With the publication of Outline of electronic invoicing and reporting, the government has made a number of important decisions.
The key dates are:
Businesses making use of the Small Business Scheme (KOR) remain exempt from the new domestic obligations, but are subject to the obligations under ViDA.
The direction is therefore clear. At the same time, a number of key elements still need to be worked out in more detail.
The decision to implement the changes in phases is a sensible one.
From July 2030, businesses must first ensure they can send and receive e-invoices. Digital reporting of domestic invoices to the Tax and Customs Administration will follow a year later.
E-invoicing is new to many organisations. Time is needed to optimise processes accordingly.
It would have been even better to start with e-invoicing alone. Other countries have shown that a two-year lead-up period before the requirement comes into force provides sufficient time for preparation.
A key decision is that the Netherlands is adopting a single European standard for e-invoices: EN-16931.
Put simply, this standard specifies which data must be included in an e-invoice and what that data means.
This has implications for sectors that currently use their own invoicing standards. In the construction and installation sector, for example, DICO is used; in the temporary employment sector, SETU; and in retail and wholesale, various EDI and GS1 messages are used.
The impact varies depending on the standard. Some are already well aligned with the European standard, whilst others are not. Where this is not the case, the invoice will need to be adapted or converted to the European standard.
This does not, however, mean that all existing sector standards will disappear. Messages such as orders, order confirmations and packing slips can continue to exist within the existing standards. This specifically concerns the invoice.
This is an important point to consider.
An e-invoice contains information exchanged between the supplier and the customer. That does not mean that all of that information must automatically be sent to the Tax and Customs Administration.
There must be a clear legal basis for the data being requested. Only information that the Tax and Customs Administration requires for its statutory duties should be reported.
This becomes particularly important as data from invoices will soon be submitted on a large scale.
This also raises a second question: what will happen to the periodic VAT return?
Under current plans, this will remain in place. If the Tax and Customs Administration is soon to receive data on an invoice-by-invoice basis, measures must be taken to ensure that businesses do not have to submit the same information a second time.
If e-invoicing is also intended to reduce administrative burdens, this is a key point for further elaboration.
It has not yet been decided via which network businesses will exchange their e-invoices.
The government is considering five principles in this regard. Remarkably, Peppol meets all of these principles.
Interoperability
Peppol has been specifically designed to enable businesses using different software and different service providers to communicate with one another. Not only is the message format standardised, but so too are addressing, transmission and the agreements between the parties involved.
The relationship between e-invoicing and digital reporting
The invoice must be sent from the supplier to the customer, whilst some of the data must be sent to the tax authorities. Within a network of Peppol Service Providers, these two functions can be organised separately without having to build two completely separate invoicing infrastructures. Various countries in Europe and beyond are already using the Peppol network for this purpose
Secure and reliable data exchange
Peppol works with authorised Service Providers, PKI certificates, security requirements and compliance agreements. This means that security and reliability are integral to the network itself, rather than being the sole responsibility of the individual software supplier.
Competition
Peppol is not a centralised platform operated by a single supplier. Organisations can choose their own Service Provider. These Service Providers compete with one another but can exchange messages via the same network.
Supervision and enforcement
Peppol already has a governance structure comprising Peppol Authorities, Service Provider Agreements and procedures for compliance and enforcement. In the Netherlands, the Dutch Peppol Authority (NPa) and RDI supervise the Peppol network. Further elaboration must, above all, clarify how this aligns with the statutory supervision required for a mandatory e-invoicing infrastructure.
The government has therefore not yet made a decision on the network. It is noteworthy, however, that all five selected principles directly relate to elements already present in the Peppol model. This is also in line with the earlier study by EY, which recommended building on Peppol for the exchange of e-invoices.
It is striking that the European Business Wallet is also mentioned.
In this regard, it is important to examine its function carefully. A Business Wallet can help to reliably establish which company is participating and who is authorised to act on that company’s behalf.
This could also be valuable for e-invoicing. Better identification makes the exchange more reliable.
However, a Business Wallet does not replace the network through which companies send e-invoices to one another from their financial systems.
In fact, the two can complement each other.
This decision marks the taking of important steps.
Implementation will be phased, there will be a single European standard for e-invoices, and there is clarity regarding the intended implementation dates.
The key questions now lie in the further elaboration:
What data must be reported to the Tax and Customs Administration? How do we prevent companies from having to submit the same information multiple times? And which network will be used for the exchange of e-invoices?
