Gwenaëlle Bernier – Partner & Avocate Associée G56, Tax Technology & Transformation at EY
As France’s ambitious e-invoicing mandate approaches, Gwenaëlle Bernier – speaker at the Tax Compliance Summit Sovos Always On: Paris (19 Nov.) – shares expert insights on how digital transformation is reshaping tax compliance and operational performance. This interview dives into the real-world challenges and opportunities facing finance and tax leaders, revealing why the intersection of technology, regulation, and data is the hottest topic in French business today.
The first challenge is organizational: companies need a truly cross-functional framework that continuously involves the finance and accounting department, the tax department, and IT. Today these three pillars exist but often operate in silos, whereas the reform requires a unified view of accounting, tax, and IT issues, with dedicated time and clear governance. Implementation cannot be entirely “outsourced” to a service provider — some decisions and trade-offs must remain within the company, as they relate directly to its data and processes.
In practice, we first help companies establish this governance framework: clear executive sponsorship, shared accountability, and regular coordination points among teams. In large groups and mid-caps, this is crucial — the scale, diversity of flows, and ERP history make fragmented approaches ineffective. For small businesses, on the other hand, the challenge is simpler and the reform can fit into a broader simplification process supported by accountants or certified platforms.
Finally, companies must build new skills: tax teams need to understand data, while IT must understand tax logic. Anticipating business impacts — data quality, timing, upstream controls, reconciliations — has become essential. Successful projects are those where companies stop opposing “IT project,” “accounting project,” and “tax project,” and instead treat the reform as a single transformation, driven by a mixed, long-term team aligned around common goals.
It’s important to remember that the e-invoicing reform is, first and foremost, a tax reform — it is written into the French General Tax Code under the VAT chapter. It is therefore part of a broader framework of compliance and tax control, which is often overlooked, though it is key to understanding why data quality is so central to its implementation.
The real shift today is that every tax department is becoming digital. It’s no longer just a few tech-curious tax professionals — it’s a broad transformation. Most tax departments are acquiring new skills, and tax professionals themselves are learning to understand systems, data flows, and formats, and to translate regulatory requirements into technical language. This allows them to apply the rules more intelligently and in closer alignment with business needs.
The best practice is to embrace this evolution toward a “tech-enabled” tax professional. Digital tools allow tax teams to collaborate with the rest of the company through a shared language: data. And this data — long used mainly for financial performance or marketing — has now become a core tool of tax compliance. That’s what makes this reform unique: though rooted in taxation, it impacts the entire company. It forces organizations to question the very nature of their ERP data — whether it’s structured, reliable, and truly usable.
The move to prefilled VAT returns will not affect all companies in the same way. For small and medium-sized enterprises, it’s primarily an administrative simplification. They will benefit from support through their accountants or simple tools, sometimes mobile applications offered by certified platforms. For them, prefilled returns will reduce administrative work without significantly changing their organization.
For large companies and mid-caps, however, the impact will be far more structural. Until now, VAT returns have been prepared mainly by accounting teams, with tax departments stepping in only later — during interactions with the tax authorities or audits. Prefilled returns will change that division of labor: tax teams will now need to monitor data continuously, as it will be transmitted to the authorities daily and may prompt immediate follow-up questions.
We are entering an era of reciprocal transparency: companies will reveal their VAT treatment of each transaction in real time, while the administration will send back a synthesized view in the form of a prefilled return. This will inevitably require companies to rethink their internal organization — particularly the split between accounting and tax functions — and to strengthen coordination with IT. It will also demand new skills and heightened vigilance on data quality. The goal will no longer be to produce an accurate return at month-end, but to ensure the reliability of information transmitted day by day. That means better mastering ERP configurations, which in France have often been defined without real tax input. The pace, granularity, and nature of the work will change: companies will need to anticipate, validate upstream, and reconcile accounting and tax data more precisely.
The French tax administration is already equipped with artificial intelligence tools, the most well-known being Galaxie. This data-mining and analytics system, whose early versions date back to 2017, was formally established by decree a few years ago. It now forms the core of the administration’s intelligent data-processing capabilities.
As the reform rolls out and companies begin transmitting their e-invoices and e-reporting data, the administration will have not only the necessary technical infrastructure but also the software capabilities to analyze this information on a massive scale. By 2027, once all businesses are connected, the tax authority will have an almost complete view of France’s economic activity — what each company buys, sells, and trades domestically and abroad.
With Galaxie and this immense volume of data, the State will be able to conduct highly detailed economic and fiscal analyses. It will also transform the way audits are carried out: by the time a tax inspection begins, auditors will already have a detailed profile of the company, its operations, and any anomalies or unusual patterns compared to its sector. This is no longer theoretical — the public administration is ready to use these tools, and their effects will become tangible as the reform is fully implemented.
Today, finance and tax departments are still poorly equipped when it comes to AI. We’re at an early, experimental stage. Most companies are only beginning to explore the subject — often through general-purpose tools like office suite copilots — but very rarely with solutions designed specifically for tax or finance functions. True AI tools for compliance, anomaly detection, or tax data analytics are still being built.
There’s also a simple economic reason for this: finance and tax are not the company’s core business. Investment naturally flows to operational functions — those that produce and sell — while support functions come later, which explains the current gap.
However, the e-invoicing reform will accelerate this transition. Once companies are connected to certified platforms and able to exchange structured invoices, the next question will inevitably be: how can we use this data intelligently? That’s where AI will come in — to automate controls, enhance reliability, and anticipate discrepancies. Some platforms already offer advanced data-analysis features powered by AI, but adoption remains limited. Over the next few years, we’ll likely see rapid growth in these applications as tax departments realize the value of the data they now possess.
AI is already legally regulated in the French tax sphere. The main framework stems from Article 154 of the 2020 Finance Law. When this law was adopted in December 2019, the Constitutional Council defined the conditions under which the administration could use AI tools, setting out eight criteria to ensure ethical, transparent, and compliant usage — particularly regarding personal data protection. These principles were further clarified by the French Data Protection Authority (CNIL) in its September 2019 report, which remains the reference for AI oversight today.
We therefore already have a clear legal framework: the State has set the guardrails. But risks still exist. With the generalization of e-invoicing, the tax administration will gain access to a vast amount of transactional data between companies. Over time, it could end up knowing an enterprise’s ecosystem better than the company itself — its suppliers, clients, and business relationships.
The challenge, therefore, extends beyond personal data protection to include trade secrecy. This is crucial: authorities must prevent even unintentional disclosure of sensitive business information that could weaken competition or expose strategic details. As long as our economic model is based on fair competition, protecting trade secrets must remain a fundamental safeguard.
France made a decisive political choice in the summer of 2019: to make e-invoicing a cornerstone of economic modernization and efficiency. This commitment took shape in Article 153 of the 2020 Finance Law, which integrated e-invoicing and e-reporting into the General Tax Code. The decision reflects a longstanding conviction. Studies conducted at the European level as early as 2007 had already highlighted the potential benefits of such reforms in terms of simplification, productivity, and transparency. But France chose an ambitious path — to move forward on a fixed timeline, making the reform mandatory for all actors to accelerate digital transition.
Another reason for France’s leadership is the scope of its model. While most European countries separated the steps — first mandating structured e-invoicing, then, later, real-time reporting — France decided to do both at once. That makes the project more complex but also more complete.
At the same time, the 2020 Finance Law introduced a separate provision authorizing data mining, which led to the creation of the Galaxie system. In other words, France simultaneously launched digitalized exchanges, large-scale data collection, and AI-based analysis capabilities. This strategic decision explains why France now appears to be leading in both digital taxation and economic data governance.
France’s influence within the ViDA project will depend largely on how its representatives engage in European discussions. Within the Fiscalis group — which brings together finance ministry representatives from all Member States and the European Commission — much will hinge on France’s ability to defend its approach and share its experience.
In practice, France is already implementing, more than three years ahead of schedule, one of ViDA’s core pillars: the Digital Reporting Requirements. Starting in September 2026, France will effectively apply the same principles set to take effect across the EU in 2030. As a result, when ViDA comes into force, little will actually change for French businesses. Having already gone through this transition, they will likely serve as pilots and references for their European counterparts.
To make this advantage meaningful, France will need to promote both its model and its methodology at the EU level. The country has done extensive work on complex use cases — such as expense notes, multi-vendor invoices, and subcontracting — and on technical standards through AFNOR commissions. These efforts produced a pragmatic, collaborative approach that should be championed in Brussels. If each Member State designs its own rules, the goal of ViDA — harmonization — will be lost. The more aligned the standards, the smoother cross-border exchanges will become, improving both efficiency and competitiveness for European companies.
We are witnessing a genuine paradigm shift in how the State conducts tax audits — and, consequently, in how companies behave as taxpayers. Until now, France has operated under a retrospective model: companies submitted highly aggregated VAT returns, and audits often took place two or three years later, with inspectors reviewing past decisions and requiring lengthy explanations.
With the combination of e-invoicing, e-reporting, and AI tools like Galaxie, we are entering an era of near real-time tax oversight. The administration will have an immediate view of economic activity and be able to target audits more precisely. This could be a positive evolution if it helps focus efforts on genuine non-compliance while easing the burden on companies acting in good faith.
However, this increased transparency also calls for a change in mindset. Instead of relying solely on ex-post enforcement, the goal could be to establish an ongoing, cooperative dialogue between companies and the tax administration — one in which businesses explain their choices and challenges as they arise. Tax law is rarely black-and-white; it often involves interpretation, especially when business innovation outpaces legislation. The challenge will be to build a relationship of trust, where the State supports companies in applying the rules rather than sanctioning them years later. In essence, this could mean moving from a “rear-view” audit model to a smarter, more collaborative approach that fosters both compliance and economic vitality.
