activity 1 interoperability analysis of the electronic ... · invoice sending process in a micro...

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E-Invoice

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Activity 1

Interoperability Analysis of the Electronic

Commercial and Transport Invoice

Document Version: 2

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ABSTRACT

This document provides a report of the work carried on in the period from September

2013 to April 2014 by partners participating at the B2MOS sub-activity 1.2

Interoperability Analysis of the Electronic Commercial and Transport Invoice. The aim

of the work was to analyse the use of electronic invoices in particular in intra-EU trade

and transport with the aim of understanding the obstacles and bottlenecks and suggest

recommendations to increase the level of dematerialisation.

DISCLAIMER

“The sole responsibility of this publication lies with the author. The European Union is not

responsible for any use that may be made of the information contained therein.”

AUTHORS

Boris Šušmak, Taj Morel and Martina Gržančić - Luka Koper, d.d.

Rok Bojanc, Luka Koper ZZI d.o.o.

Birgit Kreiensiek, Manuel Kamphues and Stefan Henke - dbh Logistics IT AG

Miguel Llop, Valenciaport Foundation

Jana Barba, Branko Lozej and Marijana Dobnikar - Intereuropa d.d.

Albert Ruiz and Bert Cappuyns – Portic

CONTRIBUTORS

Port Authority of Valencia

Boluda Lines

GRM

TIBA

2E3S

Contenosa

Port Authority of Bilbao

Neptune Shipping Lines

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Global Maritime Agency

Piraeus Port Authority

VERSION HISTORY

Date Document Version Document Revision

History

Document

Author/Reviser

Apr. 2014 1.0 First Draft (vs 1) Martina Gržančić

APPROVALS

Date Document Version Document Approved by

Apr. 2014 1.0 First Draft (vs 1) Martina Gržančić

13 October 2014 2.0 Second Draft (vs 2) Project Board

TABLE OF CONTENTS

ABSTRACT ............................................................................................................................................................................. 2

DISCLAIMER ......................................................................................................................................................................... 2

AUTHORS ............................................................................................................................................................................... 2

CONTRIBUTORS ................................................................................................................................................................. 2

VERSION HISTORY ............................................................................................................................................................ 3

APPROVALS .......................................................................................................................................................................... 3

TABLE OF CONTENTS ...................................................................................................................................................... 3

INDEX OF GRAPHS AND FIGURES ............................................................................................................................... 5

INDEX OF TABLES ............................................................................................................................................................. 6

GLOSSARY OF ABBREVIATIONS .................................................................................................................................. 6

GLOSSARY OF TERMS ...................................................................................................................................................... 7

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1 Introduction ................................................................................................................................................................... 8

1.1 Main objective of the initiative ...................................................................................... 8

1.2 The European Framework ............................................................................................. 9

1.3 Definitions and general technical aspects ................................................................... 10

1.4 Potential benefits and savings .................................................................................... 15

1.4.1 Germany ............................................................................................................................................... 20

1.4.2 Slovenia ............................................................................................................................................... 21

1.4.3 Spain ..................................................................................................................................................... 21

1.4.4 Greece ................................................................................................................................................... 21

2 Current situation of electronic invoicing systems in different Member States .................................. 22

2.1 Report on Greece ......................................................................................................... 23

2.1.1 Legal Framework ............................................................................................................................. 25

2.1.2 Initiatives of the public sector and organised groups at national level ..................... 26

2.1.3 Standardisation actions ................................................................................................................. 28

2.1.5 Archiving ............................................................................................................................................. 29

2.1.6 Identified obstacles in using e-Invoicing ................................................................................ 30

2.2 Report on Germany ..................................................................................................... 31

2.2.1 Legal Framework ............................................................................................................................. 34

2.2.2 Initiatives of the public sector and organised group at national level ....................... 35


2.2.4 Role of intermediaries.................................................................................................................... 40

2.2.5 Archiving ............................................................................................................................................. 41


2.3 Report on Slovenia ...................................................................................................................... 43

2.3.1 Legal Framework ............................................................................................................................. 46




2.3.5 Archiving ............................................................................................................................................. 50


2.4 Report on Spain ........................................................................................................................... 50

2.4.1 Legal Framework ............................................................................................................................. 52




2.4.5 Archiving ............................................................................................................................................. 59

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3 Solutions for using electronic invoices for billing MoS transport services, port operations and port dues .............................................................................................................................................................................. 60

3.1 Greece .......................................................................................................................... 60

3.2 Germany ...................................................................................................................... 61

3.3 Slovenia ........................................................................................................................ 63

3.4 Spain ............................................................................................................................ 66

4 Roadmap for the establishment of an electronic invoice environment for intra-EU freight flows .... 68

BIBLIOGRAPHY ................................................................................................................................................................ 71

INDEX OF GRAPHS AND FIGURES

Figure 1. CEN document catalogue for e-Invoice. Source: European Committee for the Standardization web site ............................................................................................................................................. 14 Figure 2: Overview of main market models. Source: Billentis ................................................................... 15 Figure 3. Invoice sending process in a Micro Company, Business Case in Finland, 2008. Source: Electronic Invoicing Initiatives in Finland and in the European Union, Helsinki School of Economics, 2008 ............................................................................................................................................................. 17 Figure 4. Invoice receiving process in a Micro Company, Business Case in Finland, 2008. Source: Electronic Invoicing Initiatives in Finland and in the European Union, Helsinki School of Economics, 2008 ............................................................................................................................................................. 18 Figure 5. Saving potential for invoice/ bill issuers. Source: Billentis...................................................... 18 Figure 6. Saving potential for invoice recipients. Source: Billentis.......................................................... 19 Figure 7. e-Invoice service ......................................................................................................................................... 24 Figure 8. E-Invoices via SPs in Greece ................................................................................................................... 25 Figure 9. Example of Information included in the Header section............................................................ 29 Figure 10. Method of sending invoices. Source: ibi research 2011 I www.elektronischerechnungsabwicklung.de ..................................................................................................... 32 Figure 11. Overview of outgoing invoices. .......................................................................................................... 33 Figure 12. Incoming Invoices. ................................................................................................................................... 34 Figure 13. Official Logo of PDF/A3. ........................................................................................................................ 39 Figure 14. Incoming invoice procedure with ZUGFeRD. ............................................................................... 39 Figure 15. Outgoing invoice procedure with ZUGFeRD. ................................................................................ 40 Figure 16: Overview constrains of sending electronic invoicing. Source: ibi research 2011/ www.elektronische–rechnungsabwicklung.de .................................................................................................. 43 Figure 17. Market maturity for e-Invoicing ........................................................................................................ 44 Figure 18. B2B/B2G/G2B - Estimated expected market penetration in year 2013 by Country. Source: Billentis, 2013 ................................................................................................................................................. 44 Figure 19. B2C - Estimated expected market penetration in year 2013 by Country. Source: Billentis, 2013 ................................................................................................................................................................... 45 Figure 20. Percentage (%) of companies using electronic invoices. Source: www.ontsi.red.es / Eurostat ............................................................................................................................................................................... 51

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INDEX OF TABLES

Table 1. The categorisation of the companies in Greece, in terms of micro, small, medium and large entities definitions. ............................................................................................................................................ 24

GLOSSARY OF ABBREVIATIONS

AO Abgabenordnung AP Accounts payable AR Accounts receivable B2B Business to business B2C Business to Consumer B2G Business to Government CEN European Committee for Standardization CII Cross Industry Invoice CSV Comma Separated Values DB Database e.g. for example EC European Commission EDI/EDIFACT Electronic Data Interchange For Administration, Commerce and

Transport EEIF European Electronic Invoicing Framework e-Invoicing Electronic invoicing EMSF European Multi- Stakeholder Forum ERP Enterprise Resource Planning Etc. Et cetera EU European Union FeRD Forum elektronische Rechnung Deutschland – forum of

electronic invoice Germany ftp(s) File transfer protocol (secure) G2B Government to Business GoBS Grundsätze ordnungsmässiger DVgestützer

Buchführungssysteme GS1 Global Standards One http(s) Hypertext transfer protocol (secure) ICT Information and Communications technology KMU Kleine und mittlere Unternehmen – Small and medium

Enterprises MINETUR Ministry of Industry, Energy and Tourism MoS Motorways of the Sea MUG Message User Guide OSIS Open System Integration Server, a converting and

communication tool of LS GmbH, Syke, Germany

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PDF Portable Document Format PPE presentment and payment SigG Signaturgesetz – signature regulation SIGV Signaturverordnung SME Small and Medium Enterprises THC Transport handling cost UBL Universal Business Language UN/CEFACT United Nations Centre for Trade Facilitation and Electronic

Business UStG Deutsches Umsatzsteuergesetz (UStG) – German Value Added Tax

Act) VAT Value added tax VeR Verband elektronischer Rechnung e.V. – E-Invoice Alliance

Germany VOI Verband Organisations- und Informationssysteme e.V. –

Federation of Organisation and Information Systems e.V. XML Extensible Markup Language ZDavP Zakon o davčnem postopku - Tax Procedure Act ZDDV Zakon o davku na dodano vrednost – Value Added Tax Act ZEPEP Zakon o elektronskem poslovanju in elektronskem podpisu –

Electronic Commerce and Electronic Signature Act ZUGFeRD Zentraler User Guide des Forums elektronisce Rechnung – central

user guide of the electronic invoice forum of Germany ZVDAGA Zakon o varstvu dokumentarnega in arhivskega gradiva ter

arhivih - Protection of Documents and Archives and Archival Institutions Act

ZOPSPU-A Zakon o opravljanju plačilnih storitev za proračunske uporabnike (Ur.l. RS št. 111/2013 z dne 27.12.2013) – providing payment services for budget users

GLOSSARY OF TERMS

Electronic

invoicing/

e-Invoicing

Although there is no official biunique definition of e-Invoicing for the

purpose of this study, e-invoicing will be considered an electronic transfer

of invoicing information (billing and payment) between business partners

(supplier and buyer)

Action “Business to Motorways of the Sea” Action

B2MoS “Business to Motorways of the Sea”

Commission Commission of the European Communities

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1 Introduction

Shippers and freight forwarders are increasingly demanding dematerialisation of

documents as they seek to remove inefficiencies from business processes. The

possibility to transmit commercial invoices electronically (further in the document e-

Invoicing) could provide significant benefits for intra-EU trade and transport.

Interoperability in e-invoices could also be used to simplify the billing and payment of

transport services to different carriers, as well as to pay port dues and THC (Transport

Handling Costs) in MoS routes.

1.1 Main objective of the initiative

The sub-activity A1.2 consisted of the following activities:

Preparation of an analysis of the current situation regarding the use of e-

invoicing in Spain, Greece, Germany and Slovenia (Member States of partners

that are participating at the activity);

Specification of needs and opportunities for the transport sector with a

particular focus on MoS and;

Creation of a Roadmap containing recommendations about actions to be taken

to create a favourable environment for e- Invoicing along the MoS corridors.

The aim of these activities was to learn about the maturity of the European markets for

the use of e-Invoicing whilst also considering the established legal framework. That was

achieved by partners researching the available literature, but also by approaching

members of the National Multi-Stakeholder forums. To understand the needs of the

transport sector, to discover limitations and obstacles that are preventing a greater use

of e-Invoicing, partners carried out a series of interviews with the members of port

communities of Valencia, Barcelona, Koper and Piraeus as well as other transport and

maritime operators. Finally the work was concluded with the preparation of a list of

suggested actions to overcome the identified problems.

The main objective of our work was finally to promote the use of e-Invoicing and on that

account dissemination events were organised by project partners.

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1.2 The European Framework

Over the last few years several initiatives took place to promote the use of e-Invoices and to

tackle technical issues that appeared during the development phase. Beside work carried out by

various organisations and projects it is worth emphasizing the efforts carried out by the

European commission to address e-Invoicing matters.

In December 2010, in a Communication entitled “Reaping the Benefits of Electronic Invoicing for

Europe (EC 2010a)”, the European Commission set out its vision for making e-Invoicing the

dominant form of invoicing in Europe by 2020. Reaping the Benefits of Electronic Invoicing for

Europe proposed the creation of a European Multi- Stakeholder Forum (EMSF) on e-Invoicing in

line with the Expert Group’s proposals, as well as the creation of corresponding national multi-

stakeholder forums in the member states. Its recommendations were accompanied by a

Commission Decision (EC 2010b). The mission of the EMSF is to assist the Commission in the

monitoring of the development of the e-Invoicing market and the e-Invoicing adoption level in

industry and services across the Member States.

Other related legislative acts address e-Invoicing directly or indirectly. The Council Directive

2010/45/EU, referred to also as e-Invoicing directive, on the common system of value added tax

revises and simplifies the rules for the submission of electronic invoices, setting the electronic

and the paper invoice on an equal footing1. A great freedom is given by the Directive to the

electronic-invoicing technology 2. The Directive establishes that the authenticity of the origin, the

integrity of the content and the legibility of an invoice, shall be ensured from the point in time of

issue until the end of the period for storage of the invoice, but it sets also conditions for storage3

and control4. The regulation also foresees the issue of batches of invoices.5

1 Par. 8: Since the use of electronic invoicing can help businesses to reduce costs and be more competitive,

current VAT requirements on electronic invoicing should be revised to remove existing burdens and barriers to

uptake. Paper invoices and electronic invoices should be treated equally and the administrative burden on paper

invoicing should not increase.

2 Par. 11: The authenticity and integrity of electronic invoices can also be ensured by using certain existing

technologies, such as Electronic Data Interchange (EDI) and advanced electronic signatures. However, since

other technologies exist, taxable persons should not be required to use any particular electronic-invoicing

technology.

3 Art. 247: ...the Member State … may require that invoices be stored in the original form in which they were

sent or made available, whether paper or electronic. Additionally, in the case of invoices stored by electronic

means, the Member State may require that the data guaranteeing the authenticity of the origin of the invoices

and the integrity of their content, as provided for in Article 233, also be stored by electronic means.

4 Art. 249: For control purposes, where a taxable person stores, by electronic means guaranteeing online access

to the data concerned, invoices which he issues or receives, the competent authorities of the Member State in

which he is established and, where the VAT is due in another Member

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With the introduction of the mandatory e-procurement, that is being pushed forward by the

Commission, all of the phases of the procedure (publication of tender notices, access to tender

documents, submission of tenders, evaluation, award, ordering, invoicing and payment) will be

conducted electronically, which will cause an increase in the use of e-Invoicing.

