The European Standard EN 16931 for e-invoicing
is a completely technology-neutral standard, see:
E-invoicing services implemented according to EN 16931
can therefore be based on various alternative techniques.
In Sweden, The Swedish Agency for Digital Government (DIGG, www.digg.se)
was tasked in 2018 with being responsible for electronic transactions linked to
e-invoices and connection to the European infrastructure for electronic procurement,
according to Regulation SFS 2018:1486.
On 1 July 2026, DIGG's tasks within e-commerce and Peppol were transferred to
The Swedish Public Procurement Authority (UHM, www.upphandlingsmyndigheten.se).
After taking over responsibility,
UHM has chosen to publish word-for-word the same information
that DIGG published on its website, in its other channels and in
its own government documents, namely a number of untrue and
completely incorrect claims that PDF-based e-invoices do not comply
with the European standard EN 16931 for e-invoicing, such as:
"Is PDF an e-invoice?
No, a PDF invoice is not an e-invoice.
According to the regulations of Ordinance (2003:770)
on electronic information exchange by government authorities
an e-invoice is an invoice that is issued, sent and received in
a structured electronic format which makes it possible to
process it automatically and electronically.
A PDF invoice does not meet these requirements and thus
cannot be counted as an e-invoice according to
the e-invoice act."
For more details see:
The Public Procurement Authority's (formerly DIGG's)
categorical claim that an e-invoice based on PDF technology
does not meet these requirements is not consistent with reality!
An incorrect claim that negatively damages confidence
in the Authority's expertise in the field of e-invoicing as well
as other stakeholders' (businesses, the general public, etc.)
acceptance of e-invoicing in Sweden, EU and elsewhere.
The fact is that since many years PDF sub-standards:
- ISO Standard 19005-3:2012 ("PDF/A-3"), and
- ISO Standard 19005-4:2020 ("PDF/A-4f")
- in combination with XML format attachments
offer precisely the basic features and functionality that are
in demand to enable e-invoicing according to EN 16931.
e-Invoices, based on PDF/A-3 or PDF/A-4f with XML attachments,
so called "Hybrid invoices", such as ZUGFeRD (Germany) / Factur-X (France),
can be created/issued, transmitted and received in a
structured electronic format that can be processed
automatically and electronically and they thereby comply
with the European Standard EN 16931.
Both ZUGFeRD and Factur-X are generally suitable formats
for electronic information exchange of e-invoices.
Other EU countries fully accept these characteristics and now
implements PDF-based e-invoicing according to EN 16931
between public administration, companies/suppliers
and consumers.
In addition,
e-invoicing according to the technology prescribed by
UHM (earlier DIGG) for e-invoicing, Peppol, is expressly
intended only for e-invoicing from/between authorities,
companies and other businesses.
Peppol is not designed/intended for e-invoicing
towards private consumers.
Therefore, a human-oriented e-invoice representation is a
absolute prerequisite for a successful implementation
in Sweden of The EU's Accessibility Directive 2025.
Individuals/consumers will then also need to be able to
receive, read and manage incoming e-invoices from
authorities, companies and other businesses.
PDF-based e-invoices
(based on PDF/A-3 or PDF/A-4f with XML attachment)
is the technical solution that already today ensures and
enables exactly this for individuals/consumers.
The Public Procurement Authority needs to correct
its information on e-invoices based on PDF technology
UHM's (earlier DIGG's) unsubstantiated claims stand in stark contrast to facts:
PDF-based e-invoices based on PDF/A and XML technology
are approved in i.a. Germany and France thanks to the fact
that they de facto fully meets the requirements of being
"structured electronic format" which can be
"processed automatically and electronically"
in accordance with the European standard EN 16931.
It is obvious that UHM (earlier DIGG) hasn't even bothered to closer
find out what requirements modern PDF technology meets.
Instead, they have based their claim solely on their own ignorance.
