ERPB Secretariat
12
June 2015
ERPB/2015/007
E-INVOICING SOLUTIONS RELATED TO RETAIL PAYMENTS
THE WAY FORWARD IN SEPA
1. Executive summary and next steps
To date in the EU the take-up of e-invoicing and the payment-related solutions is quite at an early stage.
Due to the directive 2014/55/EU on electronic e-invoicing in public procurement the general focus regards
to e-invoicing in Europe is mainly on governments and businesses. But for e-invoicing to become the
predominant method of invoicing by 2020 in Europe
1
, it is necessary to focus also on possibilities how the
benefits of e-invoicing could be maximised for consumers, SMEs and micro enterprises in the Single Euro
Payments Area, especially at the cross-border level. Therefore it is the right time to analyse the issues
and give guidance to the market participants to avoid developing non-interoperable national solutions and
services in SEPA.
The relevance of this dossier for the ERPB stems from the close links between invoicing and payment
processes. E-invoicing not only enables end-to-end straight through processing (STP) in pre- and post-
payment processes, it also influences how the payments are actually made. This has motivated the
emergence of innovative payment types combining e-invoicing and payments into electronic invoice/bill
presentment & payment (EIPP/EBPP) solutions, which have taken off especially in the business to
consumer domain.
This note deals with e-invoicing and retail payments in the SEPA context and will serve as a good starting
point for the dedicated ERPB Working Group. The note also explains that the scope of ERPB’s future
work on this dossier should be on EIPP/EBPP solutions, focusing primarily on services which are
provided by PSPs and used by consumers, SMEs and micro enterprises to enable one-off and/or re-
current payments of the corresponding invoices in the SEPA context. With the vision to facilitate and
catalyse the market in delivering a harmonised e-invoice/bill presentment & payment service for payers;
and an e-invoicing/billing network for the payees to reach all consumers and businesses in Europe. The
matter how e-invoices are being processed and sent for payment in the Enterprise Resource Planning
(ERP) or accounting system of the businesses is left out of scope.
This note confirms that the European standard on e-invoicing (as required by directive 2014/55/EU) will
be, together with the SEPA payment instruments, one fundamental building block for enabling the
development of fully automatic e-invoicing and payment solutions, which are interoperable at the pan-
European level. In the note it is also clearly suggested that the semantic content used for EIPP/EBPP
solutions should be harmonised based on this European standard on e-invoicing. However, as no final
decisions have been made regards to the list of technical message formats accompanying the European
standard, the note supports the possible inclusion of the ISO 20022 Financial Invoice message standard.
Having the ISO 20022 Financial Invoice message standard as the underlining technical message format
(syntax) for EIPP/EBPP solutions would maximize the benefits of the fully fledged pan-European SEPA
1
A goal set by the European Commission in the Single Market Act II (COM/2012/573) and in EC communication COM/2010/712.
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infrastructures. For the European Committee for Standardisation (CEN) this could provide a positive
rationale in favour.
To provide momentum to the Working Group a number of barriers to the implementation of electronic
invoice/bill presentment & payment (EIPP/EBPP) solutions have already been identified. The following
outlines the most prominent barriers hindering:
(A) the general objective the take-up of EIPP/EBPP solutions; and
1. Businesses and consumers have limited knowledge about the advantages and added value not
enough motivation to initiate change.
2. SMEs and micro enterprises perceive e-invoicing/billing and the integrated presentment &
payment solutions as complex and expensive to implement.
3. Consumers lack access to comfortable and secure solutions for receiving and paying e-
invoices/bills.
4. The payers (and even the payees) might experience a lock-in effect because of diverge service
levels and complexity in switching.
(B) the core objective EU integration EIPP/EBPP solutions
5. No EU-wide interconnected network for providing full reach.
6. Diverging standards and non-interoperable technical formats for e-invoicing/billing.
7. Diverging business rules and practices on top of the standards.
Altogether, in a two-sided market one side has to take the first step. This means that firstly the
businesses, as the biggest benefiters of the cost savings, should move towards e-invoicing, thereby
facilitating the awareness of their customers. It is acknowledged that many businesses have already
implemented supply chain & public procurement specific e-invoicing in the business-to-government (B2G)
or business-to-business (B2B) domain and use the dedicated networks for sending and receiving
invoices. But for enabling simple EIPP/EBPP services to all customers, cooperation is needed between e-
invoice service providers and PSPs. This way the supply side would be able to deliver a complete
package a harmonised e-invoice/bill presentment & payment service for payers; and an e-
invoicing/billing network for the payees to reach all consumers and businesses in Europe which would
for the interested stakeholders facilitate optimal level cash in opportunities on benefits of e-invoicing and
SEPA in business-to-consumer and B2B invoicing.
The ERPB is invited to:
- agree on the ERPB’s focus and vision on this dossier;
- agree to set up an ERPB Working Group and approve the mandate (see file “Mandate of
the Working Group on e-invoicing solutions related to retail payments”); and
- advise the ERPB Working Group to take into consideration the findings presented in the
Secretariat note.
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2. Background
Migration to SEPA payment instruments was only one piece in a jigsaw of measures and initiatives being
introduced with the aim of creating a more competitive Single Market in Europe. Also the adoption of
electronic invoicing (e-invoicing) is expected to create additional benefits in efficiency and cost savings
2
.
