If launching e-Invoicing today:

1. The SME-sector’s organizations were not involved strongly enough in the beginning.  They should have been co-owners of the productivity issue with e-invoicing and thus taking responsibility to tell enterprises that it is not only cost-saving in the core invoicing and payment process  – but an innovation platform that leads to:

- real-time view of financials with automated accounting and cash flow estimates

- automated VAT-reporting

- better cash flow based on faster payments and higher invoicing frequency

- lower credit risk based on faster payments and higher invoicing frequency

- automated invoice financing (and cheaper with supplier finance)

On this basis it would have been possible to more powerfully drive home the “Paper and e-mail invoices have no future”- mindset earlier.

Recommendation: communicate the no-future and “CUT50”-like targets and engage SME-organizations as co-owners

2. Cost-cutting aspect dwarfed other - even more important aspects -  like:

- sending and receiving e-invoices is better service for customers and suppliers alike

-  liberating back office staff for customer service (not just firing), selling and production – more interesting, productive and often better paid jobs

- CO2-reduction can be 300g per invoice (all included)

- cutting fraud risks and tax evasion (VATgap in EU 118,7 bn in 2009… our money..)

Recommendation: communicate the target beyond cutting costs – especially need to internally mobilize workforce

3. Only deadlines make it happen. General statements favoring e-invoices and carrots were not sufficient – the SMEs have so many issues to attend that migration is postponed without clear deadlines from buyers.

Recommendation: wide and early issuance of published early deadlines (all sectors – but especially public) stressing that individual exceptions can be granted for limited periods (for SMEs or their accounting service not using Internet or being in middle of upgrading invoicing applications)

4. Municipal sector was patchy (still is) – even if all have invested in receiving e-invoices they were too slow to issue deadlines for paper (not taking responsibility for tax payer’s money and pushing local enterprises into better competitiveness). Deadlines were sometimes delayed as they wanted to create ability to send first.

Recommendation: Stress need to save tax payer’s money also in municipalities and their responsibility to drive local enterprises into better productivity via e-invoicing. Deadlines for incoming paper should not be coupled to ability to send e-invoices as this takes more time.

5. The Finvoice standard was not implemented strictly enough > some interoperability challenges.

Recommendation: Use ISO20022 – both strict and equipped with clear and fast maintenance process

6. Separate bank network supporting only Finvoice. Work needed to get non-banks and banks to interoperate – worsened by lack of rulebook.

Recommendation: All service providers living up to strict customer identification, have recovery capability and support national standards should be allowed to join the network (and be shut out if rule book is not followed). The 3-corner model is anti-competitive (monopoly in relation to suppliers) and should not be allowed.

7. Too radical attempt to eliminate use of attachments in Finvoice standard. Corporate and public sector processes were not ready to integrate the attachments into the invoice.  

Recommendation: Deploy standard that supports attachments – still working on eliminating the need.

8. Buyer-specific portals deployed despite rapid signing up of 200 000 enterprises by generic portal service providers (banks doing most of it). This development may be needed in some cases as an interim solution – but is quite obviously not good for suppliers who have to use different tools with different partners. This can also tie suppliers to buyers and lead to anti-competitive situations. 

Recommendation: E-invoicing should work “just like payments” – sign up for generic service and send to all/receive from all without need for additional contracts or service charges from other end of chain.

9. Scanning invoices delayed migration to e-invoicing for no good reason. Pressing send is as easy as pressing print in most cases and scanning loses much of the data and has many quality problems.

Recommendation: No scanning – especially not in public sector. Where already in place a plan for stopping it is needed.

10. Late and patchy transparent pricing for paper invoices. Invoice senders were late (in Finland – faster in other Nordic countries) to start charging (visibly – customers pay all costs anyway) for sending paper invoices. Consumer organizations even tried to stop it – which leads to protection of unnecessary and hidden costs – instead of protecting consumers. 

Recommendation: Drive open and logical pricing – in the best interest of customers.

11. The Single European Payment Area implemented harmonized payments first and moved to promoting e-invoicing later – despite our protests. As e-invoices automatically lead to IS20022 credit payments (SEPA) it would have been much easier and natural to implement PAN-EU e-invoicing first.

Recommendation: Pay attention to plug-in provided from e-invoice to payment in ISO20022

12. International aspects did not get enough attention early on. From a legal and tax point of view 95% of invoices are national -  but from an operational point of view especially in large and export/import oriented most and sometimes all invoices are sent cross-border from service centers. This has accentuated the need for the global ISO-e-invoicing standard and connectivity (which it also furthers) – especially as it automatically produces the ISO-payments.

13. Accounting profession should have been involved from the very beginning as so much of the process improvements can take place in their area of expertise. Once involved they produced several innovative ideas.

Recommendation: involve all central players in multi-stake-holder forum