In a move towards digitalization and streamlining business processes, France will implement mandatory B2B e-invoicing and e-reporting.
Although initially set to roll out from July 2024 until January 2026, on July 28, 2023, the French government postponed the mandatory adoption of e-invoicing and e-reporting, and a new timeline is yet to be announced.
Two key considerations drive this delay:
- The extended timeline will provide businesses with a valuable opportunity to prepare thoroughly for the forthcoming e-invoicing requirements, ensuring a smoother and more effective transition when e-invoicing becomes mandatory.
- The extended timeline shows the French government’s commitment to working collaboratively with businesses and technology providers to create a supportive environment that fosters successful e-invoicing adoption across various sectors and stakeholders.
That said, this new e-invoicing mandate introduces the Continuous Transaction Controls (CTC) model and aims to increase efficiency, cut costs, and fight fraud.
To help businesses prepare for these changes, we have prepared this A-Z guide to provide you with essential information on France’s current e-invoicing rules.
What is electronic invoicing in France?
Electronic invoicing in France refers to the mandatory issuing, transmitting, and receipt of e-invoices in an established format and includes a minimum base of data in a structured form.
What are the current e-invoicing rules in France?
The current e-invoicing rules in France require that all companies, irrespective of their size, must be capable of accepting e-invoices.
This rule was initially set to roll out by July 1, 2024, before the postponement.
Nevertheless, e-invoices have been mandatory since January 2020 in France concerning transactions with the government (B2G).
Which transactions require electronic invoicing?
Transactions subject to electronic invoicing in France are business-to-business (B2B) transactions for the purchase and sale of goods and/or the supply of services subject to VAT when the transactions are within the national territory.
However, it’s important to note that mandatory electronic invoicing does not apply to transactions exempt from VAT under specific articles of the General Tax Code.
These exempt transactions include:
- Transactions in health (Article 261, 4, 1°).
- Education and training services (Article 261, 4, 4°).
- Real estate transactions (Article 261, 5).
- Transactions carried out by non-profit associations (Article 261,7).
- Banking and financial transactions.
- Insurance and reinsurance transactions (Article 261 C).
Characteristics of the electronic invoice in France
E-invoices in France must comply with specific technical and legal requirements to be valid and enforceable.
Here are some of the characteristics of e-invoicing in France:
What e-invoice format will be required?
There will be several acceptable formats for e-invoices in France, and all partner platforms must offer a minimum number of common formats to ensure interoperability.
The invoice can be created in a structured or mixed form using one of the three base formats compatible with the EN16931 standard, which is the EU's e-invoicing standard.
These three base formats are:
- UBL
- CII
- Factur-X
It is possible to create a PDF invoice, but it must still meet strict technical requirements, and scanning paper invoices is not an acceptable practice.
Factur-X is a unique standard that combines a human-readable PDF with machine-readable XML language.
This standard was developed through collaboration between France's National Forum for Electronic Invoices and Electronic Public Contracts (FNFE-MPE) and Germany's Forum elektronische Rechnung Deutschland (FeRD).
You may also like: How Many Types of E-Invoice Are There? (In-Depth Analysis).
What payment data needs to be submitted?
In France, suppliers must report payment information for sales or invoices where the tax point date is on payment under the e-reporting mandate.
This is intended to help the French Tax Administration pre-fill value-added tax returns and determine the collected VAT.
However, there are exceptions to this requirement. If a supplier has been authorized to pay the value-added tax (VAT) accounted for on an accrual basis under the “régime des débits,” or if the customer is responsible for accounting for VAT under the reverse charge mechanism, the supplier is exempted from this reporting requirement.
While we await further details on the required payment data that suppliers will need to report, we expect that it will include the following:
- Date of payment collection
- The amount collected, including VAT, broken down by the applicable VAT rate.
What network should be used?
When the new timeline is set, companies will have two options for sending electronic invoices and meeting their reporting duties in the B2B sector.
The first option is to use the services of a third-party provider (PDP) responsible for transmitting the e-invoice data to the business customer and passing on the prescribed information to the French tax authorities.
