Regulatory updates - Singapore

Following the announcement of the Singapore GST InvoiceNow Requirement, the IMDA released the PINT updates and outlined the implementation timelines at the Peppol access point meeting in July.

Starting 1 April 2025, it is mandatory for all InvoiceNow network participants within the Peppol framework to at least have the registration for the PINT SG capability to receive invoices. On the other hand, service providers must support sending and receiving PINT SG, including invoices and credit notes, beginning January 2025.

Peppol specifications update in May 2024

New Element:

• Added UUID field to capture the document identifier when creating the tax invoice and credit note

New Business Rules:

• Added new GST rule to ensure the UUID information is available in the tax invoice and credit note
• Added GST rules to ensure the supplier and customer postal address information (address line 1 and postal code) is available in the tax invoice and credit note
• Added new GST code to handle different GST scenarios.

Peppol specifications upcoming update in November 2024

New Business Rules

• Add GST rules to ensure the supplier UEN information is available in the tax invoice and credit note
• Add GST rules to ensure the supplier and customer meet the tax credit note requirements (Note field and Preceding invoice field)

The IMDA has released the InvoiceNow Technical Requirements (version 1.1), which includes technical guidance and the invoice data submission process flow required for suppliers and buyers.

The Inland Revenue Authority of Singapore (IRAS) API is estimated to be released in September.

Singapore has implemented InvoiceNow to encourage businesses to issue and receive invoices via Peppol electronically. Peppol has been a default invoice exchange mechanism for B2G transactions. Now, one more document type is supported by the Singapore public entities.

The Invoice Response document is accessible now for e-invoices sent to AGD’s Peppol ID. B2G suppliers registered with the Invoice Response document can receive real-time invoice status updates via their accredited service provider, eliminating the manual work of monitoring e-invoice status on the Vendors@Gov portal.

Additionally, if e-invoices are not successfully delivered to the government’s systems, businesses will promptly receive an email notification within 3 working days.

Pagero is an accredited service provider in Singapore and has fully supported the Invoice Response document.

Both countries showed previous commitment to Peppol and now want to collaborate on initiatives to promote supportive infrastructure and raise awareness of the benefits of e-invoicing amongst the business community.

Read more about the MoA here.

On 14 April 2024, the Inland Revenue Authority of Singapore (IRAS) and Infocomm Media Development Authority (IMDA, also Singapore Peppol Authority) announced plans for a phased adoption of B2B e-invoices through InvoiceNow (“GST InvoiceNow Requirement”) at the InvoiceNow Industry Day event.

GST InvoiceNow Requirement

InvoiceNow is a nationwide e-invoicing network established based on the Peppol network introduced by IMDA in 2019, and it has become the default format for submitting B2G invoices.

GST InvoiceNow Requirement will leverage the Peppol 5-corner model (Peppol CTC) to enhance the current 4-corner model to connect to the tax authorities. Taxpayers will be able to transmit invoice data to IRAS through an accredited service provider. When businesses exchange e-invoices in PINT SG format with their trading parties via the InvoiceNow network, an invoice copy will be delivered to IRAS.  

IMDA will publish the list of InvoiceNow solutions that connect to IRAS by May 2025.

Implementation Timelines

The GST InvoiceNow Requirement will be adopted as follows:

• 1 May 2025: Soft launch. GST-registered businesses can voluntarily adopt GST InvoiceNow Requirement;
• 1 November 2025: Newly incorporated companies[1]that voluntarily register for GST;
• 1 April 2026: All new voluntary GST-registered, regardless of incorporation date.

Scope of the GST InvoiceNow Requirement

According to the announcement, GST taxpayers will be required to use InvoiceNow solutions to transmit invoice data to IRAS for tax administration, including the following transactions:

• Standard-rated supplies, excluding reverse charge supplies;
• Zero-rated supplies;
• Standard-rated purchases on which input tax claims are made or will be made, excluding reverse charge purchases;
• Point-of-sales supplies: businesses can choose to submit aggregated data to IRAS.