Therefore the European Commission wants to see e-invoicing become the predominant method of
invoicing by 2020 in Europe.
The EU legislators define an “electronic invoice” as an invoice that has been issued, transmitted and
received in a structured electronic format which allows for its automatic and electronic processing
(Directive 2014/55/EU on electronic invoicing in public procurement). Therefore only machine readable
invoices, which can be processed automatically and digitally by the recipient
, are considered (for
example, a scanned invoice sent by email is not an e-invoice as per this definition)
In Europe according to a research conducted by Billentis (2014: 12) the annual invoice volume is
estimated to reach 35 billion and the general estimated volume of e-invoices is totalling up to 7.5 billion in
2015. More precisely, approximately half of the volume is sent to consumers (B2C); the other half to
enterprises and the public sector (B2B/B2G/G2B). The biggest incentive for accelerating the general
uptake of e-invoicing is the potential cost saving. Based on some actual case studies, it is highlighted that
e-invoicing enables businesses to reduce per invoice processing costs up to 59% for invoice issuers and
64% for invoice receivers, depending on the size of the company and the number of processed invoices
(Ibid, 2014: 5152). Needless to say that e-invoicing is more efficient, quicker, comfortable, and
environmentally friendly. It also opens additional possibilities which can be used in the context or real-
time-economy and making economic forecasts.
The European Commission believes that the Directive (2014/55/EU) on electronic invoicing in public
procurement will prevent the further fragmentation of the Internal Market and facilitate the general uptake
of e-invoicing. The directive makes e-invoicing in public procurement mandatory by 2016 and calls for a
European standard for the semantic data model of the core elements of an electronic invoice. With the
directive (2014/55/EU) the basic (core) elements of an e-invoice will be harmonised in all Member States.
The harmonisation of the core section of the e-invoice will enable cross-border interoperability and also
legal compliance.
Consequently, the general focus in Europe with the call for a European standard on e-invoicing is more
concretely on the domain between businesses and government. Approximately 4565% of all companies
are suppliers for the public sector and 100% of all companies and households receive in one or the other
form invoices (requests to pay, e.g. land tax, public service charges etc.) from the public sector (Billentis,
2014). Therefore a greater uptake of e-invoicing solutions between businesses and government will
increase also the usage of e-invoicing towards the consumers, SMEs and micro enterprises. With the
European e-invoicing standard it is aimed that the standard and the defined list of possible technical
message formats (syntaxes) should make it possible to set up user-friendly electronic invoicing systems,
which also the businesses, especially SMEs could use. It will be developed by the European Committee
for Standardisation (CEN); publication in the Official Journal of the European Union is envisaged by May
2017. This standardisation initiative (which is limited to the content and exchange on e-invoices) will be,
together with the SEPA payment instruments, one fundamental building block for enabling the
development of fully automatic e-invoicing and payment solutions, which are interoperable at the pan-
European level.
2
Reaping the benefits of e-invoicing in Europe, European Commission, 2010 (link)
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From the retail payments perspective there are emerging different solutions and services which merge
electronic invoicing and payments from the payment service users’ (PSUs) perspective (see also annex
1). Meaning that the basic e-invoicing (out of scope for ERPB) can be combined with payment services in
a way which results in an innovative payment type, enabling the payer to flexibly manage and pay
invoices/bills i.e. Electronic Invoice or Electronic Bill Presentment & Payment (hereinafter also
EIPP/EBPP)
3
solutions. The EIPP/EBPP solutions are facilitated either directly or indirectly via PSPs
and in practice they can be used in the business/government-to-consumer and business-to-business
domains. For consumers it makes handling invoice payments easier and for businesses it increases
efficiency throughout the payment as well as the reconciliation process. In some cases these services are
clearly perceived by PSUs even as alternative payment solutions on top of the SEPA payment
instruments. Unfortunately the market situation suggests that there is a need for further standardisation
and harmonisation in order to make these solutions and services interoperable at the pan-European level.
To date in the EU the take-up of e-invoicing and the payment-related solutions is quite at an early stage.
Therefore it is the right time to analyse the issues and give guidance to the market participants to avoid
developing non-interoperable national solutions and services, which would also affect the single euro
retail payments market.
3. Vision, focus and aim of the note
The vision is to facilitate and catalyse the market in delivering a harmonised e-invoice/bill presentment &
payment service for payers; and an e-invoicing/billing network for the payees to reach all consumers and
businesses in Europe.
The focus is on services which are provided by PSPs and used by consumers, SMEs and micro
enterprises to enable one-off and/or re-current payments of the corresponding invoices in the SEPA
context.
The aim is to outline the main findings of the research and analysis done by the ERPB Secretariat, with
the objective to support the take-up and EU-level integration of electronic invoice/bill presentment &
payment (EIPP/EBPP) solutions.
As the trend is towards electronic invoicing and also financial literacy is gaining ground in consumers’
everyday lives there is a need for simple solutions to manage and pay e-invoices in the entire Single
Market. Furthermore, due to limited IT skills and resources of SMEs and micro enterprises there is an
increasing demand for extremely easy-to-implement/use tools & services (provided e.g. by PSPs or third
parties) which enable the electronic sending, receiving and payment options of invoices/bills.
