There is a lot of uncertainty regarding the digital Invoice (e-Invoice). In particular, if an attempt is made to meet the requirements for e-Invoice to the federal government with the general requirements for entrepreneurs to compare.

As a common starting point it can be stated that the e-Invoice of the paper invoice with the EU Directive 2010/45/EU has been placed on an equal footing.

It gets more difficult when it comes to the definition of a e-Invoice.

As an example: In the EU Directive 2010/45/EU under Article 217[1] “For the purposes of this Directive” the term “electronic invoice” means an invoice which contains the information required in accordance with information required by this Directive and is included in an electronic format is issued and received.” This definition of the EU guideline is very broad and thus leaves a pictorial PDF that is sent by email will, too.

Directive 2014/55/EU states: (7)3 The benefits of electronic Invoicing is maximized when the creation, dispatch, transmission, receipt and processing of an invoice in full can be automated. For this reason, only machine-readable Invoices that are processed automatically and digitally by the recipient apply that they are subject to the European standard for electronic invoicing. A mere image file should not be used as a electronic invoices within the meaning of this Directive.

In contrast, the Federal Gazette for the Republic of Austria vintage 2012 issued on 27 December 2012 505. Regulation: e-Accounting Ordinance Definition e-invoice . . . . . . . . . . . . . . . . . “An electronic invoice (e-invoice) is an invoice that is based on a structured electronic format issued, sent, received and processed.[2]

There is again agreement when it is the retention obligations authenticity and integrity of electronic invoices. “The The authenticity and integrity of electronic invoices can also be through the use of certain existing technologies, such as electronic data exchange (EDI) and advanced electronic signatures, Ensure. However, as there are other technologies, the taxpayers do not use a specific technology of the electronic invoicing.’ (11) 1

In addition, the European standard for electronic invoicing also for use in commercial transactions be suitable between companies. (22) [3]

In summary, in contrast to Germany, or Switzerland, it is permitted in Austria to invoice an invoice that is e-mail to keep it in accordance with the Federal Tax Order (BOA), by printing it and archiving it in paper form. If this is due to electronic means, the authenticity and integrity of the archiving period. The invoice itself on the receiving side or to use the EDI method are examples. As in the Directive 2010/45/EU, the taxpayer may be given a specific technology should not be prescribed.

That is why Difacturo has developed a technology that Requirements for authenticity and integrity of an encrypted document in the cloud, secured by a blockchain.

There are now many ways to invoice an e-ins Create. The work group AustriaPro of the Austrian Chamber of Commerce developed format ebInterface for e-calculations to the federal government, is one of them.

Since the retention requirements for invoices – eins are not exempted from this – are regulated in the BAO and EDI has a defined exception, it is still to be clarified how ebInteface (XML files) to prove authenticity and integrity.

In the Federal Gazette 516[4] the request for the electronic invoice is determined by:

  1. Internal control procedure – Audit trail
  2. Submission via company service portal or about PEPPOL (Pan-European Public Procurement OnLine)
  3. The invoice with a qualified electronic signature is provided
  4. Transmission of the invoice by electronic exchange of data (EDI) if the agreement on such data exchange the use of procedures that the authenticity of the origin and integrity of the data.

The problem is that the ebInterface can be interface from the system of the invoice sender to an interface of the recipient system can be sent or as an XML document, e.g. by email can be sent. The former is therefore covered by the definition of an EDI interface, see point 4 above. As a result, EDI Directive 94/820/EC [5] application and an agreement with each customer and supplier. or an inter-branch agreement is to be used. An XML document like any other invoice document, it is covered by the archiving obligations of the Bao.

The use of alternative formats, such as the one in Germany decided ZUGFeRD format (Central User Guide Forum electronic invoices Germany)[6] with the embedded XML (eXtensible Markup Language) according to CII (Cross Industry Invoice) the CE16391 standard of a structured electronic Bill.

The advantage is that the recipient of the e-invoice in the ZUGFeRD format receives a PDF/A3 and this is obtained by manual recording and or automatically with most accounting systems without can be done by hand.

For example, creating a ZUGFeRD e-calculation can by a virtual printer driver. Thus, all programs from Word, Excel, facuting or ERP systems can easily e-calculations Create.


[1] DIRECTIVE 2010/45/EU DES RATES of 13 July 2010 amending the Directive 2006/112/EC on the common VAT system with regard to the Invoicing rules

[2] FEDERAL GAZETTE FOR THE REPUBLIC OF AUSTRIA 505. Ordinance of the Federal Minister for finances on the submission of e-invoices to federal departments (e-invoice regulation)

[3] DIRECTIVE 2014/55/EU OF THE EUROPEAN PARLIAMENT AND THE RATES of 16 April 2014 on electronic invoicing in public contracts

[4] FEDERAL LEGISLATIVE GAZETTE FOR THE REPUBLIC OF AUSTRIA 516. Ordinance of the Federal Minister for Finance to amend the Ordinance requirements for an invoice transmitted electronically. Be

[5] Commission Recommendation 94/820/EC on the legal aspects of the electronic data exchange

[6] https://www.ferd-net.de/zugferd/definition/ferd.html