On 7 February 2025, ETAF submitted its recommendations to the European Commission on the future EU electronic invoicing policy strategy, expected to be released in the first half of 2025.
The strategy will aim to increase the mass adoption of e-invoicing by potential integration of electronic invoicing modules in ERP systems, ensure e-invoicing efficient transmission via interoperable infrastructures and exploring new uses for e-invoicing such as leveraging e-invoicing for automated compliance in VAT reporting or ESG reporting.
ETAF stressed that one key concern is the regulation of Peppol access points, as many countries currently lack oversight, increasing the risk of fraud and privacy breaches. ETAF advocates for mandatory regulations across all EU Member States. Secure authentication processes must also be implemented to verify users accessing invoices.
Another critical demand from ETAF is setting up automatic mandates for regulated tax advisers and accountants, allowing them to verify the identity of legal representatives and validate mandates. Since legal representatives may change over time, these professionals should ensure continuous validation, enhancing trust in both domestic and international invoicing.
The rapid expansion of new e-invoicing players raises concerns about financial data ownership and misuse. Many commercial intermediaries, such as banks and software providers, lack ethical obligations and could exploit company data for profit. Additionally, accountants increasingly store client data on third-party platforms without guarantees of confidentiality. National professional bodies have taken proactive steps by developing their own platforms or collaborating with secure providers to enforce strict data protection rules. The European Commission should establish core regulatory principles for these service providers, with tax advisers and accountants playing a key role in enforcement, ETAF said.
Beyond data confidentiality, another pressing issue is the risk of unauthorized accounting practices. Without proper oversight, uncontrolled data dematerialization could accelerate the "Uberization" of accounting services, weakening regulatory protections, ETAF warned.