Support to digital services infrastructure was further also expressed in the instrument

»Connecting Europe Facility (CEF).

Among non-legislative initiatives brought forward by the Commission, there is the initiative " A

Digital Agenda for Europe«, COM(2010) 245, which should be emphasized since it calls for

removing the regulatory and technical barriers which prevent mass adoption of e-Invoicing.

By setting such a favorable environment that clearly promotes the dematerialization of invoices,

it seems that activities carried out by Member States in transposing such provisions in their own

juridical systems and stimulating e-Invoicing could play a very important role.

Moreover, since the public buyers are traditionally the largest consumer in the economy, it is

relevant also how the public sector is stimulated to use e-Invoicing.

1.3 Definitions and general technical aspects

An invoice, paper or electronic, is a document certifying the delivery of a product or the

provision of a service, showing the date of accrual and the amount payable in

consideration for the product or service provided. The invoice contains the issuer’s and

recipient’s details, a description of the products and services provided, unit prices, total

prices, discounts and taxes.

A particularly relevant use of the invoice is that it is considered to be the fiscal proof of

delivery of a product or provision of a service affecting the tax-paying issuer (the seller)

and the tax-paying recipient (the purchaser). A properly drawn-up invoice is the only

tax receipt that gives the recipient the right to claim a tax refund (VAT).

Since the term e-Invoicing is used in very different situations, for the purposes of the

current study we will consider (full) e-Invoicing the act of receiving and or sending e-

Invoices in a structured format that is suitable for automated processing. In fact this

type of e-Invoicing permits the major benefit both for the invoice issuer and for the

State, the competent authorities of that Member State, shall have the right to access, download and use those

invoices.’

5 Art. 236: Where batches containing several electronic invoices are sent or made available to the same

recipient, the details common to the individual invoices may be mentioned only once where, for each invoice, all

the information is accessible.

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recipient, since savings occur in financial terms and in terms of time management (ex.

automation of payment procedures etc.).

Nevertheless is appears true that currently operators are approaching electronic

formats by exchanging pdf files through e-mail, also sending paper invoices at the same

time for archiving purposes. During our interviews a relatively small number of subjects

were acquainted with the difference between a structured and a non-structured e-

Invoice, which means that communication activities to promote benefits of e-Invoicing

still need to be done. Taken into consideration the actual situation, it appears relevant

to depict the benefits of the use of invoices in pdf exchanged by e-mail as well as (full) e-

Invoices. It should be emphasized that in the case of e-Invoices in pdf format, savings

arise only on the side of the printing and distribution, as automation procedures using

such e-Invoice document is not possible.

Apart from paper invoices there is a wide scope of possibilities to transfer an invoice

electronically. The most common ways are the following:

via e-mail (e.g. with attached invoice in form of pdf-document or/and xml file);

via web portal (up- and download);

via computer fax;

Via EDI (other forms of data transfer, e.g. https or ftp).

Transmission of e-Invoices and other e-documents via EDI is considered the most secure

and most reliable delivery. At the same time EDI supports a maximum level of

automation of business processes within enterprises and between partners.

A non-uniform use of the term e-Invoicing is making it difficult to compare data

gathered by national statistical offices and the actual penetration of e-invoicing.

However according to Koch6, a greater permeation of e-Invoices that appears from

official statistics, is in fact a statistical effect that was created by the new EU legislation

that considers unsigned pdf invoices as valid e-Invoices.

To simplify the understanding of (full) e-Invoice, one can say that an e-Invoice consists

basically of two elements – a data and an image component. The data component has a

structured form, containing several data fields that constitute the content of the invoice.

Among the data components, there is also the digital signature, which ensures the

authenticity of the issuer and the integrity of the content of the document. If needed, the

e-Invoice also contains attachments. The purpose of the data content element is process

automation on the receiver side. The image element on the other hand provides a

human readable presentation of the invoice used for workflow and archiving. When

6 Bruno Koch, Billentis, International Market Overview & Forecast, February 2014

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archiving e-Invoices it is necessary to take into account local tax legislation. Usually it is

necessary to save both a data and an image component.

An example of a general structure of a simple invoice with all mandatory and common

invoice elements used in practice:

The head of an invoice (account number, date of issue ...).

Operators of an invoice (payer / customer / subscriber / recipient, issuer).

Items (description, quantity, price, discounts, tax base, tax rate ...).

Summaries of taxes (totals at the tax rates...).

The sum of an invoice (payment amount, invoice amount, the VAT amount ...).

Closure of invoice (free text).

Footer invoice (requested information about the issuer ...).

As an example the schema of the e-SLOG simple invoice 1.6 is presented in the Annex I to

the present report. The scheme also defines the set of allowable value of certain

elements of the code lists.

In case the network model (see below market models) is chosen for transmitting the

invoice, the e-Invoice must have an envelope. The e-Invoice and an envelope are two

separate elements that can be combined into a single file. The envelope of an e-Invoice is

an electronic document that is usually composed of two parts: a “header” placed at the

beginning of an invoice data and a “trailer” that will follow an invoice data.

While the e-Invoice contains data for the preparation of payments, the envelope

contains information about the issuer, recipient, a description of the type of document,

the number of segments included in that document and contain the data for document

routing through the network. Envelopes are independent of the format of an e-Invoice.

Technical syntax standards for e-Invoice specifying only the data part, while the

envelopes are not included in these standards. The syntax of envelopes is usually

defined by individual network operators.

One of the major issues that arises whilst discussing e-Invoicing involves

standardisation. There are more than 450 technical syntax standards in Europe and

there are common global and regional standards, industry specific standards and

national standards. Although the selection of a single standard doesn’t appear to be

feasible or desirable - there are peculiarities influencing the content of the e-invoices

due to tax regulation, peculiarities of other national provision or peculiarities related to

business sectors - in practice some standards tends to prevail. Already today it appears

that few standards (CEN, UBL, EDIFACT) cover 99% of the existing market. The

European Commission decided however that semantics rules for the core of the e-

Invoices must be created.

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The final report of the Expert Group on e-Invoicing in 20097 proposed a European

Electronic Invoicing Framework (EEIF)8. The EEIF is expected to establish a common

conceptual structure, including business requirements and standards, and propose

solutions supporting the provisions of e-invoicing services in an open and interoperable

manner across Europe. Afterwards the EC Communication on “Reaping the benefits of

electronic invoicing for Europe” appointed CEN (European Committee for

standardisation) the design of implementation guidelines for a common invoice content

standard. To this end, CEN has set up a joint project, named MUG9 (Message User Guide)

to carry out these activities and published a CWA/Guide. One of the relevant

deliverables of this guide is a reference semantic data model that is the Core European

data Model. The work carried out by CEN respects the fact that in short term the market

will use a series of syntaxes, but at the same time this work points towards the future,

the way for harmonization of European requirements and the ultimate goal of providing

one syntax solution for the European market. The guideline represents an agreement on

the content and rules for a core invoice for conducting trade within the European Union

and EEA. As such, it does not mandate that trading partners structure their invoices

accordingly but provides an option that may facilitate wider interoperability than

bespoke implementations.

7European Commission's activities on e-Invoicing. http://ec.europa.eu/enterprise/sectors/ict/e-invoicing/benefits/index_en.htm 8 http://ec.europa.eu/enterprise/sectors/ict/files/finalreport_en.pdf, page 19 9 CEN. Guide for a European CORE INVOICE data model with UN/CEFACT CII Implementation Guideline – Part 1: Introduction. CWA 16356-1:2011

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Figure 1. CEN document catalogue for e-Invoice. Source: European Committee for the

Standardization web site

While talking about the transmission of electronic invoices, the following models are

exposed as main market models:

The seller or supplier direct model.

The buyer-direct model.

The consolidator model or network model.

In the seller or supplier direct model, the seller installs the electronic invoice AR

solution to send invoices electronically to its customers. In turn, the seller sends them to

customers via e-mail, SMS etc., but normally provides a portal on which customers can

login, view invoices and download them.

In the buyer-direct model, it is the buyer who implements the AP solution to receive

invoices electronically from its customers. The buyer gets invoices directly as a data

stream for importing them into his AP solution, where smaller suppliers can generate

invoices using a web-template on the corporate invoice portal of the buyer.

The main disadvantage of these two models is the need for multiple integration projects.

The third alternative foresees a consolidator that provides an interface between

multiple sellers and buyers. Issuer and recipient have just one interface to their service

provider (called also e-delivery provider, processor etc.). The operator acts as postman,

delivering invoices, but can offer also conversion of standards, archiving and other

added value services. The operator guarantees the main legal requirements, authenticity

of the issuer and data integrity. The provider ensures secure delivery of the e-Invoice

through protected exchange channels. Based on the information in the envelope, the

provider identifies the recipient and delivers the document to its address. In the case

that the issuer and the recipient of an e-Invoice are using different standard and the

format of an e-Invoice, the provider also makes an adjustment - the conversion between

documents. The conversion is carried out in real time during the exchange. On the other

hand, the provider should not interfere with the content of the document. The provider

only ensures the delivery of the e-Invoice, such as the postman. Providers also enable

the delivery reports and traceability of delivery. Different providers with their own

networks connect with each other and allow the transmission of documents between

networks, like telecom operators.

The e-delivery providers can be classified on account of the solutions they are running

or the services they are providing. Some of the most important aspects are the following:

Target group (small, medium-size or big companies).

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Sending invoice procedure (invoice party).

Receiving invoice procedure (bill-to party).

Way of data exchange (technical aspects, communication protocol, format, etc.).

System integration.

Maintenance and support fees.

Additional services (e.g. archiving).

Among the reasons why companies are using external service providers (outsourcing)

or e-delivery providers are that they benefit from the advantages as the service is legally

compliant and enables them to concentrate on their core business. The provider, with its

electronic exchange network, represents for an enterprise’s single point of exchange,

which means unify documents, ways of data exchange and processes for all partners. A

large number of business partners can interconnect without the need to modify or

upgrade their existing ERP or information systems. On the other hand the companies do

not like to be dependent from an external service provider.

Figure 2: Overview of main market models. Source: Billentis

1.4 Potential benefits and savings

To help move from a paper invoice to an electronic invoice, organisations need to be

convinced of the benefits that have been achieved by companies who employ this

strategy. The benefits of e-Invoicing when compared to paper-based invoicing are

numerous. Electronic processing of invoices generates operational savings due to less

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complex processes and shorter processing times; it increases transparency, improves

the security and auditability of data; reduces the number of human errors; and can

reduce the administrative burden for enterprises. It is also better for the environment.

From the point of view of an organisation, introducing e-Invoicing is only one of many

possible automation improvements that can be made to bring overall higher added

values (electronic purchase, electronic approval workflow, integrate payables with back-

end systems etc.). To reach the purposes of this study and due to time limitations no

attention was given to opportunities coming from the electronic management of orders

and complete dematerialization of procurement process, although there are no doubts

about their potential advantages.

Many studies have been conducted to calculate the financial savings deriving from the

introduction of e-Invoicing. However, it should be stressed that only a complete

transition to e-Invoicing can produce such savings. In case both the systems persist, the

cost to process invoices may even double.

It appears difficult to show potential savings with just a single amount of money or one

specific cost level which covers the investment needed to implement an electronic

invoicing system for whatever organization. There are multiple aspects and variable

factors, which reflect directly on the investment. The investment depends for instance

on the size of a company and the related volume of data or amount of invoices sent out

and received. Some differences need to be made if an in-house system, a web portal or

an external service provider is used for the overall invoicing procedure.

Some attention needs to be paid in which way the archiving need to be done and where

the archiving takes place. Also it depends on how long invoices must be stored that has

an effect on the overall investment.

In literature however there are two key metrics to be considered to evaluate the

efficiency of accounting in relation to invoices:

Time to process an invoice.

Cost to process an invoice.

B. Koch10 indicates that electronic and automated invoice processes can result in savings

of 60 – 80% compared to traditional paper-based processing, and payback period of

investments in e-Invoicing should be 0.5 – 1.5 years. It is further stated that savings

between 1% and 2% of the turnover are realistic objectives.

According to a study carried out by the Helsinki School of Economics, there are

considerable savings in term of money and time for senders and receivers. Figure 3

shows savings depicted in case of semi-automated and automated processes on the

10 E-Invoicing/ E-Billing, The catalyst for AR/AP automation, B. Koch, Billentis, April 12, 2013

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sender side. Financial savings in case of semi-automated processes appear to be of 40%,

while a completed automated process brings savings of almost 42 %.

Figure 3. Invoice sending process in a Micro Company, Business Case in Finland, 2008.

Source: Electronic Invoicing Initiatives in Finland and in the European Union, Helsinki

School of Economics, 2008

On the receiver side; In case of semi-automated process, the savings amounted to about

37%. In case of automated processes, savings were calculated to be 88%.

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Figure 4. Invoice receiving process in a Micro Company, Business Case in Finland, 2008.

Source: Electronic Invoicing Initiatives in Finland and in the European Union, Helsinki

School of Economics, 2008

B. Koch reports a bit different calculations. On the side of the sender, they appear to be

more than 57%, yet on the side on the receiver, it is almost 62%.

Figure 5. Saving potential for invoice/ bill issuers. Source: Billentis

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Figure 6. Saving potential for invoice recipients. Source: Billentis

Other authors mention positive effects connected to e-Invoices such as increased quality

and efficiency, better financial management, improved customer services, risk reduction,

etc.

The most visible and immediate savings when talking about e-Invoicing appear to be on

the side of the issuer. There are direct financial savings deriving from skipping printing,

enveloping and avoiding the use of stamps. However, it is true that by choosing a

network model, expenses arise for electronic delivery (although those should be lower

than the cost of classical mail delivery). There are considerable time-savings in

performing such steps electronically, which allows the utilization of human resources to

be used for more profitable tasks i.e. employees can be shifted from physical execution

of tasks to control operations.

In case of automatic payment remittance, the issuer has a better overview of payment

status.

There are optimisations connected also with electronic archives – on one side there is no

need for large storage rooms to store invoices (although in case of outsourcing e-

archiving, costs have to be paid), on the other side e-archiving enables easier search for

information.

