GENA contributed to the European Commission’s Single Market Strategy 2025 consultation and fully supports the goal of strengthening the Single Market by enabling seamless cross-border services and goods movement. Our key message is that achieving this requires the adoption of harmonized digital trade processes, particularly in e-invoicing and related digital documentation like procurement, payment and finance.

The VAT in the Digital Age (ViDA) initiative marks a significant step towards a more integrated digital trade ecosystem but further measures are necessary to overcome existing barriers. This is why GENA proposed a set of recommendations :

GENA’s Key Recommendations :

• GENA advocates for the Decentralized 5-Corner Model (DCTCE) as a flexible and balanced solution accommodating both public and private sector needs. This model builds on existing technologies while remaining adaptable to evolving requirements. Additionally, it promotes interoperability by leveraging internationally recognized standards such as Peppol.
• To tackle the issue of fragmentation linked to national standards, which complicates e-invoicing and e-reporting, and increased compliance burdens, GENA recommends the standardization of invoice status reporting requirements across all EU Member States and the harmonization of e-invoice distribution mechanisms to ensure seamless cross-border transactions.
• We believe that a centralized European business directory would function as a digital “telephone book,” allowing businesses to identify and connect with trading partners efficiently. This would increase trust within the single market. Successful national models in Finland and Sweden could serve as blueprints for implementation.
• To enhance trust and compliance, GENA proposes an EU-wide certification framework for e-invoicing service providers. This framework would standardize provider requirements across all Member States, improve security and reliability in e-invoicing transactions, and lower entry barriers for businesses operating in multiple jurisdictions.
• Seamless connectivity within the Single Market requires mandatory roaming between certified service providers. This approach would enable businesses to reach all trading partners via a single provider, reduce artificial barriers that add costs and complexity, and support regulatory objectives through standardized compliance rules.
• GENA recommends implementing a European cloud security standard, such as EUCS+, and prohibiting national cloud preferences that hinder market integration. For example, France’s upcoming e-invoicing regulation mandates that registered platforms’ data centers comply with the French SecNumCloud standard, effectively restricting service providers to domestic hosting solutions—contradicting the principles of the Single Market.

GENA Response to the Call for Evidence