The target for the EU Commission is to cut the costs of SMEs caused by complicating legislation with 25% before 2012. As SMEs generate 60- 70% of all turnover in EU, this is the obvious thing to do to improve competitiveness.
The most important productivity area to address is now fast and easy migration from inefficient and sometimes insecure paper and e-mail and this is also where administrative burdens should be lowered - not increased. DG Taxud has launched a VAT-directive aiming at just that. The EU Expert Group on e-Invoicing is naturally asking for and supporting the equal treatment of paper and e-invoicing and other simplifying harmonization suggested.
But the debate goes on - authenticity and integrity has been lifted up to a mystic level - and few legislators or even business organization representatives seem to have the guts to say that they do not really understand what this is all about - even if the emperor looks quite naked.
The only way to solve this is to think small. Take the case of a micro-enterprise receiving most invoices in paper envelopes, some from other SMEs in e-mail and increasingly being asked by his possible accounting service and invoicing partners to accept real e-invoices (in structured form) to automate accounting and procurement processes. How can he say that he is receiving authentic invoices and integral invoices to VAT auditors? Well, by checking that it corresponds to the order he made - on the phone maybe - and that it seems to come from the right sender and then pay it to agreed account.
Should there be any additional mandatory regulation if the invoice is electronic? Certainly not - rather the other way around - especially when invoices arrive through managed networks and directly to the e-banking service. And the same goes when asked to send e-invoices. It is close to absurd try to cut burdens for SMEs and at the same time make it mandatory for them to digitally sign e-invoices.
The simple fact is that transport is irrelevant and that the same simple technology neutral procedures should apply for all invoices sent, received, paid and filed. Anything else will subsidize the least cost efficient and least secure old way.
If integrity and authenticity is difficult to understand - think small - then it is easy. Legislators in fact have the this duty - to understand the effects on SMEs - before legislating.