- is surprised and disappointed that no reference is made to a deadline for CEN to submit the proposed European standard for a semantic data model of the basic electronic invoice;
- expresses its concern that the proposed directive provides for a transposition period of 48 months;
- considers the deadline of ten years proposed for analysing the results of implementation of the Directive on the Internal Market and on the adoption of electronic invoicing to be inappropriate and quite inconsistent with the speed at which technological developments occur in a market where obsolescence is the norm;
- wonders whether all the work done, involving considerable investment in human and financial resources, would not justify the broader aim of a real standardisation of procedures and the universal acceptance by all stakeholders, both private and public, of the model that is developed for electronic invoicing;
- recommends safeguarding the interests of SMEs by adopting a solution that is affordable and easy for all users to take up, in terms of both cost and the technology used. This will be a genuine step towards eliminating existing barriers to SMEs' market participation;
- calls for the needs and interests of consumers to be taken into account, and
- reiterates its concern to safeguard the interests of people with disabilities.
Related EESC Opinions:
- e-Procurement (ongoing, INT/713)
- e-Procurement (CESE 1715/2012, INT/646)
- Electronic invoicing (CESE 1159/2011, INT/560)
- e-Procurement (CESE 1158/2011, INT/554)
- opinions on public procurement theme.