Nevertheless, in case of automated processes, savings are much bigger on the side of the

recipient. In case of automated processes, invoices are automatically imported in AP

systems, which can enable among other automatic match with orders and faster invoice

processing, therefore in case of discrepancies, disputes can be settled quicker. Payments

can be automated, which means that there is no need for physical execution of the

payment by the employee, who can take care of the process verification. Since the

recipient is obligated to keep an archive of received invoices, with e-Invoicing there is,

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again, no need for physical space to store invoices, where e-archives enable normally a

faster research.

The Aberdeen Group performed a study in 2011 to identify costs related to invoice

processing by interviewing 130 enterprises at various stages of Accounts Payable

maturity. According to the study the industry average requires 9.7 days with an average

cost of $15.61 to process a single invoice. The study indicated that what differentiates

the Best-in Class enterprises from others has to do with organizational, process and

technology-related issues, due to which the Best-in Class companies need 3.8 days at the

average cost of $3.09 to process a single invoice.

Commission Staff Working Document Impact Assessment, Accompanying the document

Proposal of the European Parliament and of the council on electronic invoicing in public

procurement reported an estimated saving of approximately € 1.5 to € 2.3 billion per

year if all public procurement invoices were submitted in electronic format.

From the analysis partners developed in the framework of the activity, we could see the

following investments and costs connected to e-Invoicing.

1.4.1 Germany

Generally spoken at least some software is mandatory to read a pdf file of an incoming

electronic invoice. Most of the existing pdf readers are free of charge and can be

downloaded for free. If a company would like to read the content of a pdf file

automatically then additional software is needed. If a company would like to read the

XML file, a corresponding software application needs to be implemented as well as an

interface to the accounting system. Alternatively if a company would like to create an

invoice as a pdf (/A3) with an embedded XML file, software must be in place, which has

the capability to do that.

Basically, there are various price models of the electronic invoicing market and most of

them consist of a one-time licence fee plus a maintenance and support fee on a monthly

or annual basis. The data volume is charged per volume of transactions or per period. An

example for an in-house software solution offers a starter package (€25.00 per month),

standard package (€50.00 per month) or a professional package (€125.00 per month)

including pdf invoices for 1,000 clients up to 15,000 clients. Another supplier offers

€0.10 down to €0.05 per invoice (depending on the volume) or also monthly packages

with €500.00 (standard) or €750.00 (premium). Apparently there is a wide scope of

prices in the market as well as a high dynamic and the mentioned costs are only some

examples that have been identified within the market survey and/or the conducted

interviews (this list is not exhaustive).

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1.4.2 Slovenia

It is difficult to gather enough information to make an informed decision on whether to

switch from paper to electronic invoices. It is dependent to some extent on how

computer and information intensive the workflow is within a particular company. For

example, a company with an information system such as ERP (Enterprise Resource

Planning), the minimum preparatory cost to be paid to a provider that takes care of the

preparation of the structure of a simple e-Invoice ranges from to €100 to €5,000. In

certain circumstances i.e. only using this service for e-Invoicing, organisations can use

these services for only €10 per month.

Larger companies that were interviewed for the purposes of this activity reported costs

ranging from €5,000 to €100,000 to set up an ERP and rearrange the organisation

workflow to be able to send and/or receive e-Invoices. In the case that the use of

intermediaries for each transferred invoice, a cost from 0.5 – 0.10 Euro has to be paid to

the e-delivery provider. Costs vary due to the quantity of invoices sent and the

destination based on network agreements between e-delivery providers. Moreover, to

be able to store (archive) received e-Invoices further costs must be added – which is

dependent on solutions and providers.

1.4.3 Spain

The investments required to implement an electronic invoicing system vary greatly on

the requirements and needs of the particular organisation. Investments and costs could

be very low if the company chooses to use the application freely distributed by the

MINETUR in the www.facturae.es website. Any of the solutions provided by different

banks (i.e. Banco Popular, Banco Sabadell, Bankia or La Caixa) or low cost ERP cloud

/software solutions (i.e. Anfix). Normally all these solutions are able to support the

format facturae 3.2 with advanced digital signatures, so it is rapidly becoming a de facto

standard in Spain.

Investments and costs increase significantly when more sophisticated ERP solutions are

used. There are requirements to connect with EDI networks for sending and receiving

invoices and/or it is required to manage different specific e-invoice formats (i.e.

EDIFACT formats still require relevant investments to be used and managed).

1.4.4 Greece

The investment costs vary depending on (a) the size of the company (b) the use of an

intermediate e-Invoicing provider or development of a system and (c) the solution to be

implemented.

http://www.facturae.es/

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Currently, the companies have their own ERP and accounting systems in place for which

they have invested approximately 20,000 – 100,000 €. They all believe that the new

system must be able to support any type of format; in order to enlarge the sellers and

buyers network.

A representative cost for implementing a full e-Invoicing system can be ~€20.000, also

providing automatic archiving. There are cases where adaptations are required for the

current accounting systems so the cost can be decreased; but this is again an issue of the

IT infrastructure of the company and its IT capacity in general. The cost is lower for

small companies, which can be up to € 5,000.

Regarding the use of intermediate e-Invoicing providers, the cost can be between 0.15 –

0.60 € per invoice, dependent on the total number of transactions. There are also

monthly rates that can range from 15 - 100 €.

2 Current situation of electronic invoicing systems in different Member

States

To provide comparable information about the current in situation in Member States a

template questionnaire with the following questions were used:

Estimations about penetration of e-Invoicing in Member States.

Is there any national legal framework regulating the use of e-Business and e-

Invoicing? Please indicate national laws dealing with e-Business and e-

Invoicing.

Please indicate the most relevant national provisions related to e-Invoicing and

the most important peculiarities of the national legislation that stimulate or

obstacle the use of paperless documentation.

What is the role of the Public Administration/ Public Sector in promoting the

use of e-Business and e-Commerce?

Are there any organised groups (of experts) that support technical development

and promote a greater use of e-Invoicing?

Is there any national standard recommended by the members of the national

multi-stakeholder forum in Member States of other organised groups of

experts? Please include information about its current use and developments.

Are there any initiatives in place to improve the legislation to stimulate the use

of e-Invoicing or eliminate the current obstacles?

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Which are the estimations about the investments needed to implement an

electronic invoicing system for an organisation in your State? What does it

include?

What is the role of e-delivery providers and EDI providers in your State? Are

banks taking over roles of e-delivery providers?

How the standardisation questions are being tackled in your country?

Are there any issues related to e-archiving?

Please indicate which are the main limitations or problems that are preventing

organisations from using the electronic invoicing system in your country.

2.1 Report on Greece

Today, in Greece, over 200 million invoices related to transactions between businesses

are handled. It is estimated that in 2011, almost 7,000 businesses circulated more than 8

million e-Invoices (through e-Invoice service providers).

It is important to note the difference in the meaning of e-Invoice and e-Invoicing in order

to clearly understand the situation in Greece and appreciate those reported in the next

section (i.e. The electronic invoice contains data from the supplier in a format that can

be entered (integrated) into the buyer’s Account Payable (AP) system without requiring

any data input from the buyer’s AP administrator). This allows a number of formats to

be employed and is useful to apply the following guidelines, concerning the actual

meaning of the e-invoice: 11

An e-Invoice is:

Structured invoice data issued in Electronic Data Interchange (EDI) or XML

formats.

Structured invoice data issued using standard Internet-based web forms.

Not a true e-Invoice if:

Unstructured invoice data issued in PDF or Word formats.

Paper invoices sent via fax machines.

Scanned paper invoices.

11 http://www.einvoicingbasics.co.uk

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Figure 7. e-Invoice service

As shown in the table below, Greece has a very high share of SMEs, particularly micro

enterprises, compared to the EU average. This can justify why the applicability of e-

Invoicing is not that wide spread, since E-invoicing is traditionally utilized by large

companies (only exchanging either proprietary or EDIFACT invoice formats)

Table 1. The categorisation of the companies in Greece, in terms of micro, small, medium and large entities definitions. 12

Number of Enterprises

Greece EU27

Number Share Share

Micro 719.252 96,5% 92,1%

Small 22.832 3,1% 6,6% Medium 2.893 0,4% 1,1%

Large 563 0,1% 0,2%

Total 746.240 100,0% 100,0%

Furthermore, the proprietary status of the enterprises can be summarised as follows:

Individuals or family based business: ~ 550,000

Legal entities (other than SA): ~ 180,000

Societe Anonyme: ~ 200,000

The use of e-invoices through the last decade in Greece are presented in the following

figure:

12 SBA Fact Sheet – Greece – 2010/11. The data does not cover the enterprises in agriculture, forestry, fishing or the largely non-market services such as education and health.

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Figure 8. E-Invoices via SPs in Greece

Some notable interesting facts regarding the use of e-invoice13 in Greece are:

There is growing rate in the use of e-invoices (with almost double values in the

last four years).

200 and 250 million invoices annually (Half of them < 300 Euros).

12 million are transmitted electronically (~ 6% - 7%).

More than 20,000 businesses are using e-invoices (most of them in retail

sector).

E-invoicing providers (10 - 15), 2 – 3 of which possess more than 90% - 95% of

e-invoicing market.

2.1.1 Legal Framework

The development of the Greek legislation follows the European Directives and Laws. The

most important legislative actions towards the establishment of e-invoice and e-

invoicing are presented below:

1. AYOO 1028970/220/0015/POL 1049/21.3.2006 (Government Gazette

380/II/28.3.2006).

2. Circular 1002841/12/0015B/POL 1004/14.1.2004;

3. Law 3193/2003 – Article 1 (Government Gazette 266/I/20.11.2003).

4. Presidential Decree 150/2001 (Government Gazette 125/I/25.6.2001).

13 AUEB ELTRUN survey 2011

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5. Circular 1118148/936/POL. 3/0015/24.11.1992 interpreting Presidential

Decree 186/1992;

6. Presidential Decree 186/1992 (Government Gazette 84/I/26.5.1992).

7. Law 1402/1983 (Government Gazette 167/I), the provisions of which ratified

Council Directive 76/308/EEC of 15 March 1976;

8. Law 1914/1990 (Government Gazette 178/I), the provisions of which ratified

Council Directive 77/799/EEC of 19 December 1977;

More information is provided for those marked in bold i.e.:

Law 3193/2003 – Article 1 (Government Gazette 266/I/20.11.2003) - The

adaptation on November 20, 2003 (Law 3193/2003) of the European Directive

2001/115CE dated December 20, 2001 to Greek law allows fiscal

dematerialization of invoices and enables the total removal of paper from the

entire invoicing chain.

Presidential Decree 150/2001 (Government Gazette 125/I/25.6.2001) -

The relevant provisions of Presidential Decree 150/2001 (Government Gazette

125/I/25.6.2001) apply to the sending of invoices with advanced electronic

signatures, without a qualified certificate requirement. However, there is a

requirement for creation of a digital signature by specific secure devices

(marking mechanisms).

Decision AYOO 1028970/220/0015/POL 1049/21.3.2006 - Accepted

electronic forwarding of electronic files and data for checking of the validity and

authenticity of invoices created by secure devices.

2.1.2 Initiatives of the public sector and organised groups at national level

The development of electronic invoicing in Greece can significantly enhance the

competitiveness of Greek businesses and National Economy, by reducing operating costs

associated with issuing, handling and storage of invoices. Specifically, the amount that

can be saved for Greek enterprises, from the adoption of electronic invoicing is

estimated at over € 1 billion annually. Moreover, the electronic invoice can be an

enabled to automate a number of processes related to e-procurement, generating

additional benefits of several billion to National Economy.

On August 3rd, 2011 in a joint press conference of the Ministers of Development, Finance,

Administrative Reform and Electronic Governance on electronic invoicing and

particularly on the electronic handling and filing of delivery notes, the Ministers signed

the decision (POL 1158/2011) to allow electronic filing of delivery notes. If a company

follows this process, the elimination of its obligation of storing the actual paper

equivalents. This decision extends the circular POL 1049/2006 to the possibility of

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electronic filing of joint invoices/delivery notes and of delivery notes. On March 22nd,

2012 the proposed standard for e-Invoicing was published and put out for public

consultation until April 13, 2012.

The Greece e-Invoicing facilitation initiative was developed according to the following

main action pillars: 14

1. Fast facilitation of using structured e-invoices; Introducing “Greek Core

Invoice”, minimum structure requirements in record keeping for tax purposes

only.

2. Recordkeeping - Hash values transaction data locking by using hash values

(SHA-1) generated by SPs / software (hardware devices -> SPs).

3. Introduction of service providers new added value services -> e-invoicing (code

matching, standardisation), transmission (paper or e-), archiving, tax reporting

obligations, etc.

4. Increasing frequency of regular data reporting annually -> monthly.

5. Public Procurement Implementation of Greek core invoice – obligatory use of e-

invoices.

6. Digitalization of paper consignment notes. Transform paper notes to electronic

announcement of dispatching goods.

On 21st January, the Greek Presidency brought the negotiations on a new directive aimed

at spreading the use of new technologies in public tenders to a successful conclusion

following a number of technical meetings and two informal discussions with the

responsible committee in the Parliament (the Internal Market Committee "IMCO") and

the Commission.

The provisional agreement between the Greek Presidency of the Council and European

Parliament representatives was confirmed by the Committee of Permanent

Representatives.

The Directive, adopted on the 16th of April 2014, shall contribute to improve the

functioning of the internal market by reducing the obstacles to entering the market,

especially for SMEs, and by solving the problem of the compatibility of different e-

invoicing systems in various member states.

It is expected that the wide use of e-Invoicing in public tenders across the EU will

generate savings of funds allocated for public procurement of up to €2.3 billion a year”.

The business sector welcomed the initiative to uptake e-Invoicing for public

procurement and acknowledged that this would significantly lower costs for economic

14 39th IATTO FORUM – EXPORT SUMMIT II- Thessaloniki Sept., 25th – 27th, 2013 - e-Transactions from Tax point of view & e-Invoicing facilitation – Greek Ministry of Finance.

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operators participating in cross-border public procurement, including costs stemming

from multiple e-Invoicing standards and systems.

The directive provides for the development of a common interoperable standard on

electronic invoicing by the European standardization organizations, which will have to

be adopted within 36 months after entry into force of the directive.

Following the publication of the new standard, central contracting authorities will have

a maximum of 18 months to implement it. Local and regional contracting authorities will

have the possibility to derogate from this deadline for up to 30 months after the

publication of the standard.

