Compulsory e-invoicing in the public sector

On 1 April 2019, all purchases within the public sector are required by law to be electronically invoiced (e-invoicing) according to a new European standard.

This means that all suppliers to the public sector must send e-invoices that comply with the new standard, and all public sector organisations must be able to receive these invoices. We recommend that all public organisations and suppliers start preparing for meeting the requirements of the new law.

The requirement to send and receive e-invoices applies to all public procurements starting after 1 April 2019, including direct procurements. Public procurements commencing before this date are not retroactively affected by the law. If the parties have agreed on an e-invoicing standard other than the European standard, the supplier may continue sending invoices according to the agreed standard.

How can suppliers to the public sector prepare themselves?

All suppliers to the public sector must provide e-invoices according to the new European standard, unless you have agreed on another standard. PDF invoices or scanned paper invoices are not considered to be e-invoices. A company which, after repeated reminders, still does not send invoices that meet the requirements of the new law may be fined.

In Sweden, the standard which meets the new law’s requirements is known as PEPPOL BIS Billing 3 ( and is recommended by SFTI (Single Face To Industry). If you already use Svefaktura BIS 5A 2.0, the switch to PEPPOL BIS Billing 3 is fairly minor. The PEPPOL network is prepared for the new e-invoice format.

First, you need to do the following:

  • Be prepared for procurement requirements which include e-invoicing and the relevant invoicing standard when answering tenders.
  • Ask your accounting system or invoicing system provider if they can send e-invoices in the PEPPOL network according to the BIS Billing 3 standard.
  • Ask your public sector customers if they have an invoicing portal, which is an alternative way of meeting the law’s requirements as long as you only send a few invoices to the public sector.

Frequently asked questions

The Act (2018:1277) regarding e-invoicing in public procurement applies to all invoices that a supplier issues as a result of a public procurement (including direct procurements) pursuant to the following acts:

  • The Defence and Security Procurement Act (2011:1029) (LUFS)
  • The Public Procurement Act (2016:1145) (LOU)
  • The Act (2016:1146) on Procurement in the Water, Energy, Transport and Postal Services Sectors (LUF)
  • The Act (2016:1147) on Procurement of Concessions (LUK).

The e-invoicing act is based on the procurement legislation (see above). DIGG does not assess individual cases. The government agency or unit must determine if the transaction is subject to the e-invoicing act.

Yes. All suppliers of goods and services are affected by the new legislation.

According to the Ordinance (2003:770) on government agencies’ electronic information exchange, government agencies shall provide an invoicing portal for suppliers who do not have their own invoicing solution.

When it comes to the rest of the public sector, such as municipalities and county councils, there is no requirement to provide invoicing portals, although it is recommended.

DIGG recommends that the entire public sector provide supplier portals for those suppliers who do not have their own invoicing solution. The reason for this is to make it easier to comply with the legislation for suppliers that only occasionally invoice public sector organisations.

No. The PEPPOL network has many advantages by being a stable and modern infrastructure that offers a complete solution for e-invoicing and e-commerce. It is also designed to make it easy to connect new suppliers, which results in low operating costs.

However, it would be going too far to require all suppliers to be connected to PEPPOL. All public purchasers thus need to be able to handle several channels of receiving invoices.

A large part of the public sector is expected to be connected to PEPPOL by 1 November 2019. Most suppliers are thus also expected to switch to PEPPOL. Almost all operator services that carry e-invoices in the Swedish market are already connected to PEPPOL.

In some rare cases, the public sector will have to pay for establishing supplier connections to other channels of communication. Depending on what agreements you have with your e-commerce service or operator service, this may entail some minor costs.

The European standard describes the business terms in an e-invoice, such as invoice number and the buyer and seller’s information. The European standard allows for two XML formats when exchanging information: UBL (Universal Business Language) and CII (Cross Industry Invoice).

Procuring organisations must be able to receive both formats while suppliers can choose to use one of them, with UBL being by far the most common. In PEPPOL, the European standard is referred to as PEPPOL BIS Billing 3 ( An easy way for procuring organisations to comply with the legislation is to register as invoice recipients in PEPPOL.

No, not for procurements that start after 1 April 2019. However, suppliers can continue to send invoices in your agreed format within previously existing agreements.

If you have functioning invoice flows for formats such as Svefaktura 1.0, Svefaktura BIS 5A 2.0 or SFTI Fulltextfaktura 2.3 and 2.4, you can continue to agree on these formats after 1 April 2019.

DIGG and SFTI recommend primarily using PEPPOL BIS Billing 3 (UBL) to comply with the European standard.

Before the e-invoice is sent to the recipient, it must be converted and validated so that the sender knows that the e-invoice matches the new European standard.

The new European standard must be complied with when sending and receiving the invoice. Before sending or after receiving the invoice, the organisations can use whatever format they like. The organisation is also responsible for ensuring that all original electronic invoices sent and received can be traced and that the information in the invoice is correct after any conversions.

Yes, you must be able to do this after 1 April 2019. DIGG recommends that actors in the Swedish public sector ensure that their e-commerce service or equivalent IT support can handle the CII format by 1 April 2019. This means that you are ready to accept such a request from your supplier.

Very few suppliers are currently using CII. The requirement has been included as certain special interest groups in the European standardisation work have argued to include the format.

Due to the limited use, it is neither necessary nor suitable to register in advance as a CII recipient in PEPPOL. Before registering, you should contact the supplier in question. CII is not as established in Europe as the UBL format, and there is less extensive technical support for it. It might therefore be a good idea when first registering for CII to test that the system really works.

No, you do not. The requirement to handle CII only applies when receiving invoices from suppliers after 1 April 2019.