In the context of the note, e-invoicing solutions which are fully integrated into the Enterprise Resource
Planning (ERP) and/or accounting software and are already supporting straight-through-processing (STP)
i.e. the payment orders are sent directly to the PSP via a SEPA compliant channel are out of scope.
This note is also not concentrating on the deliverables of the directive 2014/55/EU, i.e. the European
standard for the semantic data model of the core elements of an e-invoice, because the latter focuses
concretely on e-invoicing in public procurement, supporting also complex supply chains, and thus has a
much richer content than needed for EIPP/EBPP.
4. General state of play in Europe
In Europe the e-invoicing market is growing, but the market penetration varies quite a lot. According to
Billentis the general estimated electronic proportion of electronic invoice/bill volume is predicted to reach
3
E-invoice (used in B2B/B2G) and e-bill (used in B2C) are synonyms, in this note the abbreviation EIPP/EBPP names both.
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16% for consumers and 27% for businesses and governments in 2015. The B2C electronic share of total
invoice/bill volume is above 15% in Finland, Sweden, France, Ireland, the Netherlands and the United
Kingdom; and exceeds 40% only in Denmark, Norway and Estonia. In general electronic invoicing/billing
is still more used in B2B/G2B/B2G, the respective share in the majority of Europe is 15-40% or above.
The Directive (2014/55/EU) on electronic invoicing in public procurement will facilitate the general uptake
of e-invoicing even more. This gives more ground for saying that in the coming years e-invoicing/billing
will become more available also to consumers, SMEs and micro enterprises.
In Europe there are over 620 e-invoicing service providers (operators), which are based either on three-
or four-corner e-invoicing models. They offer different web-based, Software as a Service (SaaS, e.g.
piece of software which connects to the ERP/accounting systems) and other solutions, which enable
payees to issue e-invoices and send/receive them directly or via a consolidator/aggregator. Regarding
distribution channels in B2B/B2G/G2B invoicing the buyer/supplier directand consolidator modelsare
used more or less equally, if one considers only the presentment of the invoice. However, in the B2C
invoicing the supplier direct model is used the most. This is because most consumers prefer to receive
electronic invoices via e-mail. Therefore it is estimated that e-mailing could be the preferred delivery
channel for 2/3 of European consumers in the mid-term. Invoice presentment on the supplier portals and
via internet banking does not yet play a major role in most European countries. An exception build the
Nordic countries, where the exchanged e-invoice volume via online banking portals is almost as high as
the one distributed by other channels. (Billentis 2014 and 2015)
In the future, with stronger discipline regarding e-invoicing standards, as being applied e.g. in Finland, it
will be possible to launch piloting in respect of accounting based on statements of account and VAT
reporting. Such pilot projects will subsequently enable implementation of cash-flow forecast automation
and broader reporting automation. As more e-invoicing networks enable immediate processing, it might
be even possible to monitor the business cycle in real-time at a company as well as country level.
In 2014 the migration to SEPA credit transfers and direct debits reduced the complexity of implementing
e-invoicing solutions and enhanced the benefits of automated reconciliation latest by February 2016 all
stakeholders are using ISO 20022 XML standards for initiating bulk payments and receiving reconciliation
messages. Therefore the harmonisation of the “payment leg” and the messaging channels between the
PSPs and PSUs has made it easier for the sellers and buyers to integrate e-invoicing into their
ERP/accounting systems. The migration has even motivated PSPs in some Nordic-Baltic Member States
4
to move more towards B2C/B2B e-invoicing/e-billing, by replacing legacy direct debits with EIPP/EBPP
solutions, i.e. combining e-invoicing and SEPA credit transfers to facilitate comfortable payment of one
time and regular invoices.
4
Finland, Estonia and Latvia
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In the Nordic-Baltic countries (i.e. Finland and Estonia) the impact on the uptake of B2C invoicing has
been remarkable, because the SEPA migration provided an incentive to make the invoicing and payment
procedures more efficient, resulting in the switch of legacy direct debits to e-invoices/bills which are being
comfortably paid with SCTs. As both countries use a national four-corner e-invoicing model, the payees
can make use of e-invoice sending and receiving possibilities offered directly by their PSPs or third party
e-invoicing service providers (SaaS or web-based), unfortunately this interoperability is possible only at
national level. Based on the practice of Finnish and Estonian PSPs the payers (consumers as well as
businesses) are comfortable with the EIPP/EBPP solution and according to the competent authorities and
consumer protection bodies there have been no complaints regards to the need for a refund recorded
during 2014.
The decision how the payers want to pay the incoming e-invoices/bills always depends on different
factors, e.g. the nature of the “business” transactions they are conducting; and also the financial situation
of the payer, which will also influence the payment decisions through the level of the payer’s financial
literacy. Based on these factors the payers are free at any time to choose whether they want to pay their
e-invoices using one-off or automatic (re-current) payment options, and change their decision at will. But
it can be said that the payers (especially consumers) tend to use the EIPP/EBPP service more for
automatically paying regular e-invoices/bills, at least in the on boarding phase.
5. Barriers to take-up and integration
E-invoicing is a network business and there is a concrete need to avoid fragmentation and interconnect
all service providers in order to achieve maximum reach to all businesses and consumers. Currently the
use of e-invoicing is not widespread throughout the European Union and the use of EIPP/EBPP solutions
is even less.
