KPMG Australia (KPMG) welcomed the opportunity to make a submission to the Department of Treasury’s consultation on ‘Supporting business adoption of electronic invoicing’. We commended and supported the government’s continued agenda to increase business activity and efficiency, while cutting red tape and administrative burdens. This included, importantly, embracing digital technology that achieves these objectives and makes Australia a global leader in the digital economy.

We agreed that eInvoicing is an important digital development and ought to be implemented when possible and where it makes sense to do so. This should be undertaken consistently within and outside government. Given that collective experiences in implementing and utilising the technology are still maturing, there is an opportunity for partnership across the economy to exchange lessons learnt as we grow into using eInvoicing together.

KPMG’s response to this consultation was developed with this spirit of partnership in mind. As such, we considered that a Business eInvoicing Right and its associated protocols is neither necessary nor the most efficient tool to encourage business to take-up eInvoicing. Additionally, we considered that the timelines for implementation, as proposed, are insufficient to account for the complexities inherent to large businesses transforming, for example, their payment processing systems.

We noted that while many large businesses, such as KPMG, are already working to implement eInvoicing, there are many that have not started the often lengthy and costly journey, including due to the COVID-19 pandemic. The Commonwealth Government itself, as one of the first movers in this space which we commended, has yet to fully implement eInvoicing and share valuable lessons learnt.

Government can, and certainly is, playing a leadership role in this space and we recommended that the mandatory requirements on business be considered at a later date once systems are more mature. Alternatively, the timelines for mandatory implementation should be a minimum of five years to allow businesses and government to not only implement the systems required, but also become familiar with how they work in practice so that take-up is consistent and systems are interoperable.

We encouraged the Department of Treasury to share its lessons learnt and continue to seek out industry’s views, including KPMG’s, on this issue.

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