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Solution · Other solutionsEvery regulated euro classified, evidenced and totalled the day it is recorded
FCPA, Sunshine Act and VAT evidence collected continuously
Expense lines, invoices and event costs are classified against the rule set your compliance and tax teams own, tagged per recipient and filed with their evidence as they arrive.
Executive summary
Four annual deadlines, one dataset, and none of it rebuilt from sixty spreadsheets.
We move the checks to the point of capture and let the evidence accumulate as a by-product.
The annual disclosure becomes a report from a continuously tagged dataset, so the spring spreadsheet request stops.
the SharePoint evidence archive under Microsoft Purview retention; the transfer-of-value ledger in UiPath Data Fabric; Power BI
Business problem
Compliance
Regulated spend is recorded by people who are not thinking about regulation. A representative books a dinner and types the attendees as names. Whether those names are healthcare professionals, whether the amount per head passes the country's cap, whether the institution is a public body, is decided later, if at all.
Invoices behave the same way. Congress sponsorships, speaker fees and consultancy agreements sit in accounts payable with a cost centre and no recipient tagging. Foreign VAT is recoverable only with a compliant invoice in the right entity's name inside a fixed deadline, and the invoice is checked when the claim is prepared, months after the hotel stopped answering.
Each obligation asks for evidence in a different shape: an industry disclosure code, national transparency law, the parent's reporting, anti-bribery review, controls testing. Four deadlines, four assemblies, one dataset nobody maintains for the purpose. The reason this persists is timing: data is captured for reimbursement and payment, and compliance arrives afterwards with a request, at the moment when the attendee is a hazy memory and the correction window has closed.
How it works today
- PersonA representative submits an expense with attendees typed as free text
- SystemThe manager approves on amount, and the expense audit checks the receipt
- SystemA sponsorship, speaker fee or consultancy invoice is posted in accounts payable to a cost centre, untagged
- WaitingMonths later compliance asks every affiliate for the reporting year's transfers of value
- PersonField and finance rebuild the answer from memory and exports; compliance matches names to the register
- Risk of errorTax reviews hotel invoices for entity name and VAT details close to the refund deadline, and some suppliers no longer answer
- PersonThe disclosure is filed; months later the anti-bribery review samples the same data again
- Risk of errorAuditors ask for the evidence behind both, and it exists only as spreadsheets in mailboxes
Why the current process costs more than it appears
The bill that never reaches the budget.
- Reconstruction consumes weeks of compliance, finance and field time every year and produces a report resting on sixty memories, a strange foundation for a document the company signs.
- Foreign VAT is cash, not paperwork. Every hotel invoice in the wrong entity's name is a refund nobody will claim, and the loss repeats at every congress because nothing upstream changed.
- Caps are breached by people who did not know the cap existed and noticed by people whose job it is to notice. The first is a slip; the second is a reported item.
- Evidence living in spreadsheets fails the test it is meant to pass. Controls testing asks for the item, the rule applied, the decision and the date, in a place with retention.
Cost of inaction
Deadlines are what make this feel manageable. Each one arrives, each one is met, and the cost of meeting it is recorded nowhere, so the method is never questioned. Meanwhile the reconstruction grows with every affiliate, congress and new code, and the VAT leaks quietly: a refund nobody claimed never appears as a loss.
The exposure that does not fit the table is the asymmetric one. An unrecorded hospitality involving an official is a small item until it becomes the item an investigation is built around. We will not put a number on that, and nobody honest should; the point of the rows above is that the ordinary, countable case already carries the cost.
A plausible organisation with realistic proportions. The figures are there to be recalculated on your data; they are not a client result.
A pharmaceutical group with nine European affiliates and a listed US parent; about 1,200 field and medical staff, expenses in SAP Concur, invoices and speaker fees in SAP S/4HANA.
Roughly 18,000 expense lines a month, of which about 13%, or 2,340 lines, involve healthcare professionals or institutions. Foreign VAT on travel and events runs at about €300,000 a year.
