1. CEN Workshop on eInvoicing phase 3 eINVIII_005
Title : Mapping between the recommendations of the Expert Group of the Commission and
the workshop on eInvoicing
Source : Mr. Nisbet
Date : 2010-02-09
Status : For information
Note :
Secretariat: Nederlands Normalisatie-instituut (NEN)
Mr. G. van den Akker Telephone: +31 15 2 690 426
Vlinderweg 6 E-mail: gertjan.vandenakker@nen.nl
P.O. box 5059
2600 GB Delft
The Netherlands

2. 20 January 2010
CEN­Expert Group Mapping Project
Executive Summary
Definition of EDI In numerous CWA’s CEN sought to expand the scope of Article 232 by redefining
EDI to eliminate any specific technology and thereby include XML invoices, as
well as EDIFACT and ANSI X‐12 within the definition of EDI. The Expert Group’s
Recommendation 2.2 recommends deleting all of Article 232 and removing all
references to any technology, including EDI . The goals of both approaches are
closely aligned, but the means are different. Convergence can perhaps be
highlighted through EG Recommendation 2.5, which recommends that until
Article 232 is eliminated, Member States should implement the “other means”
option, which under CWA 16047 includes several methods of transporting XML
documents. CEN Phase 3 may also want to recommend that Member States
adopt the broader definition of EDI as a similar “interim measure” during the
time it takes to implement a new Directive eliminating Article 232. This
proposal would be consistent with the goals advanced by the Expert Group’s
“other means” recommendation.
Model Trading Partner While CWA 15574 (2006) updated the 1994 Model Trading Partner Agreement
Agreement adopted by Commission Recommendation 94/820/EC, there is no specific
reference to that Model Trading Partner Agreement in the Expert Group report.
However, Expert Group Recommendation 5.5 .11 (Need for Agreements)
recognizes the need for agreements between trading partners to “promote trust,
reach and interoperability”. Moreover, the Expert Group recommends that its
Code of Practice be incorporated into bilateral trading partner agreements.
Model EDI Agreement for CWA 15581 (2006) identifies key provisions that should be addressed in third
Service Providers party service agreements. Section 3.7 of the Expert Group Final
Recommendation (Trustworthiness and data protection) lists similar, but not
identical, issues to be included in third party service agreements.
Recommendation 5.5.11 recommends development and implementation of
model agreements “clearly establishing responsibilities and liabilities.” Neither
CEN nor the Expert Group point to an existing model agreement for service
providers, but both recognize the need for one.
Recommendations CEN has provided significant guidance on the technical aspects of AES, both in
regarding Advanced CWA 15579 and CWA 16047 provisions regarding Class “C” Business Class and
Electronic Signatures Section 7.3.8 regarding single field encryption. While the Expert Group
recommends deleting all requirements for AES, as the Expert Group in Section
4.4 recognizes that non‐VAT issues may compel parties to voluntarily use AES,
such as for legal evidence purposes or internal election to do so.
Recommendations CWA 15579 (2007) contained specific recommendations regarding the
Regarding Format of characteristics of the invoice format (static non modifiable format). Expert
Invoices Group recommends (4.4) an ultimate goal of a single syntactical format but
recognizes in the interim 2 or 3 mutually interoperable syntactical formats will
best foster mass adoption . Recommendation 4.9 also recommends “use of
choreography specifications and format conversion tools will continue to
facilitate mapping”, which recognizes that formats may need to be converted
between trading partners.
Recommendations CWA 15575 (2009) and Annex 7 of the Expert Group list invoice content details.
Regarding Minimum Specific mapping between both lists remains to be conducted (OFS Portal is
Content preparing that mapping analysis separately).
Common Set of Expert Group Recommendation 3.1 recommends “consistent use” of
Definitions terminology. CWA 16049 (2009) contains a glossary of defined terms. Does this
CWA complete the Expert Group recommendation or is there more work to be
1

3. 20 January 2010
performed?
Definition of Electronic This issue is developed in CWA’s 16047 and 16049 (2009) but is not explored by
Invoice the Expert Group. Does CEN’s emphasis on an electronic data set help
implement Expert Group recommendations regarding format and clear
implementation guidelines?
