5 = highest priority)

Objectives to be ranked:

• Increase adoption of eInvoicing in B2G transactions
• Ensure harmonised use of the European eInvoicing standard (EN 16931)
• Improve interoperability at transmission level (secure, cross-system exchange)
• Reduce eInvoicing‑related compliance costs for businesses
• Other (open text)

Why this matters:
This helps the Commission balance legal harmonisation, technical infrastructure, and cost reduction.

4. Assessment of Policy Options (High-level)

Purpose:
To assess how different legislative ambition levels would affect organisations.

Policy Options presented

• Policy Option 1
  Limited to contracts above EU thresholds with mandatory EN 16931 use.
• Policy Option 2
  Extends to above + below thresholds, addresses transmission interoperability, and accounting software integration.
• Policy Option 3
  Builds on Option 2 and adds EU governance, monitoring, and accreditation of service providers.

Question:

How would these policy options impact your organisation?
(Answered indirectly through the detailed measures below)

5. Detailed Measures (M1–M9): Agreement, Benefits & Costs

Purpose:
To evaluate specific regulatory measures underpinning each policy option.

For each measure, you must assess:

• Agreement (1 = disagree → 5 = strongly agree)
• Expected benefits (0 = none → 5 = high)
• Expected costs (0 = none → 5 = high)
• Provide qualitative comments / evidence

Measures assessed

Option 1 (M1–M4)

• M1 – Obligation for suppliers to issue eInvoices (above thresholds)
• M2 – Mandatory and exclusive use of EN 16931
• M3 – Technology‑neutral EU obligation on transmission interoperability
• M4 – Recommendation to integrate eInvoicing into accounting software

Option 2 (M5–M7)

• M5 – Obligation to issue eInvoices below thresholds
• M6 – Obligation for contracting authorities to support specific transmission methods
• M7 – Mandatory integration of EN 16931 eInvoicing into accounting software

Option 3 (M8–M9)

• M8 – EU‑wide accreditation framework for eInvoicing providers
• M9 – EU‑level monitoring of B2G eInvoicing

6. Compliance Cost Impact (Overall)

Purpose:
To measure net cost impact of eInvoicing obligations in practice.

Question:

How would you assess the overall impact on costs of complying with B2G eInvoicing requirements in your country?

Options range from:

• Very high cost increase → Very high cost decrease
• Don’t know

7. Breakdown of Compliance Cost Drivers

Purpose:
To identify what actually drives costs for businesses.

Question:

Which types of compliance costs have the highest impact on your organisation?
(Scale: 1 = very low → 5 = very high)

Cost categories:

• Managing different national requirements across Member States
• IT system adaptation and infrastructure costs
• Administrative and internal resource costs
• Regulatory / platform / system fees
• Other (open text)