Comarch: EU Commission announces plans to revise e-invoicing rules for public procurement

Tackling market fragmentation

The Commission’s decision to re-examine the rules stems from recognized challenges that have hindered the original objectives of the Directive. Despite progress made, the current landscape is characterized by a lack of uniformity in invoicing rules, divergent national practices in terms of transmission and certification, and inconsistent adoption of the EU e-invoicing standard. These differences have created administrative hurdles and prevented the full realization of a single digital market.

Central elements of the proposed revision

• Introduction of an obligation for suppliers to issue e-invoices that fully comply with the European e-invoicing standard.
• Extending the Directive to B2G transactions below the current EU public procurement thresholds.
• Implementing common transmission methods based on the e-Delivery Building Block and uniform requirements for certification schemes.

Expected impact and methodology

The proposed changes can serve either as an alternative or as a complement. The Commission intends to use existing EU instruments to implement these changes in order to minimize costs and reduce the administrative burden. By consolidating e-invoicing solutions and standardizing formats, the revised framework is expected to:

• Improve interoperability across the EU
• Reduce compliance costs for businesses by simplifying technical complexity
• Streamline public procurement processes and lower barriers to market entry 

Timetable and next steps

The regulatory process is currently in the consultation phase. A call for comments was open until December 17, 2025.

After this first phase, the Commission will conduct a 12-week public consultation as well as targeted discussions with key stakeholders. Formal adoption of the revised rules is currently scheduled for Q4 2026.

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Further links

👉 www.comarch.de  

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