The businesses below are exempted from the GST InvoiceNow Requirement:

• Overseas entities (including overseas vendors that are registered under the Overseas Vendor Registration regime);
• Businesses registered under the Reverse Charge Regime.

GST InvoiceNow Requirement aligns with global trends, with governments worldwide actively promoting the implementation of e-invoicing for tax administration. IMDA and IRAS are reviewing the market demands for further support and measures to ease tax compliance and will provide more details later.

Businesses can already issue and receive e-invoices via the Peppol network in Singapore. Pagero has been IMDA accredited as both an Access Point Provider and Peppol-Ready Solution Provider to provide e-invoice services.

[1] These are companies that are incorporated within 6 months from the time they submit their application for GST registration.

Pagero Online has renewed its Peppol-Ready accreditation, meeting the below mandatory criteria:

• Register the business user on the Singapore Service Metadata Publisher (SMP);
• Send e-invoices on the Peppol network;
• Receive e-invoices on the Peppol network and display them correctly;
• Capture and maintain the Peppol IDs of your users’ business partners (i.e. customers and/or suppliers).

In addition to meeting mandatory criteria, Pagero's solution has also fulfilled preferred criteria that will become mandatory as of 1 April 2024:

• Receiving order on the InvoiceNow network;
• Converting an incoming order from the InvoiceNow network into an invoice;
• Sending invoice response on the InvoiceNow network;
• Receiving invoice response on the InvoiceNow network.

Pagero's Peppol-ready status, valid from 28 November 2023 to 28 November 2024, is listed on IMDA’s website as a Peppol-Ready Solution Provider.

The Peppol PINT-SG BIS Billing general data model's first version introduces features distinct from SG BIS Billing 3.0.

What are the new features?

The following features have been introduced:

• cbc:IssueTime - An optional element designed to capture the issued time;
• cac:InvoiceLine / cac:OrderLineReference / cac:OrderReference / cbc:ID - Enables referencing multiple PO numbers to the item line.

Implementation schedule of the PINT and PINT-SG upgrade

• July 2023: Phase In
• February 2024: Solution Uplift
• January 2025: Switch Over
• March to July 2025: Phase Out

Together with the implementation timelines, the following detailed schedule is provided.

2024 - PINT preferred

• Between February and October: all AP are mandated to upgrade to support PINT (two-way);
• Between February and December: all SPs and Companies will be updated to support PINT (two-way);
• PINT receiving capability update begins as each connection is upgraded with bulk upgrades for solution providers;
• Domestic PINT transaction can optionally begin if agreed between parties.

2025 - PINT mandatory

• Between January and March 2025: All parties should begin sending PINT as default, alternatively BIS 3.0 format;
• From March 2025, SG BIS 3.0 will begin to be removed from the network.

The Singaporean Peppol Authority IMDA has plans to migrate from the current Peppol BIS specifications to the PINT SG specifications. This will be accomplished in a phased-out approach, with the technical specifications planned to be released by the end of February 2024.

The key milestones of the migration plans are as follows:

Uplift Phase (1 March 2024 to 31 December 2024)

• C2/C3 must be ready to send and receive PINT SG with wildcard capabilities by 30 September 2024;
• All Peppol Authority Specific Requirements (PRSPs) to support PINT SG and PINT (C1/C4) by 3 December 2024;
• Registration of SG BIS 3.0 receiving capability continues to be mandatory during this period;
• All businesses to support PINT-SG and PINT receiving capabilities by 31 Dec 24;
• All C1 will use SG BIS 3.0, unless pre-agreed between the sending and receiving parties.

Switch Over Phase (1 January 2025 to 31 March 2025)

• Registration for SG BIS 3.0 will be removed from the SGNIC-SMP;
• Registration of PINT-SG receiving capability will be mandatory.