Each affiliate reconstructs its disclosure once a year over several weeks. Recipients are matched to the register by hand, hotel invoices are checked when the claim is prepared, and VAT recovery is estimated at under a third of what is reclaimable.
Every check happens at a deadline instead of at the transaction. Six minutes of review per regulated line, applied months late, cannot recover an attendee's status or a supplier's willingness to reissue.
A robot picks up expense lines, invoices and event costs daily, Document Understanding reads them at line level, and a rule set owned by compliance and tax classifies recipient, category, cap and VAT recoverability. Clean items are tagged, totalled per recipient and filed with their evidence; everything else becomes a task in Microsoft Teams while the correction is still possible.
In the modelled case, review capacity of about €97,344 a year is released, 1,080 hours of annual reconstruction stop and €120,000 of foreign VAT becomes recoverable: roughly €273,000 a year. These are figures from a model on stated assumptions, not measurements.
Proposed solution
We move the checks to the point of capture and let the evidence accumulate as a by-product. A robot picks up expense lines, invoices and event costs daily, and UiPath Document Understanding reads them at line level, attendees included where itemised. None of this replaces judgement; it removes the reading and typing around it.
The rule set is the heart of it, and it belongs to your compliance and tax functions rather than to us. It classifies each item: the recipient matched against the register and official list you subscribe to, the country cap per head, the category, and VAT recoverability with the invoice checked for legal entity, address and VAT number. We build the rules, the matching and the checks; compliance owns the parameters and can show a version history when asked what applied last March. Personal data about recipients stays in one governed place instead of moving through mailboxes.
Items that pass are tagged, added to the recipient's running total and filed. The rest become tasks in Microsoft Teams for whoever can still fix them: the representative confirms attendees the day after the dinner, the supplier is asked for a corrected invoice while it still answers, and compliance sees anything near a cap or involving an official. The decision is filed with the item, so reasoning and evidence stay together in a SharePoint archive under the retention your regimes require. Transfers of value accumulate per recipient in a UiPath Data Fabric ledger, which is what turns a disclosure into a report. Power BI shows exposure by affiliate, recipient and rule, and VAT incurred, claimed and lost by country.
UiPath Document Understanding pre-trained Receipts and Invoices models with Validation Station; UiPath Data Fabric entities with audit; UiPath Action Center tasks completed in Microsoft Teams; SharePoint metadata with Microsoft Purview retention and sensitivity labels; UiPath Orchestrator schedules, assets and credential store
The country rule set with its caps and categories; recipient matching against your registers; the VAT-recoverability checks on invoice fields; the correction tasks and their routing; the transfer-of-value ledger; disclosure, anti-bribery and VAT report formats; the Power BI exposure view
SAP Concur expense lines and attendees through its connector; SAP S/4HANA invoices through BAPI and OData; register and official-list lookups through UiPath Integration Service Connector Builder where no connector exists; supplier correction requests through the Microsoft Outlook 365 connector
How the automated process works
- AutomationA robot picks up expense lines, accounts payable invoices and event costs every day
- AutomationDocument Understanding reads receipts and invoices at line level, attendees included where itemised
- SystemThe rule set classifies each item: recipient type against the register and official list, cap per head, category, and VAT recoverability with entity, address and VAT number checked
- AutomationItems that pass are tagged, added to the recipient's total in the ledger and filed in the SharePoint archive with their retention label
- PersonItems that fail or are ambiguous become Teams tasks for the representative, the supplier contact or compliance, depending on the gap
- AutomationThe decision is filed alongside the item, so evidence and reasoning stay together
- AutomationDisclosure extracts, anti-bribery views and VAT claim files come out of the archive on request instead of being assembled
Human-in-the-loop model
Automation handles
- Reading receipts and invoices at line level, with attendees where itemised
- Matching recipients against the registers and official lists you subscribe to
- Applying caps, categories and VAT recoverability per country, and asking for corrections while items are fresh
- Filing evidence with retention, accumulating transfers of value per recipient and producing reports
People decide
- Whether an ambiguous recipient is a healthcare professional, an official or neither
- How an event is classified, and whether a near-cap item is acceptable
- The rules and registers, which compliance maintains as codes and laws change
- Sign-off of every disclosure and VAT claim before it leaves the company
Before and after
Systems and integrations
The stack is deliberately short: one engine, one execution layer, one place where a person decides.
