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Letter to Santa Claus



Dear Santa,

We have been really nice, technology-neutral and hardworking Experts this year and look forward to You bringing us a few presents to play around with in 2009.

The first wish is a book - more precisely a handbook. We namely wrote a letter to the EU Commission in July and asked for Equal Treatment of paper and e-invoicing (from VAT-angle) and a bit to our surprise - but certainly to our joy - we did get it. Now it is naturally up to all the member states to join in with transposition. We do feel that You can help the local VAT authoritaties to do it and us Experts with wise guidance so that our Code of Practice in the coming EEI-recommendation (kind of a handbook) will describe how enterprises real easily can move to e-invoicing and not loose sleep over fear of not getting VAT refunds. We may have some challenges in passing the SME-test when we depict how they can make Tax Authorities and others happy by either reassuringly describing business processes or use a range of tools to store and protect their financial data. You may have heard about digital signatures - it is one of those tools.

The second wish is a standard - more precisely a common and global standard that will fulfill both the needs of SMEs (being easy to use) and their frequently very large and sometimes bully trading partners who have a need for lots and lots of data elements. Santa's helpers in UNCEFACT's TBGs have been working hard on CII2.0 but we have not yet seen the full results and are a little anxious. We do realize that we have a pile of standards already, but this one we would really promise to use especially in relation SME-traffic and between service providers.

The third wish is good will - more precisely to service providers - so that there will be lots of them (also banks - despite them having hard times now) - and that they will form networks and provide the interoperability with help of reformatting and verification services. This to make sure that our vision - that one contract is enough for sending to and receiving e-invoices from everyone - will become real.

The fourth wish is bravery - more precisely to invoice receivers - so that more of them will join the rapidly growing elite who have declared e-invoicing mandatory (in markets where service providers have ramped up their tools and networks) and charge transparently for more expensive paper or invoices otherwise in unstructured form.

We have heard from your native country Finland, that it was easy to get most of the enterprises to sign up for e-invoicing - but that the steep rise in usage did not start to happen until recently - much aided by aforementioned actions by progressive invoice receivers. You can always make it clear that there will not be any presents to those in finance departments who resort to change resistance.

We really look forward to your presents - not so much for ourselves really - but for our brothers and sisters in European enterprises who have to fight so hard for their daily bread these days.

Many thanks in advance.

Bo Harald

On behalf of the EU Expert Group on E-invoicing


You are of course not yourself, due to the nature of your activities, sending any invoices. You do not receive any invoices either - we are sure - as your business case would then appear challenging. But as paper invoices have no future anywhere there is a good chance that the supply of wrapping paper can be further improved.


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