The EC Expert Group on e-Invoicing - and especially its corporate members worked hard on eliminating mandatory digital signatures. DG Taxud took the clear stand
that paper-, e-mail and electronic invoices should be equally treated from the VAT-point of view.
Still there are discussions that disregard this major simplification achievement - even if it is well known that a very small part of already massive volumes of e-invoices are not digitally signed - and if there would be a problem with this - commerce would
grind to a halt.
We consider it misleading to talk about original invoice, because it is not recognized by the VAT directive. Based on the feedback received from the commission there is no “original” e-invoice that both sender and receiver should store for
VAT auditing purposes. In fact both can store the e-invoice in any format they wish.
Supplier and buyer can independently of each other ensure the authenticity of the origin of the invoice.
Supplier and buyer can independently of each other choose the way in which they fulfill the obligation integrity of content and business process is sufficient for all sorts of invoices.
The requirement of integrity of content only applies to the mentions on the invoice required for VAT purposes and not to the whole content of the invoice.
The condition of legibility will be considered as being fulfilled if the invoice can be presented in a human readable form on screen or through printing after a conversion process
There is no opposition as to the content and Member States were invited in the VAT Committee to discuss any issues of content they may have. No Member State took up the offer.