The second option is to use the official invoicing portal (PPF) connected to the Chorus Pro. The French government, however, has announced that the PPF will only have basic core functionality and is likely to be used only by the smallest companies.
Is there a need for a digital signature?
In France, the use of electronic signatures is not mandatory.
What archiving regulations apply?
In France, businesses are required to retain their invoices and related documents for ten years. This requirement also applies to e-invoices, which must be stored with exceptional care that guarantees their:
- Integrity: They cannot be altered
- Security: Concerning access, hosting, and confidentiality
- Durability: They must remain usable over time
- Traceability: Their life cycle must be able to be reconstructed
- Accessibility: They must be available and easily retrievable by authorized users while remaining confidential to all other users.
What is Chorus Pro?
Chorus Pro is the centralized platform for the administration of e-invoicing in the public sector of France. It is the sole interface that suppliers can use to interact with all authorities and government administrations in the country through traditional EDI channels and formats that have been tested and proven effective.
You can access the portal here.
The platform based on CII and Factur-X is available to suppliers and public sector customers free of charge.
However, using it requires a deep understanding of public sector administration processes in France and staying up to date with the tax authorities' constantly changing requirements and regulations.
Additionally, if you want to make the most of this platform, you must be proficient in the French language.
How to send compliant e-invoices in France
Prior to the new e-invoicing rules, companies typically send invoices directly to their clients. However, due to the new mandate, businesses in France will now send e-invoices through a dematerialization platform such as the public portal or other private electronic platforms.
These platforms will act as intermediaries between the supplier and the client, converting the invoice format to suit the recipient.
The platform chosen can be the same one used by the supplier, a different commercial platform, or the public invoicing portal, as long as it is compatible with the exchange.
That said, here is the step-by-step process of sending compliant e-invoices in France:
Step one: Generate an e-invoice
Create an e-invoice in your ERP or invoicing system. Most invoices typically will not be in one of the structured e-invoicing formats accepted under the e-invoicing regulation.
Step two: Dematerialise the invoice into the accepted format
Suppose your software cannot generate e-invoices in one of the structured invoicing formats accepted under the new e-invoicing rule. In that case, you will typically have to rely on either a PDP or a non-certified OD to help convert the invoices into an appropriate format.
On the other hand, you can create an e-invoice directly on the public platform.
Step three: Ensure interoperability
If there is a lack of interoperability between systems, you won't be able to send e-invoices successfully.
Hence, to ensure interoperability, you need to identify if the organization you want to send an invoice to uses a PDP or the public platform for e-invoicing.
Thankfully, there is a central directory managed by the public platform. This directory contains information about companies and organizations, including whether they use a PDP or a public platform for e-invoicing.
In addition, the directory helps route invoices to the appropriate recipients.
Step four: Send invoice
Once you have identified that the receiver uses a PDP or the public platform for e-invoicing, there are three possible approaches for sending the invoice based on certain conditions:
- If the receiver uses a PDP supplier, then you can send the e-invoice directly to their PDP without involving the public platform, and the invoice must be exchanged in a structured format; however, it is not limited to one of the three formats used by the public platform.
- You can send the invoice via the public platform if you do not have a PDP. In this case, one of the aforementioned invoicing formats must be used.
- When using the public platform to send the e-invoice, the same central directory will be used to identify whether the receiver uses the public platform or a PDP.
Again, one of the three prescribed invoicing formats must be used. If the receiver uses a PDP, the e-invoice will be routed directly to that PDP.
Step five: E-invoice is received
The receiver receives the invoice through either the public platform or their PDP. If the invoice is obtained through the public platform and needs reformatting to be ingested by the buyer’s Accounts Payable (AP) system, the services of an OD may be required.
Need help sending e-invoices and reports? Storecove offers a comprehensive solution for global e-invoicing and reporting requirements in France.
Set up a Storecove account, and we will receive the invoices you want us to send to your client.
What is e-reporting in France?
E-reporting in France is the use of electronic means to transmit specific information to the tax authorities (e.g., the amount of the transaction, the amount of VAT invoiced) relating to commercial transactions that do not fall within the scope of electronic invoicing.
