Transposition of the EU Electronic Invoicing Directive SPPN 3/2019

This note is to alert stakeholders to the Public Contracts (Scotland) Amendment Regulations 2019 which come into force 18 April 2019.

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Please note: this policy note was written at a time when Scottish procurement was subject to the EU legal framework. Some references may no longer be valid, caution should be exercised if you come across one of these references. Content should be cross-referenced with SPPNs which address questions and issues related to exit from the EU legal framework. It should also be read after taking note of the introduction on the SPPN index page.


1. The purpose of this Scottish Procurement Policy Note (SPPN) is to alert stakeholders to the Public Contracts (Scotland) Amendment Regulations 2019 which come into force on 18 April 2019.

Key messages

2. This instrument is required following the publication of EU Directive 2014/55/EU on electronic invoicing in public procurement on 16 April 2014 and is being implemented through amendment to the Public Contracts (Scotland) Regulations 2015, the Utilities Contracts (Scotland) Regulations 2016 and the Concession Contracts (Scotland) Regulations 2016 .


3. The change applies to contracts that are regulated by the European Public Procurement Regulations that are advertised in the Official Journal of the European Communities (OJEU).

4. The Scottish Statutory Instrument (SSI) has been signed and approved by Parliament and the Regulations will come into force on 18 April 2019.

Specific actions required by purchasing bodies

5. The EU Directive 2014/55/EU requires public contracting authorities to automatically receive and process electronic invoices from their suppliers.

6. Central contracting authorities (that are named in schedule 1 of the Public Contracts (Scotland) Regulations 2015) must comply with the Directive no later than 18 April 2019. All other contracting authorities may have a further twelve months to comply with the Directive (no later than 18 April 2020).


Please bring this SPPN to the attention of all relevant staff (particularly, those with  purchasing and financial roles), including those in Agencies, Non-Departmental Public Bodies and other sponsored public bodies within your area of responsibility.


If you have any questions about this SPPN, please contact

Scottish Procurement
The Scottish Government
5 Atlantic Quay
150 Broomielaw
G2 8LU

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