Regards to take-up, it is quite common that the migration to e-invoicing faces the well-known chicken-
and-egg dilemma. Meaning that some businesses might argue that they don’t need to start using e-
invoicing, because their customers (suppliers/consumers) don’t demand it. And vice versa the suppliers
and consumers are just incapable of demanding services related to e-invoicing if the companies are not
offering them.
Regards to EU integration, the work that is going to be done under the aegis of Directive 2014/55/EU is
addressing the general standardisation and interoperability issues of e-invoicing by means of the
European standard on e-invoicing and the limited list of syntaxes with relevant guidelines on
interoperability at the transmission level. By law e-invoicing will be compulsory only in the procurement
process, between businesses and public authorities. However, as the migration to the European e-
invoicing standard is voluntary for private businesses (B2B and B2C invoicing) it affects also the
EIPP/EBPP services offered to SMEs, micro enterprises and consumers. The most important remaining
barriers are listed in the following table.
The following list of barriers is based on a Eurosystem analysis, the Billentis e-invoicing / e-billing report
(autumn, 2014) and the European Commission’s final report of the expert group on e-invoicing
(November, 2009), etc.
The 7 key barriers to be addressed
Influencing the general take-up and implementation of EIPP/EBPP solutions
1. Businesses and consumers have limited knowledge about the advantages and added value not
enough motivation to initiate change.
2. SMEs and micro enterprises perceive e-invoicing/billing and the integrated presentment & payment
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solutions as complex and expensive to implement.
3. Consumers lack access to comfortable and secure solutions for receiving and paying e-invoices/bills.
4. The payers (and even the payees) might experience a lock-in effect because of diverge service
levels and complexity in switching.
Influencing EU integration of EIPP/EBPP solutions
5. No EU-wide interconnected network for providing full reach.
6. Diverging standards and non-interoperable technical formats for e-invoicing/billing.
7. Diverging business rules and practices on top of the standards.
6. Concluding considerations for the ERPB
As described before, the potential benefits (see also annex 2) of the adoption of e-invoicing in general
and EIPP/EBPP solutions more specifically are quite important not only for the stakeholders but also for
the whole economy. A central point for achieving migration to e-invoicing is that payees are convinced of
the added value (i.e. cost savings, speed, security and simplicity) of e-invoicing/billing and more
innovative EIPP/EBPP solutions which clearly involve also payees/payers with no technical capability of
automatizing its own payment processes.
Based on Eurostat 7.3% of all enterprises in EU28 are SMEs (10-249 employees) and 92.5% are micro
enterprises (less than 10 employees). For e-invoicing/billing to become predominant in Europe, the vast
majority of SMEs and micro enterprises must also be enabled to issue and pay e-invoices/bills in a simple
and cheap manner. In a two-sided market this would also ensure that consumers can fully benefit from e-
invoicing/billing, because it would give a greater incentive to PSPs, e-invoicing service providers and
larger payees for developing EIPP/EBPP services targeting directly consumers.
By addressing the “seven key barriers” identified in the previous chapter the following possibilities for
supporting the take-up and EU integration of EIPP/EBPP solutions are identified (as numbered before).
6.1. General objective support the take-up of EIPP/EBPP solutions
For supporting the proliferation of the electronic invoice/bill presentment & payment solutions the
following conclusions should be considered by the ERPB.
1. Better communication of the potential benefits to the supply and demand side of the market
is needed already at country level.
a. A supporting role could be played by the relevant national fora and initiatives.
b. For highlighting the social and private benefits of automated e-invoice and payment
processes in the B2G/B2B/B2C and G2C domains, the relevant authorities could consider
including it also in the scope of cost studies on retail payments.
Based on the available reports analysing the barriers hindering the up-take of e-invoicing it is
obvious that one common issue is related to the knowledge of the business owners. Because even if
there are convenient and cost effective EIPP/EBPP solutions available, the business owners tend
not to know what are the real benefits for the company.
2. Businesses need easy-to-use and cheap-to-implement EIPP/EBPP solutions (e.g. web/portal-
based or Software as a Service), enabling them the possibility to reach any payer in the
European Union. [Developments could be made by ERP/accounting software providers; e-invoicing
service providers; and also PSPs.]
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a. The ERP/accounting software providers have a key role to play many of their solutions
already enable e-invoicing, the question is how to easily send the invoice via a PSP or e-
invoicing service provider’s network to any payer in the EU.
In general, it is aimed that by 2020 e-invoicing becomes the predominant way of invoicing in the
European Union. The directive 2014/55/EU makes e-invoicing in public procurement mandatory by
2016. This will probably ensure the critical mass of adopters, because it is estimated that
approximately 4565% of all companies are suppliers for the public sector (Billentis, 2014). For
increasing the take-up of EIPP/EBPP services, the businesses already using e-invoicing in the B2G
domain should be enabled to apply that also in their B2B and B2C business, e.g. by making
available necessary conversion facilities. In addition also the vast majority of SMEs and micro
enterprises should be able to issue e-invoices.
3. Consumers need that the stakeholders, enabling them to receive, manage and pay e-
invoices/bills in the B2C/G2C domain, establish easily accessible and secure service
environments, which can also be used remotely via mobile devices or even phone calls.