2.1.3 Standardisation actions

The Ministry of Finance is the responsible body to follow and implement initiatives in

the field of invoicing according to the European and World wide standards. In this

direction, an important intervention is the development of the Greek Core Invoice (or

Document), which is the first step towards the facilitation of standardisation. The Greek

Core Document design follows CEN standards for the development of the Core Invoice.

The main goals of this initiative are:

To add value and contribute to e-invoicing interoperability framework.

To create appropriate conditions for cross-border transactions within EU and

with 3rd countries, by mapping Greek core invoice to other international

standards (existing or under development) and by taking into account

upcoming requirements.

To create the necessary dynamics to the market and increase responsiveness of

public administration for e-invoicing.

Main characteristics of the Greek Core Document are:

A structured data set should be recorded, locked and kept for each transaction.

It covers national legislation requirements.

It has an extended set of fields.

It maps all fields of CWA and PEPPOL.

It consists the basis for cross-border and industrial sectors transactional data

exchange.

The Greek Core Invoice structure consists of (2+1) sections i.e.:

1st Section of permanent data (H – Header’s section).

2nd Section of floating data (D – Details’ section).

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3rd Optional section for free use (A – Additional free data section).

The sequential order is important and should be kept as it is. In this way, it could be

stored in any form and in any DB, however it should be presented in that structure upon

request (either delimited or XML). Furthermore, it will be ready for regular reporting

(either as a whole or partially). Whenever there is availability of codes (based on

international and national standards), these will be used instead of text. As previously

stated, the Core Document maps almost all fields of CEN Core CI Invoice and PEPPOL.

Figure 9. Example of Information included in the Header section

2.1.5 Archiving

The tax liable entity may decide freely on the place of storage of invoices within Greece.

This is subject to certain requirements and on condition that the stored invoices or

information are made available without unwarranted delay to the competent authorities

within the time limits stated in the requests made by those authorities. The storage

period is the same as the period for prescription of the right of the state to impose the

tax, which is currently six years.

More specific rules in relation to archiving requirements are presented below:

1. The tax liable entity is obliged to store on paper or by electronic means within

Greece all the invoices issued by it or by any other party on its behalf, as well as

all the invoices that it receives, in the following circumstances:

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a. where the storage is not by electronic means ensuring full on-line access

to the relevant data, or

b. where the storage is in a country with which a legal act concerning mutual

assistance of a scope analogous to that provided for by Directives

76/308/EEC and 77/799/EEC and Regulation (EEC) No 218/1992 has not

been concluded.

2. Copies of invoices issued by the customer or by a third person must be passed

to this entity within the time limit for updating of the books that it keeps.

3. If the invoices are stored by electronic means, the authenticity of their origin

and the integrity of their content, as well as their legibility, must be guaranteed

throughout the obligatory storage period.

4. Inability to reproduce the content of an invoice is treated as a failure to

safeguard the relevant tax information.

5. If invoices are stored or transmitted by electronic means, the data which ensure

the authenticity of the origin and the integrity of the content of each invoice

must also be stored for the obligatory storage period.

6. If the entity stores the invoices that it issues or receives by electronic means

guaranteeing on-line access to the data, and the place of storage is in another

Member State, the tax authority has right of access by electronic means for

downloading and use of the invoices when necessary for tax control purposes.

7. The competent body may decide to impose other specific conditions prohibiting

or restricting the storage of invoices in a country with which a legal act

concerning mutual assistance of a scope analogous to that provided for by

Directives 76/308/EEC and 77/799/EEC and Regulation (EEC) No 218/1992

and right of access by electronic means, downloading and use of invoices has

not been concluded.

2.1.6 Identified obstacles in using e-Invoicing

The obstacles in using e-Invoicing are considered from two points of view (1) from the

Public Financial Control Bodies and (2) from the Business Community.

Starting from the Administration Point of view the following can be reported:

Transactions are not recorded despite means being used (such as handwritten

paper forms, or machines) for education, stimulation, “promotion”,

enforcement, etc.

Recorded transaction data are manipulated; protection of machines being used

and/or data protection is required.

Consolidated (summary) data are manipulated.

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Recorded transaction data are not depicted in accounts and books; data

protection is required.

In order to face the above obstacles the Ministry of Finance has come up with the

following immediate actions:

Use protected / shielded hardware; Fiscal cash registers, fiscal printers,

signature devices, etc.

Create and safe keep of digital fingerprints (traces).

Use 3rd trusted parties, crypto, e-signatures (PKI, timestamps, etc.).

Electronic signatures can ensure for both, the issuer and the recipient, the secure

transmission of invoices. But if a digital trace for each transmission is not kept securely,

then tax authorities cannot perform any audit based on the integrity of the data.

In other words, whenever the issuer and the recipient come to an agreement, they can

delete the initially transmitted electronic invoice, alter the data as they wish and repeat

the transmission of the altered invoices without ever this fact to be captured by the tax

audit.

From the Business Community point of view, the lack of a standardized document that

can be used for the transactions with all business partners is considered as the major

obstacle. On the other hand, since there is not a real market demand for collaborating

using e-invoices, they are not willing to invest on it.

2.2 Report on Germany

The handling of electronic business processes in Germany has become increasingly

important recently. Today, it is becoming more common for companies to use the

electronic data exchange with their business partners to make their processes faster and

even more efficient. Due to rising costs, pressure and rising competitiveness, companies

are continuously trying to improve their business processes e.g. to automate financial

transactions. This is particularly prevalent in the area of electronic billing and e-

Invoicing as there are potentially tremendous cost-savings to be made.

The accounting process can be quite different within individual companies. Some

companies are still using solely paper invoices whether other companies’ implemented

already semi-automated or fully automated electronic billing processes.

Within this report the most relevant manners of sending and or receiving invoices are

considered and evaluated; based on the conducted interviews and given statements by

the interview partners or other available information.

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The percentage of penetration of e-Invoicing in Germany is currently estimated at

approximately 5%; spanning various classes of business and based on recent studies

and market surveys. With respect to specific industries the percentage of penetration of

e-Invoicing is significantly higher. The level of e-Invoicing ranges between 20% and 30%

for industries such as large business enterprises, banks and insurance companies,

automobile industry as well as the public health sector. The percentage of penetration of

e-Invoicing depends not only on the industry but also on the size of a company (small,

medium and large-size) as well as whether a company is sending an invoice or is

receiving an invoice.

Despite the majority of the companies still using paper invoices, all parties are expecting

a significant increase of electronic invoices within the forthcoming years; in particular

within small and medium-size companies.

Nearly all companies are still sending paper invoices. But many of them are also sending

electronic invoices already. Amongst them, the most common manner of sending an

electronic invoice is via e-mail (e.g. with an attached pdf-document). The following

figure covers invoices sent to consumers (B2C) as well as to business partners (B2B).

Figure 10. Method of sending invoices. Source: ibi research 2011 I

www.elektronischerechnungsabwicklung.de

Both large and small sized enterprises could benefit from cost savings by sending

invoices electronically. However the majority of invoices are still sent out as paper

invoices.

Companies with a strong buyer/purchaser position are tending to switch from classical

paper invoices towards electronic invoices. They normally have the market power to

force their suppliers and business partners to change to an electronic invoicing practice.

http://www.elektronischerechnungsabwicklung.de/

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Some companies also already charge their business partners in the case that they are

sending paper invoices instead of electronic invoices. The “paper fee” is justified with

higher manual effort.

The most common manner of sending invoices is still the paper invoice whether it be to

consumers or to business partners, followed by e-mail, fax, EDI and web portals (Figure

10).

Figure 11. Overview of outgoing invoices.

Source: ibi research 2011 I www.elektronische-rechnungsabwicklung.de

The majority of conducted interviews and available studies state that almost all

companies are receiving paper invoices (Figure 11). Nevertheless, the percentage of

invoices received via e-mail is approximately 80% (Figure 12).

http://www.elektronische-rechnungsabwicklung.de/

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Figure 12. Incoming Invoices.

Source: ibi research 2011/ www.elektronische-rechnungsabwicklung.de

The main challenges for big companies with a high volume of invoices are that the

necessity of adjustments of internal processes to prevent format mismatching and to

enable an automated further processing.


The following laws are for regulating e-Invoicing and e-Business in Germany:

Deutsches Umsatzsteuergesetz (UStG) – (German Value Added Tax Act)

www.bundesrecht.juris.de/ustg_1980/index.html

Steuervereinfachungsgesetz 2011 im Bundesgesetzblatt Jahrgang 2011 Teil I Nr.

55

http://tinyurl.com/bs6qd4o

Grundsätze ordnungsmäßiger DV-gestützter Buchführungssysteme (GoBS)

www.tinyurl.com/2cc7lk2

Grundsätze zum Datenzugriff und zur Prüfbarkeit digitaler Unterlagen (GDPdU)

www.tinyurl.com/5te5f4w

Abgabenordnung (AO) – (General Fiscal Law)

www.bundesrecht.juris.de/ao_1977/index.html

Gesetz über Rahmenbedingungen für elektronische Signaturen (SigG –

Signaturgesetz) - (Digital Signature Act)

www.bundesrecht.juris.de/sigg_2001/index.html

Verordnung zur elektronischen Signatur (SigV – Signaturverordnung) – (Digital

Signature Regulation) www.bundesrecht.juris.de/sigv_2001/index.html


http://www.bundesrecht.juris.de/ustg_1980/index.html

http://tinyurl.com/bs6qd4o

http://www.tinyurl.com/2cc7lk2

http://www.tinyurl.com/5te5f4w

http://www.bundesrecht.juris.de/ao_1977/index.html

http://www.bundesrecht.juris.de/sigg_2001/index.html

http://www.bundesrecht.juris.de/sigv_2001/index.html

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Basically there are specific requirements related to an invoice which must be considered

by the companies within the invoicing procedure:

Value added tax related principles of an invoice.

Comfortable transmission of an invoice.

Lawful archiving of an invoice.

By mid of 2011, one important law was passed by the Federal Fiscal Authorities

reducing the requirement towards electronic invoices; in particular the abolition of the

imperative of the digital signature within electronic invoices.

Due to the fact that a lot of small and medium-size companies had technical constraints

with the digital signature, a new law came into force eliminating the digital mandatory

signing. In the area of electronic archiving, some essential proceedings were made which

had a positive impact on the companies who are asked to archive relevant

documents/invoices over a period of up to 10 years.

The German legal framework and governmental entities appear to be very supportive

toward the needs of operators in relation to e-Invoicing. Representatives of different

industries were in close discussions with governmental entities and various associations

to define minimum standards for data exchange, including formats and contents of

electronic invoices.

2.2.2 Initiatives of the public sector and organised group at national level

In Germany, the public sector is in an excellent position to promote and initialize the use

of electronic invoices within a mass market. Nearly two thirds of all companies are

suppliers of the public sector due to that fact the public sector has the market power to

push most of these companies towards the use of electronic invoices. In addition, the

public sector often has the possibility to adjust the laws and/or regulations to be in line

with market conditions and market developments.

With respect to the above statements, it was no surprise that especially in the recent

past, a few e-Invoicing projects were started by governmental entities/authorities.

In the following, some exemplary governmental entities and ministries are listed which

promoted initial projects with respect to electronic invoices:

Technisches Hilfswerk (THW) – (Federal Agency for Technical Relief).

Bundeszentrale für politische Bildung (BpB) – (Federal Agency for Civil

Education).

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Bundesverband Informationswirtschaft, Telekommunikation und neue Medien

e.V.

(BITKOM ) - (Federal Association for Information Technology,

Telecommunications

And New Media).

Bundesministerium des Innern (BMI) – (Federal Ministry of the Interior).

Bundesverwaltungsamt (BVA) – (Federal Office of Administration).

Bundesministerium der Justiz und für Verbraucherschutz (BMJV) - (Ministry of

Justice).

Within the scope of the above listed initiatives, definitions of data formats, invoice

contents and standards were made. As a result from the experience of these projects, an

overall data format (so called “ZUGFeRD”) was developed with the intention of a

national roll-out by mid of 2014.

There are quite a lot of national platforms and associations, ministries and companies

which all promote the use of electronic invoices. The overall target of all these parties is

to boost the acceptance and the extension of electronic invoicing within Germany and to

support the positive opinion forming within companies.

Another objective is to forward the German opinion to the European Coordination

Group and to work on common standards and agreements with other member states in

that context.

One main task of these platforms and associations is to support potential users

regarding technical, economical and legal aspects as well as to define suitable

measurements for a fast and simple implementation of electronic invoicing. Finally, they

are also coordinating the implementation of the identified measurements.

Some representatives of the following associations and organisations are also

participating in specific EU expert groups, focusing on legal aspects or technical

challenges. The most relevant national organisations and associations dealing with e-

Invoicing are:

FeRD (Forum elektronischer Rechnungslegung Deutschland) – (Forum

electronic Billing Germany, National e-Invoicing Forum).

AWV (Arbeitsgemeinschaft wirtschaftliche Verwaltung e.V.) – (Working

Committee of Economical Administration).

rechnungsaustausch.org (Portal zur Förderung des elektronischen

Rechnungsaustauschs – (Promotion portal of electronic invoicing).

VeR (Verband elektronischer Rechnungen e.V.) – (E-Invoice Alliance Germany).

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PDF Association (component of the ADDS – Association for Digital Document

Standards e.V.).

GS1 Germany GmbH.

Europäisches Komitee für Normung (CEN) – (European Committee for

Standardization).

Beyond that there are additional initiatives and associations who are focusing on, for

example, information security and who are offering information downloads for free on

their webpages.

Whether the national market still shows some heterogeneity; there are on-going

ambitious efforts to consider all specific demands and requirements from the individual

stakeholders and to find one common denominator.

In the long run, most of the invoicing parties, the bill-to parties and the tax authorities

would like to exchange their invoices with structured data; to process documents

automatically and to archive all relevant invoices.

Medium-size and large companies with extensive data volumes established at an early

point of time were they used EDIFACT and later XML based solutions to exchange

invoices. Due to the fact that more small and medium-size companies used electronic

invoices the percentage of pdf invoices increased.


The subject of standardization is mainly driven by big trade enterprises, which started

to define and implement standards 20 years ago. Mainly driven by the tremendous

amount of clients or articles, there was a need to have standards for identification,

classification and localization; just to name the most important ones. In addition, the

bank and health sector paid more and more attention to standards at an early point of

time. Another key player in the field of standardization is the automobile industry. Due

to the globalization and the wide spread production with plants all over the world an

extensive component supplier network was established and needed to be managed

efficiently. This is only possible by using standards. There are associations representing

single industries working together with working committees on a national and

international level to define common and worldwide applicable standards (CEN, ISO,

DIN, GS1, etc.).