These are transactions involving the sale of products and services to private individuals (or “business to consumer,” B2C transactions, such as retail trade) or dealings with operators established abroad (exports, intra-community shipments, etc.).
E-reporting makes it possible to reconstruct the whole economic activity of a company: supplementing electronic invoicing will eventually allow companies to benefit from pre-filled VAT return forms.
Note that the implementation calendar for e-reporting is the same as for the B2B e-invoicing obligation.
What transactions are affected by e-reporting?
Transactions subject to e-reporting in France are those involving companies subject to VAT in France when trading with the following parties:
- Private individuals and non-taxable entities (B2C transactions).
- Companies that are not established in France, i.e., taxable entities with no establishment, domicile, or habitual residence in France.
Additionally, companies not established in France or their tax representatives, where applicable, are required to submit transaction data for transactions conducted in France with the following entities:
- Non-taxable entities, including private individuals.
- Other taxable entities that are not established in France.
However, it's important to note that certain transactions exempt from VAT under Articles 261 to 261 E of the General Tax Code and exempt from invoicing are not subject to e-reporting.
Such exempt transactions include certain banking and insurance transactions, medical and health services, educational services, and transactions carried out by non-profit organizations managed without personal gain.
Characteristics of e-reporting in France
E-reporting in France must comply with similar characteristical requirements for e-invoicing, and these include businesses electronically submitting transactional data in specified formats, covering various types of transactions (but in this case, it excludes the unique identification number of the foreign company as they won’t have a SIREN number).
The network infrastructure for transmission will leverage existing platforms to offer multiple convenient delivery options.
While the use of digital signatures is not mandatory, businesses must adhere to archiving regulations by retaining e-reports and related documents for a period of ten years.
These characteristics reflect France's commitment to modernizing and streamlining tax reporting processes while maintaining essential record-keeping standards.
How does the e-reporting process work?
The e-reporting process in France streamlines the submission of transactional information to the tax authorities.
Here's a detailed breakdown of how the process works in practice:
Supplier sends transactional information
B2C Supply is not obligated to send an invoice for its B2C supply transactions, but they have the option to do so. They can follow their standard invoicing process if they choose to issue an invoice.
Conversely, B2B is required to send an invoice for its B2B supply transactions. However, these transactions are outside the scope of the French e-invoicing regulations.
Use of a Public Digital Platform (PDP)
If a company uses a PDP and chooses to issue invoices (regardless of whether they are B2C or B2B), the PDP can directly extract the relevant transactional information from the invoices. This simplifies the reporting process and ensures data accuracy.
In cases where no invoice is issued, especially in B2C transactions, the PDP should be able to retrieve the necessary transactional information from alternative sources, ensuring comprehensive reporting.
Providing information to the French tax authority
When a PDP is employed, it takes on the responsibility of sending the extracted transactional information to the public platform on behalf of the businesses. This ensures a seamless and automated data submission process.
However, if a company chooses not to use a PDP, it must send the transactional information directly to the public platform.
If the company has issued invoices in one of the three approved invoicing formats (CII, UBL, or Factur-X), the public portal can extract the relevant transactional information from these invoices.
Optionally, businesses can engage an OD to assist with tasks such as reformatting invoices or extracting necessary data.
However, it’s important to note that an OD does not have a direct link with the public platform and cannot transmit data directly to the tax authorities.
Need help with your French VAT compliance? Storecove ensures that companies use the right sending and receiving infrastructures for e-invoicing. Schedule a demo with one of our e-invoicing teams.
What is the required frequency for reporting transactions?
The applicable tax system for each entity will determine the frequency of reporting.
Companies subject to the standard tax regime must make three monthly transmissions no later than 10 days after the reporting period. The reporting periods are the following:
- 1st to 10th of the month
- 11th to 20th of the month
- 21st to last day of the month
Companies subject to a special tax regime must file a monthly e-report within 7 days of the end of the month.
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What are the key differences between e-invoicing and e-reporting?
The fundamental distinction between e-reporting and e-invoicing is the nature of the transactions involved; e-invoicing applies to transactions between taxpayers based in France subject to VAT and invoicing legislation.