[Developments could be made by e-invoicing service providers; and PSPs.]
Consumers lack access to comfortable and secure solutions for receiving and paying e-invoices/bills.
Smartphones, tablets and mobile internet is becoming widespread and affordable to everybody. Also
banking and e-invoicing/billing is steadily moving into mobile channels/devices.
4. A harmonised description of the basic features/principles of the EIPP/EBPP service would
avoid complexity in changing service providers. [In cooperation of PSPs and e-invoice service
providers.]
a. It also ensures a level playing field for the relevant stakeholders in the cooperative space.
b. The service providers are free to develop additional added value offerings, bearing in mind
the EBA guidelines for security of internet payments (EBA/GL/2014/12).
From the consumers’ (and possibly many micro enterprises’) perspective it would be efficient and
convenient to receive, manage and pay all e-invoices in one easily accessible environment.
6.2. Core objective support EU integration of EIPP/EBPP solutions
For increasing integration the ERPB should consider the following.
5. Leveraging the potential of SEPA payment infrastructures in cooperation with existing e-
invoicing infrastructures could result in a pan-European e-invoicing network enabling the
payees/payers to route or send all e-invoices/bills based on IBANs and/or payment card
details to any payer’s account in the European Union. The invoicing leg could operate in real-
time. For that cooperation is needed between PSPs, e-invoice service providers, SEPA
infrastructures and if needed also card payment processors in SEPA.
a. Also conversion facilities to ISO 20022 XML formats are needed for including the different e-
invoicing syntaxes.
b. This could be applied at least in the B2C and G2C domain and if applicable also for micro
enterprises and SMEs.
Despite the cooperation efforts between the existing e-invoice service providers, the general e-
invoicing network is still limited and doesn’t reach many SMEs and the majority of micro enterprises
and consumers in the EU. However, the PSPs’ network interconnects all payees and payers in the
EU, therefore the e-invoice envelope (and also e-receipt) could be sent to the payer using the SEPA
payments infrastructure.
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6. For benefiting of the fully fledged SEPA infrastructures the EIPP/EBPP solutions, which
enable consumers, SMEs and micro enterprises to initiate one-off/re-current payments of the
corresponding invoices, should ideally be based on the ISO 20022 Financial Invoice
messages (syntax). See rationale in annex 3. [In cooperation of PSPs and e-invoice service
providers.]
a. Harmonisation of the semantic content should be made based on the European standard on
e-invoicing. The European standard should be implemented at least to an extent necessary
for providing EIPP/EBPP services.
b. The ISO 20022 Financial Invoice syntax could also be mapped to enable technical
interoperability between all identified syntaxes for the European standard (i.e. by means of
conversion facilities); in particular the CEN could include it as one of its recommended
syntaxes.
Making use of the ISO 20022 Financial Invoice syntax enables the service providers and payees to
take advantage of the fully fledged SEPA infrastructures and the ISO 20022 XML compliant channels
between the payees and PSPs.
7. Harmonisation of business rules and practices and interoperability between different
EIPP/EBPP solution providers domestically and on the cross-border level is urgently needed.
In this respect, the possibility of creating a European scheme, i.e. a scheme for EIPP/EBPP services,
which makes better use of the existing payment schemes, could be explored. [In cooperation of
PSPs and e-invoice service providers]
a. The scheme should be open to all SEPA payment instruments, ensuring flexibility based on
the business needs of the involved parties; and
b. it should be based on the existing payment instruments, enabling the payer to flexibly
manage/initiate one-off and re-current payments at the service provider’s environment (incl.
authorisation of the automated payments of already received regular e-invoices and bills).
In principle and by drawing parallels from the definition
5
of a payment scheme, such a harmonisation
of rules, practices and/or implementation guidelines could lead to the development of a European
scheme for EIPP/EBPP solutions and services. On top of that a scheme ensures that the services
are provided on the same essential conditions and modalities throughout SEPA, and also that the
payees and payers have the possibility to use a single payment account irrespectively the Member
State for using the services. Such a scheme would facilitate the elimination of borders and make it
possible for consumers, SMEs and micro enterprises to use EIPP/EBPP solutions and services in
SEPA with the same level of simplicity and adequate security as within the national environment.
Ultimately a European scheme would also benefit the development of a healthy and competitive
market where the EIPP/EBPP solution and service providers can enjoy a level playing field.
6.3. Possible action points to the dedicated ERPB Working Group
In the following the above listed conclusions are transformed into more concrete action points for further
investigation.
ISO 20022 Financial Invoice message standards v/s ISO 20022 Payment message standards.
The ERPB WG should initiate:
5
payment scheme’ means a single set of rules, practices, standards and/or implementation guidelines agreed between PSPs for
the execution of payment transactions across the Union and within Member States, and which is separated from any infrastructure
or payment system that supports its operation (Article 2, Regulation 260/2012/EU)
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- a feasibility assessment for leveraging the potential of the SEPA payment infrastructures either
by (A) additionally supporting the transmission of ISO 20022 e-invoice envelopes, or (B) merging
both message standards to support EIPP/EBPP services that reach every payer (identified by
an IBAN or card details) in the European Union (i.e. full reachability using the PSPs and the
automated clearing houses or the card processing infrastructures); and
- a query on how the EPC’s scheme rulebooks and the practice of PSPs might support or restrict
this.