Cyrille Sautereau – President FNFE-MPE & CEO Admarel Conseil
Ahead of the Tax Compliance Summit Sovos Always On: Paris on 19th November, we asked Cyrille Sautereau, Chair of the AFNOR “Electronic Invoice” Commission and President of the National Forum for Electronic Invoicing and Public eProcurement (FNFE-MPE), to discuss the evolving landscape of e-invoicing reform in France, the challenges of interoperability, and the country’s role in shaping European standards.
The National Forum for Electronic Invoicing was created in 2012 following the establishment of the European Multi-Stakeholder Forum on Electronic Invoicing (EMSFEI), which led several Member States, including France and Germany, to create their own mirror forums. From the outset, its mission has been to support the development of e-invoicing in France, across both public and private sectors, in alignment with EU initiatives. We became an association in 2016 and now have more than 280 members divided into three colleges: users, service providers, and independent experts and consultants.
Our role is both normative and educational. Normative, because we actively contribute to the development of European and national e-invoicing standards, in close collaboration with the AFNOR “Electronic Invoice” Commission, which I also chair; and educational, because we provide best practices and help the ecosystem understand the regulations, enabling companies to transition smoothly to e-invoicing.
Finally, we fully play our role as a bridge between public authorities and the market. The FNFE is regularly consulted by the tax administration and lawmakers, particularly on regulatory developments related to the reform. We bring field expertise — our knowledge of invoicing practices, tools, and the operational constraints businesses face. This ongoing dialogue helps fine-tune regulations and ensures a harmonized, effective implementation of the reform.
The FNFE-MPE brings together a wide range of stakeholders: businesses, vendors, service providers, accountants, professional federations, and even representatives of the public administration. Our mission is to facilitate dialogue among these groups, which don’t always share the same priorities. The key is transparency and co-construction: everyone can take part in our working groups and contribute to developing the standards.
We hold several plenary sessions each year, along with about ten thematic working groups covering topics such as e-invoicing reform, interoperability, standards and norms, communication, best practices, invoicing and payment, B2G invoicing, and factoring. These forums allow members to share feedback, identify practical challenges, and bring them to standardization bodies.
This collaborative approach has fostered a genuine common language between public and private actors. That’s the strength of the FNFE — its ability to unite the entire ecosystem around a shared vision, ensuring that both technical and regulatory choices remain realistic, effective, and business-oriented.
Interoperability is indeed one of the most sensitive aspects of the reform. Contrary to what people might think, the main challenge doesn’t lie in connecting private platforms to the Public Invoicing Portal — that interface is precisely defined by the DGFiP’s specifications — but rather in ensuring smooth communication among private players themselves.
The first challenge concerns certified platforms (formerly PDPs), which must be able to exchange data without multiplying bilateral integrations. That’s why we supported the rollout of the Peppol network in France — a model where one connection makes you interoperable with all other network participants. The second pillar is a shared addressing system based on the SIREN number and managed within a public directory. This ensures that every business is reachable through a stable e-invoicing address — one that remains unchanged when switching platforms.
Finally, there’s the “last mile”: connecting companies’ internal systems (so-called “compatible solutions”) to their certified platforms. Given the variety of software tools on the market, proprietary integrations must be avoided. That’s the goal of the AFNOR initiative to design a standardized API — a universal connector that ensures seamless transitions between platforms. Portability is essential for an open, sustainable ecosystem.
The French reform is closely aligned with the European ViDA project, which aims to harmonize e-invoicing and reporting practices across the EU. ViDA calls on Member States to establish systems for e-reporting and e-invoicing based on structured data and standardized formats — exactly what France has already implemented.
Our national model, based on the exchange of structured electronic invoices between French taxpayers and the automatic transmission of data to the tax administration, already mirrors ViDA’s intended architecture. The key difference is that France chose from the outset to combine mandatory e-invoicing with e-reporting to the tax authorities — whereas other countries limited their first phase to B2B e-invoicing, postponing e-reporting to a later stage. We also introduced two unique features: invoice status tracking — ensuring lifecycle traceability and giving suppliers the visibility and value they’re entitled to — and B2C e-reporting, which isn’t covered by the European scope. In short, France won’t need to adapt its system to ViDA; it already embodies it.
France can indeed become a European benchmark, provided the operational rollout succeeds. What sets us apart is the decision to tackle the issue holistically, integrating technical, regulatory, and business aspects from the beginning. While other countries proceeded step by step — first e-invoicing, then reporting — we decided to merge both dimensions right away.
Requiring VAT data to be transmitted to the tax administration from each invoice inherently assumes that, within each invoice, the seller is responsible for VAT collection and the buyer for deduction. This creates additional complexity in many cases where intermediaries — such as aggregators handling invoice consolidation or grouped payments — play a role without being the actual taxpayer.
Our approach builds on significant collaborative work within the AFNOR “Electronic Invoice” Commission, which I also chair. Over six months, more than 250 experts from all sectors took part in over sixty meetings. This work revealed the real complexity of use cases, often underestimated — for example, scenarios where several service providers appear on a single invoice for one buyer, such as in the water, leasing, insurance, or travel sectors. These configurations turned out to be far more common than expected. The AFNOR work also helped align French practices with the European semantic standard EN 16931 — ViDA’s foundation — while identifying its limitations and addressing them through data extensions or management rule updates.
Finally, this process confirmed the need for flexibility — allowing human-readable formats, like hybrid Factur-X invoices, which include operationally useful data that may not fit within the semantic standard or technical capabilities of some small businesses.
This ability to identify specific cases and address them within a shared normative framework is, in my view, France’s main strength. It helps anticipate complex situations, deliver standardized solutions (“the same problems, the same answers”), and maintain coherence between regulatory requirements and business realities. Many Member States will likely draw inspiration from this integrated approach when implementing ViDA.
Beyond compliance, the reform will fundamentally change how companies manage their operations. By generalizing e-invoicing, we’re introducing structured, reliable, and continuously available data — replacing the paper and PDF-based exchanges that still dominate today. This is transformative: data becomes instantly usable by management systems, without re-entry or manual processing.
In practical terms, this will allow all companies — including SMEs — to reach levels of automation and visibility previously reserved for large groups. Cash-flow reporting or monthly closings will no longer take days of reconciliation: invoices will be integrated in real time, and discrepancies will appear immediately. This responsiveness will enhance business leaders’ ability to manage performance, detect weak signals, and anticipate payment delays — in short, to shift toward predictive management.
In the long run, value-added services could emerge from aggregated, anonymized data analysis. For example, a platform could offer buyers average market price benchmarks based on peer transactions, helping them better position themselves competitively. These uses will need to be regulated to preserve confidentiality, but they open promising perspectives. Competitiveness will thus depend not only on compliance, but on data quality and intelligent exploitation.
We regularly take part in events like Always-On because they play an essential role in collective education around the reform. The more opportunities for dialogue, the better. For the FNFE-MPE, it’s a concrete way to fulfill our mission of supporting businesses. These meetings help clarify what the reform truly entails, demystify its implementation, and provide a neutral perspective that complements that of service providers.
That’s important, because many companies still have a fragmented understanding of the reform: some overestimate its complexity, while others haven’t yet grasped its full impact. In this context, direct exchanges among public authorities, experts, vendors, and users are key to building a shared culture and reliable reference points. Such events help reinforce a crucial message: the success of e-invoicing depends on adopting shared standards, ensuring consistency of practices, and rejecting unnecessary complexity.
For too long, everyone built their own processes, portals, and formats — often with limited success. One of the reform’s main goals, and one of the benefits of events like Always-On, is to move beyond this “each to their own” mindset and build a truly interoperable ecosystem.
The importance of AI will grow as data volumes increase. AI can first help companies better understand what the administration “sees” about them by comparing their internal data with prefilled information. This “mirror visibility” can help identify and explain discrepancies even before an audit is initiated.
That said, we must remain clear-eyed about technology’s limits. AI is an analytical support tool, not an arbiter of truth. Its effectiveness will always depend on the algorithms behind it and the quality of the data it processes. Used rigorously and transparently, AI can strengthen trust between companies and tax authorities by making processes more objective and efficient. Conversely, if poorly managed, it risks creating new areas of opacity or misunderstanding.
The challenge in the years ahead will be to strike the right balance: leveraging AI’s power to make compliance more reliable and streamlined while preserving human interpretation and dialogue. Only under these conditions can technology truly serve trust, rather than weaken it.
With the pilot phase of France’s e-invoicing reform fast approaching, we’re prepared to support businesses every step of the way. As a global provider of tax compliance solutions and a trusted technology partner, we’re ready to help companies navigate the upcoming transition with confidence.
The French B2B e-invoicing reform is set to begin its pilot phase in February 2026, and we’re fully prepared to support companies during this critical stage.
With less than a year to go before the phased implementation of the mandate, we’re anticipating the needs of both French and international businesses operating in France. Our solution is complete, interoperable, and aligned with the latest specifications published by the French tax authority (DGFiP) and the AFNOR Commission.
According to Article 91 of the 2024 Finance Law, the obligation to receive electronic invoices will apply to all VAT-registered businesses from 1 September 2026. The issuance of e-invoices and e-reporting data will be introduced progressively between 2026 and 2027.
To help companies prepare, the French tax authority has announced a pilot phase starting in February 2026. Participation will be voluntary and will involve testing all end-to-end flows, formats, and business scenarios set out in the reform. Companies and their Partner Dematerialisation Platforms (PDPs) will play a central role in ensuring everything is operational before the full mandate kicks in.
We’re committed and ready to support our clients and partners in this next crucial step. Our solution enables participation in the pilot while covering all 36 use cases identified by the DGFiP, including:
Our platform is fully compliant with the latest technical specifications issued by the DGFiP, and we plan to support our first voluntary clients from the very beginning of the pilot in early 2026.
As of August 2024, we’re officially registered as a Partner Dematerialisation Platform (PDP no. 0004). Thanks to our deep regulatory expertise, strong local presence, and robust global infrastructure, we’re uniquely positioned to support clients not only during the pilot, but all the way through full implementation.