We demand a credible answer from
The Swedish Public Procurement Authority (UHM)
to the following question:
Unfortunately, UHM's untrue claims have influenced other
public authorities and actors to uncritically republish the same
false statements on their websites and in social channels.
As the Swedish expert authority for e-invoicing,
UHM (earlier DIGG) knows of course very well
the fact that EN 16931 is completely technology neutral.
It does not advocate or recommend any particular
underlying technology for e-invoicing, it only requires that
the selected e-invoicing function/service meets EN 16931.
"The Swedish Act (2018:1277) on Electronic Invoices as a
Result of Public Procurement" (the so-called e-Invoice Act),
which applies since 1 April 2019, is likewise technology-neutral:
- "2 § - Electronic invoices refer to invoices that are issued,
transmitted and received in a structured electronic format
which makes it possible to process them automatically."
Our comment on 2 §:
2 § - The requirement is met by PDF-based e-invoices
using the same modern PDF and XML technologies applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France);
they meet these requirements and thus the requirements of
EN 16931.
- "4 § - The invoices that a supplier issues to a
contracting authority or unit must be electronic invoices
that comply with the European standard for electronic invoicing
as the European Commission has referred to in
the Official Journal of the European Union.
Notwithstanding the first paragraph,
the supplier and the procurer or unit receive the authority
to enter into an agreement that another standard for
electronic invoicing shall be used."
Our comment on 4 §:
4 § - Clarifies that the chosen technology for e-invoicing
must comply with EN 16931.
The requirement is met by PDF-based e-invoices
using the same modern PDF and XML technologies applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France);
they meet these requirements and thus the requirements
of EN 16931.
Also allows authority and supplier the right to use
another standard and technology for e-invoicing
(than the one recommended by UHM, earlier DIGG).
Does not mention anything that a PDF-based e-invoice
cannot fulfill the requirements for e-invoicing according
to EN 16931 (which UHM, earlier DIGG claims)
- "5 § - Procuring authorities and units are obliged to
receive and process invoices that comply with
the European standard for electronic invoicing."
Our comment on 5 §:
5 § - Clarifies that the chosen technology for e-invoicing
must comply with EN 16931.
The requirement is met by PDF-based e-invoices
using the same modern PDF and XML technologies applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France);
they meet these requirements and thus the requirements
of EN 16931.
According to 5 §,
procuring authorities and units are expressly obliged
to also receive e-invoices that are implemented with
other alternative technology; such as PDF-based e-invoices
made with the same modern PDF and XML technology applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France),
as long as these comply with EN 16931.
- "6 § - The government or the authority that
the government decides may issue regulations on
structured electronic formats and other forms of
electronic transmission of invoices."
Our comment on 6 §:
6 § - The government has designated
The Swedish Public Procurement Authority (UHM),
(earlier The Agency for Digital Government, DIGG),
to promote the electronic procurement process within
the public administration.
As part of its mission, UHM (earlier DIGG) has issued
regulations on handling of orders and standards when
electronic information exchange (DIGG MDFFS 2021:1).
DIGG MDFFS 2021:1, Definitions 4 §,
refers to 2 § of the e-Invoice Act (above).
Clarifies that the chosen technology for e-invoicing
must comply with EN 16931.
The requirement is met by PDF-based e-invoicing
using the same modern PDF and XML technologies applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France);
they meet these requirements and thus the requirements
of EN 16931.
- "7 § - The authority that the government appoints
(earlier DIGG, now UHM) may decide to instruct a supplier
to ensure that the invoices which the supplier issues and
which is covered by the regulations in this law conforms to
the European standar for electronic invoicing."
Our comment on 7 §:
7 § - Clarifies that the supplier for e-invoicing
must comply with EN 16931.
The requirement is met if the supplier issues PDF-based e-invoices
using the same modern PDF and XML technologies applied for
ZUGFeRD e-invoice (Germany) and Factur-X e-invoice (France);
they meet these requirements and thus the requirements
of EN 16931.
