E-Invoicing in acceleration

How are countries announcing mandates and when should your organization anticipate a notification?

By Nick van den Berg E-invoicing expert Financial Management Services

Countries across all continents are announcing new e-invoicing global mandates. By now, all large corporations should have experience in implementing electronic invoicing. Usually this is the starting point from which we explain electronic invoicing and how we help our customers. This time we want to step away from all the strategy discussion on electronic invoicing, and deep dive into the process the governments go through before they announce electronic invoicing legislation. 

Although the electronic invoicing models and formats are diverse, the process of implementing a mandate is very similar across all countries, and you will not encounter many distinctions between e-invoicing in Denmark or e-invoicing in Poland, for example. These are the most common steps:
  1. Proposed changes to an existing law, or a new law
  2. Public consultation
  3. Publication of draft law
  4. Implementation of e-invoicing law
Legislative proposal
This usually starts with a legislative proposal from parliament, proposing either a legislative change to an existing law or a completely new law. The most recent example was when four members of the Belgian parliament proposed mandatory B2B e-invoicing starting 1 January 2025. 
Public consultation
If the bill is approved, governments move to a public consultation. These usually include e-invoicing vendors, local companies and industry leaders. During the public consultation all of these parties are invited to comment or advise on the e-invoicing framework. The e-invoicing framework usually comprises all of the relevant proposed legislation, potential technical systems and a demonstration of how the  electronic invoicing format will look.
Draft law published
After the public consultation, a draft law is created and published. The draft law usually confirms the e-invoicing framework, implementation dates and the companies affected by the new law. The draft law will, after approval by the senate, be published. The  draft law will not necessarily go into effect on the date it is published. For example, the e-invoicing law in Saudi Arabia was published on 4 December 2020 but went into effect as of 4 December 2021. 

Incomplete information
The process of creating the new e-invoicing mandate seems very straightforward and easy to understand. However, in reality, most organizations struggle with their resource planning during the first announcement . 
Example: e-invoicing Belgium
If you search for more information about the Belgium B2B invoicing mandate, you will find numerous industry experts speculating that the mandate will come into effect on  several different dates. Some believe it will be in 2023, others say 2024, and others think that the exact timelines and dates are already set in stone.
When you look back to the beginning of this article, you’ll see that the Belgian legislation is only at the first step of the process. It hasn’t yet been passed through parliament, there hasn’t been a public consultation and there is no law published. This means that at the time of writing this article, there are no official dates to be announced nor is there any existing e-signature legislation. It is even stated on the official Flanders e-invoicing website that there is currently no legislation for electronic invoicing mandates.
Multiple organizations have told us that they are already preparing for the Belgian B2B mandate and are investing resources in setting up the correct invoice streams. This is mostly a reaction to the mass market hysteria surrounding a potential upcoming mandate. Belgium is not the only example, however,  countries such as France, Germany and Poland have all experienced the same level of hysteria when new mandates were announced. 
When to take action
So when should you take action on a new mandate? We believe that you should wait until the draft law has been published and there are more details available to inform the technical setup you will need. Otherwise, you risk wasting time and money on changes you eventually can’t use. 

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