The Crown Commercial Service (CCS) has issued PPN 03/19 (22 November 2018).  It outlines and seeks views on the UK Government’s proposed approach to implementing EU Directive 2014/55/EU on electronic invoicing in public procurement (the e-Invoicing Directive).

In summary, the PPN explains that following the UK’s exit from the EU - assuming that the Withdrawal Agreement and a transition period are agreed - EU law will continue to apply. The Cabinet Office is therefore taking the necessary steps to implement the e-Invoicing Directive. In the event of Brexit with no deal, the UK would not be obliged to implement the e-Invoicing Directive.

The e-Invoicing Directive applies to electronic invoices issued as a result of performance of contracts under the procurement Directives (public sector, utilities, concessions and most defence & security procurement). It provides for the introduction of a common technical standard for e-invoicing. The aim is to help address the issue of many different e-invoice standards across the EU, with varied formats causing unnecessary complexity and operating costs for businesses, contracting authorities and contracting entities.

The European Committee for Standardization (CEN) issued the new e-Invoicing standard on 28 June 2017 (the Standard) and the European Commission subsequently published its Implementing Decision 2017/1870.

Important points

  • Central contracting authorities will be required to accept and process electronic invoices complying with the Standard by 18 April 2019
  • For sub-central contracting authorities and contracting entities(utilities), the e-Invoicing Directive allows for the possibility of deferring that obligation to 18 April 2020
  • The e-Invoicing Directive does not require suppliers to adopt the Standard. Suppliers may continue with current invoicing processes.


Proposed UK Approach

The CCS is seeking views on the proposed UK approach set out in PPN 03/2018 and summarised below. The deadline for submission of views is 21 December 2018.

  • mandatory requirement for contracting authorities and entities to process and undisputed invoice that complies the Standard. This would be by way of a statutory provision introducing an implied term
  • possible administrative measure to develop a model contract term to be published in further guidance
  • delayed application for sub-central contracting authorities and contracting entities to April 2020.

Follow this link to PPN 03/18

For further information and links to the e-Invoicing Directive, the Implementing Decision and the Standard issued by CEN – European Committee for Standardization as well as an e-invoicing readiness checker, see the European Commission’s e-Invoicing web page.