Inputs
- SAP Concur expense lines and attendees
- SAP S/4HANA invoices, cost centres and legal entities
- congress cost files
- the registers and official lists you subscribe to
Automation layer
- UiPath Orchestrator
- UiPath Robots
- UiPath Document Understanding
- UiPath Integration Service
- UiPath Action Center
Target systems
- the SharePoint evidence archive under Microsoft Purview retention
- the transfer-of-value ledger in UiPath Data Fabric
- Power BI
Human touchpoints: correction and decision tasks in Microsoft Teams; supplier correction requests by e‑mail; compliance sign-off on disclosures and claims
Technologies used
reads receipts and invoices at line level; Validation Station below the confidence threshold
Adaily pick-up and rule execution; schedules, assets, credential store, audit trail
Aexpense lines with attendees, AP invoices, supplier requests, register lookups where no connector exists
Acorrection and decision tasks for representatives, suppliers and compliance
Athe transfer-of-value ledger: recipient, category, amount, cap status, evidence link, with audit
Athe evidence archive, its metadata, sensitivity labels and the retention each regime needs
Aexposure by affiliate, recipient and rule; foreign VAT incurred, claimed and lost by country
Aour build, owned and versioned by your compliance and tax functions
CIllustrative economic model
Numbers you can check against your own data.
The volume in the calculator is a released equivalent rather than a count of lines, and it is worth saying why. 18,000 expense lines a month, of which 13% touch a healthcare professional or institution, give 2,340 regulated lines at six minutes of review each today. In the target state a quarter of them, 585 lines, still need a human decision at eight minutes each, so 156 hours a month are released; at six minutes per line that is a volume of 1,560. €52 an hour is a fully loaded compliance and finance cost. Two further pools sit outside the calculator and inside section 14: 1,080 hours a year of reconstruction across nine affiliates, and €120,000 a year of foreign VAT. Nothing below was measured at a client.
Run the numbers on your data
An illustrative estimate from your own inputs. It models released capacity; it is not a promise of savings.
Business benefits
- The annual disclosure becomes a report from a continuously tagged dataset, so the spring spreadsheet request stops
- Foreign VAT is recovered because invoices are checked for entity and VAT details on arrival, while suppliers still reissue them
- Cap breaches and hospitality involving officials surface before reimbursement, not a year later in somebody's sample
- Every item carries its rule, decision and date in an archive with retention, which is the shape controls testing asks for
- The field does less, not more: one correction the day after a dinner instead of a reconstruction request in March
The management view
- Exposure is visible at any time, by affiliate, recipient and rule, including who is nearing a cap and which items await a decision
- The rule set is written down, versioned and applied the same way in nine affiliates, a position that can be explained rather than defended
- Recoverable VAT is visible by country, claimed and lost, with the reason traceable to its source, usually a booking tool addressing invoices to the wrong entity
Board-level KPIs
Security and governance
Security is designed with the process, not after it.