In the past couple of years, the combination of a pdf-invoice with an additional XML-file

became increasingly popular. Both files can be sent individually or with the XML-file

embedded within the pdf-invoice. This combination develops an entirely acceptable

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solution, which matches the demands and requirements from large, medium, and small-

sized companies.

Mainly driven by the FeRD association, a new and commonly agreed format for

electronic invoices was worked out which is intended to be used for the exchange of

invoices between companies, authorities and consumers, which enables the exchange of

structured data between the invoice party and bill-to party. The defined data format of

electronic invoice based on PDF/A3 is called ZUGFeRD.

The ZUGFeRD data format facilitates the transmission of invoicing data in a structured

manner into a pdf-file. Due to the fact that the XML-file is machine-readable, the

necessary information can be directly imported to ERP or other accounting systems.

The invoice procedure works as follows:

1. The invoice party imbeds the FeRD compatible XML file into a PDF/A3 file.

2. The bill-to party reads the XML-file and transfers it into their ERP system which

processed the invoice.

3. The “FeRD” data format was defined by companies from the automobile

industry, the retail industry, by the banking sector and the software industry

but also by representatives from the public sector.

4. The defined data format matches the requirement of international

standardization and can be applied within the European and international

invoicing procedure.

The main principles of the ZUGFeRD data format:

The invoice data standard uses a semantic data model based on Core Cross-

Industry-Invoice (Core CII):

Recoverability of existing approaches.

International compatibility.

There are several profiles of the ZUGFeRD data model.

The ZUGFeRD data format consists solely of intersect oral data for the

generation of an electronic invoice based on Core Cross-Industry-Invoice (Core

CII).

Every invoice using the ZUGFeRD data format must be complete and valid

invoice (both pdf-file and XML-file).

The target group for the ZUGFeRD data format are large and medium-sized companies,

and amongst others also the public sector and in particular small companies, which can

act as invoice party and/or bill-to party.

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Figure 13. Official Logo of PDF/A3.

Source: ibi research 2011/ www.elektronische-rechnungsabwicklung.de

Apart from the structured data format, software is needed to create a pdf-file as well as

imbedding the XML-file into the pdf (issuing an invoice) and also software is necessary

to read the XML file at the invoice recipient (receiving an invoice).

Based on the conducted interviews and own research, there are quite a lot of software

solutions available which match existing or upcoming requirements of the industries.

Some of them are still prototypes and will be adjusted and enhanced in the forthcoming

years.

Figure 14 shows schematic representations of the incoming procedure to receive the

invoice in the mentioned format as well as the outgoing procedure to send the invoice

using ZUGFeRD; using one of the available software.

Figure 14. Incoming invoice procedure with ZUGFeRD.

Source: Gesellschaft für Logistische Systeme LS GmbH


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Figure 15. Outgoing invoice procedure with ZUGFeRD.

Source: Gesellschaft für Logistische Systeme LS GmbH

The ZUGFeRD data format is defined in a close dialog with the German Federal Ministry

of Finance and other governmental authorities and industry associations. The main

intention by starting with the work on a structured data format was to provide a

standard solution; in particular, for small and medium-sized companies because there

were limited standard formats in place at present. The intention was not to replace

currently existing formats or solutions; the objective was to close an existing gap.

The existing ZUGFeRD data format can/will be customized to specific requirements and

demands from individual industries if necessary. There are three stages of development

already defined; basic, comfort and extended. The basic standard covers the least

common denominator regarding the content of an invoice defined by the main

industries together with the public sector. Both the comfort and the extended standards

of the ZUGFeRD data format consider additional data contents related to specific

industry demands.

2.2.4 Role of intermediaries

There are various e-delivery providers and EDI providers present in Germany. They are

providing different services related to the needs and requirements of the clients or

business partners. Solutions are available for small and big companies with huge data

volumes. Some of the e-delivery providers focus on a single industry and are skilled

with their specific requirements. If the services of an e-delivery provider is used, it

depends mainly on the cost and company strategy guidelines.

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2.2.5 Archiving

Although the term electronic archiving is very differently used, from the German

perspective two definitions for electronic archiving have become standard:

Electronic long-term archiving: One speaks of long-term archiving if the

information is kept at least 10 years or more and needs to be kept accessible.

Revision-safe electronic archiving: One speaks of revision-safe archiving if the

archive system solution corresponds to the demands of the

“Handelsgesetzbuches” (German commercial code - HGB) §§ 239, 257 as well as

the tax code and the GoBS (Principles of Regular Data Processing-supported

Accounting Systems) to the safe, normal keeping of commercial documents and

fulfils the periods for safekeeping of six to ten years.

The HGB and the tax code (AO) dictates the basis for storage, regardless of whether in

conventional paper archives or electronic systems, as noted here:

Correctness.

Completeness.

Security of the total procedure.

Protection from change and falsification.

Safety from loss.

Use only by entitled personnel.

Adherence to the periods for safekeeping.

Documentation of the procedure.

Comprehensibleness.

Controllability.

The demands are summarised in the code of practice “Grundsätze der elektronischen

Archivierung” (Principles of Electronic Archiving) of the VOI (Federation of Organisation

and Information Systems e.V. 1996). Internationally, the functionality and the extent of

electronic archives are defined in ISO standard 17421 and records management systems

defined in ISO 15489. In Germany, for the intent of security and examination of archive

systems, the BSI Grundschutzhandbuch, Basic Protection Manual, (Chapter 9.5) can be

consulted.

The following 10 characteristics for revision-safe electronic archiving originate from VOI

(Federation of Organisation and Information Systems e. V.):

1. Each document must be unchangeable when archived.

2. No document may be lost on the way into archives or in the archive itself.

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3. Each document must be findable again with suitable retrieval techniques.

4. Exactly the document that was looked for must be regained.

5. No document may be able to be destroyed during its intended lifetime.

6. Each document must be able to be displayed and printed again in exactly the

same form as it was captured.

7. Each document must be able to be regained in real time.

8. All actions in the archives, which cause changes in the organisation and

structure, are to be logged in such a manner that the re-establishment of the

original condition is possible.

9. Electronic archives are to be laid out in such a way that a migration to new

platforms, media, software versions and components is possible without

information loss.

10. The system must offer the capability to the user to guarantee the keeping of

the legal regulations (BDSG, HGB/AO etc.) as well as the operational

regulations of the user regarding data security and data protection for the life

span of the archive.

Based on a marked survey conducted by ibi research (2011) most of the big companies

are scanning incoming paper invoices for in-house digital archiving. However, the

overall share of non-electronic archiving / filing is still quite high in small, medium and

large sized companies. There are only a few companies using digital archiving with a

service provider.


The following figure gives an overview about reasons why companies are not sending

electronic invoices:

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Figure 16: Overview constrains of sending electronic invoicing. Source: ibi research

2011/ www.elektronische–rechnungsabwicklung.de

With respect to the existing surveys and based on the feedback from the conducted

interviews, an increasing amount of companies are currently using electronic invoices or

are intended to start with electronic invoicing soon are driven mainly by the aim to

realize cost saving and to process invoices faster.

Nevertheless companies have to cope with some challenges by implementing electronic

invoicing systems. The most commonly mentioned challenge is legal uncertainty,

whether on the part of the invoice party as well as on the bill-to party. In particular,

small companies often have difficulties identifying the most adequate solution due to the

fact that they normally do not have the required skills for an electronic invoicing

solution selection process. Again, small and medium-sized companies have the biggest

share of the overall invoice volume within Germany. A higher usage of electronic

invoicing within these companies would boost significantly the cost saving potentials on

a macroeconomic level.

2.3 Report on Slovenia

Although the official statistics doesn’t rank Slovenia among major users of e-Invoicing in

the European area (see Eurostat or SI STAT), the studies carried out by B. Koch suggest

that the maturity of the Slovenian market appears to be average.

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Figure 17. Market maturity for e-Invoicing

Source: Billentis, 2013

In the study published in 2013, B. Koch depicted the expected market penetration of e-

Invoicing for 2013, which for the cases of B2B, B2G and G2B in Slovenia were estimated

to be lower than 15% (in the study for year 2012 the mark was higher than 30%), and

for the segment B2C higher than 30%.

Figure 18. B2B/B2G/G2B - Estimated expected market penetration in year 2013 by Country. Source: Billentis, 2013

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Figure 19. B2C - Estimated expected market penetration in year 2013 by Country. Source: Billentis, 2013

According to the national statistical databases, a total of 6982 enterprises participated in

the interviews concerning the use of e-Invoicing in 2011, 16.3% of them were sending

and/or receiving e-Invoices in a standard structure suitable for automated processes.

There were 715 companies receiving e-Invoices and 379 sending e-invoices.

Considering the total of 496 companies performing transport and storage activities in

Slovenia that participated in the survey, 16.33 % of those were sending and/or receiving

e-invoices. The official statistics show that the percentage of enterprises sending and/or

receiving e-invoices has grown to reach 19.78 % in 2012 and 22.27 % in 2013. The

share in transport is not stable and grew firstly to 20.78 %, but has decreased in 2013 to

15.99%.

The number of companies sending electronic invoices in a nonstandard structured way

that participated in the interviews amounted to 2,215; 2,133 and 2,661 in the years

2011, 2012 and 2013, respectively, which represents approximately 40% of the

enterprises.

Some major Slovenian companies started their interest in e-Invoicing almost 15 years

ago. The need for developing a national standard was perceived by a working group in

the framework of the Chamber of Commerce and Industry of Slovenia, who participated

at the creation of a first Slovenian standard for e-Invoicing that was published in 2000.

According to Mr. Dušan Zupančič, director of the Association of Informatics and

Telecommunications that participates as a Slovenian member to the European Multi

Stakeholder Forum on Electronic Invoicing the legal framework in Slovenia is very much

favourable for the introduction of e-Invoicing. However, the percentage of penetration is

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still lower than desired. According to Mr. Zupančič it is very difficult to give a more

accurate answer about the use of e-Invoices in Slovenia since there are a great variety of

situations present in the market. For example, companies that are ready to send and/or

receive e-Invoices, but are effectively using e-Invoices only with few of their business

partners. So the question is whether to count companies that in general are able and are

exchanging e-Invoicing or the share of e-Invoices on a total of issued invoices etc. This is

why it seems relevant to consider the maturity of the market whilst analysing the

situation.


The following acts discipline the use of e-invoicing in Slovenia:

Value Added Tax Act – Zakon o davku na dodano vrednost (ZDDV), Official

Gazette of the RS nr. 117/06 and modifications.

Electronic Commerce and Electronic Signature Act - Zakon o elektronskem

poslovanju in elektronskem podpisu (ZEPEP), Official Gazette of the RS nr.

98/2004 and modifications.

Protection of Documents and Archives and Archival Institutions Act - Zakon o

varstvu dokumentarnega in arhivskega gradiva ter arhivih (ZVDAGA), Official

Gazette of the RS nr. 30/2006.

Tax Procedure Act - Zakon o davčnem postopku (ZDavP), Official Gazette of the

Rs nr. 117/2006.

According to ZEPEP (article 13) in case a law or regulation requires a written form of a

document, the electronic format is equivalent to a paper format if data contained in the

electronic format are available and suitable for a subsequent use.

According to ZDDV (article 84) an invoice can be issued in a paper format, but also in an

electronic format if the buyer and the seller agree on that and if the authenticity of the

origin and the integrity of the content are assured.

The following conditions shall be fulfilled:

The authenticity of the origin must be assured so that the invoice recipients can

determine that the invoice was really issued by the issuer;

From the electronic message the time and place of issue and receipt must be

visible;

The integrity of the invoice must be assured in a way that the technology

employed and procedures disable in a sufficient degree changing of data

contained in the invoice.

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Independently from the conditions listed above, the same article establishes that an

invoice for VAT purposes can be sent and given at disposal in an electronic way through

electronic data interchange (EDI) if the authenticity of the origin and the integrity of the

content can be assured.

If a taxable person who sends or gives at disposal to the same recipient a package with

more invoices (collecting invoice), can list only once data that are common to single

invoices, with the condition that data for every invoice is available.

According to “ZDavP” (Art. 38) a taxable person who wishes to process data

electronically for tax purposes shall:

Store data that is generated or received in electronic format in electronic form

and enable access in an electronic format.

Assure readability of original data.

Assure a regulated storage for the required period.

Assure access to electronically managed books and evidence also if they are

stored in an electronic format by other subjects or in other countries.

Store data in a suitable way that enables inspection in a reasonable time.

Also ZDavP requires the authenticity of the origin and the integrity of the content of the

document.

ZEPEP (article 14 and 15) also prohibits discrimination of electronic signatures and

defines the conditions under which electronic signatures equivalent to handwritten

signature. A secure electronic signature verified by a qualified digital certificate is for the

data in electronic form equivalent to a handwritten signature and therefore has the

same validity and probative value. A secure electronic signature is an electronic

signature, which must comply with the following requirements:

It is strictly linked to the signatory.

That we can undoubtedly identify the signatory.

It is created using assets for secure electronic signing which are exclusively

under the control of the signatory.

It is connected with the data to which it relates, so that it is visible to any

subsequent change of the data.


As written already in the introduction of the report Public sectors have an important

role in incentivising the use of e-Invoices.

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According to official statistics in 2010, expenditures of the public sector in Slovenia (incl.

public administration, defence, public order, economic activities, environment

protection, housing, health care, recreation, culture, education and social care)

represented 50% of the national GDP, from which it can be clearly understood that the

Public Sector is crucial in increasing the use of e-Invoicing in the country.

The Act on the Provision of Payment Services to Budget Users and the amendment

adopted on the 27th of December 2013 (Zakon o spremembah in dopolnitvah Zakona o

opravljanju plačilnih storitev za proračunske uporabnike /ZOPSPU - A) is making a very

important announcement to operations with the Public Administration. From the 1st of

January 2015, all the spending authorities (proračunski uporabniki) will have to receive

invoices and accompanying documents exclusively in the electronic format. For goods

supply, construction or services carried out by natural persons and legal persons, e-

Invoices will have to be sent to spending authorities via the Public Payments

Administration of the Republic of Slovenia (Uprava Republike Slovenije za javna plačila –

UJP). After receiving an e-Invoice, the Public Payments Administration will act as

processor for all spending authorities distributing e-Invoices in its network. Businesses

and private individuals cannot send e-Invoices directly to Public Payments

Administration but through an e-delivery provider who has signed an agreement with

the Public Payments Administration. Alternative option for businesses and private

individuals is to send their e-Invoices over Public Payments Administration web portal

(valid only for a limited number of e-Invoices). The Public Payments Administration has

published a register of issuers of e-Invoices, which is available at the following link:

http://www.bankart.si/si/ponudba/simp/register-e-racunov/ .

