France is one of the leading countries in Europe in terms of following the global CTC trends and tax technology requirements. While there are already mandated SAF-T FEC (Fichier d’Ecritures Comptables) and B2G e-Invoicing requirements in place, in the following years it is scheduled to broaden the scope of e-Invoicing in B2B and B2C transactions as well.
Ordinance No. 2021-1190, which was published in the French Official Journal on 15 September 2021, approves the introduction of mandatory e-Invoicing for domestic B2B transactions and e-Reporting of transactional data for cross-border B2C transactions. This legislation was followed by Order of October 7, 2022, which lays down the requirements for service providers to comply with the upcoming mandate. Additionally, Direction Générale des Finances Publiques (DGFIP) regularly publishes technical specifications to prepare taxpayers for the e-Invoicing and e-Reporting mandate.
We have gathered the top-five critical questions from our clients.
- What is the difference between e-Invoicing and e-Reporting?
E-Invoicing is the process of creating, sending, and receiving electronic invoices that follow a mandated format and contain a minimum amount of structured data. French companies will have to issue e-invoices to other French company customers.
E-Reporting refers to the submission of specific mandated data regarding transactions that are not covered by the e-invoicing mandate to the French tax authorities. E-Reporting includes data related to international B2B transactions to or from a taxable legal person not established in France or transactions between taxable persons not established in France that are required to pay VAT in France. E-Reporting also covers data related to B2C transactions (transactions between non-taxable persons) and data related to the payment of invoices (status/billing cycle).
2. What is the implementation timeline of the system?
The tax authority has set a phased approach for rolling out the e-Invoicing/e-Reporting system according to the company’s size:
- From July 1, 2024: large companies
- From January 1, 2025: mid-sized companies
- From January 1, 2026: small and medium-sized enterprises
As of July 1, 2024, the obligation to receive invoices in electronic format will be mandatory for companies regardless of their turnover. Additionally, a pilot phase is scheduled between 3 January 2024 and 30 June 2024.
Medium-sized companies are defined as having fewer than 5,000 employees, an annual turnover less than 1,500 million Euros, and a total balance sheet that does not exceed 2,000 million Euros.
Small and medium-sized companies (SMEs) have fewer than 250 employees, and annual turnover that does not exceed 50 million Euros, and a total balance sheet does not exceed 43 million Euros.
Micro-enterprises have fewer than 10 employees, an annual turnover that does not exceed, and a total balance sheet of less than 2 million Euros.
3. What are the submission methods for sending invoices?
For submission of e-Invoices, the French government has selected the Y model, which is an approach that includes two types of submission methods.
Firstly, taxpayers may opt to use the public invoicing portal (PPF, the national invoicing portal) to send their invoices directly. PPF is a Chorus Pro based portal that is also used in B2G transactions where all suppliers must upload their invoices. PPF will play a central role in gathering data and providing basic services to companies.
Secondly, taxpayers may use a trusted service provider, namely partner dematerialization platforms (PDP), that are required to be registered by France tax administration. Registration needed to be renewed every three years. PDPs will intervene as a trustworthy third party to process invoices on behalf of companies. The roles and capabilities of partner dematerialization platforms (PDP) can include:
– transforming, validating and sending invoices to the French tax authority
– extracting data from invoices to send them to the tax authorities
– aActing as an intermediary between a supplier and a customer
Additionally, dematerialization operators (ODs) will be able to place themselves as service providers in the upcoming mandate. ODs will not be able to directly send electronic invoices to their recipients, which differentiates them from PDPs. ODs must be connected to the PPF or at least one PDP to be able to send electronic invoices.
4. What is the invoice format?
The DGFIP has set UBL, CII, and Factur-X (a hybrid structure that allows both XML and PDF submissions) as minimum base formats to generate invoices. If taxpayers exchange their invoices directly through PPF, they will be required to issue them in one of these three formats. On the other hand, if taxpayers opt to exchange invoices through a PDP, it will be possible to agree on what type of format taxpayers want to send to their PDP other than the minimum base formats.
5. Will there be an archiving period for the invoices?
Yes. Taxpayers should archive their invoices for at least 10 years.
For more information about the process and our solutions, please contact us at firstname.lastname@example.org