- The archive holds personal data about healthcare professionals and details of sensitive spend, so access runs through Microsoft Entra ID groups limited to compliance, tax and audit roles, with sensitivity labels and retention set by your own compliance function. Consent status for individual disclosure is recorded per recipient where your counsel determines it is required, and travels with the item
- We implement a control and an evidence trail. We certify nothing: no product named here, and no work we do, makes a company compliant with any statute, code or refund procedure, and the rule set deciding what is compliant belongs to your legal, compliance and tax teams
- Robots read; they never correct. A wrong attendee is fixed by the representative, a wrong invoice by the supplier, an ambiguous recipient by compliance, each recorded with a name and a timestamp
- Extraction runs under the UiPath AI Trust Layer with allow-listed models in EU regions and masking on any generative step; processing stays in the EU region of UiPath Automation Cloud and your Microsoft 365 tenant within the EU Data Boundary, and the US parent receives an extract rather than access
Why now
Disclosure obligations have spread from industry codes into national law across Europe, with individual-level reporting and consent questions attached, and enforcement around hospitality in healthcare is routine
Foreign VAT refund procedures are electronic and deadline-bound, which rewards a clean invoice on arrival and punishes reconstruction; in the model that is €120,000 a year on the wrong side of a submission date
Reading a receipt at line level, attendees included, no longer needs a template per supplier, and one tagged dataset serves disclosure, anti-bribery review, controls evidence and VAT claims, so one build retires four annual assemblies
Relevant executive roles
Four annual projects become outputs of one process, and foreign VAT stops leaking at each congress
Exposure is visible continuously, and the disclosure comes from a ledger rather than sixty replies
A written rule set applied consistently across nine affiliates, with the evidence and decision behind every item
Recoverable VAT is claimed on compliant invoices, and the reasons for loss appear early enough to fix at source
Common questions and objections
It records what the representative selected. It does not match a name against a register, apply a country cap, check the invoice's legal entity or hold the evidence for as long as your retention policy requires.
They do, which is why the rule set is versioned and owned by compliance rather than buried in a workflow. A code change becomes an update with a test and a date.
The field gets fewer. One correction the day after a dinner replaces the spreadsheet request every spring, and it takes a minute because the evening is still recent.
When this is not the right solution
- A company with no healthcare, public-sector or cross-border hospitality spend, where the rules would rarely fire and the archive would hold nothing anyone needs
- A compliance platform already integrated with expenses and payables that tags recipients, applies caps and files evidence with retention
- No register or official-list subscription to match against. The rules need reference data; without it, recipient matching is guesswork dressed as a control
A question for the next management meeting
Three years of transfers of value to one hospital, with the evidence behind each of them: is that a report this group can run, or a project it would have to staff?
Implementation approach
A scope without ambiguity, before anything is signed.
We deliver
- A regulatory rule catalogue per country, drafted with your compliance, legal and tax owners and versioned from day one
- Document Understanding configuration for receipts and invoices at line level, attendees included where itemised
- The pick-up, classification, correction-task and filing automation, the SAP Concur, SAP and register integrations, the evidence archive with retention labels and the transfer-of-value ledger
- Disclosure, anti-bribery and VAT report formats, plus the Power BI exposure view
- Testing against one reporting year of history, training and rule updates in the run phase
We need from you
- Last year's disclosure file and the spreadsheets behind it, plus a congress season of hotel invoices
- The registers and official lists you subscribe to, and owners for the rules in compliance and tax
- Service accounts with read access to SAP Concur and SAP
- A decision, taken with your counsel, on how consent status for individual disclosure is recorded
Stages
Discovery
Replay last year's disclosure and a congress season against a draft rule set, showing what it would have tagged, flagged and recovered
Rule design
Country caps, categories, recipient definitions, VAT field checks, routing for each kind of gap
Pilot
One affiliate and one regime live, compliance reviewing every flag to calibrate the rules
Scale
Further affiliates, anti-bribery views, VAT recoverability, the controls-evidence view, the parent's extract
Run
Rule review whenever a code or law changes, with the version history kept
Departmental. Effort is driven by the number of affiliates and regimes, the quality of the register data you can match against, and how much attendee information is itemised on receipts today.
Sixty spreadsheets arrive every spring, and each one is somebody's memory of a dinner.
Send us last year's disclosure file and one congress season of hotel invoices. We come back with what a rule set would have tagged on its own, and what those invoices cost you in VAT, in a short written read-out.
Test last year's disclosure fileThe neighbouring process usually has the same problem
Stop paying nine expense claims in ten on trust because nobody has time to check them against policy.
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