Procurement Policy Note 03/19: The Public Procurement (Electronic Invoices etc.) Regulations · first published 20 May 2019
This Procurement Policy Note (PPN) 03/19 explains that the UK government has brought into law the EU Directive on electronic invoicing in public procurement via The Public Procurement (Electronic Invoices etc.) Regulations 2019. Contracting authorities — including central government buyers and utilities — are now legally required to receive and process supplier invoices that comply with a specific technical e-invoicing standard. For small businesses, this is potentially good news: buyers cannot refuse a compliant electronic invoice. However, the obligation sits with the buyer to accept e-invoices, not with suppliers to send them — so switching to e-invoicing is an option, not a legal requirement, for SMEs (small and medium-sized enterprises). The document is brief and the full PDF has not been reviewed, so some detail may be missing.
WHO THIS APPLIES TO
THE ENKII VIEW
The key opportunity here is for SMEs to move to electronic invoicing knowing that in-scope public buyers are legally obliged to accept compliant e-invoices — removing a historic barrier where buyers could simply refuse non-paper formats. SMEs that adopt e-invoicing aligned to the standard may benefit from faster processing and payment, which helps cash flow. The document does not confirm a supplier-side mandate, so small firms are not at risk of non-compliance by continuing to send paper invoices for now.
1. Check whether your invoicing software can produce e-invoices that comply with the technical standard referenced in the Regulations (the European standard EN 16931). If it can, consider switching to e-invoicing for public-sector customers — buyers are now legally obliged to accept compliant e-invoices.
All SMEs supplying public-sector contracts — Contracting authorities 'are now required to receive and process supplier invoices that comply with the technical e-invoicing standard developed under the Directive,' so a compliant e-invoice cannot be refused.
2. Raise e-invoicing with your public-sector buyer as a route to faster invoice processing. Reference the Regulations to confirm the buyer's legal obligation to accept compliant electronic invoices.
SMEs experiencing slow payment from public-sector buyers — The buyer's legal duty to receive and process compliant e-invoices removes the option to reject them on format grounds, potentially accelerating the payment cycle.
3. Review the full PDF of PPN 03/19 on GOV.UK to check for any specific timelines, technical implementation details or transition arrangements not captured in the summary reviewed here.
All SMEs supplying public-sector contracts — This brief is based on the GOV.UK summary only — the full document may contain deadlines or technical requirements relevant to suppliers.
Every rule below quotes the official document verbatim.
Contracting authorities and utilities are legally required to receive and process supplier invoices that comply with the new technical e-invoicing standard. (All contracting authorities and contracting entities (utilities) in public procurement, from enactment of The Public Procurement (Electronic Invoices etc.) Regulations 2019.)
“Contracting authorities and other contracting entities (utilities) are now required to receive and process supplier invoices that comply with the technical e-invoicing standard developed under the Directive.”
The Regulations implement the EU Directive on electronic invoicing in public procurement into UK law. (All public procurement within scope of the Regulations.)
“Government has implemented The EU Directive on electronic invoicing in public procurement through The Public Procurement (Electronic Invoices etc.) Regulations 2019.”
This briefing is enkii's interpretation of the official document — the official text always governs.
Source document © Crown copyright, reused under the Open Government Licence v3.0 via the GOV.UK Content API. enkii tracks every Procurement Policy Note and briefs changes the day they land — see all briefings.