It is expected that the new legislative framework will further accelerate the use of e-

Invoicing in Slovenia and on that account the National Forum and the Public Payments

Administration are very active in spreading information about the new system. In the

future, it is also expected an increase in use of e-Invoices in B2B because organisations

have already implemented systems that support sending and receiving e-Invoices.

Therefore using e-Invoices in other business areas are going to be cheaper and more

effective in the long-term.

Besides that, another initiative in place is to create a register of e-Invoice receivers. Such

a register would be stored by the Agency of the Republic of Slovenia for Public Legal

Records and Related Services (Agencija Republike Slovenije za javnopravne evidence in

storitve – AJPES) and could enable the issuers an easier overview of who is capable of

receiving e-Invoices. With the aim to identify the physical address and the e-Business

address, an initiative is going on to create a new identity for e Business, maybe with the

use of the GLN ID, which would enable international cooperation.

http://www.bankart.si/si/ponudba/simp/register-e-racunov/

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Today, the National Multi-Stakeholder Forum for the e-Invoice is the only organised

group that supports and promotes a greater use of e-Invoice. Before the foundation of

the Forum, the Association of Informatics and Telecommunications, which is working

within the Chamber of Commerce and Industry of Slovenia was the main promoter of e-

Commerce and e-Invoicing in Slovenia.

The National Multi-Stakeholder forum has regular meetings and is very active in

different fields. Promotion of the use of e-Invoicing among Slovenian organisations,

preparation of legislative initiatives, exposing and dealing with technical issues, cross-

border cooperation (in particular with Croatian institutions) with the aim of improving

the use of e-Invoicing in a cross-border (international) environment.


In 2000, the Association of Informatics and Telecommunications of the Chamber of

Commerce and Industry of Slovenia established a new Slovenian standard for e-

Invoicing named e-Slog, which is a structured document in XML format. It was based on

GS1 EANCOM standard, but was developed in two versions:

A simplified version that was seen as an opportunity to promote e-Invoicing on

a wider scale as it was easier to be read and since it included only some of the

information contained in the complex invoice.

A complex version that was an opportunity to include a greater amount of

information which could be used in case there was any need for traceability of

information along the supply chain or other purposes (ex. collecting invoicing –

document issues only periodically containing many invoices).

A potential solution suggested by the Association was the use of the complex version as

an attachment to the simplified version.


In Slovenia, various providers are present. There are experts offering digitisation of

internal workflows and the preparation of the e-Invoice, e-delivery providers offering

transfer of e-Invoices, sometimes also standard conversion and e-archives, there are

experts offering only e-archiving. The Public Administration has shown a preference in

using e-delivery providers, so their role will be likely to be more important in time.

Banks in Slovenia also offers services such as e-delivery providers to their clients. In

2011, the Association of Banks of Slovenia introduced an e-Invoicing system based on

agreements between groups of banks, whereas in the relation between issuer and

recipient of invoices their banks acts as intermediaries.

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The majority of Slovenian companies that introduced e-Invoicing in their business

processes are based on the e-Slog standard. Nevertheless, the e-Slog standard is under

revision. In the future, it is expected to converge toward the CEN standard.

2.3.5 Archiving

Some legislative uncertainties are present when talking about e-archiving, since the

ZVDAGA legislation is in parliament process for amendments. An invoice sent in an

electronic format must also be stored in an electronic format. According to ZVDAGA,

public bodies must have their e-archives or internal rules certified by the Archive of the

RS. It is also possible to outsource archiving by using a certified provider15. There are no

such legal restrictions for private enterprises.


The market penetration is not sufficiently high, so although there are companies, which

are able to send and receive e-Invoices, they are maintaining both the systems including

paper and electronic version, which means that they have to sustain costs of both

systems. Moreover, although e-Invoices are in use, paper documents are still sent. For

now, organisations must agree separately with each business partner about the use of e-

Invoices, which represents an administrative burden. A solution could appear the

institution of a public register and the provision about which organisation included in

the register confirm their availability in using e-Invoicing. It also appears quite difficult

to calculate exactly the savings that derive from switching to e-Invoicing due to a variety

of available solutions and services related to e-Invoicing.

2.4 Report on Spain

The report on “ICT in Spanish SME and big companies” published in 2012 by the

National Observatory of Telecommunications and Information Society16 states that 43%

of companies with 10 or more employees send electronic invoices. 60.4% of large-sized

companies (>250 employees) send electronic invoices, followed by 53% of medium-

sized companies (50-249 employees); while small-sized companies (10-49 employees)

have lower adoption than average.

15 For certification of providers is responsible Archive of the Republic of Slovenia. 16 http://www.ontsi.red.es/ontsi/es/estudios-informes/las-tic-en-las-empresas-y-microempresas-espa%C3%B1olas-edici%C3%B3n-2012

http://www.ontsi.red.es/ontsi/es/estudios-informes/las-tic-en-las-empresas-y-microempresas-espa%C3%B1olas-edici%C3%B3n-2012

http://www.ontsi.red.es/ontsi/es/estudios-informes/las-tic-en-las-empresas-y-microempresas-espa%C3%B1olas-edici%C3%B3n-2012

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However, taking into account the distinction of e-Invoice with structured and non-

structured format (i.e. images or pdf), only 15.7% of the companies are using structured

formats.

Another survey published in the observatory for the use of “ICT in the Spanish

Companies in 2010” indicated that 6.5% of Spanish entities were sending e-Invoices

while 25.9% foresee to do so in less than 3 years. The majority of these firms (83.4%)

send e-Invoices by their own means while only 8.6% use banks and 1.5% other service

suppliers. This report stated that the main reason (67.6%) why companies were not

sending e-Invoices was that clients were not requesting them, followed by lack of

information (16.5%), not having the required software tools (9.4%) or not having the

digital signature (8.7%). Only 10.5% of the companies were using e-invoices in all their

operations, while for 28.7% of the companies, e-Invoices were used in less than 10% of

total. In terms of e-Invoice reception, the penetration is larger with 30.8% of the

companies. Only 9.2% of these companies were receiving e-Invoices in more than half of

its volume.

The penetration of e-Invoice in the self-employed collective was 2.7%, with its intention

to use it in 2 or 3 years of 15.1%. From this collective, 89.9% sent the e-Invoices

themselves while 10.1% use a bank as intermediary, and 15.6% sent all invoices in

digital format. In terms of reception 11.1% had received e-invoices, and 5% were

receiving all invoices in this format.

A useful indicator about the penetration, given by this observatory, is the percentage of

companies that are sending and/or receiving electronic invoices:

Figure 20. Percentage (%) of companies using electronic invoices. Source: www.ontsi.red.es / Eurostat

Although these figures are quite encouraging, it must be recognised that the adoption of

e-Invoicing in the Spanish port and transport sector is still very low. The creation of the

http://www.ontsi.red.es/

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conditions for the adoption of e-Invoicing represents a clear opportunity for B2MoS to

increase the efficiency of the Motorways of the Sea.

Another interesting report is the survey on the use of electronic invoices in Spain. For

the period 2009-2012, which was published in June 2013 by SERES17, a company

specialised in document process automation and interconnection services. According to

this study, during the first half of 2012, there were approximately 56 million of

electronic invoices issued, a five-fold increase from approximately 12 million electronic

invoices processed in the same period in 2009. During the period under analysis,

approximately 107.000 companies were issuing or receiving electronic invoices. This

quantity reflected that there was a clear majority of companies receiving e-Invoices in

comparison with the ones issuing e-Invoices. This study confirmed a sustained growth of

the e-Invoice in a market driven by large companies, especially in the retail and

automotive sectors.

The use of the e-Invoice is also quite unbalanced for Spanish regions. Catalonia and

Madrid are leading in terms of the usage of electronic invoicing and Andalusia and

Castilla-León are still quite active in terms of receiving e-Invoices, while the rest of Spain

is still in quite lower rates. The different rates of adoption are influenced by the

promotion measures taken by public administrations as well as by the configuration of

the business fabric.


The most relevant law in-force dealing with e-Invoicing is the Regulation18 approved in

November 2012 for the obligations of invoicing. This law is the transposition of

Directive 2010/45/EU, concerning the approval of a common system for the VAT.

The regulation guarantees the equivalence in dealing with electronic and paper invoices.

It recognises that the expedition of an electronic invoice is not subject to a particular

technology, provided this technology satisfies the requirements of an invoice.

Thus, although it is no longer required the use of EDI or advanced digital signatures for

e-Invoices, the regulation recognises that both particular solutions guarantee the

authenticity of origin and the integrity of the content of electronic invoices.

17 SERES Group is a company that belongs to Docapost group and Bull. SERES headquarter is in France and it is

exclusively dedicated to providing solutions for secure electronic exchange of business document will legal force,

including EDI and electronic invoicing. 18 Royal Decree 1619/2012, of 30th November 2012, which approves the Regulation of the obligations for

invoicing.

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Other regulations associated with the e-Invoice are:

Law for the measures to boost the information society19

Order which develops certain provisions related to online invoicing and

electronic invoice storage20.

Order on the issuing of invoices by electronic means when their addressee is the

General Administration of the State21.

Regulation on the e-invoice format for the invoices addressee to the Public

Sector22

Regulation on the VAT23.

General tax law24.

Electronic signature law25.

Approval procedure for digitisation software26.

The regulation for the obligations of invoicing, in force since January 2013, establishes

the following requirements:

1. The issuer shall generate and deliver an invoice for the products and services

delivered in its commercial or professional activity. It must account and

annotate the invoice in the VAT records and it must keep a copy or the original

(database) recording the issuance for 4 years following the year of accounting. It

shall guarantee complete accessibility for visualization, selective search, copy or

19 Law 56/2007, of 28th December, of measures to boost the information society. 20 ORDER EHA/962/2007, of 10 April, which develops certain provisions related to online invoicing and electronic

invoice storage, contained in Royal Decree 1496/2003, of 28 November, which approved the Invoicing

Obligations Regulations.

21 ORDER PRE/2971/2007, of 5 October, on the issuing of invoices by electronic means when their addressee is

the General Administration of the State or public organisations linked to or dependent on the former, and on

filing with the General Administration of the State or public organisations linked to or dependent on the former

invoices issued between private individuals.

22 Order PRE/2971/2007, of 5th october, on the issuing of electronic invoices when the recipient is the General

Administration of the State or public organisms.

23 Royal Decree 1496/2003, of 28th november, on the aproval of the regulation of the obligations of invoicing

and the modification of the regulation of the VAT.

Law 37/1992, of 28th december, of the Value Added Tax.

24 Law 58/2003, of 17th decemeber, of General Tax.

25 Law 59/2003, of 19th december, of electronic signatures.

26 Resolution of 24 October 2007, issued by the Tax Agency and relating to the approval procedure for

digitisation software dealt with in Order EHA/962/2007, dated 10 April 2007.

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printing during its storage in order to facilitate auditing and inspection of

invoices.

2. The recipient of the invoice shall verify the content required for the invoice, the

authenticity of origin and integrity. It must account and annotate the invoice in

the VAT records, keep and guard the invoices received for 4 years following the

year of accounting. It shall guarantee complete accessibility for visualization,

selective search, copy or printing during its storage in order to facilitate

auditing and inspection of invoices.

3. The content to be included in an invoice, where the most relevant items are :

a. Invoice number: a sequential number and, if it is the case, the series,

which uniquely identifies the invoice.

b. Issue date.

c. Full name and address of the issuer and recipient of the invoice.

d. VAT identification number of the issuer and recipient, when they are

based on any Member State of the Union.

e. Description of the operations: quantity and nature of the goods supplied

or the extent and nature of the services rendered.

f. Date on which the supply of goods or services was made or completed or

the date on which the payment on account was made, when it differs from

the date of issue of the invoice;

g. Taxable amount per rate or exemption, unit price exclusive of VAT and

any discounts or rebates if they are not included in the unit price;

h. the VAT rate/s applied;

i. the VAT amount payable; and

j. Other particular provisions included in the directive.

4. An invoice can be generated in any way or means provided it guarantees the

authenticity of origin, the integrity of content and the legibility of an invoice.

5. The use of an electronic invoice shall be subject to acceptance by the recipient.

6. The use of advanced digital signatures guarantees the authenticity of origin and

the integrity of content.

7. The use of EDI as defined by article 2 of Commission Recommendation

94/820/EC guarantees the authenticity of origin and the integrity of content

when the interchange agreement provides the use of procedures that guarantee

these aspects.

8. Invoices shall be issued at the moment the operation takes place. However, in

cases where the invoice is for the supply of goods or the recipient is a company

or professional, the invoice could be issued up to the 16th of the following month

of the commitment of the operation or the initiation of the transportation.

Summary invoices are also permitted subject to specific rules.

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9. The use of any currency provided the tax value is indicated in euros and a valid

currency exchange rate is applied.

10. The use of any language provided that tax authorities may require the

translation into Spanish when they consider it necessary.

11. The use of amendment invoices for showing corrections to one or more

previous invoices, or product returns, packaging and packaging or volume

extra fees are subject to specific rules.

The legal obligations of invoicing can be subcontracted by the issuer or recipient but

without losing their legal responsibility.

Spanish regulations also support for digitisation of documents, including invoices

received on paper to be recognised as valid, thus enabling the substitution of the original

paper documents by the corresponding files containing their graphic images and,

thereby, allowing the destruction of large quantities of paper that comprise the original

documents. To this end the digitisation software needs to be approved by the Spanish

Tax Agency.

There are also provisions for electronic invoices to be received from third countries. In

order to guarantee authenticity of origin and content integrity, the requirements

applicable to electronic invoices or substitute documents received from third countries

shall be the same as the requirements applicable to those issued and sent within Spanish

territory, regardless of their media or electronic format.