E-reporting affects transactions undertaken in an international B2B context and B2C transactions.
New French B2B e-invoicing and e-VAT reporting system
The new tax scheme in France includes mandatory electronic invoicing and electronic reporting of accounting data between private companies.
These guidelines were developed by the Direction Générale des Finances Publiques (DGFiP) based on the results of a pilot phase and evaluation conducted with stakeholders, including companies, technology providers, and the government.
What companies will be affected by the new regulations?
The new regulations will affect all companies headquartered in France doing domestic sales and purchases.
It is important to note that some foreign companies not established in France but registered for VAT in the country must comply with the new e-reporting requirements if their customers are not business customers, including private individuals.
Visit Storecove to see France's e-invoicing facts and the latest updates as far as 2026.
Phases and roll-out dates of the e-invoice based on company size
Initially planned for July 2024, the roll-out dates have been postponed. The postponed obligation will be launched in phases based on the size of the company and the business activity carried out, although the new starting date has yet to be confirmed.
The table below shows the initial dates for implementation:
What should businesses do to comply with e-invoice regulations in France?
As a Supplier, to meet the French e-invoice reporting requirement, you must ensure that your invoices contain all the mandatory fields that the government requires (in addition to any that your customers require).
You will also need to send status messages to the PPF, including when you’ve been paid.
As a Buyer, depending on your size, you may need to send e-invoices if you are not already doing this. Structured PDFs will no longer be accepted after 2027. Status messages will need to be sent to update both the government and your suppliers when payments are made.
Meeting French VAT reporting requirements will be a significant challenge. However, with the assistance of Storecove, it will be hassle-free.
Storecove is an authorized e-invoicing and e-procurement solution provider, meaning B2B can use our platform to send and receive e-invoices. Speak to Dolf and learn how we can help you securely issue and receive invoices in France.
Penalties for non-compliance with the e-invoicing requirements in France
To ensure compliance with the e-invoicing requirement, businesses must use the Electronic Archiving System (EAS) or Electronic Vault, which is the only technical solution capable of protecting the integrity and authenticity of the archived document.
It is crucial to note that failure to comply with these archiving requirements can result in significant penalties and fines from the French tax authorities, and this will be:
- €15 per invoice limited to €15,000 total per annum for taxpayers
- €15 per invoice limited to €45,000 sum per annum for e-invoice certified agents (PDP, Plateformes de dématérialisation partenaires)
- €250 per transmission, capped at EUR 15,000 (for E-reporting)
Therefore, businesses must ensure that their e-invoicing and archiving processes comply with French regulations.
You may also like: Requirements For Mandatory E-Invoices In France (Beginning 2024)
Goals of the new e-invoicing and e-reporting system
The goals pursued by the government in implementing the new e-invoicing and e-reporting system include the following:
- To prevent and combat tax fraud.
- To simplify VAT reporting obligations.
- To reduce the costs of tax control.
- To simplify business life and enhance competitiveness.
- To improve understanding of the economic situation with real-time reporting on business activity.
Takeaway: Understand the e-invoicing requirements to prepare for France's B2B e-invoicing revolution
Since the French government implemented the EU’s e-invoicing directive for B2G transactions in 2017, all VAT-registered businesses must understand it and what it offers, including the penalty involved if they fail to comply.
Businesses will no longer be mandated to send compliant invoices directly to their clients. Instead, they will use a commercial third party or the PPF to send electronic invoices.
These platforms will act as intermediaries between the supplier and the client, converting the invoice format to suit the recipient.
Unlike conventional methods, the new system is more efficient and will help companies reduce invoice and payment processing costs and boost overall productivity in compliance with Chorus Pro.
If you’re a business in France looking for a safe, seamless, and secure electronic invoicing system that adheres to the financial and tax regulations surrounding e-invoicing in France, Storecove can help you.
We provide a comprehensive solution for businesses in sending and receiving electronic invoices with complete compliance with the French government’s legal requirements. Request a demo for more information.
More information about B2B e-Invoicing in France?
Contact us for more information or request a demo with one of our e-invoicing experts.
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