Partial or Full Acceptance CWA 16047 explains that allowing invoice senders the option to designate
of Invoice whether a contested invoice should be rejected in full or in part will aid both
SME’s, who typically prefer partial rejection, and large trading partners, who
typically prefer rejection in full. This is consistent with Expert Group
Recommendation 1, which recommends meeting the needs of SME’s as a
“priority focus” by concentrating on specific business requirements.
Invoice Storage Both CWA 16047 and the Expert Group (Code of Practice, Section 11) anticipate
that converted invoices may be stored in different formats, so long as the
underlying transaction data and relevant supporting documentation are
accessible by tax auditors.
Conversion CEN CWA 16047 describes permitted forms of conversions, (to the extent
allowed under national law) and Expert Group Recommendation 4.9 calls on
CEN to support implementation guidelines that include the “use of choreography
specifications and format conversion tools” to facilitate mapping between
standards.
Other Means CWA 16047, Section 7.3.8 identifies several examples of “other means” and the
Expert Group recommendation calls for more Member States to implement the
“other means” option.
New Organization to EG recommends a multi‐stakeholder e‐Invoicing Forum at European Level made
Monitor and Promote e‐ up of 1 to 2 representatives per Member State bodies meeting quarterly. Is this
Invoicing derived from the CWA 16046 Community of Practice, or a separate process. If
separate, what is role of CEN?
2

4. Draft: 21 January 2010
Mapping Expert Group Final Recommendations Regarding CEN
to CEN Phases 3 and 4
Prior CWAs Expert Group Recommendation Future CWAs
CWA 16046 Responsibility for Recommendation 3: The multi‐ Should this be Phase 3,
(Adoption stakeholder e‐Invoicing Forum recommended below CWA 4 (Awareness and
programme for to operate at European level should take the lead, Promotion) or elsewhere
increased electronic supported by CEN, the service and solution provider in Phase 3? Is it a Phase
invoicing in community, as well as community projects, 4?
European business associations and user groups. Progress should be
processes) continuously monitored over the next two year
period in the expectation that tangible progress will
have be achieved by end‐2011.
CEN CWA 15574 July R4.9: The EG recommends that the European user Possibly Phase 3 CWA 1
2006 (recommends community should develop clear profiles and (Development of
broad definition of implementation guidelines based on common Sustainable Compliance
EDI and attaches recommendations facilitated through CEN to Guidelines for Electronic
model EDI Trading support the use of e‐invoicing and facilitate Invoicing) or CWA 2 (E
Partner Agreement)? interoperability. These implementation guidelines Invoicing Processes in
should be made freely available and stored publicly. Europe and enablement
CEN CWA 16047 (E‐ Until full standards convergence based on these of SMEs)
Invoicing Compliance implementation guidelines occurs, the use of
Guidelines) choreography specifications and format conversion
tools will continue to facilitate mapping between
standards.
Responsible for Recommendation 4: As stated Same as above, but
above, UN/CEFACT and ISO, as global standards deadline for the
organisations should continue to collaborate on the “implementation
development and maintenance of the CII. CEN guidelines” is September
should develop the required set of implementation 2010. Meeting this time
guidelines as soon as possible and no later than deadline will require
September 2010. All user groups adopt or are significant effort.
helped to adopt the standard, and all service and
solution providers (including ERP vendors) are
expected to implement in all applications.
R5.7: The EG recommends to continue the current General endorsement of
CEN Workshop and enhance its activities to take Phase 3 by Expert Group
account of the Expert Group recommendations. per discussions in
Brussels
Responsible for Recommendation 5: The Should this be CWA 4
European Commission and Member States to (Awareness and
establish the proposed forums by September 2010 Promotion) or elsewhere
with the engagement of all stakeholder groups. CEN in Phase 3? Is it a Phase
is to facilitate the continuation of its Workshop in 4?
synchronisation with these activities.
CWA 16047 (E‐ 4.5. Development of good practices Phase 3 CWA 1
Invoicing Compliance The Expert Group recommends the development (Development of
Guidelines) and use of tools for good practices. Such tools Sustainable Compliance
should be appropriate to the requirements of Guidelines for Electronic
trading parties, their advisers and service providers. Invoicing)
It is important that such tools do not impose new
requirements on trading parties, who have choice
and freedom over their use and that they are
technology neutral and fully aligned with the core
principles stated in the Code of Practice.
