This blog was last updated on September 23, 2019

The rules on conversion of invoice form and format are not harmonized across the EU and EEA. Thus, even though the majority of these countries allow for an invoice to be converted from paper to electronic form upon receipt, and at the same time for discarding the paper version, this is often permitted only subject to certain conditions. One of these conditions is well founded in the general invoicing rules of the VAT Directive and present in all countries either explicitly or implicitly, namely to ensure the authenticity and integrity of the invoice during and after conversion. Other requirements may lead to the inhibition of conversion in modern e-invoicing systems, e.g. the pre-condition to store the original paper invoice for a given period of time in parallel with the scanned version. There are also still a couple of countries in Europe that do simply not allow for conversion of received paper invoices.

In the last couple of years, we have seen a number of countries changing their legislation in this respect. However, there is no clear trend as to making these rules more or less stringent. Some of the countries have withdrawn burdensome requirements, such as Italy removing the requirements for local storage of scanned invoices, or Spain abolishing the digitization law, which among other things regulated in detail the scanning process and required use of a certified scanning software. Meanwhile, other countries recently regulated the involvement of qualified service providers for these cases, e.g. Belgium, Luxembourg and Slovakia. Conversion of received paper invoices is currently not allowed in France, but it has been recently announced in the yearly budget law that a ministerial decree will regulate this matter in detail in the coming months. It remains to be seen what conditions will be prescribed, among the proposed prerequisites are i.a. the use of e-signatures and local storage.