Pan-European reachability: in relation to the feasibility assessment, specified above, the ERPB WG
should initiate an analysis for the development of a framework for the pan-European e-invoicing/billing
network, also taking into account the developments of e-invoicing networks in the B2G domain and
considering interoperability options.
Avoiding complexity in changing service providers: the ERPB WG could propose a harmonised
description of the basic features/principles of the EIPP/EBPP service, which could be included in a
European scheme for EIPP/EBPP services.
Harmonising the business rules, practices and implementation guidelines: for EIPP/EBPP
solutions (targeting SMEs, micro enterprises and consumers), the ERPB WG should describe a set of
“minimum criteria” for business interoperability that all service providers respect in providing the
respective services in the EU. The relevant market stakeholders should discuss and agree on the way
forward regards to the establishment of the European scheme for EIPP/EBPP services.
Facilitating different payment habits: from the payers perspective it is comfortable to manage the
payment option (one-off/automatic) of incoming one-off and regular e-invoices at the payers PSP (i.e.
authorise the automated payments of invoices after receiving the e-invoice). This might have the
potential to motivate the uptake of e-invoicing in the B2C and also B2B domain. The ERPB WG could
investigate whether the needs of all invoice issuers/payers in Europe could be supported by the
existing payment schemes and propose ways to address this if it is not the case.
Page 11 of 15
Annexes
Annex 1. Combining e-invoicing and retail payments
E-invoicing is the electronic transfer of invoicing information between business partners (seller and
buyer). It is an essential part of an efficient financial supply chain and it links the internal processes of
enterprises to their payment systems. However, the benefits of electronic invoicing are maximised when
the generation, sending, transmission, reception and processing of an invoice can be fully automated.
In general e-invoices can be routed and displayed to the payers (consumer, SME & micro enterprise) via
different channels. The payee has the possibility to:
issue e-invoices directly to the payers (e.g. using a supplier/buyer direct model)
6
, if it has enough
resources to integrate e-invoicing into the ERP/accounting system; or if not
use a service provider (a PSP or a 3
rd
party), which can provide an easy-to-use solution for
compiling e-invoice envelopes, also enabling aggregation possibilities (consolidator model)
7
.
This enables to make the connection between the general e-invoicing and the automation of the
presentment and payment of the invoice (i.e. EIPP/EBPP) towards the payers. It also includes the after-
payment processes, enabling automated reconciliation
8
of outstanding e-invoices and payments
made/received.
The following figures show the involved parties and illustrate the possible e-invoice flows in case of 3-
corner and 4-corner models (non-exhaustive)
9
. It has to be noted that more and more e-invoicing
networks are processing information flows in real-time.
3-corner e-invoicing models
It is important to stress that all EIPP/EBPP solutions enable via the PSPs the buyer-side (payer) to initiate
an electronic payment either using a credit transfer, a direct debit, or a card payment (as described in the
following table). In addition the seller-side (payee) can enjoy automated reconciliation in its
ERP/accounting systems (or via an accounting service provider).
6
The seller direct model implies that the vendor possesses the EBPP system on which invoices are presented to customers (one-
to-many relationship). In the buyer direct model, the customer controls the EBPP application (many-to-one relationship). The
vendor either posts his invoices on the customer’s system or the customer creates the invoice himself from his own order.
7
The consolidator model promotes many-to-many relationships between payees and payers. A consolidator (e.g. a third
party/PSP) acts as an intermediary, collecting or aggregating invoices from multiple payees for multiple payers, eliminating the need
for point-to-point connections.
8
Within SEPA the automation of reconciliation can be achieved by using the ISO 20022 XML messages for Account Reports in the
payment service provider (PSP) to customer domain.
9
EBA e-invoicing initiative Service Description & Rulebook Version 2.0, published 2011 (see pages 8586)
Page 12 of 15
Electronic Invoice or Electronic Bill Presentment & Payment
(EIPP/EBPP) solutions
1. PRESENTMENT
PSPs' Internet Banking websites;
3rd Party Service Providers' websites/secure
e-mails (non-PSPs);
acquiring the
payment option
via PSPs
Payees' websites.
2. PAYMENT
Credit Transfers, Direct Debits, or Card Payments
Recognizing that for EIPP/EBPP solutions the payees can use their own websites, it has to be stressed
that PSPs and non-PSP third party service providers (e.g. e-invoicing operators/service providers) are
better placed for proliferation of e-invoicing in Europe. The e-invoicing operators can provide easy-to-use
and simple-to-implement e-invoicing solutions for issuing invoices (which is their primary business), but
also address the payers’ needs by offering EIPP/EBPP services to consumers, SMEs and micro
enterprises.
The PSPs network provides strong authentication of the payees/payers as well as strong authorisation of
payments. The PSPs are also inter-connected via the SCT and SDD infrastructures into a pan-European
network, which reaches all stakeholders. Currently in the Single Euro Payments Area (SEPA) there are
three EU-wide payment schemes developed by the European Payment Council: one for credit transfers
(SEPA Credit Transfer Scheme) and two for direct debits (SEPA Direct Debit Core and B2B Scheme).