CWA 16047 (E‐ 4.5. Development of good practices Phase 3 CWA 1
Invoicing Compliance As an example and on a voluntary basis, tools such (Development of
Guidelines) as the E‐Invoicing Compliance Guidelines developed Sustainable Compliance
by the CEN/ISSS workshop on e‐Invoicing, could be Guidelines for Electronic

5. used by businesses and service providers, as a self‐ Invoicing)
assessment tool for auditing and compliance
checking e‐invoicing solutions and thereby provide
certainty on the appropriateness of the solution.
CWA 16050 5.2. Current market reality Phase 3, CWA 3
(Framework for Based on these trends, a number of interoperability (Conformance criteria for
emerging network initiatives are currently observable in terms of the interoperability across e‐
infrastructure of development of network models: business networks and
eInvoice service  The growth of interoperability agreements services)
providers throughout between service providers including
Europe) collective agreements.
Section 4.4 – Service  Banks providing channels and linking to
provider criteria other service providers in a number of
includes “appropriate markets and potentially on a pan‐European
date security” basis.
Section 4.5 – lists  Public initiatives such as PEPPOL and the
minimum Commission procurement programmes and
requirements for initiatives among various Member States.
interoperability  The CEN Workshop Agreement on the
agreements, interconnection of service providers being
including worked on in the CEN/ISSS‐eInvoice/2
“confidentiality and Workshop.
secrecy” but no  The issue of addressing is also receiving
details. increased attention.
CWA 16049 5.5.1. Identification of actors and roles Was this accomplished by
(Assessing new Actor and role definitions should be agreed and CWA 16049 or is there
business processes maintained by an appropriate body such as CEN and more to be done?
and technologies for shared with all stakeholders. They should also be
eInvoicing) aligned with those already used in other
standardization domains (e.g. UN/CEFACT and
ISO20022 repository definitions).
CWA 16050 5.5.5. Addressing and Routing Phase 3, CWA 3
(Framework for Industry participants are encouraged to cooperate (Conformance criteria for
emerging network in the development and adoption of more interoperability across e‐
infrastructure of interoperable and easy to use addressing and business networks and
eInvoice service routing procedures within a standards body such as services)
providers throughout CEN, taking due account of the relevant
Europe) international standards.
CWA 16050 5.5.5. Addressing and Routing Phase 3, CWA 3
(Framework for While these are desirable goals, we must live with (Conformance criteria for
emerging network the fact that there is a large number of different interoperability across e‐
infrastructure of entity identification systems for different purposes – business networks and
eInvoice service for instance the draft CEN Workshop Agreement services)
providers throughout (CWA) on Cyber Identity (to be published end‐2009
Europe); or early 2010) identifies 15 company identity ‘use
cases’ all with their own characteristics. Setting out
Need to review CWA requirements and encouraging convergence – in the
on Cyber Identity short or medium‐term – represent the first steps
when published. towards interoperable solutions.
CWA 16047 (E‐ 5.5.7. Use of Recommended Good Practice Phase 3 CWA 1
Invoicing Compliance Guidelines (Development of
Guidelines) The Guidance Recommendations propose the use of Sustainable Compliance
well constructed good practice guidelines as a self Guidelines for Electronic
assessment tool on a voluntary basis and draw Invoicing)
attention to the CEN Compliance Guidelines as a
recent good example that have defined a general e‐
invoicing process analysis model that can be applied
to a wide universe of implementation scenarios. In
‐ 2 ‐

6. addition to supporting legal compliance, these
guidelines also assist with achieving business and
organisational interoperability.
CWA 16049 6.6. E­invoice Content Standards – Phase 3?
(Assessing new Recommendations Is this accomplished by
business processes The European user community should develop clear CWA 16049 or is there
and technologies for profiles and implementation guidelines based on more to be done?
eInvoicing) common recommendations facilitated through CEN
to support the use of e‐invoicing and facilitate
interoperability. These implementation guidelines
should be made freely available and stored publicly.
Until full standards convergence based on these
implementation guidelines occurs, the use of
choreography specifications and format conversion
tools will continue to facilitate mapping between
standards. Note: Identical to Recommendation 4.9
above
7.2. Standardization Phase 3 and Phase 4.
The Expert Group recommendation is to continue How should CEN align
the current CEN Workshop and enhance its and coordinate with Pan‐
activities to take account of the Expert Group European e‐Invoicing
recommendations. The previous CEN/ISSS Forum(s)?
