The Global Exchange Network Association (GENA) is a global non-profit trade body representing the e-invoicing industry, bringing together over 100 members. We work closely with policymakers to ensure regulations reflect industry needs. By fostering collaboration and interoperability, we help businesses streamline cross-border invoicing and improve efficiency worldwide.
EU consultation
Revision of EU rules on the eInvoicing
18 submissions from 18 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 139 submissions on this file. Shown here: the 18 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
14 submissions from industry — companies and their trade associations — against 2 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 7 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 10 Jun 2026 — it ran from 18 Mar 2026.
- Policy area
- Industry (DG GROW)
- Where it stands
- Awaiting adoption
- Adoption expected
- 31 Mar 2027 · in 213 days
How it got here
- Call for evidence · impact assessment17 Dec 2025
- Public consultation10 Jun 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Proposal for a regulation.
18 positions
Please find attached Vertex Inc.'s response to the consultation on revising Directive 2014/55/EU. Vertex is a global provider of indirect tax technology solutions with extensive experience implementing e-invoicing across EU Member States. Our submission provides evidence-based recommendations on harmonisation, transmission interoperability, and alignment with ViDA.
CPME points out that while the adaptation of the European framework for electronic invoicing has real advantages, it also entails compliance costs for both the French administration and businesses. The Confederation therefore stresses the need to preserve the stability of the French regulatory framework, in order to ensure the clarity of the applicable rules and avoid successive adjustments that could generate…
Filed in French · English published by the European Commission
Bloomberg LP
· · filed 17 Dec 2025 · source
Bloomberg notes that European companies operating across borders continue to face challenges arising from the lack of globally harmonized identification standards. These inconsistencies increase operational complexity, elevate administrative burdens, and hinder efficient international business activity.
Electronic invoicing can contribute to burden reduction and reduce payment delays. The phase-in of new digital tools such as electronic invoicing across the EU can not only contribute to reduce payment terms but also to better payment controls and ultimately, improve the regulatory oversight of payment terms. However, its introduction needs to be within the reach of all businesses.
Bundesverband der Deutschen Industrie
· · filed 17 Dec 2025 · source
For German industry, the standard for the exchange of electronic invoices (EDI and in particular EDIFACT in the automotive industry), which has been proven for decades, must be maintained with the introduction of the European reporting system.
Filed in German · English published by the European Commission
N.B – Original text in Swedish is enclosed Current Situation The implementation of Directive 2014/55 in Sweden entails a statutory requirement for B2G e-invoicing in accordance with the European standard, regardless of the value of the purchase.
Filed in Swedish · English published by the European Commission
The French National Forum for Electronic Invoicing (FNFE) has been founded in 2012 and supports the ecosystem, namely companies, service providers, software editors, integrators, consultants, and regulators, in the rollout of electronic invoicing.
This contribution outlines practical challenges and fragmentation in the current EU eInvoicing landscape based on extensive cross-border B2B and B2G experience. It aims to support the Call for Evidence by providing concrete examples and targeted recommendations to improve harmonisation, interoperability and SME-friendliness under the revised framework.
Zentralverband des Deutschen Handwerks (ZDH)
· · filed 17 Dec 2025 · source
The Central Association of German Skilled Crafts (ZDH) supports the plan to revise EU rules on electronic invoicing. However, from a ZDH point of view, the use of so-called extensions, i.e. extensions of the e-invoice beyond the core CEN EN 16931 standard, must still be allowed in both B2G and B2B cases if the issuer of the invoice and the recipient of the invoice agree on the use.
Filed in German · English published by the European Commission
Odette International
· · filed 17 Dec 2025 · source
As an industry organisation, Odette International has been supporting the digitalisation of processes in the automotive supply chain for over 40 years and welcome every initiative to extend the reach and scope of digitalisation in our business environment.
Dansk Erhverv
· · filed 16 Dec 2025 · source
Brugen af E-faktura når der handles med offentlige myndigheder har været obligatorisk i Danmark siden 2005. For at sikre mest mulig interoperabilitet er det vigtigt, at man fra EU-systemets side ikke påtvinge én bestemt teknisk transmissionsmetode i forhold til brugen af E-faktura.
Global Legal Entity Identifier Foundation (GLEIF)
· · filed 12 Dec 2025 · source
The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to review the EU rules on electronic invoicing in public procurement. Public procurement is a cornerstone of the Single Market, underpinning transparency, competition, and innovation.
Please find attached my response focussed on practical implementation pathways for eInvoicing harmonisation and arguing that standards definition alone is insufficient without implementation-level support including Open Source implemntation and funding support recommendation.
With E-Invoicing standard(s) like others, there is always the process discussion. It is good to see that in the 16931-1 development, the syntax discussion is well addressed. Feedback here is that the time that it takes should also be followed. It is important that besides that we understand what the standard is about, that we also understand what the process is what we try to achieve.
Vattenfall
· · filed 10 Dec 2025 · source
The issue I find within e-invoicing today is when working with many companies in different countries are not the formats themselves but the medium in which they are sent. For example with it being allowed for an XML-file sent by e-mail in Germany which requires an additional way of extracting information than regular e-invoices (between VAN-operators).
Istituto Nazionale Tributaristi
· · filed 10 Dec 2025 · source
The implementation of the harmonisation of electronic invoicing for public procurement in the European Union is certainly welcome and would facilitate cross-border trade between Member States. It is therefore necessary to amend Directive 2014/55/EU, which made electronic invoicing mandatory in B2G (business to government) transactions across the EU, as many countries have been delayed in implementation or have…
Filed in Italian · English published by the European Commission
PeppolEDGE
· · filed 4 Dec 2025 · source
Data quality is a strategic priority. Member States should take ownership of the e-invoicing networks participant data quality. For example, in the context of Peppol, this could mean integrating SML registration processes with their already existing national business/company registry systems.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.