When the documents received by electronic means employ an electronic signature

mechanism system to guarantee their authenticity of origin and content integrity, having

said that, a signature must be a qualified electronic signature; according to Council

Directive 1999/93/EC, dated 13th December 1999, which establishes an EU framework

for the electronic signature. In the event that the system used to send electronic invoices

or substitute documents is a qualified electronic signature, the addressee of the

document, resident in Spain, will be responsible for verifying, prior to accepting receipt,

that the electronic signature used is a qualified electronic signature. The certificate used

for the electronic signature must be a recognised certificate in the Member State where

the invoice was issued.

In the case were an e-Invoice uses mechanisms to guarantee the authenticity of origin

and content integrity other than advanced digital signatures or EDI27, the Spanish Tax

Agency will need to priory approve these mechanisms.

27 When the interchange agreement includes procedures to guarantee these characteristics, as foreseen in

Commission recomendation 94/820/CE

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The Ministry of Industry, Energy and Tourism (MINETUR) is the administration in

charge of the dissemination of the e-Invoice in Spain in the private sector, particularly in

SME, whereas the Ministry of Finance and Public Administrations is in charge of the

adoption of the e-Invoice in the Public Sector.

The widespread use of the e-Invoice is one of the objectives of the Spanish government

for the development of the information society introduced in its strategy 2011-2015. A

plan for the generalization of the use of the e-Invoice has been elaborated based on

previous public consultations among relevant associations. The strategic lines defined in

this plan are: communication and training on e-Invoice, dissemination of tools for the

management of e-Invoices, development of e-Invoice services, aids in the introductions

of e-Invoices, accessibility in the viewing of e-Invoices and evolution of the existing

format “facturae”.

In terms of dissemination, the creation of a website dedicated exclusively to electronic

invoicing (www.facturae.es) by the both ministries involved, is an extremely valuable

tool. This website helps users to easily understand the use of e-invoices. It provides all

the technical specifications of the format “facturae” and, particularly relevant, provides

the tools for the companies to use e-Invoice solutions at low cost. The website

concentrates the information regarding the e-Invoice, formats, applications, regulations

and guides.

On the other hand, a law for boosting the use of electronic invoices in the public

administration sector was approved on December 201328. With this law, public

procurement providers will have more protection in their commercial relations through

a recording of invoices in the public sector, which will fix the dates for payment of

interests in case of delays.

This law foresees the mandatory use of electronic invoices in the public sector by

January 2015 and the creation of general points of entry for the presentation of e-

Invoices to the competent registry and accountant office. In principle there will be up to

three points of entry for e-Invoices (at national, regional and local level). This legislation

also intends to boost the use of the e-Invoice in the private sector.

The law establishes that all e-Invoices for the public sector will follow the same

structured format and will be signed with an advanced digital signature with a

certificate recognized by the Public Administration. Although a change in the format is

28 Law 25/2013, of 27th December, for boosting the use of electronic invoices and the creation of an accounting

of invoices in the Public Sector.


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foreseen briefly, the current approved format is “facturae” version 3.2. An advanced

digital stamp29, when defined and formalized, will also be allowed to identify the person

that digitally stamps an e-Invoice.

In 2011, the Council of ministers in Spain approved the creation of a National Multi-

stakeholder Forum for the electronic invoicing and promotion of the Electronic

Invoicing Central Management System in the General Administration of the State30. A

Technical Commission for the e-Invoice was also created for assisting the competent

ministries in its dissemination and adoption. There are 40 members in this commission.

Its goal is to ensure that the electronic invoice and its advantages become a reality in

Spain.

The national multi-stakeholder forum is composed of members of the technical

commission, representatives of the Secretary of State for Telecommunications and

Information Society, and representatives of the following associations: multi-sectorial

association of ICT companies (AMETIC), internet companies’ national association

(ANEI), Spanish association of telecommunication and information society users

(AUTELSI), Spanish association of digital economy (ADIGITAL), council of consumers

and users (CCU), inter-bank cooperation center (CCI) and Spanish organization of

enterprise organizations (CEOE).

The public corporate entity RED.ES31 attached to the MINETUR, which is responsible for

promoting the development of the Information Society in Spain. It is also playing a key

role in promoting a greater use of the e-Invoice.

The activity of the National multi-stakeholder forum is:

Propose initiatives oriented to the promotion and adoption of e-invoice in Spain,

especially in regulation, standardization and interoperability.

Assistance in the elaboration and initiation of activities for the dissemination of

the use of e-Invoice in Spain.

Collaboration in actions oriented to disseminate the use of e-Invoice in Spain,

especially within SMEs.

Facilitate the exchange of experiences and good practices in the process of

development and adoption of e-Invoice in Spain.

29 A digital stamp is the set of electronic data, consigned or associated to electronic invoices, which can be used

by a legal entity or an individual to guarantee the origin and the integrity of its content. 30 Ministry of the Presidency of Spain. Order PRE/2794/2011. Council of Ministries agreement on the framework

for the competences of the State in electronic invoicing, creation of the National Multi-stakeholder forum on

electronic invoicing and boost of the Central Service of the management of electronic invoicing in the domain of

the General Administration of the State. 31 http://www.red.es/redes/en/quienes-somos.html

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Perform analysis and studies regarding the adoption of the e-Invoice in different

economic sectors.


A ministerial order in 200732 established the format of e-Invoice and the technical

conditions to present it in front of the Public Sector, with the objective to ensure the

interoperability of the invoices sent to the Administration. This regulation established

the requirement to use advanced digital signatures to guarantee the authenticity of

origin and the integrity of content, for e-Invoices addressed to the Public Sector.

Concretely, the established format for the advanced digital signature will be compliant

with the specification XML-Advanced Electronic Signatures (XAdES) conformant to the

standard ETSI TS 101 903.

The format established by this regulation is named “facturae”. The format is described

through a XSD schema, and its specification is maintained and updated in the website

(www.facturae.es.) Current active version is “facturae 3.2” and there are two previous

versions (“facturae 3.0” and “facturae 3.1”). However the regulation states that the

electronic invoice format will be adapted to the UBL (Universal Business Language)

format or the one that is established by the normalisation organisms CEN (European

Committee for standardisation) or CENELEC (European Committee for electro technical

standardization) of the European Union. Consequently, it is expected that in the future,

the format “facturae” will evolve towards the Core Invoice data model that has been

established by CEN. In this sense, a draft version of the “facturae 4.0” was published that

goes in the direction of migration towards European standards.

Finally, the regulation also mandated the MINETUR to publish the required tools to

ensure the convertibility and interoperability of the established format for the e-Invoice

and any evolution of this format in the future.

The regulation of the invoices on the other hand gives freedom to the private sector to

choose the format for the e-Invoice. It recognises that the expedition of an electronic

invoice is not subject to a particular technology, provided this technology satisfies the

requirements of the regulations. However, it is expected that the adoption of set of

standards by the Public Sector will also promote its adoption within the private sector

and it will generate the availability of IT solutions supporting this standard at lower

costs.

32 Order PRE/2971/2007, of 5th October, on issuing invoices by electronic means when the recipient is the

Central Administration of the State or its public organisms and the presentation of invoices among particulars

to these bodies.


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When advanced digital signatures for e-Invoice are used, the use of an e-delivery or EDI

providers are not required. However the issuing and receiving of invoices and storage

services can be subcontracted to third parties.

Many banks are providing e-Invoicing services linked with payments. The following

banks are offering this kind of solutions from their web sites: Banco Popular, Banco

Sabadell, Bankia, Bankinter and La Caixa. Some banks are providing electronic services

through a company created by them for this purpose, named Eurobits.

Although the characteristics of the service offered may vary slightly, the following

common characteristics are quite usual: sending/receiving invoices by e-mail, loading of

invoices, access to the website, compliance with all legal requirements for the storage

and queries, signing and verifying signatures on bills and integrity, compliance with

“facturae 3.2” format. These solutions offered by banks are usually provided free of

charge or at a very low price to their enterprise clients (as it is used by the bank to sell

its financial services for payments).

On the other hand, bigger companies are still using EDI solutions for e-Invoicing and

relying on EDI networks and providers. For example, there is a consolidated company

named EDICOM, who provides this kind of service to large companies in different

sectors like retail, manufacturing, logistics and transport, health, etc.

2.4.5 Archiving

The regulation states that the sender shall account for and annotate the invoice in the

VAT records and it must keep a copy or the original (database) recording the issuance

for 4 years following the year of accounting. It shall guarantee complete accessibility for

visualization, selective search, copy or printing during its storage in order to facilitate

auditing and inspection of invoices.

For the recipient, it states that they shall verify the content required for the invoice, the

authenticity of origin and integrity. It must account and annotate the invoice in the VAT

records, keep and guard the invoices received for 4 years following the year of

accounting. It shall guarantee complete accessibility for visualization, selective search,

copy or printing during its storage in order to facilitate auditing and inspection of

invoices.

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The report “ICT in the Spanish Companies in 2010” identified that the main reasons why

companies were not sending e-Invoices was because clients were not requesting them,

followed by lack of information, not having the required software tools or not having the

digital signature.

There is a chicken-and-egg dilemma in the adoption of e-Invoices; the issuance of e-

Invoices requires the conformity of the recipient. So, if there is a low volume of

recipients prepared and requesting e-Invoicing, issuers will not offer this service. If

there is a low volume of issuers ready to send e-invoices, then the recipient is not going

to ask for them. Another typical problem to start using e-Invoices is to know which

companies are ready to send or to receive e-Invoices.

However, a more detailed study will be required in port communities to clearly

understand what the barriers are for the adoption of e-invoice solutions in Motorways of

the Sea.

3 Solutions for using electronic invoices for billing MoS transport services,

port operations and port dues

In the period from February-March 2014, interviews conducted for members of the port

communities participating at the project and transport actors. Eventually, shippers and

consignees were interviewed to understand the maturity of the MoS market in relation

to e-Invoicing. These are the highlights from interviews performed.

3.1 Greece

The summary of the findings from the questionnaire survey are presented below.

Sample size: 4 forwarders, 2 Shipping Lines, 2 Shipping Agents.

The questionnaire survey was conducted with onsite visits and free discussion with the

interviewees. The main messages (apart from those filled in the questionnaires) have

been described.

All companies used e-invoices but of a “Untrue e-invoice type”. They have developed

their own applications, mainly to serve their internal needs for financial and accounting

management. Their invoicing systems are able to print out the invoice in several formats

that can be used by e-mail to send to their collaborators. Some of the invoice’s required

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data is retrieved from their internal databases, thus they do not have to enter all the data

manually.

The main reason for not having a “True type” is that their customers are not able to

receive them and/or they have not requested it. Only one company has e-Invoicing with

a major client who has asked for it. In this context, the company reported that if another

client would favor this type of transaction, they would implement another customized

solution. Another issue reported is related to the legal framework, which is currently

under major reformation in Greece. Thus, they prefer to wait until the final regulations

are set regarding VAT, validity of the transactions etc.

All companies recognize the benefits from e-Invoicing. In the cases of Shipping Lines

where invoicing must be made for several clients per item, the possibility of using e-

Invoices is considered as a valuable advantage towards efficiency. Cost savings,

resources savings, and fewer errors are the main benefits that are recognized.

Standardisation is considered important in case they would like (or imposed by the

market) to implement an e-invoicing system. They welcome the initiative for developing

Greek Core Invoice, even though they consider it a starting point for their activities. The

main reason is that the maritime sector lacks the codification of activities and items and

this cannot be covered by the generic template. They recommend that if the Ministry of

Finance imposes this type of collaboration, the penetration of e-Invoicing in the Greek

Market will be facilitated. But they emphasise that in order for the implementation costs

to be compensated, the tailor made solutions with their partners must be eliminated.

3.2 Germany

Stakeholders from liners, port authorities, logistic service providers and associations as

well as forums and working committees were interviewed. The results along with

feedback and conclusions are considered in this report.

Among others the following organisations were contacted directly:

Hapag Lloyd AG Germany (liner/ carrier).

UNIVEG Deutschland GmbH (logistics service provider/fruit importer).

GS 1 Germany GmbH (company/ standardisation expert).

FeRD – AWV e.V. (forum of electronic invoices).

Gesellschaft für Logistische Systeme LS GmbH (IT company/ business process

integration expert).

Apart from the aforementioned interview partners, six additional interviews were

conducted by phone with representatives of towage companies, truckers and rail

operators. Basically, the percentage of penetration of e-Invoicing in the transport sector

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and in particular in the surveyed maritime logistics industry is currently estimated with

an average of approximately 5% or less.

It can be stated that analogous to other industries, there are differences between small,

medium and large sized companies that is directly related to the amount of invoices and

corresponding data volumes but also to the existing IT systems and implemented

software applications. Comparing the maritime industry with the big trade enterprises

or the automobile industry it must be admitted that electronic invoicing is only partly

spread and not really accepted by all of the business partners yet.

However, companies already tried to implement electronic invoicing systems in their

companies but some of the trails failed due to the fact that business partners were not

able to send or to receive electronic invoices and/or the big heterogeneity within the

business landscape prevented the implementation of electronic invoicing systems at that

time.

The identified constraints are more or less the same within other industries as legal

uncertainties, technical and organizational imponderability’s or acceptance problems on

the client side as well as high investment levels for the implementation of electronic

invoicing systems. On the other hand, there are companies working close together with

the big trade enterprises and the communication as well as the invoicing procedure,

which is managed via EDI / EDIFACT messages or using other formats (outgoing

invoices). So they are in-line with the established data exchange standards, which are in

use during the last 20 years. One stakeholder for instance is using an external service

provider, which is distributing and receiving the EDIFACT messages to the

communication partners.

With respect to the conducted interviews there is no real or unique best practice

identified which can be applied or rolled out within the whole maritime industry such as

transport services, port operations or port authorities.

Due to the fact that the specific requirements of the individual business processes are

quite different, it is difficult to find a case that matches them all. However, it can be

stated that solutions like EDI/EDIFACT and XML have been proven to work e.g. in the

case of large companies. They have been using these kinds of data exchanges for a very

long period of time with great success. With respect to small and medium-sized

companies, the e-mail with an attached pdf document covers (in most of the cases) the

existing needs. Additionally, it can be stated that this system works, irrespective of

media disruptions and inoperability of automation.