Workshops have worked well and could easily be
evolved into a long term activity. This activity
should be open to all interested parties, with
transparent governance and balanced
representation, a well accepted consultation and
decision making process, the continued expectation
that participants will provide the necessary
resources in terms of effort, and the assurance that
resulting standards will be made available free of
charge. The Workshop should operate on a rolling
basis with a work programme agreed at least
annually based on clear and measurable objectives,
business plans, the deployment of a qualified project
manager and draft consensus documents to be
submitted to public consultation. These activities
need to be fully aligned with the work of the Pan‐
European e‐Invoicing Forum described in the
paragraph above.
7.2. Standardization Phase 3 and Phase 4.
In the area of e‐invoicing, CEN should provide the Specific CWA’s?
necessary consensus‐based platform and tools to Forging, developing and
help the implementation of relevant standards in strengthening links with
Europe, and to ensure international standards other international
bodies meet European requirements. CEN will standards bodies should
continue to be the European gateway into be included in Phase 3
UN/CEFACT. and Phase 4
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7. Draft: 18 January 2010
CEN – Expert Group Mapping of Selected E­Invoicing Issues
Commission 2006 CWA 15574 or 2007 CWA 2009 CWAs 16046, 2009 Expert Group Final
Recommendation 2006 CWA 15581 15579 16047 CEN Good Report
94/820/EC Practice Guidelines,
16048, 16049, 16050 or
15575
Definition of EDI Recommends Model EDI 2006 CWA 15574 N/A CWA 16047 Defines EDI as Recommendation R2.2
Agreement Implements Commission follows:
Recommendation Recommends deleting Articles
Article 2.2 of Model EDI 94/820/EC Electronic data 232‐237 of Directive
Agreement defines EDI as interchange (EDI): The 1006/112/EC and Recommends
follows: Preamble states: “The transfer of commercial, adoption of proposed new VAT
term ‘EDI’ in the Directive administrative and Directive for the following
Electronic data 2001/115/EC should have business information reasons:
interchange is the the widest possible between computer  It clearly provides for the
electronic transfer, from meaning of formatted systems, using data elimination of the
computer to computer, of exchanges, not dependent formats which have been distinction between paper
commercial and on a specific ‘technology’ mutually agreed by the and electronic invoices for
administrative data using (EDIFACT, X‐12, XML, etc.), parties. EDI exchanges of VAT purposes.
an agreed standard to nor limited to specific invoices are normally used  It deletes reference to
structure an EDI message. international, national or between trading partners specific technologies such as
sector standards.” to (partially) automate EDI, electronic signatures
This definition was later their supply chain. In and other technical options.
adopted by reference in Revised Model EDI most interpretations, the  It eliminates the
Directives 2001/115/EC Agreement attached to use of structured data requirement for
and Directive CWA has following new alone does not make a authenticity and integrity as
2006/112/EC Article 232: definition for EDI: process EDI. a feature of the
Invoices sent or made transmission process for
available by electronic 2.2 EDI: A key element of an EDI electronic invoices.
means shall be accepted Electronic data system is the Interchange
by Member States interchange is the transfer Agreement between the See Reference to EDI in Section
provided that the of commercial, EDI trading partners 5.5.6, but no definition.
authenticity of the origin administrative and making provision for the
and integrity of the business information use of various technical, See also Recommendation 2.5
contents are guaranteed between computer security and business regarding implementation of
by one of the following systems, using data procedures including “other means” option pending
methods: messages as defined in 2.3 those amendment to Directive.

8. which have been mutually aimed at ensuring and
(b) by means of electronic agreed by the parties in proving the authenticity of
data interchange (EDI) as the transfer. the origin and integrity of
defined in Article 2 of the data.
Commission In this context, Electronic
Recommendation data interchange or EDI is
1994/820/EC of 19 a generic term that covers
October 1994 relating to conventional EDI file
the legal aspects of formats (UN/EDIFACT
electronic data [31], ANSI‐X12) as well as
interchange when the later developments using
agreement relating to the XML (Extended Markup
exchange provides for the Language) using
use of procedures UN/CEFACT or other
guaranteeing the formats.
authenticity of the origin
and integrity of the data; Note: CWA 16048
however Member States contains same definition;
may, subject to conditions CWA 16049 points out
which they lay down, difference between this
require that an additional definition and Commission
summary document on Recommendation
paper is necessary.
