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European Union – COVID-19: invoices sent via pdf with electronic signature are VAT compliant

During the COVID-19 crisis, employees are being asked in many countries to work from home. That would mean that paper invoices can not longer be processed as the invoices are mailed to the address of a company while employees dealing with these invoices are not at the office. To avoid invoices are getting booked, paid and reported for VAT purposes, it may be interesting to consider the issuance of invoices in pdf format with an electronic signature and sent them via e-mail to your customers. This should avoid any late reporting and payment of invoices.

The applicable article in the VAT Directive 2006/112/EC is art. 233, 2.

Article 233


  • The authenticity of the origin, the integrity of the content and the legibility of an invoice, whether on paper or in electronic form, shall be ensured from the point in time of issue until the end of the period for storage of the invoice.
  • Each taxable person shall determine the way to ensure the authenticity of the origin, the integrity of the content and the legibility of the invoice. This may be achieved by any business controls which create a reliable audit trail between an invoice and a supply of goods or services.
  • “Authenticity of the origin” means the assurance of the identity of the supplier or the issuer of the invoice.
  • “Integrity of the content” means that the content required according to this Directive has not been altered.


  • (a) Other than by way of the type of business controls described in paragraph 1, the following are examples of technologies that ensure the authenticity of the origin and the integrity of the content of an electronic invoice: (a) an advanced electronic signature within the meaning of point (2) of Article 2 of Directive 1999/93/EC of the European Parliament and of the Council of 13
    December 1999 on a Community framework for electronic signatures, based on a qualified certificate and created by a secure signature creation device, within the meaning of points (6) and (10) of Article 2 of Directive 1999/93/EC;
  • (b) Electronic data interchange (EDI), as defined in Article 2 of Annex 1 to Commission Recommendation 1994/820/EC of 19 October 1994 relating to the legal aspects of electronic data interchange, where the agreement relating to the exchange provides for the use of procedures guaranteeing the authenticity of the origin and integrity of the data.