For making inter-bank payments the PSPs make use of relevant infrastructures and the corresponding
services for clearing and settlement of credit transfers and direct debits
The following table shows how it is possible to combine e-invoicing, different payment instruments and
related infrastructures to enable comfortable payment of an invoice.
EIPP/EBPP solutions
e-invoicing
standard/format
e-invoicing file/envelope
payment instrument
credit transfers direct debits card payments
and infrastructure SCT infrastructure SDD infrastructure processing infrastructure
At the service level
the payers are
enabled to make
- one-off payments (for one time or regular e-invoices); and/or
- re-current payments (for regular e-invoices)
As the table is generic, it is flexible towards the different needs and payment habits of the payment
service users in Europe. From the security perspective the EBA guidelines on the security of internet
payments are applicable to all combinations.
Annex 2. Benefits of using electronic invoicing
The implementation of e-invoicing brings benefits for the society as a whole convenience for
consumers, efficiency and productivity for businesses as well as for public administrations. The
digitalization of business processes in general and e-invoicing in particular is a prime opportunity to
improve the competitiveness of European enterprises and raise productivity and customer satisfaction. In
addition to the reduction of private costs also the environmental benefits of e-invoicing must be
considered. E-invoicing helps to reduce paper consumption and energy costs of transportation,
generating significant carbon savings and reducing the ecological footprint of companies
10
.
10
Economically friendly electronic invoice, Federation of Finnish Financial Services, 2010
Page 13 of 15
The structured e-invoicing enables integration of processing in the ERP and accounting software and will
make it possible to fully automate buyer and seller business processes (i.e. starting from placing the
order, to the actual payment and reconciliation of the invoice). This leads to improved STP (straight-
through-processing) for payments and reconciliation of outstanding invoices. With faster invoice approval
times the payment delays will be shorter, and if needed the businesses will have also faster payments
and improved supply chain finance opportunities, enabling them to generate more value. The EIPP/EBPP
services offered by PSPs and e-invoicing operators make these benefits easily accessible to consumers,
SMEs and micro enterprises, enabling them to issue and pay e-invoices in a simple, secure and efficient
manner. So, with EIPP/EBPP services it is a win-win situation to businesses/consumers as well as to the
PSPs and e-invoicing service providers. By introducing new convenient services the PSPs and the e-
invoicing service providers are able to find new sources of income flows and thereby also to better
acquire new customers and satisfy/retain the current customer base.
In addition, general migration to e-invoicing benefits the “real-time economy” in the entire EU, i.e. will help
to create an environment where all transactions are digital, automatically generated and in real time
(Bank of Finland, 2015)
11
. For companies, public authorities and consumers this means that orders, order
confirmations, invoices and payments move from one system to another without delay. This will also
enable the uptake of electronic filing, electronic accounting and automated financial administration and
standardised, structured and automated reporting (towards relevant authorities). Full migration to e-
invoicing will enable governments to fight against grey economy and tax evasion; it will also make it
possible to accurately monitor the health of the economy as a whole.
In the following the most important benefits, categorised by stakeholder groups, are outlined
12
.
For businesses as sellers/payees and buyers/payers
Cost reduction
– e-invoicing creates substantial cost savings through a reduction in manual administrative
work, material and transport/postal costs. In particular a full integration of procurement/purchase
processes, invoicing and payments along the physical and financial supply chain is an essential driver for
enterprise cost savings. Straight through processing (STP) and semi/full automation of the invoice
presentment and payment makes the whole process more efficient (e.g. no mistakes in the payment
orders and less problems in reconciliation). Additional cost savings arise in fraud and loss prevention and
auditing costs for trading parties and tax authorities.
Faster processing and payment cycles e-invoicing enables instant and secure delivery of multiple
invoices to the payers, i.e. ensuring also faster invoice routing and approval times. It also enables faster
payments, either initiated through the payer’s own automated ERP and accounting software (exporting
payment data to PSPs) or via EIPP/EBPP solutions enabling easier and more efficient payment
opportunities for SMEs, micro enterprises and consumers. By using the automated ISO 20022 XML
account reports messages in the ERP and accounting software, the businesses can make use of
enhanced account reconciliation. This enables also better monitoring of the days sales outstanding, i.e.
acknowledgement of invoice receipt and transparency of the payment status.
Faster business cycle due to the faster approval and processing of e-invoices, businesses can increase
their working capital by making use of flexible supply chain financing, i.e. they have the opportunity to
borrow against approved receivables, thus increase the speed and productivity of their business cycle.
11
Payments in an increasingly digital economy, Payments Council Working Group 2, Bank of Finland, 2015
12
This part has benefited from different sources released by commercial and public sector entities. Including also the “Final report of
the expert group on e-invoicing”, published by the European Commission in November 2009. The benefits for the Public
Administrations are not described as they are out of the scope of this report.
Page 14 of 15
Improved cash management for businesses the ability to optimise their working capital is essential. It
improves business agility and can minimise the need for external financing. By shrinking the order-to-pay
and order-to-cash cycles, e-invoicing allows businesses to receive payments in a timely manner and take
advantage of any trade discount schemes that may be available.