CWA 16048
7.1 EDI
The definition of EDI in the
directive 2001/115/EC is
based on and refers to
Article 2 of Commission
Recommendation
1994/820/EC of 19
October 1994. The
Recommendation is
restrictive and not
considered actual with
present day EDI
implementation of
UN/EDIFACT,
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9. UN/CEFACT, other
recognised standards, or
agreements between
trading partners. The CEN
e‐Invoicing Workshop
phase 1, recommended a
revision of the October
1994 Recommendation
and provided a proposal
for review by DG Taxation
and Customs (DG/TAXUD)
and DG Enterprise
(DG/ENTR).
The directive presents
three approaches, EDI,
digital signature or other
means. But several
Member States have
interpreted that as EDI
and digital signature or
EDI and other means. As a
consequence, the
application and use of e‐
Invoicing is not promoted,
as was the aim of the
directive 2001/115/EC,
but rather made more
complex, complicated, and
expensive.
The group strongly
recommend that it should
be possible to use EDI for
e‐Invoicing without
imposing additional
requirements, such as
digital signature or paper
summary sheet under the
provision that
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10. authenticity, non‐
repudiation, and integrity
are maintained by the
transmission technique,
e.g. the use of value added
networks (VANs) or other
reliable transfer protocols.
Model EDI Promulgated by Revised by CWA 15574 CWA 16046 References “Code of Practice” should be
Agreement Commission 94/820/EC but not CWA incorporated in bilateral
between Trading Recommendation 15574 revisions agreements entered into
Partners 94/820/EC between Trading Partners on
voluntary basis.
No other reference to Model EDI
Agreement
Model EDI CWA 15581 Section 3.7 Areas requiring
Agreement for improvement mainly involve
Service Providers 3.2 Third party service strengthening the trust
agreement environment
It is recommended that an Service providers should be
explicit agreement is encouraged to meet the
drawn up between the following requirements,
customer and the Service including a range of normal
Provider. In the terms within their contractual
agreement, at least the agreements with users. Such
following points should be provisions should encompass
considered: inter alia:
‐ the parties and the  Confidentiality of the
contact persons content of the submitted
‐ communications documents.
‐ intellectual property  The possibility to exclude
rights listings of data in public
‐ responsibilities and directories unless
duties, e.g. where, in the permission has been
process, is the granted.
responsibility transferred  Access to addressing data
to the SP should not be granted to any
‐ the level of service and private entities that intend
‐ 4 ‐

11. support to make use of it for
‐ data security and commercial purposes.
confidentiality issues Offering a fair pricing model
‐ liability for damages that recognises the real
‐ handling of disputes needs of trading parties to
‐ handling force majeure benefit from a coherent and
events well‐connected environment
‐ term of the contract for interoperability.
‐ cancellation of the  Unless specifically
agreement contracted by its principal, a
‐ making data and/or service provider should not
documents available on or open, interpret or
after termination. manipulate electronic
It will normally be messages without specific
appropriate to have authority. Unauthorised
agreements between the information‐transformation
customer and the may initially be seen as only
customer’s trading an information integrity
partners and/or between issue, but with a growing
the service provider and number of commercial
the customer’s trading documents exchanged
partners. electronically, many
organisations may also find
3.3 Interconnection it to be of commercial
agreement between concern.
Service Providers As appropriate, such provisions
It is recommended that an should also apply to trading
explicit agreement is parties in relation to each other
drawn up between the in order to safeguard data and
Service Providers. In the avoid unauthorised disclosures
agreement, at least the and unrequested process steps.
following points should be See also Section 5.5.11 (The
addressed Need for Agreements)
‐ the parties and the
contact persons;
‐ general obligations of a
contracting party;
‐ definitions of, and
‐ 5 ‐

12. standards for, the
contracting parties’
services;
‐ changing the services of
the contracting parties;
‐ service availability;
‐ technical solution;
‐ compensation for
damages and limits to
liability;
‐ confidentiality and
secrecy;
‐ agreement validity
period, and notice of
termination of the
contract;
‐ handling of disputes.
