The Digital Operational Resilience Act (DORA) sets uniform rules for digital resilience in the financial sector — what does this mean for e‑invoicing providers?
EU Regulation 2022/2554 entered into force on 17 January 2025. An IT provider can be critical for one client but not for another — the assessment lies with the financial institution itself.
DORA sets uniform rules for digital resilience in the financial sector. Financial entities must manage ICT risks and reflect specific obligations in contracts with their IT vendors.
DORA distinguishes between standard ICT services and services supporting critical or important functions: if the failure of a service would materially impair a firm's financial performance or regulatory compliance, it triggers additional contractual obligations.
Must be included in every contract between a financial firm and an IT provider:
Additional requirements when a service supports a critical or important function:
In the CAL&F case study, e-invoicing is generally seen as an ancillary process:
Does not directly affect lending or factoring
Can be temporarily replaced by paper invoices
Many alternative providers available
Many financial firms deem e-invoicing non-critical and apply only basic Article 30(2) requirements. However, the final classification always rests with the bank or factoring company.
If a service provider considers its service non-critical, it sends a negative declaration — a statement that:
Even if a function is deemed non-critical, the contract must include mandatory Article 30(2) elements:
Provider agrees to give access to data and liaise with supervisory authorities.
Provider helps investigate and resolve ICT incidents at no extra cost.
Rules for retrieving data upon contract termination or provider insolvency.
Provider takes part in client's training and testing activities.
Invoice-Portal's logs and data enable clients to meet their monitoring and reporting duties: every event is recorded, documents are preserved in original form, and reports can be produced on demand.
E-invoice decisions of the Ministry of Finance from 15/10/2024
/in eInvoice NewsInvoice transmission: The contracting parties must agree between themselves under civil law which permissible electronic invoice format and which permissible transmission channel is to be used.
Receipt channels: An e-mail inbox is sufficient for the legally compliant receipt of electronic invoices. Alternatively, interfaces or portals are also permitted.
In the long term, the transmission channels will be reviewed as part of the VIDA implementation, with more specific requirements being defined if necessary.
Sanctions: From the start of the obligation (2027 or 2028), ‘other invoices’ (e.g. paper or PDF) will no longer be eligible for input tax deduction. Additional penalties for refusing to accept an e-invoice are currently not envisaged. However, if the recipient refuses to accept the e-invoice even though the sender has demonstrably endeavoured to transmit it correctly, the recipient will be in default.
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