Improved compliance and security businesses can take advantage of e-invoicing service providers
(PSPs or e-invoicing operators) whose solutions ensure security and regulatory compliance, i.e. VAT
compliance of invoices. For example: enabling e-invoices to be signed by a qualified electronic signature
and used/accepted as source documents in accounting, i.e. making the whole accounting process more
efficient.
For consumers as buyers/payers
Convenience and control of finances
all purchases end with a paper or electronic invoice/receipt, with
EIPP/EBPP services consumers have simple and easy access to their invoices at the payees’ digital
environment, at the PSPs’ internet banking environment or 3
rd
party service providers’ digital environment
(including notifications/monitoring via e-mail or SMS). With the latter two it is possible also to collect all
invoices into one place, which gives the consumer a good overview of expenditures, enabling to better
plan one’s finances. Including choosing when, where and how to pay. It makes also possible to access
archived invoices for warranty purposes, etc.
Better payment choices
with EIPP/EBPP services the consumers are always in charge, i.e. having an
overview of outstanding invoices and choosing payment options best fitting their financial needs (e.g.
using one-off or re-current payments). As the invoices are presented to the payer well before the due
date, the payer can check the details and rightfully change also pre-authorised re-current payments. The
payers will enjoy all benefits of the SEPA payment instruments.
Increased security with e-invoicing the payer cannot make any mistakes in the payment order, because
the latter is generated automatically from the e-invoicing envelope sent by the payee. This means that the
invoice is always paid correctly, i.e. with the right payer and recipient name, account and reference
number and other relevant remittance data. In addition with using EIPP/EBPP services the payer will
always receive the invoice, it won’t get lost in post.
Annex 3. Rationale of using ISO 20022 Financial Invoice messages for EIPP/EBPP
The EIPP/EBPP solution providers, which enable consumers, SMEs and micro enterprises to initiate one-
off/re-current payments of the corresponding invoices, should be incentivised, by the ERPB, to migrate to
the European e-invoicing standard and the ISO 20022 XML Financial Invoice messages as one of the
potential
13
interoperable syntax. As the European e-invoicing standard (i.e. the semantic data model of
the core elements of an e-invoice) provides more information than needed for providing EIPP/EBPP
services, it should be implemented at least to an extent necessary for providing the service to consumers,
micro enterprises and interested SMEs. In addition making use of the syntax based on the ISO 20022
methodology would enable the service providers and payees to take advantage of the fully fledged SEPA
infrastructures especially reaching consumers and businesses with simpler supply chains. See the
elaborated rationale in the following table.
It has to be noted that even if the ISO 20022 Financial Invoice would not be included in the final list of
syntaxes that will accompany the European standard on e-invoicing, there is a possibility to establish
interoperability based on other syntax (i.e. UN/CEFACT Cross Industry Invoice). This can be done by
means of conversion services which the EIPP/EBPP service providers could include in their value
13
Currently the assessment of the syntaxes that are to be included in the final list is on-going in the CEN/PC434.
Page 15 of 15
proposition to the payees/payers. In practise this would facilitate the businesses, which have
implemented some other syntaxes in the B2G domain, to send “requests to pay” to consumers, micro
enterprises and SMEs by making use of EIPP/EBPP services.
Rationale of using ISO 20022 Financial Invoice messages (syntax)
Strengths
-
It is a XML global message fully based on the
ISO20022 standard; it is based on the same
methodology as the payment messages used for SEPA
Credit Transfers and Direct Debits.
-
It is entirely based upon the CII Version 2.0 (Cross
Industry
Invoice) data model as the overall business
reference model for invoicing and fully maps to that
model.
- It provides an immensely useful and useable sub-set of
the UN/CEFACT CII data model by means of a
minimum core dataset. It will meet the majority of
com
mercial requirements for a general purpose
invoice, as well as being capable of extension to more
specialised requirements.
Weaknesses
-
It intentionally does not cover the features of entire
UN/CEFACT CII model, which reflects an enormous
range of speciali
sed requirements intended for the
needs of supply chain management, specific sectors
and functions, customs, and transport etc., but it does
provide the necessary flexibility for such requirements
to be added by selection from the CII data model.
- The UBL (Universal Business Language) e-invoice
message structure encompasses a wide range of e-
business messages (purchase to pay, order to cash,
pricelist, tender…). The ISO 20022 standard does not
yet encompass that variety of messages.
Opportunities
-
It does cover all currently identified financial
requirements for use in the financial environment, both
in terms of the invoice content itself, as well as the
integration to other financial messaging and business
requirements such as requests for payment initiation,
direct debits, card payments, electronic bill
presentment and payment, trade and invoice financing,
factoring, and supply chain finance.
-
It might enable the businesses, PSPs and
ERP/accounting software developers to exploit the
same ISO 20022
compatible channels, which were
developed in the course of the SEPA migration.
-
It might enable the usage of the SEPA payments
infrastructure, i.e. full reachability to all EU payers and
payees via the interconnected SEPA infrastructures.
Threats
- From a sy
ntax point of view it is based on a different
methodology from the commercial messages forming
part of ISO15000 and therefore will not be identical in
all respects to other syntactical representations of the
UN/CEFACT CII that may be developed (for example
as part of ISO15000).
-
The public sector has invested heavily in other
syntaxes and therefore might oppose stronger support
of ISO 20022.