Choosing a PEPPOL e-invoicing partner

The key to how the PEPPOL e-invoicing network operates is the Access Point providers. Specifically, those that have been accredited by MBIE (Ministry of Business, Innovation and Employment NZ) and ATO (Australia Tax Office) to provide the proverbial doorways in and out of the network in these two countries. While your accounting software may be ‘PEPPOL ready’ or ‘e-invoicing compatible’ in the sense that the required formats and integrations are built-in, without an Access Point service the e-invoices won’t actually be sent or received. Think of it like getting on the internet. You may own a computer and router, but without an ISP account you won’t actually get online.  

As more companies gain MBIE / ATO accreditation to provide PEPPOL Access Point services and the network continues to grow, it’s important to understand that not all services are created equally. While on paper each vendor will ultimately achieve a similar end result which is that of providing access to the PEPPOL network, the process matters as much as the result.

To help you navigate the process of finding a PEPPOL partner, here are a few questions you should be asking.  

Are you an accredited provider in this region?

The keyword in that question is “accredited” as there is a common misconception between certification and accreditation. Certification is something achieved as a result of OpenPEPPOL membership. Accreditation is awarded by a regional authority after a rigorous process that verifies capability and security compliance.  

There are some linguistic liberties being employed by some who are quite accurately claiming to be a Certified Provider and are using the below image, however that doesn’t mean they are accredited to provide services in Australia and New Zealand.

This only means that they are a member of OpenPEPPOL (more about that soon). It does not mean they have passed the accreditation process administered by ATO or MBIE. The accreditation process covers several elements such as CyberSecurity, local presence / acceptance of local jurisdiction, the ability to process local invoices, a requirement to engage with local govt & coordinate with other local providers.

At the time of writing this article, there are 9 accredited commercial Access Point providers on the ATO list in Australia and 6 on the MBIE list in NZ. If they aren’t on the accreditation list for the country you are based in, then they shouldn’t be providing Access Point services in NZ and AUS. While from a technical perspective it is possible to use an Access Point service from another region, that loophole is expected to close in the immediate future which could leave you needing a new partner.

(The NZ accredited supplier list maintained by MBIE is here - https://www.nzbn.govt.nz/assets/e-invoicing/new-zealand-accredited-peppol-service-providers-final.xlsx and the ATO list is here - https://www.ato.gov.au/Business/E-invoicing/In-detail/E-invoicing-accredited-provider-list/)

There are other companies that are part way through completing their accreditation process, however until they are on the MBIE / ATO lists they shouldn’t be providing Access Point services to NZ or Australian customers.

Who maintains the OpenPEPPOL membership?

OpenPEPPOL is a non-profit international association based in Europe that governs the development and maintenance of the PEPPOL e-invoicing standards. One of the prerequisites of accreditation is that the provider is a member of OpenPEPPOL. This membership means they have agreed to be bound by the rules and regulations related to those standards. It isn’t immediately clear when reading the OpenPEPPOL website, but membership is not the same as being an AP provider (Service Provider in OpenPeppol terms). There are also Peppol Authority members and End User members. The latter being much cheaper, and appropriate for someone who wants to participate in OpenPeppol but not run their own service. To be able to provide Access Point services you must be a Certified AP as well as a member and this is where some vendors are muddying the waters.

In most cases there will be no need for an end-user customer to be an OpenPEPPOL Service Provider as that burden is borne by the accredited Access Point provider you are partnering with. However there are some providers that are trying to shift their obligations to OpenPEPPOL on to the end customer by making this one of their subscription requirements. OpenPEPPOL membership isn’t free and has both a signup cost as well as annual subscription costs. Aside from the monetary costs, forcing OpenPEPPOL membership on clients allows the provider to shift technical and legal obligations to the client and absolve themselves of some responsibilities.  

