16 June 2026 — Consultation Response
Accountancy Europe has responded to the European Commission’s public consultation on the revision of EU electronic invoicing rules.
This consultation is important because any revision of the EU’s eInvoicing rules will set the template for the implementation of VAT in the Digital Age, with major implications for most businesses and their advisers.
Accountancy Europe supports eInvoicing as a tool that can help businesses improve efficiency, provide more up-to-date financial information, and open the door to cost-saving measures that Member States’ tax authorities could introduce, such as prefilled tax returns. It could also help improve the speed of payment.
The information exchanged would also give tax authorities far more up-to-date data, helping them assess risk and respond to threats to their tax bases more quickly and effectively.
However, the move to eInvoicing will create short-term costs for both businesses and tax authorities, and these costs will be particularly heavy for SMEs.
We therefore call for all technical standards relating to eInvoicing and the exchange of eInvoicing data to be finalised as soon as possible, so that software solution providers can update their systems well in advance of the implementation date. However, we do not support the mandatory inclusion of eInvoicing in all software solutions, as this may create unnecessary costs for the very smallest businesses and their solution providers.
We are also concerned that requiring suppliers to issue eInvoices for public procurement contracts below the current threshold could create difficulties for SMEs, particularly where invoicing is infrequent.
There is a risk that mandatory eInvoicing could discourage some SMEs from seeking contracts with public bodies, something that is already difficult in some Member States because of public procurement requirements.
The introduction of eInvoicing needs to be clearly communicated to businesses well in advance, so that they have time to prepare for the significant changes to systems and processes that many will need to make.
We also believe that governments should consider practical support measures to help businesses make these changes, particularly SMEs.
It is important to have a harmonised eInvoice standard and system across Europe to help reduce implementation and operating costs, and to avoid hindering cross-border trade.
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