Recommendations CWA 15579, Class “C” of CWA 16047 Recommends deleting Article
regarding 2007 (E‐ 233(2) of Directive
Advanced Invoices and 2006/112/EC allowing Member
Electronic Digital states to require AES
Signatures Signatures)
Focuses on But notes in Section 4.4 that
technical non‐VAT issues may still require
implementation use of electronic signatures:
of Directive
2001/115/EC  Legal evidence of invoices in
provisions court procedures may
regarding require paper invoices or in
Advanced case of electronic invoices
Electronic may require electronic
Signature signatures.
 The need for
interoperability and
harmonization of e‐
Signature practices across
European Member States for
those trading parties that
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13. voluntarily choose to use e‐
Signatures.
Recommendations CWA 15579, R4.4: The EG recommends
Regarding Format 2007 convergence in the area of
of Invoices Therefore, it is syntax and methodology
highly expression. This convergence
recommended will avoid standards
that static non fragmentation and unnecessary
modifiable cost burdens. Whilst the
document ultimate goal should be the
formats are single syntactical format, it is
used that either clearly recognised that in the
do not outright interim 2 or 3 mutually
support active interoperable syntactical
code, which can formats would foster mass
dynamically adoption and provide support
change the for the reference semantic data
presentation, or model.
that allow for
disabling these
hidden codes
mechanisms.
As a matter of
fact, some
applicable law
outright
forbids the use
of macros and
hidden codes
mechanisms.
Recommendations CWA 15575, Recommendation 4:
Regarding November 29, The EG recommends that all
Minimum Content 2009, specifies actors within both the private
list of invoice and public sector adopt a
content details common invoice content
for Directive standard and data model – the
2006/112/EC UNCEFACT Cross‐Industry
expressed as Invoice (CII) v.2.
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14. UN/CEFACT
Core Recommendation R5.3:
Components The EG recommends to take
forward the CII v.2 content
standard: including the
preparation of a set of European
implementation guidelines to be
completed as soon as possible
and no later than September
2010.
R4.10: The EG recommends
that users of the referenced
semantic data model should
engage actively in the
maintenance and further
development of C11.
R4.11: The EG recommends
that UN/CEFACT completes the
necessary components to
support implementation of the
C11 v.2 standard as soon as
possible so that the whole
package can be launched by the
end of 2010.
Further to fostering
interoperability the Expert
Group has worked upon the
definition of
a 'core e‐invoice data set' (refer
to Annex 7) within the single
semantic data model. This is
core set of data elements that
constitutes the minimum legally
required and commonly
expected set of data ‐ among
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15. other things containing the data
specified in Articles 226 and
238 of Directive 2006/112/EC
for an invoice no matter the size
of enterprise of domain/sector
it is used within.
The proposed mechanism is that
any user of e‐invoicing at a
minimum will always support
this core set in any
implementation although in
almost all cases more elements
may need to be conveyed even
by SME users. The validation
though should preferably refer
to the full
semantic data model allowing
easy implementation of more
data elements. Hence it is also
recommended that ERP and
application service providers of
e‐invoice services implement
the full capability of the
recommended semantic data
model.
The core data set and the single
semantic data model support
basic cross‐industry e‐Invoicing
business requirements. They do
not include all business
requirements specific to any
one particular industry sector,
but will be applicable to a broad
community of users and
especially deliver support for a
core set of requirements
including integration to
payments
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16. and any common legal
requirements established by
relevant legislation.
The UN/CEFACT to complete
the necessary components to
support implementation of the
CII standard as soon as possible
so that the whole package can
be launched by the end of 2010.
Common Set of CWA 16049 contains set of R3.1: The EG recommends the
Definitions proposed definitions for consistent use of a terminology
key e‐invoicing terms to describe and clarify the roles
and responsibilities of actors.
Definition of CWA 16047: Electronic
“Electronic Invoice: An electronic
Invoice” dataset prepared by or on
behalf of a Supplier listing
items sold and presented
to the Buyer for payment,
which contains all details
agreed between the
Trading Partners.
Electronic Tax Invoice:
The designated electronic
invoice for tax audit
purposes with at a
minimum all the
properties that are legally
required. In this
Commentary and the
Compliance Matrix, the
Electronic Tax Invoice is
referred to as E­Invoice;
further the corresponding
terms E‐Invoicing and
Invoice/Invoicing are used
where appropriate.
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17.
While CWA’s 16048 and
16049 include these
definitions, CWA 16050
does not.