This combination of technology, expertise, and trusted partnership makes Sovos a strategic ally in the transition to e-invoicing. We’re here to guide businesses of all sizes with confidence, ensuring full compliance with the evolving requirements in France, across Europe, and around the world.
Greece has been in the process of implementing mandatory B2G e-invoicing over the past few years, with a B2B e-invoicing mandate expected to follow.
Following reports that Greece had requested a derogation to introduce mandatory B2B e-invoicing in 2024, the European Commission has published a proposal for a Council Implementing Decision to grant this authorisation.
This proposal confirms the Commission’s unanimous support for Greece’s intention to introduce a country-wide B2B e-invoicing mandate. It will be submitted to the European Council as a formal step before becoming an official decision.
In July 2024, Greece requested authorisation from the European Commission to introduce mandatory B2B e-invoicing.
According to the Commission’s proposed decision, the obligation will cover transactions between taxable persons established in Greece (B2B transactions). As a result, taxpayers who are VAT-registered in Greece but not established in the country will be excluded from the mandatory scope.
According to the Greek government’s request, mandatory e-invoicing will strengthen the existing myDATA e-accounting system which has been in place since 2018. The system requires taxpayers to transmit transactional and accounting data to the tax administration in real-time or periodically, updating a set of online ledgers maintained on the government portal.
myDATA will continue to exist, but the Greek government foresees its improvement once e-invoicing becomes mandatory. E-invoice data will directly feed into myDATA, providing real-time information and ensuring higher data quality.
Additionally, such data will be used to pre-fill VAT returns – a measure already in place in Greece – but which should be facilitated and improved with the advent of mandatory e-invoicing.
Greece should allow the issuance of e-invoices compliant with the European standard (EN 16931) in order to foster interoperability. The Commission does not mention any other specific formats.
While taxpayers will be able to exchange e-invoices in line with the EU standard, they will only report to myDATA the information necessary for tax purposes – rather than the full invoice.
Taxpayers are expected to be able to issue e-invoices via an Electronic Invoicing Service Provider, upgraded management programs (commercial/accounting, ERP) or the “timologio” free government application. However, more details will be revealed after the derogation is granted and the Greek government publishes its mandatory e-invoicing framework.
The European Commission’s explanations also conclude that the e-invoicing system Greece aims to implement is aligned with the VAT in the Digital Age (ViDA) proposal, which was recently approved by ECOFIN (Economic and Financial Affairs Council configuration of the Council of the European Union) and is expected to be officially adopted during 2025.
Seeking EU approval has become a common approach in the EU, as the current VAT Directive allows taxpayers to exchange invoices in any format, paper or electronic. It also mandates that the use of an electronic invoice is subject to the buyer’s acceptance.
Countries such as Italy, Poland and Romania, and others have already obtained authorisation to implement mandatory e-invoicing systems. However, this will change once ViDA is enforced, as EU Member States will no longer need to request such authorisation if they wish to introduce mandatory e-invoicing systems for domestic transactions.
The Commission proposes to grant Greece the authorisation from 1 July 2025 until 30 June 2026, as derogations are temporary and must be renewed over time. The Decision will apply until its final date or until ViDA requires Member States to apply any national provisions transposing the Directive once ViDA is officially approved.
This is a proposed decision by the European Commission to allow Greece to introduce mandatory e-invoicing measures. It must follow to by the Council before it becomes official and can produce legal effects. This is a procedural step and, based on the experience of other countries, is not expected to pose an obstacle to Greece’s receipt of the derogation.
Find out more about e-invoicing in Greece.
The global adoption of electronic invoicing is accelerating. Governments worldwide are pushing to adopt e-invoicing to digitally transform their national systems and, often, to close the VAT gap.
While many countries have introduced their own e-invoicing mandate to digitise fiscal controls, the requirements and systems implemented by each country often fail to align with one another. This makes it complex for multinational organisations to meet their electronic invoicing obligations.
To enhance interoperability, countries across Asia and Europe are embracing Peppol, a framework established to simplify interoperability for e-invoicing and other procurement documents. But what exactly is it? This blog has all the information you need.
Peppol began in 2008 as an effort to standardise public procurement in governments across the European Union. It is a framework made up of specifications that enable cross-border electronic procurement and a method of sending invoices to customers. Peppol integrates business processes by standardising the way information is structured and exchanged.
In recent years, Peppol has expanded its remit to include APAC. Singapore was the first Asian country to establish a Peppol authority. As well as being established in Europe, it also includes Australia, Japan, Malaysia and New Zealand.
Peppol is short for Pan-European Public Procurement On-Line, as it was initially a European initiative.
While receiving e-invoices has been mandated by law for all public sector entities in the EU since April 2020, being Peppol one of the options chosen by many countries to implement such obligation, and Peppol’s name derives from its European service, the standard is now being adopted outside of the union. Malaysia and Singapore are two non-European countries that have embraced Peppol in recent years, for example.
While we have made it clear that Peppol is an EU-wide standard for exchanging electronic documents like e-invoices, that doesn’t explain how it actually works.
The European Union laid out standards for electronic invoices. These documents must meet the required specifications and, in most cases, be sent through its network. Most public sector entities in the EU are required to be able to receive such invoices, creating a uniform and universal method of invoicing B2G transactions across the region.
It’s worth noting that while the public sector is obligated to receive these invoices in some cases, they can also be sent to companies for B2B transactions. Peppol enables the efficient electronic exchange of e-invoices, purchase orders, and other business documents, whether you are a private business or a public organization.
Peppol invoices are sent to the recipient through a Peppol Access Point. This connects to the Peppol network and comes from an approved service provider, allowing businesses to electronically exchange documents with other organisations with an Access Point.
Peppol connects organisations through a network of Peppol-accredited Service Providers, removing barriers to electronic trading created by closed ‘three-corner’ networks.
To ensure that the aforementioned Access Points follow the rules and regulations set out, it has official authorities. They are also in place to “set national requirements for the design and content of Peppol documents,” according to PEPPOL itself.
There are currently 17 Peppol Authorities in place, all of which are national bodies – bar one. OpenPeppol is the only authority which is not attached to a country as it serves as the official Peppol Authority in jurisdictions where no authority exists.
Its widespread implementation makes it an appealing option for many. Considering the variety of approaches to electronic invoicing across countries, the appeal to Peppol is the standardisation and interoperability of global electronic document exchange.
Having a collection of common standards for transferring electronic documents for every country an organisation conducts business in makes the process simpler – thus reducing the possibility of errors.
Standardising the way information is structured and exchanged makes it more secure. As well as invoices and purchase orders, Peppol has the potential to automate the exchange of any kind of business document, between any organisation, anywhere in the world.
Peppol currently has 37 member countries, 29 of which of which are in Europe.
Outside of Europe, countries that have implemented Peppol standards include:
Corner models are frameworks for digital transactions. There are multiple approaches, though Peppol’s base framework is the 4-corner model
Now considered an old model, the 3-corner model for e-invoicing required senders and receivers to connect through a single service provider. Buyers would often decide on which service provider they use, meaning suppliers had to use multiple systems across their customers.
An upgrade to the previous approach, the 4-corner e-invoicing model connects four entities. The four corners are:
The introduction of Access Points secures transactions by ensuring that communication of documents is sent and received correctly, using document validation, Know Your Customer (KYC) procedures and more.
As seen in Singapore, Peppol also has a 5-corner model. This approach adds another corner to the traditional model, being the Tax Authority/Government central platform. This framework is also known as Peppol CTC.
The 5-corner model allows tax authorities to receive almost real-time access to invoices, ensuring that tax information is transferred correctly.
At the discretion of the applicable government, the central platform can either validate documents before they are sent to the recipient or allow certified service providers to validate them instead, serving as a repository for the electronic invoices.
This pilot project established by OpenPeppol demonstrates that the network and e-invoicing specifications can also be used to meet the digital reporting requirements of the EU’s VIDA proposal.
The project is open to EU Tax Authorities/Administrations, Service Providers and end users.
Sovos is participating in this pilot project. We are a respected member, serving as a provider in both Malaysia and Singapore.
Learn more about the adoption of electronic invoicing and its many rules and regulations in our E-invoicing Guide. For help complying with e-invoicing requirements and other tax considerations, consider our Compliance Cloud solution.
By Christiaan Van Der Valk
The French tax administration has just announced structural changes to the 2026 French e-invoicing mandate that will discontinue the development of the free state-operated invoice exchange service. This decision will put increased pressure on taxpayers and software vendors to select a certified ‘PDP’ to fill the void created by this decision.
When France introduced mandatory business-to-business e-invoicing in its 2020 Finance Law, the tax administration conducted a broad comparative study of how other countries had implemented similar obligations. However, France adopted a unique approach, creating the complex ‘Y model,’ which combined elements from several countries’ systems. Like Italy for example, it included a central state-operated platform (the ‘PPF’) that businesses could use as a free, basic service for the exchange and reporting of e-invoices.
In parallel with the PPF’s own ability to exchange e-invoices for French taxpayer, the French tax authority solicited candidate PDPs to perform the same function for more complex business use cases.
These organizations were registered, put through vigorous testing and some were pre-approved, pending final testing with the PPF. PDPs are designed to seamlessly exchange invoices with each other and are required to report these transactions to the PPF.
And as it turned out, many companies in the French market decided to use a PDP to organize the exchange of invoice data with trading partners in a way that fits their unique business circumstances. Other French businesses counted on the availability of the free-of-charge PDP services to be provided by PPF, rather than selecting a private PDP.
The overall architecture of data flows between the public and private entities involved in the French scheme led to unprecedented complexity in the technical specifications released by the public administration. It has been clear for some time that this complexity was putting strain of budgets and timelines for the technical development of the PPF by the French public administration.
The French tax administration (DG-FIP) announced on 15 October that while the development of the PPF will continue, its focus will shift to providing directory services for routing e-invoices, without offering PDP services.