Furthermore, within this report, the ZUGFeRD data format offers great potential to be

the best practice in the near future. This is due to the fact that this format offers two

different options; the pdf format as well the XML format. ZUGFeRD is most likely to be an

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adequate solution for small companies (using the pdf option) and also for medium-sized

companies (using the XML option). By doing so, the ZUGFeRD format could match the

demands and requirements of the majority of companies and will most likely boost the

penetration of electronic invoice within Germany.

In general, the companies of the transport sector have to cope with more or less the

same challenges and constraints related to the introduction of electronic invoices as

other major industries. Amongst other companies, there is one specific problem

identified, which concerns the transport of goods and the enclosure documents or

accompanying documents. Often a signing or stamp is requested for approvals or

authorisations. Basically, these documents need to be transmitted with the invoice to the

client or to the business partner. The ZUGFeRD data format offers also the possibility to

attach other documents e.g. pictures, to the embedded XML file. At this point of time, a

solution for the aforementioned problem might be visible.

Another problem was mentioned by the port authority, which works together with some

external service providers and/or pilots. Their services to vessels are normally recorded

on paper slips/receipts and signed by the captain of the served vessel. The information

from the receipts needs to be entered manually into the accounting systems of the port

authority. Currently, it is under investigation to explore whether tablets can be used by

the external service providers/pilots for the recording of the services, and if the

information can be transferred via some interface to corresponding accounting / ERP

systems or to the existing port community system (PCS).

3.3 Slovenia

In the framework of the activity besides contacting the representative of the National

Forum on e-Invoicing Intereuropa and Luka Koper interviewed the following

organisations:

Slovenske železnice – Slovenian railways – national railway carrier

Adria Transport – private railway carrier

Adria Kombi – railway operator

Metrans Koper – railway operator

Maersk Koper – shipping agent

CMA CGM Koper – shipping agent

Pacorini Koper – forwarder & logistics operator

DHL Slovenia – courier service company

Gefco – forwarder & logistics operator

Alfa sp – forwarder & logistics operator

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Europacific d.o.o. - forwarder & logistics operator

Adria Airways – air carrier

Urdih transport – road haulage

Porsche Inter Auto – automotive vendor

Piloti Koper - pilots

Uprava Republike Slovenije za pomorstvo – Maritime Administration of the

Republic of Slovenia.

Moreover, they gathered information indirectly about the Custom Administration of the

Republic of Slovenia, Ruben (trader) and Philip Morris Ljubljana (trader).

The companies that participated at the interviews were already interested and

acquainted with the topic, so it seems that they were somehow advanced in comparison

to the average of operators present in Slovenia. Generally, it suggests that companies are

getting ready to use electronic invoices (e.g. Luka Koper, Intereuropa, Pacorini) and

some are already exchanging with just few customers or suppliers e-mails with pdf (e.g.

Metrans, Maersk Koper, Alfa sp) or e-mails with xml (e.g. Pacorini, Slovenske železnice,

Adria Kombi, CMA CGM Koper, Europacific d.o.o.). Only DHL Express has used e-Invoices

for several years now, issuing 62% of e-Invoices of the total percentage. In the majority

of cases, paper invoices are still sent, even accompanying the electronic invoice. It

appears that there are not many pressures from the environment to change the way

they are working today.

Few companies are using intermediaries such as e-delivery providers, since e-mail is

thought to be a suitable and reliable channel for transmission. Few were interested in

proof of delivery, possibly due to the fact that in the majority of cases, paper still persists

together with the electronic form.

When talking about structured invoices, the operators reported to be focused only on

the domestic market and are implementing solutions using the national standard e-Slog.

It appears that the volume with the domestic market is much bigger, therefore they will

give their attention to cross-border relations in a second stage. Regarding this, there

were even some uncertainties regarding VAT legislation in the foreign countries; not

knowing if electronic invoices were considered equivalent to paper ones, even for

operations in EU.

There were some figures about costs that related to the introduction of e-Invoicing, but

it was difficult to indicate any financial savings. Most operators indicated other reasons

for choosing e-Invoicing. Large companies are approaching e-Invoicing as part of

internal optimization processes. Many companies are moving towards electronic

invoicing and the connected automatization of processes as it is an opportunity to

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disburden people from administrative tasks, to be able to put them on more productive

and important functions.

Enclosures are very problematic in the port and transport sector. Regarding railway

transportation, according to legislation, CIM can be created in an electronic form, but it

must be printable in any circumstance. Due to this requirement, it is problematic, and

paper is used for the entire process. However, the national carrier is conducting an

internal project to make the transition to electronic railway bills. In case of the rolling

highways that are organized by Adria Kombi, the railway bills will also used as tickets

for truck drivers. But at present, they find it more convenient in a paper format.

Similarly the CMR is accompanying cargo as a paper document and there currently

aren’t any possibilities to change the situation.

In port business, there are many enclosures accompanying the invoices, but since they

originate as paper documents, they can be scanned and digitalized, however, the

originals must be stored in paper.

E-archiving is still an enigma for private operators in Slovenia. According to legislation,

to have proof of authenticity of the origin, integrity and legibility of the content, an e-

Invoice, which is generated and transmitted in an electronic version, must be stored in

and e-archive. The problem is that it is very difficult to have the internal rules certified

by the National Archive of the Republic of Slovenia, because the rules for certifying the

archives were made for the public sector. Another strategy is to outsource storage to a

certified provider, which comes with a cost. Nevertheless it seems that some changes in

the legislation would be needed.

Unfortunately, only one case could be identified as a perfect example. DHL Express

Slovenia, which operates as a branch office of the global courier Service Company, has

been using e-Invoices for several years now. The volume of e-Invoices issued is 62%,

with the objective to reach 85% by the end of 2014. They recognized the benefits in

reduced process time, savings in money, and being seen as a “green” business in terms of

operation. The formats of sent invoices are pdf, csv, xml and html, via e-mail or using

web-portal software. In their business environment, they are typically defined by the

following aspects;

They don’t use any external delivery provider, but implement their own.

Since the clients enter all the data when entering the order into their system,

they are able to check the CMR or proof of delivery.

They have offered the web-portal solution for small clients.

In their business environment they act as a driver for introducing e-Invoices and serves

as a prime example or benchmark for other companies to follow.

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Interestingly, both the Maritime Administration and the Customs Authority approached

e-Invoicing ahead of time (in particular before the 27th of December 2013, date of the

adoption of amendment to the Act on the Provision of Payment Services to Budget

Users). Several Slovenian freight forwarders practiced structured XML e-Invoicing with

the Customs Authority when acting as an authorized entity for customs services. If they

can fulfill formal technical conditions according to customs regulation (ZICPES law)

regarding electronic communication with Customs authority, they receive formal

statement from Customs Authority. This allows them to use EDI for receiving invoices

for customs services, which completely substitute the paper. The Maritime

Administration on the other hand issues invoices for port dues in pdf, which are

downloadable from the SI SSN system that shipping agents are using to announce

vessels’ arrivals.

3.4 Spain

Spain partners have executed a set of surveys to several partners related with the port

community.

The scenario of the study is the following:

Survey time interval: Between February 2014 and April 2014.

Number of participating companies: 27.

Roles of participants:

o PCS’s.

o Port Authorities.

o Freight Forwarders.

o Ship Agents.

o Custom brokers.

o NVOCC’s.

o Container terminals.

As a result of the executed surveys, we can extract the following conclusions described

below.

66.67% of the surveyed companies are currently using electronic invoices. Within those

companies, 48.15% of them state that electronic invoices have legal validity.

Most of the companies that are using electronic invoices are sending and receiving the

paper printed invoices too, so they are duplicating work (even if companies know that

electronic invoices have legal validity).

There are several formats used, but one of the problems is that many of the companies

don’t know the format used by their software applications. The official format in Spain is

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‘facturae 3.2’ (http://www.facturae.gob.es/paginas/Index.aspx), but there are other

commonly used formats such as Edifact, INVOIC or even signed pdf files.

Companies are especially concerned about the length of time spent on invoice processes

or cost savings, but on the other hand, companies identify the following inconvenience

on introducing electronic invoices:

Implementation costs.

Lack of specifics related to the maritime sector:

o References (Booking number, container plates, etc.)

o A standard codification of services and items in invoice details.

Lack of technical and information support. Companies know that ‘facturae 3.2’ is

the recommended official format by the Spanish government, but some vendors

or customers are working with other formats like EDIFACT-INVOIC or UBL. Due

to this, companies have doubts about which is the best or recommended

technology in order to use electronic invoices.

Difficulty obtaining and applying digital signatures.

In relation to software tools, the most commonly used strategy is to integrate electronic

invoices with the company Enterprise Resource Planning (ERP). The other two possible

strategies to choose from are either free tools or low cost invoicing and accounting

systems (of course, with electronic invoices capabilities).

Below, the specific results of the Spanish survey:

# Question ANSWER Quant. %

1 Are you currently sending or receiving electronic invoices?

Yes 18 66.67

No 9 33.33

2 When yes, are those invoices legally valid?

Yes 13 48.15

I don’t know 10 37.04

No 4 14.81

3 Which electronic format is used in order to send or receive electronic invoices?


I’m not working with it 9 31.03

EDIFACT-INVOIC 3 10.34

Signed PDF 3 10.34

Spanish format ‘Facturae 3.2’ 2 6.90

Other 1 3.45

4 What are the benefits in using e-Invoicing?

Saving time 14 38.89

Cost Savings 10 27.78

Automation 8 22.22

Ease and control 4 11.11

5 What hesitations or barriers do you Investment costs 4 30.77

http://www.facturae.gob.es/paginas/Index.aspx

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identify in order to send or receive electronic invoices?

Lack of maritime references 3 23.08

Need of coded services in detail of invoice

2 15.38

Possibility of invoice rejection 1 7.69

Digital signature 1 7.69

Lack of information 1 7.69

Lack of parties predisposition 1 7.69

6 What type of tool do you need to use electronic invoices?

ERP Integration 12 48.00

Free tolos 6 24.00

Low cost tools 5 20.00

Signed PDF 1 4.00


7 Can you participate in a pilot action using e-Invoice?

Yes 16 59.26

No 11 40.74

8 Can you get involve to vendors in order to send electronic invoices to you?

Yes 15 55.56

No 12 44.44

9 Can you get involve to customers in order to send electronic invoices to you?

Yes 15 55.56

No 12 44.44

4 Roadmap for the establishment of an electronic invoice environment for

intra-EU freight flows

The analysis of the current situation in Germany, Greece, Slovenia and Spain shows that

there is a relatively small volume of electronic invoices in use, which statistically

appears to cover an average of 15 to 20% of economic operators. However, it appears

that some companies are moving towards or getting ready to start using structured or

non-structured electronic invoices. It is necessary to clearly distinguish between

structured and non-structured e-Invoice format because the current understanding of

the term ‘e-Invoice’ in individual countries can be quite different. It has to be recognized

that only structured e-Invoices can automate and optimize business processes within

the company and between partners. There are some enterprises, in particular large and

medium enterprises that found it convenient to introduce e-Invoicing, but have

problems in increasing the share of e-Invoices in comparison to a paper one, since the

majority of their business partners are persisting to still use paper. The maritime and

transport sectors do not seem to be any particular exception to the general situation;

this is why the following recommendations can be applied to any intra EU trade:

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1. The analysed Member States have adjusted their legislations and have created

the condition to favour e-Invoicing. The Member States have transferred

provisions from the Council Directive 2010/45/EU in national legislation with

quite similar approaches.

At that point it appears relevant to understand if there are uncertainties present

in legislation (ex. the case of the need of certifying e-archiving in Slovenia) that

should be clarified, but it would be also important to try to introduce further

simplifications when possible in particular if and when the legal requirements

appear to be too high to be met (ex. abolition of the imperative of the digital

signature within electronic invoices in Germany).

2. Through interviews with maritime and transport operators, it appears very clear

that legal requirements and even benefits of e-Invoicing are not always known. It

means that a greater communication effort must be carried out to explain the

legal aspects in the use of e-Invoicing, clarify legal and other doubts, but in

particular present the advantages from using e-Invoicing. Such work could be

done through many channels, with particular attention directed towards small

and medium sized enterprises that do not always dispose of sufficient resources

to concentrate on IT and legal themes; where it is very relevant that activities are

coordinated by a national actor with a suitable mandate.

3. Increased communication should be followed by training programmes just as

they were introduced in Spanish strategic plans to support a capacity shortage

and to prepare the environment for the use for electronic invoicing.

4. To stimulate the business environment, but in particular in the case of micro and

small companies, there could be financial incentives given by Member States to

support investments needed to introduce e-Invoicing.

5. To spread the use of e-Invoicing; it would be very useful to exchange experience

and good practices. Since knowing the advantages in using e-Invoicing, operators

will be motivated to change the way they are operating today.

6. From interviews with operators, it appeared that those who are approaching e-

Invoicing are focused on domestic needs first using national standards, since they

are afraid of issues related to the use of different standards in case of intra EU

operations. Availability of technical solutions that could ease such operations

would be necessary. Moreover, further research on such aspects will be needed

(despite the semantics rules for the core of the e-Invoices that are under

preparation).

7. For the maritime and transport sector, attachments to invoices are problematic,

since they originate in a paper form and are normally requested as a proof of an

executed service (example: CMR, CIM, pilotage confirmation, confirmation of

water supply to vessels etc.). Technical solutions should be found that support

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the digitalisation of such invoices or even the introduction of modified

procedures to enable paperless operations. The case of digitalisation software

introduced in Spanish legislation should be further studied.

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BIBLIOGRAPHY

E-Invoicing Standardisation, Overview, issues and conclusions for future

actions, Industrial Innovation and Mobility Industries, ICT for Competitiveness

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E-Rechnungen als Chance in einem veränderlichen Marktumfeld, Bruno Koch,

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Invoicing and Workflow, Integrating Process Automation to Enhance

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SEPA: potential benefits at stake, Capogemini Consulting.

International Market Overview & Forecast, Bruno Koch, Billentis, February

2014.

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Electronic Invoicing Initiatives in Finland and in the European Union, Helsinki

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http://www.vlada.si/fileadmin/dokumenti/si/Sporocila_za_javnost/prilagajanje_izdatkov_sektorja_drzava_v_casu_krize-umar.pdf

http://www.vlada.si/fileadmin/dokumenti/si/Sporocila_za_javnost/prilagajanje_izdatkov_sektorja_drzava_v_casu_krize-umar.pdf

http://www.gzs.si/slo/6679

http://www.ujp.gov.si/dokumenti/dokument.asp?id=411