Key takeaways
- An invoice's evidential value does not rest on the medium: it rests on three guarantees the law requires from issue until the end of storage.
- Article 233 of Directive 2006/112/EC requires authenticity of origin, integrity of content and legibility, for paper and electronic invoices alike.
- The default method is the reliable audit trail: linking the invoice to the real supply or service.
- A structured invoice sent over Peppol delivers authenticity and integrity by design, with no technical handling on your part.
What the evidential value of an e-invoice really means
Moving to electronic invoicing quickly raises a fundamental question: does this file carry the same weight as a paper invoice in a tax audit? The answer lies in a precise notion, the evidential value of an e-invoice, meaning its ability to prove a transaction and a right to deduct VAT.
The key point is counter-intuitive: the law does not attach evidential value to the medium. A PDF is not "valid" and paper "safer". What the law requires is that three guarantees be ensured, whatever the form of the invoice. Those guarantees appear in Article 233 of Directive 2006/112/EC, in the version stemming from Directive 2010/45/EU, transposed into Belgian law in the VAT Code.
This article explains those three guarantees, the default method to hold them, and why a structured invoice sent over Peppol satisfies them more simply than a file emailed around.
The three guarantees that ground evidential value
Evidential value is not declared: it is demonstrated by three guarantees the invoice must meet, from issue until the end of the storage period. They apply in the same way to paper and to electronic form.
The three guarantees of Article 233
Authenticity of the origin
The assurance of the identity of the supplier or issuer of the invoice. It must be possible to establish who actually issued the document.
Integrity of the content
The content required by the rules has not been altered between issue and storage. No mandatory detail has been changed.
Legibility
The invoice remains readable by a person, on screen or on paper, throughout the storage period.
The three requirements are cumulative: an invoice that is perfectly legible but whose origin cannot be established does not meet the condition. That is why the question is never "is it a PDF or a structured file", but "are the three guarantees held, and how can you prove it".
Legibility deserves a note for structured formats. A UBL file is not meant to be read by the naked eye, but the guarantee is met as long as a human-readable display can be produced on request during storage. The details that must appear in it are set out in our article on the mandatory details of an invoice in Belgium.
The reliable audit trail: the default method
How do you hold those three guarantees in practice? The Directive leaves the choice of means to the business, but names a default method: any business controls that create a reliable audit trail between the invoice and the supply of goods or services.
In plain terms, it means being able to link each invoice to the real transaction it documents. The purchase order, the delivery note, the contract and the proof of payment together form a chain that shows the invoice matches an actual transaction and that its content has not been invented or altered. This organisational approach is open to every business, with no specific tool.
Structured invoicing and Peppol: evidential value by design
This is where the format and the network change things. An invoice emailed as a PDF forces the business to build the audit trail itself and document its controls. A structured invoice sent over Peppol brings authenticity and integrity through the very way it travels.
On the Peppol network, each party is uniquely identified, the document follows a standard profile (Peppol BIS Billing 3.0, built on EN 16931 and UBL 2.1) and its routing between access points is traced. The issuer is established, the content travels in a controlled form, and the exchange leaves a trail. The three guarantees no longer rest on an internal procedure to reconstruct after the fact: they follow from the transport itself.
| PDF by email | Structured invoice over Peppol | |
|---|---|---|
| Issuer reliably identified | To document | By design |
| Content integrity verifiable | To document | By format validation |
| Trace of the exchange | Email inbox | Routing between access points |
| Audit trail to build manually |
cumulative guarantees
authenticity, integrity, legibility
reference article
Directive 2006/112/EC
structured format
Peppol BIS Billing 3.0 profile
One caveat, though: evidential value does not stop at issue. The three guarantees must hold until the end of the storage period. Keeping the invoice in a form that preserves its integrity is therefore part of the demonstration, a point we cover in Archiving your electronic invoices.
Invoices whose evidential value is ensured
YouInv issues your invoices in a structured format, validates them and sends them over Peppol: authenticity, integrity and traceability are ensured by the flow.
What it changes for your business
Evidential value is not an obstacle to moving to electronic invoicing: it is a framework that already applies to your paper invoices. The real question is not "is the file valid", but "can I demonstrate the three guarantees, from issue until the end of storage".
On that ground, a structured flow sent over Peppol is stronger than a hand-emailed PDF, because it builds in the identification of the issuer, the checking of the format and the traceability of the exchange. The criterion to keep when choosing a tool is simple: does it produce invoices whose three guarantees are ensured with no manoeuvre on your part, and does it keep them in a state that preserves their integrity.
Further reading
- Mandatory details of an invoice in Belgium: the content whose integrity must be preserved.
- Archiving your electronic invoices: keeping the invoice without breaking the guarantees.
- How long to keep your invoices in Belgium: the period over which evidential value must hold.
The reference source is authoritative: Article 233 of Directive 2006/112/EC on EUR-Lex.
What is the evidential value of an e-invoice?
It is its ability to serve as proof, notably before the tax authority. The law does not attach it to the medium itself: it requires that three guarantees be ensured from issue until the end of storage, namely the authenticity of the origin, the integrity of the content and the legibility of the invoice.
What are the three guarantees required by law?
Article 233 of Directive 2006/112/EC requires the authenticity of the origin (assurance of the issuer's identity), the integrity of the content (the required details have not been altered) and legibility (the invoice remains readable by a person). All three apply to paper and electronic invoices alike.
Does a PDF invoice have evidential value?
Yes, provided the three guarantees are ensured. But a plain PDF does not guarantee them on its own: the business must put in place a reliable audit trail or a technology such as an electronic signature. A structured invoice sent over Peppol delivers those guarantees by design.
What is a reliable audit trail?
It is a set of business controls that links an invoice to the underlying supply: purchase order, delivery note, payment. Reconstructing that link shows that the invoice matches a real transaction and that its content has not been altered. It is the default method set out in the Directive.
Do you need an electronic signature for an invoice to be valid?
No. The advanced electronic signature and EDI are cited by the Directive as examples of possible technologies, not as a requirement. A reliable audit trail is enough on its own. On the Peppol network, authenticity and integrity follow from the structured, traced transport of the document.