As a result, many French businesses and software vendors now face the challenge of securing the services of a private PDP. Although the e-invoicing mandate’s go-live date on September 2026, initially applies only to the largest businesses, more than four million companies will have to rely on PDP-enabled accounting software to receive those transactions regardless of their size.
Sovos was one of the first PDPs to be pre-authorized by the French tax authority and brings more than two decades of experience providing compliance technology for businesses in France. Sovos is uniquely positioned to meet the needs of companies that must now choose a reliable provider.
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The Government of the Republic of Slovenia has released a draft proposal to implement mandatory e-invoicing and e-reporting for B2B and B2C transactions. This implementation would mark a significant shift in the country’s e-invoicing landscape.
Should the proposal be approved, taxpayers will be subject to a two-fold obligation: they must issue and exchange B2B invoices electronically and report B2B and B2C transactional data to the tax authority. Although clearance will not be required in the e-invoice issuance process, transactional data must be reported to the tax authority in near real-time, which shows that Slovenia is aligning with the global trend of governments implementing Continuous Transaction Controls (CTC).
Taxpayers under scope are all business entities registered in Slovenia’s Business Register (PRS), including companies, self-employed entities and associations. To register in the PRS, business entities must have a registered office or address in the territory of the Republic of Slovenia.
This new system also introduces a decentralised reporting and exchange model facilitated by registered service providers, called e-route providers. These are similar to the network exchange requirements in France and those planned for Spain.
The proposed mandatory e-invoicing and CTC e-reporting will be introduced from 1 June 2026.
The e-invoicing mandate would require taxpayers to issue, send and receive e-invoices and other e-documents for B2B domestic transactions.
Under the Slovenian proposal, e-invoices refer to an invoice or similar accounting document that records business transactions, regardless of what they are called. This includes credit notes, debit notes, advance invoices, payment requests, etc.
There are multiple supported formats for the exchange of e-invoices:
The proposal allows three methods for e-invoice issuance and exchange:
In cases where the issuer and recipient use e-invoice different standards, if using e-route providers, the recipient’s provider must convert the e-invoice to the syntax accepted by the recipient.
Regarding B2C transactions, consumers will have the option to receive either e-invoices or paper invoices. This must be agreed upon by the parties. If an e-invoice is issued, suppliers will be obliged to provide a visualised content version (e.g., PDF).
The proposal states that taxpayers must electronically report B2B and B2C transactional data, including cross-border transactions, to the Financial Administration of the Republic of Slovenia (FURS) within eight days of invoice issuance or receipt. Reporting must be done exclusively in the e-SLOG standard.
The reporting requirement extends to B2C and cross-border transactions, regardless of whether an invoice was issued electronically. This ensures that transactions such as these, for which e-invoicing is not mandatory, are reported to the FURS allowing it a comprehensive collection of taxpayers’ transactional data.
The selected method for e-invoice exchange will impact the e-reporting of transactional data. If the parties use e-route providers, both the issuer’s and recipient’s providers must send the e-invoice to FURS. For direct exchanges, both parties must separately report their transactions to FURS.
The draft establishes obligations and certain technical requirements applicable to e-route providers. According to the Slovenian government, the requirements to become an e-route provider are comparable to those in France but without the need for certification
However, the public authorities will maintain a list of registered e-route service providers who must fulfil certain requirements, some of which are already listed in the draft law. The proposal does not state explicit local registration/establishment rules for e-route providers. The government will publish further regulations detailing the application process and other applicable requirements.
The government must take certain crucial steps before enforcing the mandate. The Parliament must officially approve the draft law before the requirements are confirmed.
Moreover, publication of the technical specifications and further regulations are awaited, including details of the data reporting methods to the tax authority. Slovenia will need to apply for a derogation from the VAT Directive with the EU Commission to enforce mandatory B2B e-invoicing before the adoption of ViDA (VAT in the Digital Age).
For businesses operating in Slovenia, this will mean impactful changes to their outbound and inbound processes by 1 June 2026. This includes the acquisition of software or update of their systems to issue, send and receive e-invoices, adapting to the allowed e-invoicing formats and connecting to the FURS or availing the services of e-route providers to electronically report their data.
Have questions about how these changes could affect your operations? Ask our team of experts.
The Inland Revenue Authority of Singapore (IRAS) has announced the implementation of a phased adoption of InvoiceNow, the national e-invoicing framework based on the Peppol network, for GST registered businesses starting voluntarily in May 2025. The mandate will cover B2B transactions only, as the government is expected to make B2G mandatory in the coming years.
InvoiceNow is a nationwide e-invoicing initiative by The Infocomm Media Development Authority (IMDA) for SMEs and large enterprises to streamline their invoicing for a faster and more sustainable way to transact, nationwide and worldwide.
Singapore’s nationwide e-invoicing network was first announced in 2019 and has recently been referred to as InvoiceNow. The mandate will require GST registered businesses to use InvoiceNow solutions to transmit invoice data to IRAS. The transmission of invoice data to IRAS will be done through Peppol Access Point (AP) service providers, extending the traditional four corner e-delivery model to a fifth corner model.
The mandate will be implemented in phases, as follows:
Even though an implementation timeline for all businesses has not been shared yet, further updates are expected in the future.
Saphety Level – Trusted Services, S.A is an IMDA-certified Peppol service provider in Singapore. Our regulatory experts can connect to the InvoiceNow network on your behalf.
When it was announced recently that the introduction of a new French e-invoicing mandate had been delayed until September 2026 there was a collective sigh of relief amongst many in the tax and finance world. More time to adequately prepare, put systems and methodologies in place and have your business ready to be compliant from the get-go.
Sounds optimal, but let’s focus on reality. First, the reported delay is a bit deceiving. While it may not officially take effect until 2026, you only have a matter of months to get prepared to participate in the extended trial. Human nature may be to push it to the side and focus on more short-term deadlines. However, to not take advantage of the extra time provided would be shortsighted at best.
Here are five ways you can make this extra time work for you:
Note: portions of this section originally appeared in the Sovos blog, France: B2B E-Invoicing Mandate Postponed, updated 19 September 23.
Businesses will soon be able to register proactively for the pilot program, which has been designed to allow businesses to test the PDP platform. This program is intended to build knowledge and confidence and ensure businesses are on the path to readiness.
Therefore, it would be prudent to regard the delay as a mere six-month postponement, with the beginning of the pilot program acting as the de facto starting date. To understand the full impact on their business processes and data flows, companies will need to thoroughly test up to 36 use-cases.
The good news is that the many software vendors helping companies to streamline their purchase-to-pay and order-to-cash processes will be eager to test the compliance of their solutions as early as possible in what has become a completely new ecosystem.
We are proud to say that Sovos is one of the first 20 candidates for service provider (PDP) accreditation in France and as such, will be fully prepared to assist your organization through the trial process and beyond.
Looking for more information about how to comply with the French Mandate?
Download our French Mandate eBook or Contact our expert team.
E-documents or electronic documents are rapidly growing in usage across businesses of all shapes and sizes, in countries around the world.
While the automated exchange of e-documents is a relatively new phenomenon which is being adopted on a country-by-country basis, there is basic universal information that your business would benefit from understanding – and potentially utilizing.
This blog will serve as your one-stop shop for required e-document knowledge.
An e-document is an electronic transactional document or message and is typically used in an automated business process.
As the digitisation of business accelerates, so too does the use of electronic documents – whether that be an electronic invoice sent in real-time to a national tax authority or an electronic goods receipt note exchanged between companies.
The difference between electronic documents and other digital documents such as PDFs is that e-documents are machine-readable and are generally exchanged by online platforms or software.
That said, there are numerous types of e-documents and there is little standardisation as each country has its own stance and potential mandate on their adoption. The European Union has long been working on its approach to e-documents for increased interoperability with definitions and rules as part of its efforts under the eGovernment Action plan and eIDAS regulation to facilitate digital transactions and services in the EU.
In addition, the UK recently adopted the UK’s Electronic Document Trade Act which is a huge step towards the digitization of trade documents and potentially paperless global trade.
There is a wide variety of electronic documents to suit a number of applications across business, helping to streamline workflows and operations, facilitate cross-border trade and save on costs.
E-document mandates in Turkey, for example, include:
Other electronic documents that are used in some countries include:
There has been a notable implementation of e-documents in transport in recent years, with the likes of Romania adopting a system that requires taxpayers to use an electronic waybill system to obtain clearance of the transport document before the transport of goods begins. Read our dedicated blog to find out more about the global rise of e-transport documents.
One particular e-document that has had an exponential rise in utility over the past few years is the e-invoice. Electronic invoices have grown in popularity as countries develop their continuous transaction controls (CTC) and e-invoicing regulatory obligations. The likes of France, Spain and Poland all plan to introduce e-invoice mandates, requiring taxpayers to send invoices electronically.
Read our comprehensive e-invoicing guide for more information.
There is a host of reasons that electronic documents can be beneficial, which explains why tax administrations globally are implementing e-document mandates.
A primary reason for the use of e-documents is that they generally allow for the automation of workflows, increasing safety, accuracy, transparency and cost-saving for the involved parties. Automating the process of generating and exchanging documentation reduces the risk of error, allows for seamless transmission of information (including to tax authorities who seek greater transparency) and reduces the reliance on paper (providing an environmental benefit).
Another reason businesses use electronic documents is simply because they are mandated to do so as part of tax digitization controls. An increasing amount of tax authorities are making it an obligation to send documents electronically, and facing a penalty due to non-compliance is not desirable. As CTC regime adoption grows, so too does the need for businesses to meet their new e-document obligations.
The compliance conditions of e-documents vary depending on the national rules, but there are some typical conditions across regimes.
In the context of tax digitization controls, the conditions that apply to some of the most regulated e-document types, such as the e-invoice, include:
The difference between electronic documents and digital documents is a hot topic. It’s easy to get confused between the two considering that “digital” and “electronic” are used interchangeably by many, but it’s important to understand the difference.
Digital documents are often a digital analogue of a physical document – think a scanned document, photograph, or PDF – and oftentimes are simple for people to read and digest. An example of a digital document would be an invoice sent as a PDF via email.