Partial or Full CWA 16047, Section 7.4.1 The EG recommends meeting
Acceptance of It is recommended that the needs of SMEs as a priority
Invoice the Supplier be enabled to focus, by concentrating on a
designate whether an number of specific business
incorrect or contested requirements.
invoice must be rejected in
full or may be partially
rejected with partial
payment, but the trading
partners must reach
agreement on that election
based on their particular
circumstances. Allowing
Suppliers to make such an
election may have a
significant impact on rate
of
adoption as many SME’s
may elect to allow partial
rejection in order to
receive partial payment
prior to
reconciling the Invoice and
maximize their working
capital. Larger Supplier
enterprises operating ERP
systems may prefer only
full rejection of their
Invoices in order to
minimize the costs
associated with
reconciling a partial
payment against the
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18. invoiced amount.
Imposing a universal
“reject in full” rule on all
Suppliers might impose
significant burdens on
SMEs whose cash flow
depends on receiving a
partial payment of the
uncontested amount,
while imposing a “partial
rejection” rule on all
Suppliers may impose
significant administrative
cost and burden on larger
Suppliers.
Invoice Storage CWA 15579 CWA 16047, Section 11 “Core Principles” of Code of
“The authenticity of the 6.6.3(c) To the extent Practice includes “Auditability”
origin and integrity of the permitted by applicable Auditability: Businesses must
content of the invoices, as law, the parties may also be able to demonstrate and
well as their readability, agree to store their E‐ explain their administrative and
must be guaranteed Invoice sent or received in control capability. Businesses
throughout the storage their respective formats must maintain an audit trail,
period…. The information (i.e. the Supplier stores the including the underlying
they contain must not be invoice in the format it transaction data and any
altered; it must remain was in when it left the relevant supporting
legible throughout the Supplier’s computer or documentation and data, which
aforementioned period”. ERP system and the Buyer must be accessible towards
Citing Directive stores the invoice in the external auditors, both statutory
2001/115/EC format it was consumed in and tax. Accessibility must be
by its computer of ERP ensured for at least six years.
Proposed Directive on VAT system) for the specified
Invoicing Amending time to allow for
2006/112/EC, Article 249 comparison between the
stored E‐Invoice to
“For control purposes, determine that the
where a taxable person conversion did not alter
stores, by electronic the information
means guaranteeing on‐ represented in the
‐ 12 ‐

19. line access to the data EInvoice.
concerned, invoices which
he issues or receives, the
competent authorities of
the Member State in which
he is established and,
when the VAT is due in
another Member State, the
competent authorities of
that Member State, shall
have the right to access,
download and use those
invoices.”
Conversion CWA 15581: CWA 16047, Section 6.6.3: Using a Signed PDF has the
Conversions that only benefit of transmitting a
3.5 Conversions between change the format of the universally accepted format that
formats electronic invoice in allows easy readability for
Conversions from one accordance with agreed workflow applications and tax
format to another are and reproducible maps are audits. It is accepted practice
needed, as there are many considered not to for unsigned structured data to
individual formats in use substantively alter the be transmitted together with
for electronic invoicing – data contained in the the signed invoice so that data
even within a single electronic invoice. To the conversions can easily be
Member State. However, extent permitted by performed at every step where
the need for conversion applicable law, the parties necessary.
should be minimised may also agree to store
wherever possible and their E‐invoice sent or R4.9: The EG recommends that
conversions restricted to received in their the European user community
those that are necessary to respective formats (i.e. the should develop clear profiles
bridge the differing Supplier stores the invoice and implementation guidelines
formats of the message in the format it was in based on common
originator and the when it left the Supplier’s recommendations facilitated
message end receiver, computer or ERP system through CEN to support the use
since repeated and the Buyer stores the of e‐invoicing and facilitate
conversions may result in invoice in the format it interoperability. These
loss of data quality, or was consumed in by its implementation guidelines
even loss of data, in the computer or ERP system) should be made freely available
individual messages being for the specified time to and stored publicly. Until full
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20. converted. allow for comparison standards convergence based
between the stored E‐ on these implementation
Invoice to determine that guidelines occurs, the use of
the conversion did not choreography specifications and
alter the information format conversion tools will
represented in the E‐ continue to facilitate mapping
Invoice. between standards.
CWA 16050:
5.2 Recommendations
for conversion
In situations where
conversion is needed a
service provider should
not make any changes or
other reproduction in the
content of an electronic
invoice message while it is
in his custody, unless
agreed with his client.
