CEN/ISSS Task 3. Storage of Electronic Invoices

Working Group 3
Storage of Electronic Invoices
Heli Salmi

e-invoicing Public Event - Brussels, 11 April 2006

eInvoicing WS Public Event, Brussels 11 April 2006

Problems of electronic
storage of invoices
Based on the work of CEN/ISSS eInvoice Focus Group
report

http://www.cenorm.be/cenorm/businessdomains/businessd
omains/isss/activity/einvoice_fg.asp


storage of invoices
Problems that may occur will be in cross border
transactions due to differences in the way the Directive is
transposed in individual countries
Location and access: e.g. multinational corporations who
have centralised processing and storage of electronic
invoices in another Member State, invoices will have to be
stored according to the regulation in the Member State,
where the company in question is registered.
Duration: the number of years a taxable person has to store
invoices varies quite much, from 4 to 10 years (eIFG 2003)
If documents have to be stored over a period of seven to
ten years, there can easily be one or two technology
changes during that period.


storage of invoices
Format: In some countries, the invoice data is to be stored
in the form it has been exchanged in, e.g. EDIFACT format,
in order to decode the EDI format into clear format it has to
be accompanied by the directories
Medium of storage: The medium of storage should not be a
problem


Task 3.1 Quidelines for
storage

To describe rules for storage of electronic invoices within
the member states, including rules and guidelines for
inspection.
Deliverable: CWA


Task 3.2 Co-operation with
Tax Authorities
In furtherance of the objective of the EC Directive on
Invoicing, to establish a number of common arrangements
governing the use of electronic invoicing, it is
recommended that the competent authorities in all EU
Member States should consider further opportunities for
implementing the Directive in a compatible way, in
particular, for cross-border electronic invoicing.
Deliverable: Annex to the CWA


Task 3.3. Service Providers
Quidelines
To describe rules and guidelines for service providers
Deliverable: CWA


Task 3.3 Service Providers
Quidelines
A questionnaire for Service Providers
The questionnaire covers the following issues:
Background
Standards
Storage
Electronic Signatures
Modelling
Feedback for recommendations
27 questions
41 answers


storage

Background: Service Providers’ View
The majority of the respondents (73%), offer an
integrated electronic storage service solution for their
customers’ invoices.
There appear to be sufficient standards; only 12,8 % of
the respondents wished to have more standards for
storage.
The most consistent comments and wishes for storage
centre upon legislation. Respondents hoped that invoice
storage, in electronic form only, will be made legal
throughout the Member States and that when electronic
archiving is in use, no paper documents should be
required.


storage

Legislation on storage – main rules
National legislations
Duration of storage
Place of storage
Storage in the original form
Storage media
Storage of coded data
Storage of digital signatures
Technology change during the storage period
Terminating the storage service
Annex: Legislation on storage in member states


storage

Electronic Signatures, recommendations
• Authentication and integrity have to be guaranteed over
the whole storage period of invoices
• Electronic invoices have to be stored in a way that the
electronic signature stays verifiable over years.
• Without the addition of other relevant data, like
revocation information, the electronic signature could
not be verifiable in the future.
• Ensuring stored invoices are long term valid, as
specified above, depends on both organisational and
technical measures.


storage

Questions to the local tax authorities
• Period of storage
• Kind of data
• Kind of storage: what methods of electronic storage, if
any, are not permitted?
• Is storage of invoices by 3rd parties allowed? If YES,
what special conditions, if any, are imposed?
• Is storage of invoices within other EU member states
allowed? If YES, what special conditions, if any, are
imposed?
• Is storage of invoices outside EU member states
allowed? If YES, what special conditions, if any, are
imposed?

storage

Questions to the local tax authorities (continued)
Are there special requirements for indexing or
search possibilities?
Are there requirements for storage of sum or
subtotal amounts (tax codes, invoice total, etc.) for
the defined period?
Are there additional requirements for storage which
have to be fulfilled concerning electronic invoices?


Quidelines
Different legislation
Third party service agreement
Interconnection agreement between Service Providers
Mandatory data on the invoice
Conversions between formats
Digital signatures
Cross-border electronic invoicing
Annex: Cases


Quidelines
Different legislation, main rules
The invoice issuer follows the legislation in his
country and the receiver follows the legislation in
his country. The invoice issuer and the recipient are
always responsible for fulfilling their own national
legal requirements for invoicing, even where a third
party service is used.


Quidelines
Conversions
The need for conversion should be minimised
wherever possible and conversions restricted to
those that are necessary to bridge the differing
formats of the message originator and the message
end receiver, since repeated conversions may result
in loss of data quality, or even loss of data, in the
individual messages being converted


Quidelines
European e-Invoice Forum, recommendation
In order to support the cross-border electronic
invoicing between traders in different Member
States, an European e-Invoice Forum could be
established.


Thank you

Questions?

heli.salmi@elma.net

http://comelec.afnor.fr/cen/wsei


Directive 2001/115/EC on
Electronic storage of Invoices

With regard to the electronic storage of invoices for goods
or services, any taxable person shall ensure that copies of
invoices issued by himself, by his customer or, in his name
and on his behalf, by a third party, and all the invoices
which he has received are stored.



The authenticity of the origin and integrity of the content of
the invoices, as well as their readability, must be
guaranteed throughout the storage period. The information
they contain may not be altered; it must remain legible
throughout the aforementioned period.

Member States referred may require that invoices be stored
in the original form in which they were sent, whether paper
or electronic.
They may also require that when invoices are stored by
electronic means, the data guaranteeing the authenticity of
the origin and integrity of the content also be stored.



The taxable person may decide the place of storage
provided that he makes the invoices or information stored
there available without undue delay to the competent
authorities.
In case the invoices are stored in another Member State;
the Member State where the taxable person is registered
will have the right to access the data within the limits of the
Directive.
The Member States may impose specific conditions
prohibiting or restricting the storage of invoices in a
country with which no legal instrument exists relating to
mutual assistance similar in scope to that laid down by the
Directives.



Member States may, however, require taxable persons
established in their territory to notify them of the place of
storage, if it is outside their territory.
The Member States shall determine the period for which
taxable persons must store invoices relating to goods or
services supplied in their territory and invoices received by
taxable persons established in their territory.


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