Electronic documents are files of data that are generated by and for computers, making them hard for people to read due to their formatting. Such data – like that seen in a structured e-invoice (e.g. XML) – is meant to be sent from one system to another without interference from humans.
Sovos’ software allows businesses to manage CTC obligations, including e-invoicing compliance and archiving.
As the world continues its digitisation, it’s important to stay on top of evolving regulations and to keep up with best practices for your business. Working with Sovos, your business can:
Find out more about Sovos’ CTC solutions.
The Chilean Internal Revenue Service (SII) recently published version 4.00 of the document describing the format of electronic tickets for Sales and Services.
The electronic ticket (or Boleta Electrónica) is an electronic receipt issued for the sale of goods or services to individuals, consumers or end users.
The document includes basic information about the transaction, such as:
The electronic ticket is for less formal, business-to-consumer (B2C) transactions and is subject to less rigorous reporting requirements than electronic invoices (Factura Electrónica). It is often used for smaller transactions, such as retail purchases or services rendered to individuals.
Businesses must use certified invoicing software to generate electronic tickets. These software solutions need to be approved by the Chilean tax authority, the Servicio de Impuestos Internos (SII).
The generated electronic invoices must be digitally signed using an electronic signature to ensure their authenticity and integrity.
Taxpayers authorised as issuers of electronic tickets must digitally send all the electronic tickets issued and generated to the SII. These should follow the Technical Instructions provided in Annex 1 of Resolution 74 of 2020, and any future updates.
In accordance with the Technical Instructions, the electronic ticket must contain the following information:
After generating the electronic tickets, businesses submit them to the SII. Since the SII must validate both the XML format of the document and its electronic signature, the SII has established a limit of 500 ballots per batch.
On the other side of the transaction, the recipient of an electronic ticket can access and verify the invoice through the SII’s online platform. They can accept or reject the invoice, which helps maintain transparency and accurate transactions.
The data generated by this electronic receipt system drives efficiency. For example, businesses can obtain important information, such as:
Businesses must maintain records for six years in the XML format established in version 4.00.
Non-compliance with the electronic invoicing requirements or submitting inaccurate information can lead to penalties. The SII has the authority to audit businesses to ensure compliance with tax regulations.
Are you in financial services or working at a bank with more questions about invoicing in Chile? Speak to our tax experts.
Update: 9 December 2024
On September 15th, 2024, the French Tax Authorities published a Press Release announcing a profound change in the upcoming French Mandate for electronic e-invoicing & e-reporting.
Indeed, the Public Portal (aka PPF) will no longer provide e-Invoicing Services, making it compulsory for every FR-established and VAT-Registered Taxpayer to send and receive e-Invoices via a 3rd Party Dematerialization Platform (aka PDP) of its choice.
After this initial announcement, the FR TA has communicated additional details, whether on the rationale behind that pivotal decision or on the next milestones until the Mandate enters into force:
Update: 2 January 2024
The Finance Law for 2024 has been officially adopted and published in the Official Gazette on 30 December 2023. With the finalization of the law, the new implementation dates are as follows:
Receipt of e-invoices: Starting from 1 September 2026, ALL taxpayers, regardless of their size, will be required to be capable of receiving e-invoices. This date may be extended to December 1, 2026, at the latest, but only by decree.
Issuing e-invoices:
International B2B, B2C transaction and payment data transmission:
The e-reporting obligation for international B2B (sales and purchases) and B2C transactions and Payment data follows the same timetable as that for issuing electronic invoices (September 1, 2026 or September 1, 2027 depending on the size of the company).
The implementing decree that will formally ratify this new schedule is expected during the first quarter of 2024.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
Update: 19 October 2023
The long-awaited new implementation timeline regarding the e-invoicing and e-reporting within the draft Finance Law for 2024 has been unveiled on 17 October 2023.
According to the draft amending General Tax Code and Law No. 2022-1157, the new dates are as follows:
Implementation phases: The roll out of the mandate will now occur in two phases, as opposed to the previously planned three phases.
Issuing e-invoices:
Receipt of e-invoices: Starting from 1 September 2026, all taxpayers will be required to be capable of receiving e-invoices.
E-reporting obligations: The enforcement of e-reporting obligations will follow the same revised dates.
It is important to note that the above-mentioned dates, September 2026 and September 2027, may be subject to readjustment with the possibility of rescheduling to the 1st of December as the latest date, in the respective years.
After the adoption of Finance Law for 2024, a Decree complementing the law is expected to be issued in the first quarter of the upcoming year for full enforcement of aforementioned obligations.
Companies need to take advantage of the additional time through active participation in the pilot phase during which all relevant use cases should be tested so that changes to applications, processes and systems can be taken care of and fine-tuned in good time to ensure compliance.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
Update: 15 September 2023
In a recent meeting of the Communauté des Relais, the tax authority released additional details surrounding the previously communicated postponement of the B2B e-invoicing mandate in France.
This delay is a result of the tax authority listening to feedback from French businesses who have struggled to meet the original timeline. It’s further evidence, as previously iterated by the ICC of just how much time and effort is required for most businesses to compare for the complexities of a new mandate.
While the formal dates are still to be defined, the revised main timeline was presented as part of a roll-out in 3 stages:
2024: The authorities will publish the first list of officially registered service providers (PDPs – Plateformes de Dématérialisation Partenaires) by the spring of 2024. During the course of 2024, the development of the public portal (PPF – Portail Public de Facturation) will be completed.
2025: During this year, a large-scale pilot project, involving companies of all sizes will be conducted. The tax authority views this pilot as an opportunity for taxpayers to fine-tune their e-invoicing and e-reporting processes and systems to comply with what has grown to be, a complex and sophisticated CTC framework.
2026: The roll-out of the obligation for the entire economy will largely take place during 2026. However, at what pace remains to be seen once the Finance Law is adopted by Parliament at the end of 2023.
Businesses impacted by the French mandate, headquartered in France and elsewhere, will now be in a better position to successfully comply with the new reform, assuming they make use of the added time provided by the French authorities. In particular, by proactively using the pilot program to build confidence and knowledge on the critical path to readiness. For the largest taxpayers facing these obligations, it would be prudent to regard these changes as a mere 6-month postponement, with the beginning of the pilot program acting as the de facto starting date. To understand the full impact on their business processes and data flows, companies will need to thoroughly test up to 36 use-cases. The many software vendors helping companies to streamline their purchase-to-pay and order-to-cash processes will certainly be eager to test the compliance of their solutions as early as possible in what has become a completely new ecosystem.
Participation in the extended pilot, with professional support from Sovos, provides a risk-free environment to assess and then conduct the essential finetuning.
Sovos is one of the first 20 candidates for service provider (PDP) accreditation in France, and as such will be ready to sustain our customers as they take the numerous steps needed to fully comply with the new CTC framework, drawing on its rich experience of keeping customers compliant with complicated e-invoicing obligations around the world.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
10 August 2023
The French Directorate General of Public Finances (DGFiP) officially postponed the implementation of the country’s electronic invoicing mandate on 28 July. The postponement is in order to provide necessary time for taxpayers to comply with the mandate.
The latest official word states that the revised timeline for the mandate will be provided within the framework of the Finance Law for 2024. We expect this law to be adopted in late 2023.
In addition, on 31 July the DGFiP published updated ‘External specifications file for electronic invoicing’(version 2.3). Despite deferral of the initial go-live, these updates demonstrate the authorities’ commitment to developing the mandate and set the expectation that preparations by taxpayers, vendors, PDP candidates and professional organizations must continue.
The French Mandate is one of the most complex tax digitization initiatives seen in EMEA to date. It’s essential that companies continue their preparations. Compliance with this mandate requires readying applications, processes and systems to a complex set of requirements. According to the ICC, businesses need at least 12-18 months to prepare for the shift to e-invoicing and e-reporting.
Please note that this information is subject to any further updates or changes from the French authorities and no further details are available at present. We will communicate any additional information once it is made available.
Sovos is experienced in helping our customers navigate digitization regulations around the world, including the French Mandate.
Looking for more information about how to comply with the French Mandate? Contact our expert team.
Update: 12 September 2025 by Kelly Muniz
Malaysia has expanded the scope of its mandatory e-invoicing requirements to include additional types of activities/transactions, according to the latest E-Invoice Specific Guideline (Version 4.4) released on 12 September 2025 by the Inland Revenue Board of Malaysia (IRBM).
Effective 1 January 2026, two additional categories of transactions will require individual e-invoices to be issued for each transaction, rather than consolidated e-invoices:
These additions increase the total number of specific industry activities requiring individual e-invoices, joining existing categories such as automotive, aviation, construction, luxury goods, betting/gaming, and high-value transactions.
Businesses operating in these newly added sectors will need to:
Malaysia continues to implement mandatory e-invoicing and e-reporting through its phased approach, where different taxpayer groups are onboarded according to their annual turnover thresholds. Each group receives a six-month “relaxation period” from their respective mandatory implementation dates, during which businesses can issue consolidated e-invoices for all transactions, including those that would normally require individual e-invoices. Click here to learn more about the current Malaysian e-invoicing timeline.
For future updates on Malaysia and similar developments in other countries, follow our Regulatory Analysis page.
Update: 20 August 2025
Sovos has been granted accreditation as a Peppol Service Provider by the Malaysia Digital Economy Corporation (MDEC). We are authorized to register end-user participants in Malaysia Service Metadata Publisher (SMP).
Peppol Service Providers, or Peppol Access Points (APs), are tasked with establishing and managing the connectivity gateways that serve as access nodes within the e-invoicing network. They ensure compliance with Peppol standards, facilitate the routing of e-invoices to the appropriate destination APs, and handle the registration and updating of participant information in the Malaysia SMP.
Update: 9 June 2025
Malaysia Updates E-invoicing Timeline for Smaller Taxpayers
The Inland Revenue Board of Malaysia (IRBM) has released updated e-Invoice Guidelines, revising the implementation timeline and introducing more granular turnover-based categories.