If you are an ERP vendor or an Accounts Payable / Receivable solution provider there are some legitimate scenarios in which having an OpenPEPPOL subscription is an essential requirement. For example, if you are looking to completely white label an Access Point as a Service to then on-sell to your clients. But generally speaking, if the PEPPOL partner you are considering requires you to have an OpenPEPPOL membership, the alarm bells should be ringing and you should be certain about exactly what you are signing up for.

Do you have experience?

The process of becoming an accredited access point provider is one based largely around demonstrating technical capability and security compliance. It’s not surprising then that there are several providers who have achieved accreditation, but who have yet to make their solution work in a commercial model that can scale with the demand. In short, they are allowed to provide a solution, but don’t yet have one that works.

Some of the warning signs that could suggest inexperience include delays in sending test invoices and a heavy reliance on SFTP and email for invoice ingestion and distribution. If your potential partner is asking you to ‘register an expression of interest’, this could possibly mean that they haven’t actually built their commercial solution.

How does your ‘free’ service work and is it on the PEPPOL network?

For companies with extremely low volume sending requirements, there are vendors who offer a free service. This is often based around an online portal where the user generates a normal invoice and then has to enter the invoice data into online fields manually. While this may be workable for 1 or 2 invoices per month, if the volume of e-invoices you are sending grows then this process will become very time-consuming. These free services can be a fantastic starting point that can enable you to get started immediately, however they ought to be positioned as a short term solution. Scalability, integration methods and pricing at higher volumes should still remain factors in which free service you opt to use as undoubtedly your volumes will change as more of your trading partners get connected.  

Also, just because a subscription says “e-invoicing”, that doesn’t mean its e-invoicing via the PEPPOL network. Some companies have a proprietary e-invoicing format that allows all the customers on their platform to transact with each other. If it doesn’t say PEPPOL then it could be a proprietary process and might not be what you need.

Who handles the data transformation?

The format used for sending e-invoices across the network is UBL which is a fairly complex XML format. This format is not a standard output across ERPs and Accounting Software in the region, and getting the information between your system and the PEPPOL network is going to require some data transformation. Some providers make this easy by providing APIs to work with and map the data. Some providers do it manually by taking the existing output from your system and massaging it into the right format so it can be processed in batches. Yet still others will push that problem back onto the customer to figure out and demand a correctly generated UBL.

For many customers, creating PEPPOL compliant UBL is well beyond their technical capability to achieve. Make sure you check out exactly what the ‘Free Implementation’ or ‘no setup costs’ means. Are they committed to helping you with free professional services efforts, or are they expecting you to do all the work and come back to them when you have your UBL ready? One easy way to do this is to ask if they have a free developer sandbox that can be used to verify the requirements of your project before you incur any costs.

Can I keep my existing systems?

Very few of the Access Point providers trade exclusively in Peppol services. Most have added this functionality to the existing solutions they provide. While they can absolutely enable PEPPOL e-invoicing for their own solutions, they may not be as motivated to work with new clients that aren’t also interested in changing to their platforms.

For example, an ERP vendor may become an Access Point provider and offer that service to their customers, however their interest lies in selling their ERP platform and is likely not in enabling competitive platforms. Similarly, some of the accredited vendors provide complementary solutions such as Accounts Payable workflow platforms. It's best to ask upfront whether they will be helping connect your existing systems or whether they expect you to change your platforms to their solution.

If I’m using you for sending, can I use someone else for receiving? 

Each entity can only register to receive e-invoices from one access point at a time. So if you are signing up to send PEPPOL e-invoices now, it pays to ask what options you have should you want to receive them down the track. For example, if you are trading with an Australian government agency then your main concern right now might just be about sending e-invoices to get 5-day payment terms. However, the subscription you have with your chosen partner may also register you to their access point for future receiving. If your preferred partner sells either an Accounts Payable or Accounts Receivable solution, you may need to check to see if they can also provide the other solution as well.  

These are just some of the many questions companies need to start becoming familiar with when investigating potential PEPPOL partners. If you have other questions then please feel free to get in touch with me as I’d be happy to provide the answers.

Kris Elliott

Sales Manager – AUS/NZ