Phase Out (1 April 25 to 30 May 2025)

• All SG BIS 3.0 participant receiving capabilities will be removed from the SGNIC-SMP
• C1/C4 and PRSPs to remove systems' handling of SG BIS 3.0 (encouraged but optional)

It is worth mentioning that Peppol PINT is not a specification but rather a new approach to designing specifications. The core idea of the PINT design is to enable interoperability between related specifications out of the box, while affording flexibility to support the unique requirements of a jurisdiction or industry.

Stay tuned with Pagero, as we closely monitor the regulatory developments in Singapore.

The Infocomm Media Development Authority (IMDA) is the Peppol Authority in Singapore. As a Peppol Authority, they control the registration of Peppol IDs for businesses and organizations. Furthermore, IMDA maintains the centralized Service Metadata Publisher (SMP) in which Peppol IDs are published.

It is mandatory for Peppol Service Providers who wish to provide Access Point services in Singapore to comply with the Peppol Authority Specific Requirements (PASR).

What has changed in the new PASR version?

On 28 September 2023, IMDA submitted a revised version of the PASR to the Managing Committee for approval. The review period finishes on 20 October 2023, and once approved, the new PASR will be included in the Peppol Interoperability Framework.

Section 6, “Use of local interoperability specifications”, was the only section that underwent amendments and is now subject to review.

The existing formulation sounds as follows:

Service Providers shall comply with the Singapore Peppol BIS specifications at www.peppolguide.sg, which apply when offering services to End Users residing in Singapore.

The statement is proposed to be replaced with the following text:

The business documents below are mandatory to be supported by Service Providers accredited by the Singapore Peppol Authority:

1. SG Peppol BIS Billing 3.0 Invoice
2. SG Peppol BIS Billing 3.0 Credit Note
3. Peppol BIS Invoice Response 3
4. Peppol BIS Order Only 3

The business documents below are mandatory to be registered by Service Providers for End Users who are receivers residing in Singapore:

1. SG Peppol BIS Billing 3.0 Invoice

Specifications and guidance for SG business documents are on www.peppolguide.sg.

Expressing opinion on other PASR aspects

For comments on other parts of the PASR of Singapore, a Request for Comments (RFC) must be submitted by the Peppol Authorities and Service Providers through the service desk.

Parties with comments must use the comment template and send it to [email protected]. All comments submitted in the review period will be processed and made available to the Peppol Authority of Singapore and the Managing Committee.

For a more seamless and convenient taxpaying experience, Inland Revenue Authority of Singapore (IRAS) together the Infocomm Media Development Authority (IMDA) and other relevant stakeholders have concluded to implement Peppol CTC framework for a more efficient provision of GST data to IRAS.

In Singapore, Peppol is known under the name InvoiceNow. As the first step, it is planned to become the default e-invoice submission channel for all Government vendors within the next few years, to increase the usage and its network effect. In parallel, IRAS will continue working with IMDA, the Accountant-General's Department and businesses to increase the adoption of InvoiceNow for GST administration.

The Singaporean government has now announced plans to establish InvoiceNow as the sole means of issuing electronic invoices with all vendors providing goods and services to public sector recipients. InvoiceNow would effectively replace the vendors@gov portal over the next few years, further requiring solution providers to equip capabilities for issuing invoices via the new obligatory method.

The Accountant-General’s Department has already made clear that InvoiceNow is the preferred channel for e-invoice submission, but looking to the future, acknowledges that there are aspects to be introduced to optimize its use further.

The recognition of the importance of adapting invoice responses and purchase orders is also addressed by the initiative to promote InvoiceNow. For solution providers, it is recommended that the minimum capabilities be enabled:

*M – Mandatory, R – Recommended

While the timelines for complete conversion to InvoiceNow are not finalized, IMDA and AGD strongly recommend that entities acknowledge the upcoming changes' notifications. Stay tuned with Pagero as we monitor the upcoming timelines.