Updated Implementation Schedule:
The phased rollout is based on annual turnover thresholds, with delayed start dates for smaller businesses:
No Change:
Updated Timeline:
New Businesses:
From 2026 onwards:
Additional Updates:
Update: 23 February 2024 by Carolina Silva
On 9 February 2024, the Inland Revenue Board of Malaysia (IRBM) published long-awaited updates on the upcoming continuous transaction controls (CTC) reform. More specifically, the IRBM has released its Software Development Kit (SDK), along with new versions of the e-invoicing and e-invoicing specific guidelines containing significant changes to the CTC mandate beginning in August 2024.
The new versions of the e-invoicing documentation define the scope of sectors and transactions subject to mandatory e-invoicing and clearance through the IRBM platform, MyInvois.
Sectors in scope are:
Transactions with individual buyers (B2C) fall outside of the e-invoicing mandate scope. Any e-invoices for transactions not in scope are subject to the buyer’s request.
In cases where the buyer does not request an e-invoice, suppliers can continue to issue an invoice or receipt as they do today. Initially, this exception was only foreseen for B2C transactions, but has now been extended to all transactions besides the ones included in the mandatory e-invoice scope.
However, suppliers will be subject to an invoice data reporting obligation and will be required to issue a monthly consolidated e-invoice (within 7 days of the month end) aggregating all invoices and receipts issued during the period.
Another scenario clarified by the IRBM is the treatment of cross-border transactions under the Malaysian CTC e-invoice reporting mandate.
Foreign parties are not mandated to implement Malaysia’s CTC system but Malaysian buyers must issue a self-billed e-invoice to document the expense. This should be in the same structured XML or JSON format and submitted to the MyInvois platform, similar to a reporting obligation for cross-border transactions.
The Malaysian CTC system will allow buyers to reject incoming invoices in their e-invoicing flows, as well as allowing suppliers to issue cancellations. These requests are subject to a 72 hour time limit, after that the invoice is considered issued and any correction or amendment will need to be through credit, debit or refund notes.
According to the IRBM, these functionalities were added solely for the convenience of the parties. Corrections can still be done through credit, debit or refund invoices if the supplier prefers.
Additionally, the new documentation has also clarified and explained how self-billing should be handled under the CTC e-invoice reporting mandate scope, as well as specific transactions such as reimbursements, employment benefits, profit distributions, foreign income and e-commerce transactions.
Want help with e-invoicing in Malaysia? Contact our team of experts today.
Update: 29 November 2023 by Carolina Silva
The Malaysian 2024 Budget law, which is currently pending parliamentary approval, introduces changes to the implementation timeline of mandatory e-invoicing in the country.
According to the new budget law, implementation of electronic invoicing will be delayed and start for taxpayers with an annual turnover of revenue of more than RM100 million (appx. 20 million euros) on 1 August 2024 – instead of the original planned date of June 2024.
The implementation timeline included in the e-invoicing guidelines was updated at the end of October 2023, and the Malaysian tax authority has shared a new phased timeline:
This proposal offers more time for taxpayers to prepare for the new e-invoicing mandate, although these postponements are not significant. Taxpayers in the first implementation group should start preparing imminently for the new e-invoicing system in order to comply by August 2024.
Currently, the IRBM is set to release a software development kit including the relevant technical documentation by the end of 2023.
Interested in finding out more about e-invoicing’s global rise? Read our dedicated E-invoicing Guide.
Update: 25 July 2023 by Enis Gencer
In October 2022, the Malaysian Ministry of Finance announced in its state budget plans to launch a pilot e-invoicing program in 2023 – starting with selected taxpayers.
The budget statement views e-invoices as the main strategy to improve the country’s tax revenue and digital services infrastructure. The Inland Revenue Board of Malaysia (IRBM) and the Malaysian Digital Economy Corporation (MDEC) have been working on the e-invoicing project to meet this goal. They have organised engagement sessions with stakeholders to share details regarding the project.
Following the engagement sessions, the IRBM has published a guideline regarding the implementation details of the upcoming e-invoicing system. The Malaysian e-invoicing system will be a CTC clearance model scheduled to begin in June 2024, with approximately 4,000 companies exceeding the determined threshold.
Read this blog for more information about e-invoicing in Asia.
The new e-invoicing system, called MyInvois, will require all taxpayers engaged in commercial activities to issue invoices electronically in Malaysia. This applies to all individuals and organisations including, but not limited to, associations, corporations and limited liability partnerships.
The transactional scope of the requirements covers all B2B, B2G and B2C transactions – both domestic and cross-border.
The following will be subject to e-invoicing:
A separate guideline will provide further details on the treatment of cross-border transactions.
B2B and B2G e-invoicing will follow a similar workflow, as described below.
For B2C transactions where end consumers do not request e-invoices, suppliers will be allowed to issue receipts or invoices as per the current practices. However, taxpayers must aggregate the receipts or invoices issued to consumers and report them through the e-invoicing system within a set timeframe.
To generate e-invoices, taxpayers must use the MyInvois platform through the free solution provided by IRBM or via APIs. The authentication with the platform is based on digital certificates issued by IRBM.
Taxpayers must create and submit their e-invoices in either XML or JSON format to the MyInvois platform. After successful submission, the platform performs schema checks and assigns a unique ID to each e-invoice.
It’s important to understand that the exchange of e-invoices will not be handled by the MyInvois platform. Instead, suppliers will be responsible for including the validation link provided by IRBM, in the form of a QR Code, on the e-invoice and sending it to buyers. Buyers will utilise this QR Code to validate the existence and status of the e-invoice via the MyInvois platform.
The roll-out of the mandate will follow this schedule:
The annual turnover or revenue will be based on audited financial statements or tax returns from 2022. Once a taxpayer’s implementation timeline has been set using the 2022 financial statements, any subsequent changes to their annual turnover or revenue will not impact their go-live date.
With more detailed information now available about the implementation of e-invoicing in Malaysia, taxpayers must begin preparing their systems for the upcoming changes.
In Q4 2023, the IRBM is set to release a Software Development Kit including the relevant technical documentation and APIs. Furthermore, additional guidance on certain aspects of the implementation and anticipated legislative changes are expected in due course.
Looking for further information on e-invoicing in Malaysia? Contact our expert team.
The Portuguese government has been working on introducing mandatory B2G (Business-to-Government) electronic invoicing in recent years, alongside other obligations for the digitization of VAT compliance in the country.
This aligns with the European Union’s efforts towards harmonising the adoption of e-invoicing in public procurement. To achieve this goal, the EU has implemented Directive 2014/55/EU to outline the responsibilities and criteria for e-invoicing in public procurement processes. The EU requires Member States to enforce an obligation for the Public Administration to receive invoices electronically.
However, several Member States, such as Portugal, have taken a step forward by making the issuance of electronic invoices mandatory for suppliers of the Public Administration. The Portuguese mandate, known as “Electronic Invoicing to the Public Administration” (Fatura Eletrónica à Administração Pública – FEAP), was introduced to streamline invoicing processes and improve efficiency in transactions between businesses and the public sector.
In Portugal, Law Decree 111-B/2017 and subsequent amendments established the beginning of the obligation to issue, receive and process electronic invoices in public procurement. ESPAP (Entidade de Serviços Partilhados da Administração Pública) is the Portuguese entity responsible for the implementation and management of B2G e-invoicing.
This obligation is also present in the Public Contracts Code and requires suppliers of the Public Administration to issue all invoices to public sector entities in electronic format. This excluded contracts declared secret or accompanied by special security measures and contracts concluded following the simplified direct award process (contracts below EUR 5,000).
The implementation of this regime was gradual, starting with the mandatory receipt of electronic invoices by the Public Administration in April 2019. This was followed by a phased introduction of compulsory issuance of e-invoices for suppliers of the Public Administration, starting with large companies in January 2021. The implementation calendar has been postponed several times for small, medium and microenterprises. Currently, only large companies are required to issue invoices electronically.
An e-invoice, according to the EU Directive on e-invoicing in public procurement, is an invoice issued, transmitted and received in a structured electronic format.
Electronic invoicing requires data creation in a structured format and its transmission from the seller’s system to the buyer’s system in an automated manner. As a result, the invoice can be automatically imported into the public entity’s system.
As per Portuguese regulations, the e-invoicing model to be adopted is the semantic data model proposed for the Portuguese standard known as CIUS-PT. There is no obligation to send a PDF document attached to the electronic invoice. An invoice in PDF format is not considered an electronic invoice as they do not comply with European standards.
Suppliers must also archive electronic invoices and ensure they are accessible for the period required by the tax authority, which is typically 10 years.
Considering the general obligation to issue e-invoices in the B2G sector, it is possible to identify four main legal consequences for non-compliance with this legal obligation:
All public administration entities are currently obligated to receive e-invoices in the structured CIUS-PT format. Additionally, all large company suppliers to the public administration must issue e-invoices in the same format.
Once again, the obligation for small, medium and microenterprises was postponed in 2025 and is now poised to enter into force on 1 January 2026.
Until then, micro, small and medium-sized companies can use invoicing mechanisms other than e-invoicing in the structured CIUS-PT schema when contracting with the Public Administration.
Need more information on B2G e-invoicing in Portugal? Speak with our expert team.
The Electronic Invoicing Law of the Dominican Republic was published on 17 May 2023, mandating e-invoicing throughout the territory as of 18 May 2023.
The law was published in the Official Gazette, whose purpose is to regulate the mandatory use of electronic invoicing in the Dominican Republic, including the establishment of the electronic invoicing tax system and its characteristics, optimisation results and contingencies, as well as the entry periods and tax facilities that taxpayers who take advantage of this system will be granted.
The law includes a Chapter on the Criminal and Tax infractions and penalties for non-compliance and still allows using paper invoices for certain contingencies.
