Electronic transmission of invoices

Taxation authorities recognise an electronic invoice as complying with the VAT Directive, where the invoice is furnished with an electronic signature that is based on a certificate able to be verified by the signature verification service operated by RTR or by an equivalent verification process.

This specifically means that such an advanced electronic signature has to meet these requirements:

• it has been exclusively assigned to the signatory;
• it allows the signatory to be identified;
• it has been created by means solely under the control of the signatory;
• any modification of the data signed with the advanced signature can be identified.

Several providers issue certificates for advanced electronic signatures. On condition that such certificates are suitable for use with electronic invoices, they are integrated in RTR’s signature verification service at the provider’s request. In some cases, a certificate is offered as part of a complete electronic invoicing package.

If automatic invoicing, including activation of the signature function, is needed, the qualified electronic signature is not a suitable option as this requires entry of a PIN code. Signing a defined number of previously generated invoices with qualified electronic signatures simultaneously by entering just one PIN code is, however, permitted.

In all cases, qualified certificates can only be issued to natural persons. It is nonetheless permissible to use a pseudonym in the certificate; yet, particularly with a qualified certificate, care needs to be taken to avoid any risk of confusing the pseudonym with names or trademarks.

In accordance with the requirements set forth in EU Directives 2001/115/EC, 2006/112/EC, 2010/45/EU and 2014/55/EU, it is necessary to ensure the authenticity of the origin and the integrity of the contents of invoices transmitted by electronic means. This can be achieved in numerous Member States of the European Union through the use of electronic signatures. Related information is available on the European Commission website.

In the case of invoices, the authenticity of the origin and the integrity of the contents are primarily significant in relation to VAT deduction. Consequently, where VAT need not be indicated on an invoice, that invoice also does not require an electronic signature.

Which solution is appropriate for a particular company depends on how frequently electronic invoicing is used. With a limited number of invoices, it may well suffice to create the invoices as PDF files, assigning each an advanced or qualified electronic signature (refer to Applications) and sending it to the recipient by e-mail.

Theoretically it would suffice to send the invoices as electronically signed e-mails in S/MIME format. However, such e-mails would need to be archived in such a way as to allow the electronic signatures to be verified during the entire seven-year retention period required by law. It is presumably easier to archive electronically signed PDF files than electronically signed e-mails.

The expense entailed in such a solution is, in the least expensive case, limited to the certificate and the personnel expenses for installing the system. No general estimate of costs can be made though, as these largely depend on system complexity and the billing model applied in the particular case.

Apart from PDF, ebInterface, the Austrian XML standard for invoices, could be considered here. The standard is supported by numerous partner companies specialised in implementation.

As of 1 January 2014, invoices issued to public administration have to be submitted electronically. This is done via the e-government application E-RECHNUNG.GV.AT, which can be reached only through the Business Service Portal (USP) and requires registration in USP (details can be viewed at Business Service Portal).

Additional information can be viewed by following these links:

• eb Interface website
  
• List of partners implementing eb Interface
• E-RECHNUNG.GV.AT