Service provider carrying
out conversion services
shall provide his client
with details of the
conversion and, if needed,
advise on the necessary
mechanisms for storage
and audit trail.
Conversions are always
increasing the cost,
complexity and possibility
for errors and
malfunctions in the
eInvoicing chain. Hence,
unless specifically
contracted by trading
party, a service provider
shall make no
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21. attempt to open, interpret
or reproduce electronic
messages.
A great step forward in
national, regional and
international environment
would be a commonly
agreed interchange format
in eInvoicing
communication between
service providers. The use
of common format could
create remarkable benefits
and cost savings in terms
of fewer conversions made
by service providers as
well as reduced need of
mapping of invoice
content when establishing
new connections.
Data Protection Commission Recommendation R1.5:
Recommendation
1994/820/EC October The EG recommends to develop
1994, Article 7.1 of Model and maintain a competitive and
EDI Agreement: trusted market place for
services and solutions and
The parties shall ensure assure trustworthiness and data
that EDI messages protection.
containing information
specified to be confidential
by the sender or agreed
mutually to be confidential
between parties, are
maintained in confidence
and are not disclosed or
transmitted to any
unauthorized persons nor
used for any purposes
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22. other than those intended
by the parties.
Manual Processes While manual processes R1.2: The EG recommends that
are permitted when e‐Invoicing should enable SMEs
agreed upon by mutual to create savings in time and
consent of the parties, the money through a favourable
requirement to use cost/benefit equation and that
manual processes should all e‐Invoicing solutions and
not be imposed on any tools should be easy to use.
trading partner by another
trading partner.  Business integration:
Integration of services with
other process, systems or
solutions is competitive.
“Other Means” CWA 16047 Section 7.3.8 Recommendation R2.5:
Lists several examples of
“other means”: SSL/TLS, A The EG recommends that in the
S1‐3, secure e‐mail, single short term, pending the
field encryption, VAN, adoption of the new VAT
OFTP/OFTP2 Directive, those Member States
who have not yet done so,
should implement the option of
‘other means’ as provided for in
the current VAT directive
(Directive 2006/112/EC) so as
to enable the practical
implementation of the Expert
Group’s Code of Practice.
New Organisation e‐Invoicing Gateway, R5.2: The EG recommends to
to Monitor and enlisting of organizations, set up a pan‐European e‐
Promote e­ Country leads and Invoicing Forum.
Invoicing proposed annual event of R5.2.1: The EG recommends
“Community of Practice” that there should be a multi‐
of CWA 16046 stakeholder e‐Invoicing Forum
at European level, made up of 1
or 2 representatives of the
Member State bodies meeting
quarterly (or as required more
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23. frequently).
R5.2.2: The EG recommends
that ten further seats should be
added for experts,
constituencies missing from the
national selection processes,
pan‐European associations, and
the Commission etc. The
European Commission should
ensure a balanced composition
of interested stakeholders.
R5.2.3: The EG recommends
that the body should elect a
Chair and a Steering Committee
and be supported by a
Secretariat provided by the
European Commission, who
should take a pro‐active role. It
should have the necessary
resources to undertake wide
communication and maintain an
active website.
R5.2.4: The EG recommends
that the Commission should
continue to drive the
development by establishing the
Forum for at least an initial
period of two years as no
market driven body able to take
on this task has been identified.
R5.2.5: The EG recommends
that the body should have the
following concrete tasks in full
liaison with the national e‐
Invoicing bodies:
• Support and monitor adoption
of the Invoicing Directive and
other regulatory simplification
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24. and harmonization
recommendations;
• Maintain and further develop
the Code of Practice;
• Support and monitor adoption
of the CII and give continuing
guidance to relevant
standardization bodies for
further development of
standards;
• Support and monitor roll‐out
and observance of the Guidance
Recommendations for
Interoperability;
• Monitor adoption rates of e‐
invoicing and identify and share
best practices;
• Identify and promote EU‐wide
action harmonization programs
– such as automation of
procurement, accounting and
financing enhancements etc. –
building on the einvoicing
platform;
• Undertake communication and
promotion, regulatory relations,
and stakeholder consultation
and take responsibility for the
proposed communications plan
described in the next
recommendation;
• Provide an environment for
the progressive maintenance
and further development of the
European e‐Invoicing
Framework, as required.
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