The law applies to natural and legal persons, public or private. It’s also applicable to entities without legal personality domiciled in the Dominican Republic that carry out the transfer of goods, delivery in use or provision and lease of services for consideration or free of charge.
All electronic invoice issuers in the country shall:
The requirement for holographic or handwritten signatures and commercial seals for electronic invoices is fulfilled by using digital signatures supported by a digital certificate.
Electronic invoices cannot be modified once signed digitally and sent to the DGII.
The electronic invoice must comply with the standard format established by the tax authority, which will be validated by computer systems. E-invoices will only be admissible when they comply with this validation.
Electronic invoices will be sent to the authority and the electronic receiver through electronic applications connected to the internet and in an XML file.
The electronic invoice will have a Printed Representation (RI) of the E-CF which will be delivered as a physical document to non-electronic receivers in exceptions. Otherwise, it will be delivered to electronic receivers when they are in contingency so that they can prove and report purchase transactions to the authority and third parties – as well as support tax credit or consumption, and keep the indicated documents as established by current legislation.
The General Directorate of Internal Taxes (DGII) will be the competent authority for validating and certifying the content and integrity of the electronic invoice.
The Electronic Invoicing Tax System is administered by the DGII and will be used to validate and accredit all electronic tax receipts resulting from electronic invoices. It will also validate legal forms or electronic tax documents that modify them and that serve as support to back up expenses and tax credits.
The DGII is also responsible for ensuring the integrity of information that is sent instantly for validation and the accreditation of electronic tax receipts (E-CF).
The three forms of Issuance of Electronic Tax Receipts (E-CF) are as follows:
The electronic tax receipts sent to the DGII will be validated online through the information system, according to the schemes published by the technical documentation and complementary standards that define their structure and behaviour.
Once they’ve been compared and validated against the criteria, the DGII will respond by delivering a response number identified as “trackID” with which the E-CF issuer can consult the document’s status.
There are 10 types of electronic tax receipts or documents as part of the law. These include:
All E-CFs must have an electronic tax receipt number (E-NCF), authorised by the DGII, which consists of an alphanumeric sequence.
The number and type of electronic tax receipt numbers will be authorised according to the economic activity registered in the National Taxpayer Registry (RNC), operational volume, and level of compliance of the taxpayer – as well as the risk profile of the taxpayer, in accordance with the parameters established by the DGII.
The duties required of electronic issues, in order, consist of:
The standard format for the structure of E-CFs is as follows:
Taxpayers must indicate data that modifies or affects electronic tax receipts of credit and debit notes.
The DGII will publish the list of taxpayers required by law to issue E-CF. With the approval of the DGII, taxpayers may agree to extend the deadline for compliance with electronic invoicing regulations.
A voluntary period is provided for all taxpayers who wish to be issuers of electronic invoices before implement the previous calendar. The DGII is providing incentives consisting of tax credits for MIPYMES and Large National Taxpayers.
Looking for further information on e-invoicing in the Dominican Republic? Contact our expert team.
The Spanish government has published the much-anticipated draft regulation with the framework for implementing mandatory B2B e-invoicing.
The proposed legislation outlines the operation of the Spanish e-invoicing system. Its main feature is the reliance on the principles of interoperability of e-invoice formats and interconnectivity of e-invoicing platforms. The goal is to promote digitalization (particularly for smaller companies), reduce late invoice payments and save on administrative costs such as the management of invoices.
The draft Royal Decree provides further details to the Law for Creation and Growth of companies published in September 2022, which initially establishes the e-invoicing obligation for companies and professionals.
All companies and professionals required to issue invoices under Spanish law will be obliged to do so electronically. This applies to B2B operations with a few excluded transactions, such as: when issuing a simplified invoice, issuing an invoice voluntarily when there is no such obligation to do so under Spanish rules and in other cases that the government may regulate in the future.
However, the obligation does not apply if one of the parties to the transaction does not have an established business, a fixed establishment or habitual business residence in Spanish territory where invoices are directly issued.
The Spanish e-invoicing system will consist of privately owned electronic invoicing platforms and the public electronic invoicing solution managed by the State Tax Administration Agency. Taxpayers under scope must send and receive e-invoices through one of these two means and will be able to use both in parallel.
Other important characteristics and requirements of this system are:
The proposed Royal Decree defines an e-invoice as a structured document, which means that a PDF will no longer be considered an electronic invoice. Taxpayers will be required to issue e-invoices using one of the accepted formats:
Additionally, in line with the principle of interoperability, private e-invoicing platforms must be able to convert e-invoices into all supported formats while preserving I&A.
The invoice recipient must communicate the e-invoice status to the invoice issuer within the maximum deadline of four calendar days counted from the date of the reported status.
Mandatory statuses comprise the following:
Additionally, the draft regulation establishes optional statuses:
The Royal Decree is currently in draft form but will be effective 12 months after its official publication on the Spanish Official Gazette (BOE). Following the Law for Creation and Growth of companies, the 12-month-timeline will apply to entrepreneurs and professionals whose annual turnover is over €8 million, and for the remaining taxpayers under scope the deadline is 24 months.
In the first year from the regulation’s effective date, companies under the e-invoicing obligation must attach a PDF file to the legal e-invoice to ensure readability to counterparties not yet in scope – unless the recipient agrees to receive it in the original format.
The obligation to report the e-invoice statuses will come into effect 36 months after the publication of the Royal Decree for entrepreneurs with an annual turnover below €6 million and 48 months after the publication of the Royal Decree for professionals below the same threshold.
Further details are expected concerning how taxpayers under the SII (Suministro Imediato de Información) mandate must inform the mandatory e-invoice statuses.
As this is still a draft and certain details remain to be established, taxpayers can expect changes before publication of the final version. Additionally, until 10 July 2023, the draft regulation is open for comments from the general public.
Another important note is that the entry into force of this draft Royal Decree is subject to Spain obtaining derogation from Articles 218 and 232 of the EU VAT Directive before the EU Commission. Although this is a formal step and there is no indication that the Commission would not grant the derogation, until it happens the new Spanish rules cannot enter into force.
Looking for further information on e-invoicing in Spain? Contact our expert team.
For an overview about other VAT-related requirements in Spain read this comprehensive page about VAT compliance in Spain.
According to the latest global market report, Billentis, the Asia Pacific region is expected to achieve the highest annual e-invoice volume growth rates compared to Latin America and Europe until 2025.
This is mainly because the Asian market, outside of South Korea, is new to the tax digitization journey and is accelerating the adoption of e-invoicing as an effective measure for VAT control.
Though the types of e-invoicing strategies implemented in the APAC region vary greatly, we can also identify some common characteristics.
There are jurisdictions with a strong common law legacy, such as Singapore and Japan, which typically focus regulatory measures on record retention. In recent years, many of these countries have started gearing up toward regulating e-invoicing issuance (notably by adhesion to the Peppol system), e.g., Singapore. Associated national standards have been adopted for a wide range of e-invoicing flows for B2B and B2G scenarios.
Conversely, Latin American clearance models and continuous transaction controls (CTCs) influence some countries. Examples of jurisdictions with CTCs are China and Taiwan.
More countries aim to introduce a staged approach to mandatory e-invoicing or CTCs in the coming years. Notable examples are Saudi Arabia, which in January 2023 introduced a clearance regime in multiple phases for different taxpayer groups, and Vietnam, which will be doing the same in the coming years.
Here’s a highlight of the recent e-invoicing developments in Asia Pacific.
In October 2022, the Malaysian Ministry of Finance announced their plans to implement a CTC model.
Malaysia has implemented a CTC clearance model for certain transactions, such as the one implemented in Italy, where e-invoices must be sent to the tax authority in real time to obtain validation before being delivered to buyers. The scope of the system will cover all domestic (B2G, B2B and B2C) and cross-border transactions.
The scope of transactions that are subject, per default, to mandatory e-invoicing are B2B and B2G in the following sectors: automotive, aviation, luxury goods and jewellery, construction, licensed betting and gaming, and payments to agents, dealers and distributors.
Malaysia will also follow a CTC reporting model for all other transactions where e-invoicing is not mandatory and not requested by the buyer. In these cases, taxpayers will be allowed to issue invoices and receipts as per the current practices and then report them monthly through the issuance of a consolidated e-invoice.
The mandate has been rolled out in a phased manner, starting in August 2024, for taxpayers with an annual turnover or revenue of more than MR100 million, and it will apply to taxpayers with an annual turnover or revenue of up to RM500,000 from January 2026.
Read more about e-invoicing in Malaysia.
In Thailand, the government has been working to develop a robust e-invoicing system with a framework that boosts e-invoicing using certified third-party service providers for e-tax issuance.
Using service providers is a viable alternative for businesses as some don’t want to invest or develop their own e-tax systems, whilst others cannot afford to create a compliant invoicing system. This is due to the complex technical and legal steps to maintain their own compliant system. The Electronic Transactions Development Agency (ETDA) started a certification process for electronic service providers to assess whether the applicant’s solution is secure and compliant.
More recently, the Thai Revenue Department (TRD) and the Electronic Transactions Development Agency (ETDA) published new regulations to improve the e-tax invoicing system. The regulations include aspects like the e-tax invoice content and standards for forms, delivery methods, storage and information security for operations relating to electronic invoicing.
Thailand has also recently announced an extension of tax incentives for taxpayers using the current e-tax invoicing system to promote e-invoices in the country. These measures could also signal a future mandatory e-invoicing mandate; however, there is no mandate or defined timeline yet.
Read more about e-invoicing in Thailand.
E-invoicing has been mandatory in South Korea since 2011 with the implementation of their Electronic Tax Invoice System.
The scope of the e-invoicing obligation covers all corporations as well as individual taxable persons that exceed a certain turnover threshold. Since entering into effect in January 2012, the scope for sole proprietors has been reduced from 1 billion KRW to 0.1 billion KRW in July 2023.
