External accounting and authorizations

How can a client and an external accountant work with e-invoice?

Short answer

The law does not require the client and external accountant to use the same delivery-service provider. Where the chosen solution supports it, the client may grant the accountant controlled access to the application. Other options include export or integration with the accounting system. Access rights, revocation and activity auditing are product and contractual settings; they do not automatically transfer the client’s responsibility for tax and archiving obligations.

Law

The same postman is not mandatory

The regulation specifies the obligations and the delivery service, not the common supplier of the software for the client and the accountant.

Access

Only if the system supports it

The financial report allows the granting of access to the accountant; however, specific roles are determined by the product.

Alternative

Export or integration

XML can be transferred to accounting via secure export, API or link according to the solution.

Control

The client remains responsible

Delegation of work does not automatically change the legal obligations of the payer or recipient.

As confirmed by the Financial Administration

The Financial Administration’s FAQ states that a user may work via the provider’s accounting software, web application or mobile app, and may grant an accountant access to the application. However, it does not stipulate that an accountancy firm and all its clients must use the same provider.

Three permissible operating models

Delegated access: the client invites the accountant into their solution and sets appropriate permissions for them.
Integration: the provider or ERP system transfers documents directly to the accounting system.
Controlled export: The client or accountant exports the original XML and the necessary related data.

What needs to be agreed

who receives and monitors new documents,
who is authorised to issue or send an invoice,
who deals with errors and undelivered messages,
who is responsible for archiving the XML files,
how access is revoked once the collaboration ends,
whether the system maintains an audit trail of user actions.

Conclusion

Using one provider may simplify the workflow but does not guarantee a shared inbox; access rights, integration and contractual responsibility remain decisive.

Legal and technical basis

Financial Administration FAQ, Example No. 14
Section 76a of the VAT Act
Section 85o(9), (10) and (15) on reporting and archiving