GENA has submitted its contribution to the European Commission’s Call for Evidence on the revision of EU rules on electronic invoicing in public procurement. This review is a key opportunity to address remaining fragmentation and move closer to fully digital, end-to-end trade processes across the EU.

While e-invoicing in B2G has expanded significantly over the past decade, adoption remains uneven. Different formats, platforms, and national requirements continue to limit interoperability, increase costs for suppliers — particularly SMEs — and restrict the reuse of data. GENA therefore encourages the Commission to build on existing progress by removing remaining thresholds for B2G e-invoicing, extending digital processes beyond invoices to include purchase orders and delivery notes, and promoting common syntaxes and semantic standards across Member States.

In its response, GENA also stresses the importance of aligning the revised framework with broader EU initiatives such as VAT in the Digital Age (ViDA), eIDAS 2.0, and the European Business Wallet, where e-invoicing has already been identified as a key use case. Beyond mandates, GENA highlights the role of incentives — such as faster payment for electronic invoices — to accelerate adoption, drawing on successful examples from countries like New Zealand and Australia.

Finally, GENA calls for stronger harmonisation at EU level, including a common certification scheme for access points, aligned security requirements, and a consistent definition of “critical data.” It also recommends making Peppol or eDelivery the default channels for B2G exchanges, replacing email with secure, interoperable networks. With these steps, the revised e-invoicing framework can reduce administrative burdens, strengthen trust, and support a more efficient and digitally mature Single Market.