South Korea´s Electronic Tax Invoice System is considered to be a CTC (Continuous Transaction Control) model – not due to the e-invoicing requirements, since the Tax Authority does not interfere in the process of their issuance, as opposed to CTC clearance models. Instead, it has a CTC reporting model in place as all e-tax invoices must be reported to National Tax Service (NTS) within one day of issuance.
The scope of the mandate in the country covers only domestic transactions (B2G, B2B and B2C). Cross-border transactions are out of scope.
Read more about e-invoicing in South Korea.
E-invoicing has been gradually introduced in China, starting with B2C. In September 2020, the State Taxation Administration (STA) announced a pilot program enabling selected taxpayers operating in China to issue VAT special electronic invoices on a voluntary basis, which are generally used in B2B transactions.
In 2021, the Tax Bureaus of Shanghai, Guangdong Province and Inner Mongolia Autonomous Region announced a new pilot program covering selected taxpayers, introducing a new fully digitized e-invoice.
Following the recent developments in China regarding the Pilot Program for e-Invoicing, which was expanded to new provinces and cities in November 2023, the last province of Tibet has now implemented issuing fully digitalized electronic invoices (e-fapiao) for selected taxpayers.
The State Taxation Administration (STA) in China decided to officially promote the optional adoption of digital electronic invoices throughout the country. The announcement, effective from 1 December 2024, confirms that digital invoices will have the same legal effect as paper invoices.
The announcement also mentions some information, such as the basic contents of the digital invoice, and makes some remarks regarding the number of the digital invoice, which will be 20 digits.
The issuance of digital invoices is still not mandatory and remains optional for taxpayers. However, this announcement marks the end of the previous pilot project for e-invoicing. It is a big step towards the full adoption of electronic invoices, which will optimise the taxpayer’s operations, improve administrative efficiency and promote the digital transformation of the economy and society.
Read more about e-invoicing in China.
In 2018, the Singapore Government Agency, Infocomm Media Development Authority (IMDA), joined the non-profit international association OpenPeppol, which is responsible for developing and maintaining the Peppol specifications. Singapore became the first National Authority outside Europe to join as a Peppol Authority.
In 2019, the IMDA officially launched a nationwide e-invoicing network (InvoiceNow) with intentions to extend the International Peppol E-Delivery Network by allowing businesses to transact internationally with other companies through this network. The IMDA has been encouraging businesses to use InvoiceNow in B2B and B2G transactions as an efficient, modern solution for invoicing and document delivery.
Additionally, it was recently announced the adoption of a Peppol 5-corner model for invoice data reporting based on InvoiceNow for B2B transactions. The implementation of this mandate sees a move away from a Peppol 4 corner model, with taxpayers instead now transmitting invoice data to the IRAS, the nation’s tax authority. Accredited Access Points (AP) are the only parties allowed to submit invoice data to IRAS using C5 API – Sovos is an accredited AP in Singapore.
It will start voluntarily for GST-registered businesses in May 2025 and will be mandatory for newly incorporated companies and those who register for GST on a voluntary basis from November 2025. This mandate is expected to be rolled out to other categories of taxpayers in the future.
Find out more about e-invoicing in Singapore.
Japan has adopted a voluntary e-invoicing system. The Standard Specification for Digital Invoices (JP PINT) based on the global standard Peppol specification is published for Japanese taxpayers wishing to issue and exchange electronic invoices over the Peppol network. The E-Invoice Promotion Association (EIPA) is encouraging taxpayers to use the Peppol standard.
In line with the country’s efforts to improve tax controls, Japan introduced the so-called Qualified Invoice System (QIS) in October 2023. In this system, the total amount of the consumption tax corresponding to each rate must be included in the invoice along with the registration number of the qualified issuer. Taxpayers must register to issue qualified invoices. The QIS does not mandate taxpayers to issue invoices electronically.
Read more about e-invoicing in Japan.
In 2019, the Philippines introduced the Innovation Act as a part of its Digital Transformation Strategy (PDTS). In line with this strategy and the provisions of the Tax Reform for Acceleration and Inclusion (TRAIN) Act, the Electronic Invoicing/Receipting System (EIS) was launched on 1 July 2022 for 100 pilot taxpayers. Since then, e-invoicing and CTC e-reporting have not yet been enforced beyond the pilot group.
In February 2025, the Philippines Bureau of Internal Revenue (BIR) published new rules on e-invoicing and CTC e-reporting. Key changes include expanding the taxpayer base subject to these obligations and providing tax benefits for compliant taxpayers. Additionally, e-invoices are now redefined to refer only to documents issued in a structured format from which data can be easily extracted and reported to the BIR.
As a result, starting in March 2026, structured e-invoicing becomes mandatory for companies engaged in e-commerce and all large taxpayers. Separate regulations mandating compliance with both structured e-invoicing and CTC e-reporting are still to be issued and will impact all taxpayers subject to the system.
Read more about e-invoicing in the Philippines.
India’s Goods and Services Tax (GST) framework introduced an e-invoicing system which falls under the Continuous Transaction Controls (CTCs) category, to improve tax compliance and reduce evasion.
This system mandates reporting invoice data to an Invoice Registration Portal (IRP) for clearance before the exchange with the trading party. For an invoice to be legally valid, it must include an Invoice Registration Number (IRN) obtained from an IRP. This requirement applies to B2B, B2G and export transactions.
In 2024, the GST recommended an extension of the CTC mandate to B2C and a pilot rollout for B2C e-invoicing. Invoice data must be submitted in JSON format to IRPs, although invoices can be exchanged in JSON, PDF, or paper form, with a mandatory archiving period of eight years.
The e-invoicing rollout began voluntarily in January 2020 for businesses with turnovers exceeding Rs. 500 Crore, gradually extending to smaller businesses. By August 2023, the mandate applied to taxpayers with annual turnovers of Rs. 5 Crore or more. Non-compliance, such as failing to register an invoice on the IRP, incurs penalties of at least Rs. 10,000 per instance, along with additional GST penalties and interest.
In late 2024, a new functionality called the Invoice Management System (IMS) was launched on the GST portal. The IMS allows taxpayers to accept, reject or mark an invoice received as pending. The functionality is available for regular taxpayers and taxpayers using the Quarterly Return Monthly Payment (QRMP) scheme.
Read more about e-invoicing in India.
Indonesia embraced digital transformation in its tax system by introducing the e-Faktur system in 2014, becoming effective in 2016. This move towards electronic invoicing is a strategic effort to combat tax evasion and narrow the tax gap through continuous transaction controls (CTCs).
Mandatory for all corporate VAT taxpayers since July 2016, e-Faktur requires invoices to be generated through approved systems and validated by the Directorate General of Taxes (DGT) before being issued. Invoices must include tax invoice series number (“NSFP”) allocated by the DGT, and a QR Code. This CTC system enforces the use of electronic signatures and mandates processing through the eFaktur platform.
Read more about e-invoicing in Indonesia.
Vietnam advanced its tax compliance efforts by implementing a nationwide e-invoicing mandate on 1 July 2022, aimed at combating VAT fraud and reducing the VAT gap. The rollout began in March 2022 in select provinces and cities and moved to a full national implementation by July. The initial implementation phase involved technical solutions in six local tax administrations and expanded to all provinces by April 2022, setting a comprehensive framework for e-invoicing compliance across Vietnam.
This mandate requires all businesses, including enterprises, organisations, business households, and individuals, to register for and issue e-invoices in XML format for transactions.
Vietnam’s e-invoicing system distinguishes between authenticated e-invoices, which require a tax authority code before being sent to the buyer, and unauthenticated e-invoices, which do not require said unique code. Most taxpayers in Vietnam must issue authenticated e-invoices to comply with this mandate. E-invoices must be digitally signed by the supplier and archived electronically with secure and reliable methods to ensure integrity and authenticity.
Read more about e-invoicing in Vietnam.
The winds of change in the region are blowing strongly in favour of digitizing invoicing systems. We see influences from different parts of the world, from Latin America with its decentralised clearance models to Europe with the Italian-style centralised clearance system, as well as with Peppol-inspired e-invoicing frameworks.
These are only a few examples of countries in the region adopting a CTC system. Businesses must prepare to adopt the new e-invoice compliance requirements trending around the world, and in particular, across Asia.
Get in touch with our tax experts for a global e-invoicing solution.
Japan’s new e-invoice retention requirements are part of the country’s latest Electronic Record Retention Law (ERRL) reform.
Along with measures such as the Qualified Invoice System (QIS) and the possibility to issue and send invoices electronically via PEPPOL, Japan is implementing different indirect tax control measures, seeking to reduce tax evasion and promote digital transformation.
In line with these objectives, the amended ERRL will require taxable persons in Japan to follow several compliance rules when archiving documents originating from electronic transactions, such as e-invoices.
The reform has abolished the hard-copy retention option for electronic transactions. Starting 1 January 2024, records of electronic transaction information must be archived electronically.
As per the definition of the ERRL, “electronic transactions” includes transaction information carried out via Electronic Data Interchange (EDI), transactions via the Internet, and transactions in which transaction information is exchanged by email, among others.
The scope of such transaction information may include order forms, contracts, invoices, receipts, and other similar documents related to the transaction sent and received electronically.
Taxpayers must retain any records of electronic transaction information, including e-invoices, in an electronic archive, as prescribed in the Ordinance for Enforcement of the ERRL.
When retaining e-invoices, the following are alternative ways to ensure compliance with the ERRL:
Updated rules are also in place for taxable persons who convert their paper invoices into a digitized document and keep the invoice exclusively in electronic format.
One of the following is required to ensure the authenticity and integrity of the scanned invoice:
Under new rules as of 1 January 2022, there has been an extension to the timestamping deadline to about two months.
In addition to enforcement of the QIS and all changes described above, Japan introduced transitional measures for taxable persons to provide a grace period for necessary preparations. The tax authority will abolish transitional measures under the ERRL on 31 December 2023. Invoice issuers should check their compliance with the Japanese tax framework in the meantime.
Have questions about e-invoicing changes in Japan? Get in touch with our tax experts.