From January 1, 2024, Polish entrepreneurs will be obliged to issue accounting documents exclusively using the National e-Invoice System (KSeF). Similar solutions have already been implemented or are planned in other European Union countries. We are looking at systems in the Community's three largest economies - Italy, France and Germany. 

The most important reason for the European Union's push to make e-invoicing mandatory in B2B transactions is the desire to close VAT gaps as quickly as possible. On average, it amounts to about €140 billion a year, but in 2020, for example, it reached a value of €164 billion, or more than 11 percent of expected revenues. For this reason, the European Commission is pushing for electronic invoice systems to be launched in all countries of the Community. EU member states are approaching these recommendations each in their own way. 

Italy

Italy was the first EU country to mandate electronic invoicing for all B2B transactions. The state-run system, called Sistema di Interscambio (SDI) , has been operational since January 1, 2019, and has received more than 2 billion accounting documents in its first 15 months alone. What are the characteristics of the Italian e-invoicing model?  

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• SDI is based on a uniform structured invoice format(FatturaPA xml) for all users. Its template has been defined by the state digital authority - Agenzia per I'Italia digitale

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• It is recommended that invoices sent to the system be signed using a qualified electronic signature. However, any other means for electronic identity and access management I&A (Identity and Access Management) is accepted in SDI.

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• An entrepreneur can outsource the issuance of invoices to third parties, but this requires signing a contract with them, the content of which is regulated by separate tax regulations. If the invoice is issued by an authorized person, this must be noted in the appropriate field of the invoice itself.

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• All invoices are automatically archived in SDI, but entrepreneurs also have the right to store them themselves in their own resources.

France

In France, work on the Portail Public de Facturation (PPF) e-invoicing system is still underway. It was originally scheduled to be ready in January 2023, but the deadline has now been pushed back to July 1 of 2024. What does the PPF implementation plan entail?

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• The system will be launched gradually until 2026.

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• In the first instance, about 300 of the largest companies will be obliged to use the PPF, from January 2025 they will be joined by medium-sized companies (about 8,000 entities), and a year later all others, amounting to about 4 million

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• The system will not cover foreign and B2C transactions, and related invoices will continue to be issued digitally or on paper outside the system, but companies will be required to periodically report them to the FPP

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• The invoice format valid in the system will be Factur-X (German: ZUGFeRD), developed jointly with Germany, which combines XML and PDF standards 

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• Invoices added to the FPP will be signed in three ways: using a qualified electronic signature, a Référentiel Général de Sécurité signature (a French-only solution that is not recognized in the rest of the EU), or other EDI (Electronic Data Interchange) compliant systems 

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• Companies will be able to outsource the issuance of invoices to third parties, but this will require either explicit or implicit authorization (a provision for this is to be included in the invoice itself)

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Germany

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There is no mandatory electronic invoicing for B2B transactions in Germany, and it is unclear when and in what form it will be introduced. What is known, however, is the format of the future e-invoice (it is the aforementioned ZUGFeRD), and it is also known that the future system is to accept qualified electronic signatures and other EDI-compliant authentication methods.  

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KSeF - vademecum of an entrepreneur

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Want to know more about the Polish e-invoicing model? Our experts have created a vademecum for entrepreneurs preparing for the introduction of the new system, in which you will find answers to the most frequently asked questions about KSeF. You will learn from it, among other things, what a structured invoice looks like and what benefits it can bring to your company.        

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Download the entrepreneur's vademecum