UHM has not been mandated by the government to prevent
a supplier that in its business activities with Swedish authorities
use alternative technology for e-invoicing.
Thus, the supplier is free to issue PDF-based e-invoices
that comply with the European standard for
electronic invoicing - EN 16931.
Thus, the published, untrue and baseless, claim by UHM (earlier DIGG)
that e-invoicing cannot be based on PDF technology falls completely.
UHM's (earlier DIGG's) favoring of certain specific technology
for e-invoicing according to EN 16931 and the spreading of
misinformation must stop!
UHM (earlier DIGG) is of course welcome to question both
the PDF technology or other technology,
but it is not professional to, as appointed expert authority,
and year after year, do so with completely untrue claims,
that PDF-based e-invoices do not comply with the requirement
to constitute a structured electronic format.
UHM (earlier DIGG) may have other preferences and may have
been the driving force and actor in the choice of technology,
the so called "The Peppol Infrastructure", for the technical
implemention of e-invoicing between authorities in Sweden.
However, we would like to remind UHM at this point that
the European Standard EN 16931 for e-invoicing
is a completely technology-neutral standard.
That The Swedish Public Procurement Authority,
as Swedish Authority, then takes to prescribe with
which specific technique some electronic services
shall be realized with is completely unique!
It is misleading and not very serious.
This is not how The Swedish Public Procurement Authority,
in its role as the Swedish expert authority for e-invoicing,
shall act, if The Swedish Public Procurement Authority
wants to be a credible expert authority!
Already today, Swedish suppliers to authorities within the EU
can use e-invoicing based on modern hybrid invoices
(PDF/A and XML technology) in fully compliance with
the European standard for electronic invoicing - EN 16931.
The cooperation within the EU aims to remove barriers to trade
in goods/services and transactions across national borders.
Sweden cannot, probably, therefore unilaterally block suppliers in
other countries to use PDF-based e-invoicing to Swedish authorities
as long as it complies with it the European standard for
electronic invoicing - EN 16931.
It's time for The Swedish Public Procurement Authority,
along with other responsible actors in Sweden, to wake up now!
Update yourself on how modern PDF and XML technologies solve
digital challenges within the EU and in the rest of the world.
Learn and accept the facts about the technical features in
the PDF document format, with substandards, and the XML format,
as well as the ability of these formats to together comply with
EN 16931 for e-invoicing!
Request
We request that
The Swedish Public Procurement Authority immediately:
- Approve and publicly publish that all e-invoicing carried out
according to the European standard EN 16931 for e-invoicing
between authorities, companies/suppliers and other businesses
is accepted as recognized and approved e-invoicing formats in Sweden.
- The approval also applies to so-called hybrid invoices
based on PDF and XML technology
(such as PDF/A-3 and/or PDF/A-4f with XML attachment)
which fully meet the requirements of EN 16931.
- Hybrid invoices, based on PDF and XML technology,
are already approved by other EU countries (Germany, France,..)
as well as by the Swedish Tax Agency.
- Act in a technology-neutral manner and
cease to favor some specific technique (Peppol)
for e-invoicing between public administration,
companies/suppliers and other businesses in Sweden.
- The European standard, EN 16931, for e-invoicing between
public administration, companies/suppliers and
other businesses is technology-neutral.
- The regulation that only Peppol infrastructure must be used
for e-invoicing between public administration
is not technology-neutral.
This regulation has to be corrected.
- Corrects the following incorrect statements that
PDF-based e-invoicing does not meet the requirements of
the European standard for e-invoicing EN 16931
from its websites, other channels, and in related
government documents such as regulations and ordinances:
- "No, a PDF invoice is not an e-invoice."
- "PDF invoice does not meet these (EN 16931) requirements
and therefore cannot be counted as an e-invoice
according to the e-invoice act."
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