E-invoicing developments in Europe in June 2023

The publication of Directive 2014/55/EU marked a turning point for e-invoicing. Since then, e-invoicing has spread to every corner of the European continent. Prior to this legislation, Denmark, Sweden and Finland were the pioneering countries that took a step forward in implementing e-invoicing. Initially, it started with B2G transactions, and in the near future, mandatory use is expected to be extended to all B2B transactions.

When we add all that the ViDA project involves, we will understand the scope it will have in the future, as many European countries work to establish the best model and system to make it work.


Recently in the Balkan country the Official Gazette No. 47/23 has published a set of rules on e-invoicing that will come into effect in July.

As a result, the following will no longer be valid:

  • The Regulation on the Method and Procedure of Registration for Access to the Electronic Invoicing System, the Method of Access to and Use of the Electronic Invoicing System, and the Method of Use of the Data Available in the Electronic Invoicing System.
  • Rules on the elements of an electronic invoice, the form and method of delivery of accompanying documents and other documents via the electronic invoicing system, the method and procedure of electronic registration of the VAT calculation in the electronic invoicing system, and the method of application of the rules on electronic invoicing.
  • Regulation on the operation of the Central Information Intermediary.


The Council of Ministers has approved a draft Royal Decree that introduces changes to the guarantee and mandatory e-invoicing provisions in public procurement.

According to the draft decree, the contractor is obliged to provide a guarantee, which is automatically set at 5% of the contract value. In cases where the contracting authority decides not to require a guarantee or sets it at less than 5%, such provision must be included in the tender documents without justification. However, if the percentage exceeds 5%, a justification is required.

Furthermore, the obligation for companies to submit their invoices electronically for public contracts with an estimated value of less than €30,000 has been extended until 1 March 2024.

It is important to note that this obligation does not apply to public contracts with a value of €3,000 or less. From 1 March 2024, federal contracting authorities will also be required to use e-invoicing for amounts below €3,000.


The European Commission has published a proposal to allow Romania to implement national e-invoicing from 1 January 2024.

This authorisation will be valid until December 2026 or until the EU agrees to lift the authorisation requirement, whichever is earlier.

In line with the EC proposal, the e-invoicing regime will require the prior submission of invoices in CIUS_RO format (UBL 2.1 or CIN) to the government portal for approval. It will also include essential information on the validation process and the invoice format.

However, there are plans to remove this requirement from January 2026, in order to comply with the ViDA project's proposal to remove prior government checks for authorisation from 2028.


The European Commission (EC) has started the approval process for Germany's implementation of mandatory electronic invoicing for B2B transactions.

The expected implementation date is January 2025, although there is a possibility of a delay due to an ongoing online consultation and the lack of technical specifications.

In addition, the EC must approve Germany's derogation from Articles 219 and 232 of the EU VAT Directive, which mainly limit the government's use of mandatory e-invoicing compared to paper invoices.

Given that Germany has largely opted to follow the European Commission's proposed guidelines, it is expected that approval will be granted without significant changes.

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Key numbers

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+30 years

of experience
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+750 MM

€/year managed
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3 Millions

active users
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+1.000 M

documents/year exchanged
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connected companies
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countries with exchange

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